[RawAlex]

Greg, the difference is that the HSBC banks in question were warned, not shut down. Do you not think that the St Kitt's people contacted e-pass long before the shut down and said "hey, you are out of compliance, we need to fix this"?

Epass was loose and fast with money, on accounts under 5k a year. I am sure there are plenty of scammers out there who were using epass accounts as money laundering toilet paper, sort of laundering the cash by wiping the shit off of it.

Why do you think that nearly half the traffic to the st kitt's bank after the epass issue was from Russia?

At the end of the day, Epass was in a position where the St Kitt's bank could no longer front for them, likely under pressure from Visa system or regulators. Epass was unable to come into compliance, and there you go.

The real issue (for American courts, I suspect) will be what Mallick knew, when he knew it, and if he failed to disclose those facts to clients who were passing money into the system that Mallick knew as a result would likely not be easily returned.