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I'm an American taxpayer, and I'm furious. I'm sick and tired of watching my hard-earned money, the money I pay in taxes, get wasted, stolen, and funneled away to line the pockets of corrupt officials and their cronies. It's a betrayal, a slap in the face to every American who believes in honest government and the fair use of public funds.



I'm talking about the Commonwealth of the Northern Mariana Islands (CNMI), a beautiful U.S. territory in the Pacific that has become a breeding ground for corruption. My tax dollars, meant to help the CNMI recover from disasters and the COVID-19 pandemic, are being diverted, laundered, and used for personal gain, with little to no accountability. This isn't just bad management; it's outright theft, and it's happening right under our noses.


The CNMI government, which is supposed to be responsible for managing these funds, has repeatedly failed to uphold its obligation to be transparent and accountable. Instead of using the funds to help the CNMI people, they've been funneling them to their own pockets, to their friends, and to questionable projects that benefit a select few.



A Trail of Misused Funds: Unveiling the Corruption

The evidence is clear. An independent audit conducted by Ernst & Young (CNMI) Inc., revealed a staggering $51.96 million in total questioned costs of federal funds. This isn't a small mistake; it’s a systematic pattern of abuse, corruption, and disregard for the principles of transparency and accountability.


 

Ernest and Young Audits Parts 1 & 2:





 

Here's how the CNMI government has misspent our taxpayer dollars:


1. Misuse of Coronavirus Relief Funds: The audit exposed a significant misuse of funds from the Coronavirus Relief Fund (CRF), totaling $20,341,913. The CNMI government failed to provide basic documentation to justify their spending, indicating a lack of proper procedures and oversight.


The Auditor's Findings: The auditor found that out of nine expenditures totaling $20.8 million from a $25 million population of expenditures from the Coronavirus Relief Fund, two expenditures, totaling $20,341,913, lacked supporting documentation such as check payments or invoices. This failure to maintain adequate records raised serious concerns about the CNMI’s accountability and compliance with the CARES Act.


2. Improper Procurement Practices: The audit highlighted a systematic failure by the CNMI government to comply with established procurement regulations, resulting in $18,353,963 in questioned costs. This includes awarding contracts to friends without fair competition and failing to keep proper records.


The Auditor's Findings: The auditor tested 14 expenditures totaling $18.4 million from a population of $20.2 million in nonpayroll expenditures subject to procurement. They found that 11 expenditures (79%) lacked procurement files, written justifications, or the Procurement & Supply Director’s written approvals of the emergency procurement method used. This pattern of ignoring proper procurement processes and potentially awarding contracts without proper justification suggests a lack of oversight and potential abuse


3. Mismanagement of Nutrition Assistance Program (NAP): The audit revealed that the CNMI government did not periodically reconcile its recorded program benefit costs with the total food coupons redeemed under the NAP, costing us taxpayers over $3 million. This raises concerns about the accuracy of the program's accounting and the potential for misappropriation of funds.


The Auditor's Findings: The audit found that the CNMI did not periodically reconcile its recorded program benefit costs with the total food coupons redeemed under the NAP. This resulted in $3,375,452 in questioned costs. They failed to reconcile differences between the submission of the monthly FNS-388 (State Issuance and Participation Estimates report) and the monthly reconciliation provided by the authorized redemption agent.


4. Violating Procurement Regulations for SLFRF: The audit found that the CNMI government violated procurement regulations for the Coronavirus State and Local Fiscal Recovery Funds (SLFRF), costing taxpayers over $2 million. This indicates a disregard for established procurement regulations and a potential for abuse in awarding contracts.


The Auditor's Findings: The auditor tested 51 nonpayroll expenditures totaling $3.1 million from a total population of $6.7 million expenditures subject to procurement. They found that 34 expenditures (67%) lacked procurement documents. This suggests a blatant disregard for established procurement regulations and a potential for abuse in awarding contracts.


The CNMI Government’s Response: Denial and Deceit

The CNMI government's response to the auditor's findings presented a stark contrast. While acknowledging some of the findings and promising corrective action, the CNMI government also vigorously disputed other allegations, claiming that the auditor had misinterpreted certain aspects of the findings and had failed to consider the extenuating circumstances surrounding the CNMI’s response to the pandemic.


