Response to Article on Probes of FBME: Ayoub-Farid Michel Saab

To the Editor:

Re article, “Banned Over Terror Clients, FBME Has Added Woe: U.S. Probe” (Dec. 16, 2017)

We are writing in response to your December 16 article about FBME Bank, which we, as the shareholders of the bank, believe conveyed a number of inaccurate statements. These include claims attributed to the U.S. Treasury and internal bank documents that the bank acted for Somali pirates, terrorists and chemical-weapons manufacturers, or knowingly acted for any sanctioned individuals. We would also take issue with any suggestion that FBME harbored funds stolen from Equatorial Guinea. We believe these allegations emanate from reports provided by parties with whom we are in litigation.

Moreover, it is by no means incriminating that in a one-year period in 2013 and 2014, $390 million in transactions were flagged for further review, as the article cites FinCEN as concluding. That allegation is derived from Suspicious Activity Reports filed by FBME’s U.S. correspondent banks. These reports, which prophylactically show any transactions that might reflect money-laundering, are generated for all banks and are not unusual in themselves. The time period coincided with capital controls that the Cypriot Government imposed on all Cyprus banks. Clients would often transact in smaller sums during this restrictive financial environment, below the specified thresholds, and as a result their withdrawal patterns could resemble so-called structuring. Notably, FBME’s SARs data, which constitute less than one percent of the bank’s total turnover for that period, weren’t compared side by side with those of other Cypriot banks, so there’s no indication whether the bank was an outlier during the period.

Yours sincerely,

Ayoub-Farid Michel Saab, Director, FBME Ltd.
Fadi Michel Saab, Director, FBME Ltd.

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