Ghana Cited in A Major Narcotic Trafficking and Money Laundering

Ghana and other West African Countries Cited in A Major Narcotic Trafficking and Money Laundering.

By: SHARON COHEN LEVIN

MICHAEL D. LOCKARD

JASON H. COWLEY

ALEXANDER J. WILSON

One St. Andrew's Plaza

New York, New York 10007

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,

Plaintiff,

- v. -

LEBANESE CANADIAN BANK SAL, ELLISSA

HOLDING COMPANY, HASSAN AYASH EXCHANGE

COMPANY, CYBAMAR SWISS GMBH, LLC, STE

In addition, Ellissa Group SA, Ellissa

Holding, Ellissa Megastore, Ellissa Parc Cotonou, and Ellissa

Shipping, the latter three of which are located in Benin, were

designated (the Ellissa companies collectively, "Ellis sa

Holding").

?

c. Narcotics Trafficking in West Africa

During the last decade, drug trafficking

organizations have increasingly used countries along or near the

West African coast as trans-shipment hubs for importing massive

quantities of narcotics, particularly cocaine from South America,

to be later distributed in Europe or elsewhere within Africa.

Through a combination of privately owned aircraft and maritime

vessels, these organizations, predominantly based in Venezuela

and Colombia, have transported hundreds of tons of cocaine, worth

billions of dollars, to West African nations such as Benin,

Sierra Leone, and Togo.

F. The Ellissa Exchange, Ellissa Shipping Company, and Ellissa

Car Parc in Cotonou

50. The Ellissa Holding Company owns or controls

approximately nine companies in Lebanon, Benin and the DRC,

including the Ellissa Exchange, a money exchange based in

Sarafand, Lebanon; Ellissa Group SA, which owns a car park in

Cotonou, Benin, for receiving and selling used cars imported to

the Cotonou port; and Ellissa Shipping, which is principally

engaged in shipping used cars to Benin through the Cotonou port.

The Ellissa Holding Company is principally owned and controlled

by Jamal Mohamad Kharoubi and Ali Mohammed Kharroubi.

51. Wire transfers originating from the Ellissa

Exchange totaling approximately $61,747,524 were sent to United

States accounts for the purpose of purchasing or shipping cars

between in or about January 2007 and in or about January 2011.

G. Transfers from Ayash, Ellissa and Others to the United

States to Buy and Ship Used Cars

52. Between in or about January 2007 and in or about

January 2011, the Ayash Exchange and the Ellissa Exchange

originated approximately $203,269,615 or more in wire transfers

(the nExchange Funds") from'accounts held at LCB, Federal Bank,

BLOM, and MEAB (collectively, the nLebanese Banks") to bank

accounts in the United States for the purchase or shipping of

used cars.

53. Account holders other than Hassan Ayash Exchange

and Ellissa Exchange initiated wire transfers totaling at least

approximately $126,281,969 (the nNon-Exchange Funds") to bank

accounts in the United States for the purchase or shipping of

used cars. Some of the originators for these Non-Exchange. Funds

are discussed below, see ~ 77.

55. Between 2008 and 2010, used cars valued

collectively at over $1 billion were shipped from the United

States to Benin, including hundreds of millions' worth of used

cars purchased with funds from the Lebanese Banks.

65. Money couriers also transport millions of dollars

from Benin on commercial air flights.

Couriers travel on these

flights and carry the undeclared cash with them in order to evade

detection. For example, on December 9, 2010, three individuals

who had traveled on a flight from Benin were arrested at Charles

De Gaulle International Airport in Paris, France. The three were

en route to Beirut, Lebanon. They were discovered to be carrying

over $6.5 million in United States currency and €48,500. These

funds were not declared. One of the individuals was carrying a

business card for Ellissa Megastore, Ellissa's car lot in

Cotonou, Benin.

66. Cash is also commonly transported out of Benin

through the airport in Accra, Ghana,

approximately 210 miles from

Cotonou, Benin. The route from Cotonou to Accra passes through

Togo and its capital, Lome, on the Ghana border. The Ghanaian

Customs, Excise, and Preventive Services recorded approximately

$1.2 billion in declared United States currency imported across

the Lome border crossing in 2007 and 2008. Approximately $845

million of this was declared by Lebanese nationals.

67. From Accra, the cash is often flown to Beirut.

Hizballah security facilitates the receipt of cash flown into the

Beirut International Airport. For example, money couriers are

sometimes instructed over the public address system to deplane

first, and are escorted to private rooms in the airport where the

cash would be received.

Dated: New York, New York

December 15, 2011

PREET BHARARA

United States Attorney for the

Southern District of New York

By:

Michael D. Lockard

Jason H. Cowley

Alexander J. Wilson

Assistant United States Attorneys

One St. Andrew's Plaza

New York, New York 10007

(212) 637-1060/2193/2479/2453