They’ve even attempted to blame the auditor, claiming the auditors got their facts wrong or didn't fully understand the complex situation on the ground. This is a classic tactic of deflecting blame and trying to mislead the public.


THESE FUNDS ARE DIRECTLY BEING FUNNELED TO THE PHILLIPINES AND CHINA; THROUGH TAN HOLDINGS, VARIOUS CHINESE SHELL-COMPANIES AND THE QUASI-HUMANITARIAN GROUPS: CALLING ITSELF, THE UNITED FILIPINO ORGANIZATION; WHICH IS CONTROLLED BY THE CHINESE/FILIPINO ASSOCIATION ( https://cfbci.ph/ ) WHICH RECEIVES FUNDS DIRECTLY FROM THE CCP IN THE PHILLIPINES.


UFO which is funded by the CCP in the Philippines'



The BOOST Program: A Deeper Dive into Mismanagement and Corruption


The BOOST (Building Optimism, Opportunity and Stability Together) program, funded by the American Rescue Plan Act (ARPA), is another area where the CNMI government has been accused of misusing federal funds. The CNMI House conducted hearings to investigate the BOOST program, specifically focusing on alleged waste, fraud, and abuse of public funds.

Allegations of Misuse: The CNMI House hearings highlighted serious concerns about the allocation of BOOST funds, raising questions about the transparency and accountability of the program's implementation.


Calls for Further Investigation: The CNMI House recommended the engagement of federal authorities, including the FBI and the Office of the Inspector General, for further investigation into alleged waste, fraud, and abuse of public funds.


Governor Palacios’ Response: Governor Arnold I. Palacios, acknowledging the concerns, stated that he has requested funding from the U.S. Department of the Interior to conduct forensic audits on ARPA funds, including the BOOST program, as well as other federal monies received by the Commonwealth in the past five to six years.


The U.S. Government’s Response: A Slow and Painful Process

The U.S. government, the one supposed to be watching over these funds and ensuring accountability, has been slow to react. They have conducted their own investigations and offered assistance, but they've not taken any strong action to hold the CNMI accountable.

The Need for Justice: A Call for Action from American Taxpayers

We need to demand more from the federal government. We need them to:

Conduct thorough forensic audits of all federal funds that have been provided to the CNMI in recent years.


Investigate the potential for criminal activity, including money laundering and fraud, and prosecute those responsible to the fullest extent of the law.


Hold the CNMI government accountable for its failures and demand that it implement meaningful reforms to prevent future misuse of federal funds.


This is not about politics, this is about justice.


The CNMI is not the only U.S. territory or jurisdiction facing these issues. Corruption and misuse of federal funds are happening in various places, and we, as taxpayers, are bearing the brunt of it. We deserve better! We deserve honesty, transparency, and accountability from those entrusted with our money. We deserve to know that our tax dollars are being used for their intended purpose, to help people in need and to build a better future for our nation.


We need them to:


Conduct thorough forensic audits of all federal funds that have been provided to the CNMI in recent years.


Investigate the potential for criminal activity, including money laundering and fraud, and prosecute those responsible to the fullest extent of the law.


Hold the CNMI government accountable for its failures and demand that it implement meaningful reforms to prevent future misuse of federal funds.





Here's what we need to do:


Demand Action: We need to raise our voices and demand that the U.S. government takes decisive action to hold the CNMI government accountable. We need to let our elected officials know that we’re not going to tolerate this kind of corruption anymore.


Stay Informed: We need to stay informed about the situation in the CNMI and about the efforts being made to hold the CNMI government accountable. We need to hold our elected officials accountable for their inaction.


Support Transparency and Accountability: We need to support organizations and individuals who are working to promote transparency and accountability in government.


Hold Our Elected Officials Accountable: We need to hold our elected officials accountable for their actions or inaction on this issue. We need to let them know that we are watching them, and we expect them to act in our best interests.



This is our money, and we deserve to have it used responsibly. The CNMI is not a paradise; it's a cautionary tale of how corruption can flourish even in the most beautiful places. Let’s demand justice, hold the CNMI accountable, and ensure that our tax dollars are used for their intended purpose: to help those in need and to build a brighter future for all Americans.

A Deeper Dive: The Details of the CNMI’s Corruption and The Stories of the People Affected

The $51.96 million in questioned costs represents a significant portion of the federal funds the CNMI received, and it’s a testament to the extent of the corruption and mismanagement that has plagued the territory. But the numbers only tell part of the story. To understand the real impact of this misuse of federal funds, we need to look at the stories of the people who have been affected.

The Pain of Paradise Lost

The CNMI's people, especially its most vulnerable residents, are suffering from the consequences of the CNMI government’s corruption and mismanagement. Here are just a few examples:

The CNMI's Elderly: Many elderly residents rely on the CNMI’s Nutrition Assistance Program for food assistance. However, the mismanagement of these funds, as highlighted by the audit, puts the program’s future in jeopardy. This means that many seniors in the CNMI, already struggling to make ends meet, may face even greater challenges in obtaining adequate nutrition.

The CNMI’s Healthcare System: The CNMI’s healthcare system is already overburdened and struggling to provide adequate care to its residents. The misuse of federal funds intended for pandemic relief further strains the system, leading to delays in care, inadequate staffing, and a lack of essential resources. This impacts the health and well-being of all CNMI residents, but especially those with chronic illnesses or those who are most vulnerable.


The CNMI’s Infrastructure: The CNMI’s infrastructure is in dire need of repair and improvement. However, the misuse of federal funds has left many infrastructure projects in a state of disrepair, making it more difficult for residents to access essential services and for businesses to operate efficiently.


The CNMI’s Economy: The CNMI's economy, already struggling before the pandemic, has been further weakened by the misuse of federal funds. The lack of transparency and accountability has deterred potential investors and has created a climate of uncertainty for businesses, making it more difficult for the CNMI to attract investment and create new jobs.


 

 

A Deeper Dive: The Details of the CNMI’s Corruption and The Stories of the People Affected

The Stories Behind the Numbers


Beyond the statistics, the stories of individuals affected by the CNMI’s financial mismanagement are heart-wrenching. Here are a few examples:


Maria, a Senior Citizen: Maria, a 72-year-old widow, relies on the CNMI’s Nutrition Assistance Program to put food on the table. However, due to the program's mismanagement, Maria has been forced to skip meals and cut back on essential medications.


John, a Small Business Owner: John, a hardworking small business owner, saw his business suffer during the pandemic. He applied for a loan through the CARES Act, but the process was delayed and bureaucratic, preventing him from accessing the funds he needed to keep his business afloat.


Sarah, a Healthcare Worker: Sarah, a dedicated healthcare worker, has been working tirelessly to care for patients during the pandemic. However, she has been frustrated by the lack of resources and the delays in receiving supplies due to the mismanagement of federal funds.



Beyond the CNMI: A Systemic Problem


The CNMI is not an isolated case. The misuse of federal funds, corruption, and lack of accountability plague various U.S. territories and jurisdictions. These issues are rooted in a systemic problem that requires a comprehensive solution. We need to hold all those responsible accountable, from the local officials to the federal agencies that oversee these programs.


The Path to Justice: A Call for Action

We, the American taxpayers, deserve to have our tax dollars used responsibly and ethically.

We deserve to know that these funds are being used to help those in need, to build a stronger and more equitable society, and to ensure that our government is working for the good of all citizens.


We need to demand justice for the stolen tax funds that were intended to help the CNMI. We need to demand transparency and accountability from our government. We need to ensure that our tax dollars are used responsibly and ethically. We must hold those responsible accountable for their actions, and we must work together to create a better future for the CNMI and for all Americans.



The Legal Framework for Justice: Citing Federal Laws

To bring those responsible for the misuse of federal funds in the CNMI to justice, we need to understand the legal authorities granted to the various federal agencies.


Here's a breakdown of the legal framework that empowers the IRS, the U.S. Treasury, and the Offices of Inspector General to investigate, locate, arrest, and prosecute those involved in financial crimes:


The Internal Revenue Code (IRC): The IRC, specifically Title 26 of the U.S. Code, empowers the IRS, particularly its Criminal Investigation (CI) division, to investigate and prosecute financial crimes related to federal taxes, including tax fraud, money laundering, and tax evasion.


Relevant Sections:

Section 7201: "Attempt to evade or defeat tax." This section provides for criminal penalties for intentionally attempting to evade or defeat federal taxes.


Section 7206: "Fraud and false statements." This section covers the making of false statements or fraudulent returns in connection with federal taxes.


Section 7802: This section grants the IRS authority to investigate potential criminal violations of the IRC.


Section 7803: This section establishes the IRS CI division as the primary agency responsible for investigating criminal violations of the IRC.

The Financial Crimes Enforcement Network (FinCEN): FinCEN is a bureau of the U.S. Department of the Treasury tasked with safeguarding the financial system from illicit use and combating money laundering.


Relevant Laws:


The Bank Secrecy Act (BSA): 31 U.S.C. § 5311 et seq. This Act requires financial institutions to file reports with FinCEN regarding suspicious transactions.


The Money Laundering Control Act (MLCA): 18 U.S.C. § 1956 et seq. This Act criminalizes money laundering and provides FinCEN with the authority to investigate and pursue legal actions against those involved.


The Offices of Inspector General (OIGs): OIGs are independent oversight bodies within federal agencies, tasked with promoting efficiency, effectiveness, and integrity. They investigate waste, fraud, and abuse related to the programs and operations of the agencies they oversee.


Relevant Provisions: The Inspector General Act of 1978, 5 U.S.C. App. § 1 et seq., grants OIGs authority to conduct investigations and audits, issue subpoenas, and refer cases for criminal prosecution.


The False Claims Act (FCA): 31 U.S.C. §§ 3729-3733. The FCA allows whistleblowers to file lawsuits against those who have knowingly submitted false claims for payment to the federal government. This law can be a powerful tool in holding accountable those who have misappropriated federal funds.


The Federal Program Integrity Act (FPIA): 42 U.S.C. § 1320c-5 et seq. The FPIA establishes a framework for combating fraud, waste, and abuse in federal healthcare programs, such as Medicare and Medicaid. This law provides additional tools and resources for investigators to pursue those who have engaged in fraudulent activities related to these programs.

 

 

How You Can Help:


Contact Your Elected Officials: Let your senators and representatives know that you are concerned about the misuse of federal funds in the CNMI. Demand action and accountability from them.


Support Investigative Journalism: Support organizations that are working to investigate corruption and misuse of public funds. These organizations play a vital role in holding those in power accountable and in bringing these issues to light.


Educate Yourself and Others: Learn more about the situation in the CNMI and about the importance of transparency and accountability in government. Share what you learn with others and encourage them to take action as well.


Join a Grassroots Movement: Connect with other concerned citizens who are demanding accountability for the misuse of federal funds. Together, we can make a difference.


This isn't just about the CNMI. This is about ensuring that our tax dollars are used responsibly and ethically, and that those who misuse them are held accountable. Let's demand justice, hold the CNMI accountable, and work together to build a better future for all Americans.


This fight is not easy, but it is necessary. The CNMI is a beautiful place, and its people deserve better. Let's join together and demand that our government takes action to ensure that the CNMI is a paradise regained, not a paradise lost.


Authors’ Profile:

Zaji "Persona Non Grata" Zajradhara: A Voice for the Voiceless Zaji "Persona Non Grata" Zajradhara isn't just an author; he's a force of nature. A staunch advocate for American workers and Indigenous rights in the CNMI, Zaji's life reads like a gritty urban novel, filled with struggle, resilience, and an unwavering commitment to justice. Labeled "persona non grata" by the CNMI government for his relentless pursuit of truth and his outspoken criticism of corruption, Zaji has become a symbol of resistance against those who seek to exploit the islands and its people. As an unemployed Afro-American father, he knows firsthand the sting of the CNMI's dysfunctional labor market, its rigged political system, and the exploitation of vulnerable communities. His experiences fuel his activism, driving him to file numerous legal claims against companies for violating labor laws and discriminating against American workers. Zaji's voice, though silenced by the establishment, resonates through his writing, exposing the harsh realities faced by those on the margins. But Zaji's compassion extends far beyond the shores of the CNMI.

As Program Director of CNMIGA.org, a non-profit dedicated to providing humanitarian assistance in Myanmar, he leads a team committed to delivering essential support and resources to communities in need.

Zaji's story is a testament to the power of one person to make a difference. He is a writer, an activist, a humanitarian – a true urban warrior fighting for a more just and equitable world.

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The Commonwealth of the Northern Mariana Islands (CNMI), a U.S. territory nestled in the heart of the Pacific, is a paradise betrayed. While the world pictures pristine beaches and vibrant culture, a dark reality lurks beneath the surface. This is a story of a stolen democracy, a silent coup, where corruption thrives in the shadows, facilitated by a compliant, foreign-owned press and a government that has become a puppet of its own making. This is a story of Paradise Lost.


The Media Machine: A Puppet Show of Silence

Imagine a stage where the news is not reported, but carefully crafted. This is the reality in the CNMI, where the two dominant newspapers; which reflect nothing of substance, policy, insights, "Americana", or "Reflective Embrace" of their adopted (h)omeland-; Our American soil; The Marianas Variety and The Saipan Tribune, are not beacons of truth, but propaganda machines controlled by foreign interests. Their "reporters," primarily Filipinos and are controlled by Chinese or other Foreign nationals; are not journalists with a dedication to uncovering the truth. They are paid performers, following a script dictated by the powerful forces that hold sway in the CNMI.


 

List of individuals that assisted CCP Chinese Casino defraud America.


 

The media landscape in the CNMI has become a distorted mockery of a free press.

These so-called "newspapers" and so-called "Reporters" no longer serve as watchdogs of the powerful but have become instruments for concealing the truth, silencing opposition, and crafting a false narrative that obscures the harsh reality. Rather than holding leaders accountable, they shield them from scrutiny, leaving the public unaware of the corruption and inequality that persist. Where are the investigative reports? As these critical stories vanish, the people continue to suffer under the weight of poverty and systemic corruption.


The Missing Pieces: A Labyrinth of Lies

The most blatant example of this media manipulation is the systematic disappearance of critical articles exposing the CNMI government's policies, particularly those involving the CW-1 worker program. This program, designed to bring in foreign workers for specific industries, has morphed into a tool of exploitation. It has allowed foreign corporations to circumvent local hiring regulations and prioritize cheap labor, leaving American workers on the sidelines and creating a system where worker rights are routinely violated.


The CW-1 program has created a two-tiered labor system, where foreign workers, often lured by false promises and exploited by unscrupulous employers, are treated as disposable resources. This exploitation is not just a moral failing; it has significant economic consequences, contributing to the decline of the local workforce and hindering the development of a sustainable, locally driven economy.



The "reporters" of the Marianas Variety and the Saipan Tribune, however, are curiously silent on this issue. Any articles critical of the CW-1 program, or that shed light on the exploitation and abuse of foreign workers, are conveniently scrubbed from their archives. The truth is inconvenient, and it is buried, leaving a void filled with carefully crafted narratives that downplay the true consequences of this program.


Beyond the Labor Market: The Shadow of Crime

The silence extends beyond the labor market. The CNMI's crime statistics, especially those concerning the disproportionate impact on the native Indigenous and transplanted American community, are systematically buried. The real extent of drug trafficking, human trafficking, and violence, often perpetrated by the same foreign workers the CNMI government claims to be protecting, is concealed from public view.


The government, in its efforts to maintain a facade of order, prioritizes presenting a sanitized image of the CNMI. This, however, comes at a cost. The real issues facing the community, the true impact of crime, and the struggles faced by the native Indigenous and transplanted American population are ignored, creating a false sense of security and leaving the community vulnerable to the very dangers that are being concealed.


The Ghosts of Investigative Journalism: A Silence Compounded

The absence of true investigative journalism in the CNMI is not a coincidence. It is a symptom of a system deliberately designed to stifle dissent and protect the powerful. Investigative journalism, with its dedication to uncovering the truth, would expose the intricate web of corruption that binds the CNMI government officials and their families, foreign corporations, and so-called "quasi-humanitarian" organizations. It would reveal the emperors with no clothes, the shadowy figures pulling the strings behind the scenes.


Imagine a world where the government officials responsible for overseeing the CW-1 program are themselves beneficiaries of its exploitative practices. Imagine a world where foreign corporations, with their vested interests in the CNMI's resources and labor, have infiltrated the government, manipulating policies to their advantage. Imagine a world where "humanitarian" organizations, supposedly dedicated to helping the marginalized, are actually fronts for profit-driven enterprises. These are the truths that a truly investigative press would expose, but they remain hidden in the CNMI's labyrinth of silence.




The Silent Coup: A Government Without Scrutiny

The CNMI government, rife with corruption and seemingly beholden to foreign interests, thrives in this manufactured silence. Their actions are not scrutinized, their promises are not held to account, and their true agenda remains shrouded in a veil of deceit. The government has become a puppet, dancing to the tune of its foreign benefactors.

The CNMI's elected officials have become so accustomed to this environment of unchecked power that they have lost sight of their fundamental responsibility to their constituents. They have forgotten that their duty is not to serve foreign interests, but to uphold the rights of the people they represent. They have forgotten that their actions should be transparent, their decisions accountable, and their motives beyond reproach.

(FYI: The authors' First Amendment Protected opinion is: Former Secretary of the CNMI Dept of Labor defrauded / embezzled $3-4 Million in PUA federal funds using a third-party VPN and routing said federal funds to a third country via family members)


The People's Voices: A Cry for Change

The CNMI community is being robbed of its voice, its future, and its very identity. The manufactured silence is a threat to the very fabric of their society. This is not just a matter of a few bad actors; it is a systematic assault on democracy, a slow and steady erosion of the fundamental rights of the people.


 

this was due to "our" call for an Audit of the CNMI DEPT OF LABOR PUA PROGRAM: in which SEC OF DEPT OF CNMI LABOR ILLEGALLY GAVE HUNDREDS OF MILLIONS TO FOREIGN WORKERS & THEIR FAMILY MEMBERS


 


The CNMI community deserves better. They deserve transparency, accountability, and a government that truly represents their interests. They deserve a media that acts as a watchdog, not a puppet. They deserve a future where they are not the victims of a silent coup, but the architects of their own destiny.



The Fight for Truth: A Reclaiming of Paradise

The CNMI community has a right to know the truth. They have a right to participate in a democracy where their voices are heard, their concerns addressed, and their rights upheld. They have a right to reclaim their paradise.


Here are the steps that need to be taken:

Demand a Free and Independent Press: The CNMI community must demand the establishment of an independent, locally owned and operated media outlet that is truly committed to reporting the truth and holding the powerful accountable. This can be achieved through public pressure, advocacy groups, and the support of local investors.



Expose the Truth: The CNMI community must actively seek out and share information that exposes the true nature of the CNMI's government and its complicit media outlets. This includes promoting independent blogs, podcasts, and online forums, encouraging whistleblowers, and supporting investigative journalism initiatives.



Hold the Government Accountable: The CNMI community must demand transparency, accountability, and an end to the abuse of power by the CNMI government. This requires engaging in public protests, filing freedom of information requests, supporting independent investigations, and holding their elected officials responsible for their actions.


Protect American Workers: The CNMI community must fight for the rights of American workers and demand an end to the exploitation of foreign workers under the CW-1 program. This includes advocating for stricter regulations, promoting fair labor practices, and supporting local hiring initiatives.


The fight for truth and justice is far from over. Organizations like CNMIGA.ORG, dedicated to exposing the truth and advocating for the rights of the CNMI community, are on the frontlines of this struggle. They are providing a platform for the silenced voices of the CNMI, empowering them to fight for their rights and reclaim their paradise.

The CNMI community has the power to break free from the shackles of manufactured silence. It is time to embrace the truth, no matter how uncomfortable it may be.




The future of the CNMI depends on it.



It is time to reclaim Paradise Lost.



AUTHORS PROFILE:


Authors’ Profile:



Zaji "Persona Non Grata" Zajradhara: A Voice for the Voiceless Zaji "Persona Non Grata" Zajradhara isn't just an author; he's a force of nature. A staunch advocate for American workers and Indigenous rights in the CNMI, Zaji's life reads like a gritty urban novel, filled with struggle, resilience, and an unwavering commitment to justice. Labeled "persona non grata" by the CNMI government for his relentless pursuit of truth and his outspoken criticism of corruption, Zaji has become a symbol of resistance against those who seek to exploit the islands and its people. As an unemployed Afro-American father, he knows firsthand the sting of the CNMI's dysfunctional labor market, its rigged political system, and the exploitation of vulnerable communities. His experiences fuel his activism, driving him to file numerous legal claims against companies for violating labor laws and discriminating against American workers. Zaji's voice, though silenced by the establishment, resonates through his writing, exposing the harsh realities faced by those on the margins. But Zaji's compassion extends far beyond the shores of the CNMI.


As Program Director of CNMIGA.org, a non-profit dedicated to providing humanitarian assistance in Myanmar, he leads a team committed to delivering essential support and resources to communities in need.


Zaji's story is a testament to the power of one person to make a difference. He is a writer, an activist, a humanitarian – a true urban warrior fighting for a more just and equitable world.

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The DOJ just rolled out a Corporate Whistleblower Awards Pilot Program https://www.justice.gov/criminal/criminal-division-corporate-whistleblower-awards-pilot-program on August 1, 2024, that could lead to big payouts for anyone blowing the whistle on shady corporate dealings. This new 3-year initiative could reward you up to $50 million if you provide inside info that exposes corruption or financial crimes in certain sectors. To qualify, the tip has to be about four key areas: financial crimes, foreign or domestic corporate corruption, or health care fraud involving private health programs.


 


 

This program could impact workers in financial institutions (FIs) who are part of anti-money laundering (AML) and counter-financing of terrorism (CFT) compliance teams. The program’s details reveal a potential conflict with existing whistleblower protections under the Bank Secrecy Act (BSA), which was revamped by the Anti-Money Laundering Act (AML Act). We've talked about these issues extensively (you can read more here, here, and here).



 


 

Who Can Score the Reward?

To be eligible, you must be an individual (not a company) who provides written information to the DOJ about corporate crimes that result in at least $1 million in forfeitures. The tip must be voluntary—meaning you offered it up before being asked, with no obligation to do so, and with no ongoing investigation.



Also, to cash in, you can’t be involved in the crime you're reporting, and you have to tell the whole truth—no holding back info.


What Counts as “Original Info”?

You have to bring new information to the table—stuff that comes from your personal experience, not something already out in public. If the DOJ already knows about it, your info must add significant value.


This is especially relevant for AML/CFT compliance workers. The program says compliance workers usually can't qualify if the info they have is related to their job duties, like flagging suspicious activity or reporting violations. However, compliance folks can still be eligible if they believe reporting to the DOJ will prevent a serious crime like national security threats, violence, or major harm. And if you wait 120 days after reporting the info internally to your company's legal or compliance officers, you can still qualify for a reward.



Even though the program has some tricky rules for whistleblowers, companies need to take these complaints seriously. They have a tight window to report any misconduct once they get wind of it. Whether or not the whistleblower gets paid, their info can be a huge risk for the company.


What Kind of Crimes Are Covered?

Here’s the type of misconduct that can get you the bag:


Crimes by financial institutions, like money laundering, non-compliance with AML laws, or fraud.

Bribery and corruption by companies overseas, including violations of the Foreign Corrupt Practices Act (FCPA).

Bribery and kickbacks to public officials here at home.

Health care fraud, especially against private health care benefit programs.

How Much Can You Make?

The DOJ is offering up to 30% of the first $100 million in forfeited funds, and up to 5% of anything between $100 million and $500 million, with a cap of $50 million. But keep in mind, property owners and victims get paid first, so your reward will come from whatever’s left.


 



 


The DOJ will decide the payout based on factors like how important your info was, how much help you provided, and if you reported the issue through your company’s internal system first. If you made money from the crime, delayed reporting, or caused trouble for your company’s internal compliance, your reward could be reduced.


Unlike the AML Act, which focuses on fines, this new program is all about forfeiture—assets seized as a result of the crime. This is a big deal because many of the biggest AML enforcement actions have centered on forfeiture. For example, Danske Bank was hit with over $2 billion in forfeitures for failing on AML compliance. So, this new program could be more attractive for whistleblowers looking at AML/CFT-related cases.


 


 

How Does This Program Play With Other Whistleblower Programs?

If you're eligible for another government whistleblower program—like one from the SEC or IRS—you can't get paid under the Pilot Program for the same information. But the DOJ suggests reporting to both programs just to be safe, and they’ll decide if you qualify under this program.



What Should Companies Do?

The whole point of this new program is to motivate people to speak up about corporate crimes, either directly to the DOJ or internally to their company. If you report internally first, you might increase your payout, as long as you report to the DOJ within 120 days of telling your company. And if your company self-reports to the DOJ within that same time frame, they can avoid some punishment.



 


 

For companies, the pressure is on to beef up compliance programs and encourage internal reporting. They need to train their compliance teams to handle complaints fast and loop in legal counsel early. Doing this gives them the best chance to fix the problem and stay in the DOJ's good graces.




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