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$500 million Belize Penny Stock Manipulation Ring shut down

10 Sep $500 million Belize Penny Stock Manipulation Ring shut down


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Robert Bandfield, Andrew Godfrey, Kelvin Leach, Rohn Knowles, Brian De Wit, and Cem Can (aka Jim Can) Indicted as part of a $500 million money laundering scheme

Today both the SEC and DOJ filed charges against Robert Bandfield and Andrew Godfrey for their involvement in managing an offshore business intended to help clients evade U.S. securities laws and U.S. tax laws by concealing the ownership of certain microcap stocks as part of a larger money laundering scheme that allowed their clients which totaled more than 100 U.S. citizens and residents to launder more than $500 Million.

The SEC Complaint can be read here.

The DOJ press release can be viewed here.

The SEC requires that any client that owns more than 5% of a stock report their ownership.   The SEC alleges that Belize residents Robert Bandfield and Andrew Godfrey through a company called IPC Corporate Services have helped clients who own significant amounts of thinly-traded microcap stocks avoid SEC reporting requirements.   Through ICP Corporate Services, Bandfield and Godfrey would set up anonymous foreign entities that used nominee officers. Ownership in the stock would then be divide up between those anonymous entities so that no single entity had more than 5% ownership in an issuer.  This allowed their clients to illegally avoid their reporting requirements and to remain anonymous to authorities and the IRS at the same time.  This scheme was carried out for over dozens of individuals and used for dozens of penny stocks many of which became big name paid promotions.

The DOJ went into further detail explaining that the Bandfield and Godfrey used the scheme to help their clients avoid Securities and Tax laws laundering more than $500 million in the process. 

The bust was part of a 2 year undercover investigation by the Federal Bureau of Investigation during which an undercover agent posing as a stock promoter traveled to Belize to meet with some of the alleged conspirators and set up offshore entities, according to court documents.

During subsequent recorded conversations, Mr. Bandfield explained to the agent that he had incorporated some 5,000 sham companies allowing clients to manipulate penny stock markets by concealing the client's ownership of the stocks, the documents said.

Bandfield and Godfrey also explained that they would offer clients prepaid credit cards on which they could load up to $50,000 a month to launder the fraudulent proceeds, according to the documents. "We can make it so it's not attached to you," the men said in one recorded conversation, according to the court documents.

The agents subsequently obtained court-approved wiretaps, which led them to the U.S. clients, according to court documents.

The Belize penny stock manipulation ring also allegedly involved the stock held anonymously in these foreign entities to be cleared through two Belize brokerage firms, Legacy Global Markets (Brian De Wit), Titan Securities (Kelvin Leach and Rohn Knowles), and Unicorn International Securities (Jim Can). 

The Belize News has a great article about the bust that even includes details of the arrest as they are happening.  From that article:

"Tonight, Belize's Offshore Banking sector is under extreme scrutiny from US authorities, and they have local police doing their work. The US Department of Justice says they are cracking the key play players in a billion dollar scheme to defraud US tax authorities.

It's playing out right now at the fourth floor of the Matalon Building on Coney Drive at the office of Titan Securities. At 1:00 pm, three police pickups and the Financial Intelligence Unit swept in, reportedly to confiscate all documents and they may also arrest at least three persons who have been named in a US indictment. They are 51 year old Belizean ANDREW GODFREY, 34 year old Bahamian KELVIN LEACH and 29 year old Bahamian Rohn Knowles. Leach and Knowles are principals in Titan, while Godfrey also has an office on the fourth floor.

They are three of 6 persons named in a US indictment which was unsealed today in New York. A release from the department of Justice says that the multi-count indictment is against six defendants, including the three we already named and Robert Bandfield, who is a U.S. citizen very well known in Belize's Offhsore Banking sector; along with Canadians Brian De Wit and Cem Can who have both been involved in the offshore sector in Belize.

Their companies were also named in the indictment. Those that are registered in Belize are Titan International Securities, Inc., Legacy Global Markets which has a San Pedro Address, and Unicorn International Securities which is based at the Gordon building.

Bandfield has already been arrested and will appear in a new York Court tomorrow. As for the others, three of whom are in Belize, the press release says that the US government will seek extradition for them."


How the scam works

In several of our reports in the past we detailed the basic way that these types of scams operated.

1) Form a business entity with a forward looking business plan using some nominee CEO

2) Locate a dirty attorney to provide the legal opinion for the future insider enrichment scheme and a dirty accountant to provide the accounting services

3) Submit an S-1 filing with a bogus business plan to the SEC registering some shares for sale to a hand picked group of nominees usually for around $.01/share.

4) After obtaining public company status from the SEC, focus on how insiders can dump their S-1 shares into the public market for huge profits.

5) Set-up anonymous offshore accounts  in corporate egos to hold your free trading stock.

6) Deposit shares with a dirty offshore broker who will clear certificates using its house account so they can be easily dumped into the market.

7) Do a name change/merger/acquisition of some sort to coincide with a large forward split so you can build the investor relations campaign (See Number 9 Below) around the corporate changes and at the same time increase the shares held by the insiders. 

8) Have the shady attorney send in an application for the name change/forward split with FINRA.  Thanks to the large forward split insiders now own tens of millions of free trading stock that cost them fractions of a penny to acquire.

9) Find a stock tout with a quality list to do a pump & paid promotion/or other form of market manipulation

10) And finally dump the super cheap free trading shares into the market earning huge profits while investors suffer losses.


We also detailed the money laundering part of the scheme further as follows:

(i) the Participants set up a foreign corporation (“Blind Corp.”) to hold stock in the British Virgin Islands, Belize, the Marshal Islands, Panama, Nevis, the West Indies, Switzerland, or some other tax haven country using an anonymous trustee to avoid detection;
(ii) the Participants then cause the Blind Corp. to open an account with an offshore brokerage company (like Bank Gutenburg in Zurich, Legacy Global Markets or Titan International Securities or Unicorn International Securities in Belize, etc.);
(iii) the Participants obtain control of a U.S. Shell company and create a bogus business plan;
(iv) the Shell Company is structured so that the Participants can obtain control of the public float;
(v) the Participants arrange for large blocks of (“illegally”) free trading unregistered and non- exempt Shares to be issued in the name of the Blind Corp. and delivered to offshore broker;
(vi) The broker deposits a portion of the Shares into its global custody account with a large U.S. institution;
(vii) The broker deposits a portion of the Shares into Delivery vs. Payment (DVP) accounts with specific market makers;
(viii) The broker places buy orders with a first market maker and sell orders with a second in order to create the appearance of volume and demand for the Shares;
(ix) the Participants bombard investors with misleading and false public information including unfounded and inflated price predictions, bogus research reports using both phone rooms, spam email and stock-hype websites which promise unsupported returns and baseless forecasts and results; and
(x) The broker dumps the Shares at inflated prices during the hype and the Participants receive the proceeds while remaining anonymous.


Our Research on Bandfield and Godfrey

Robert Bandfield and Andrew Godfrey are very familiar names to us.  Their scheme was no secret to us either.  In old research I posted on the IHUB going back to early 2012, I identified Robert Bandfield and Andrew Godfrey for their roles in helping set up anonymous Belize business entities for various pump in dump schemes including SNPK, ROSV, and NTRO. using their company ICP Corporate Services LLC. I also pointed out how they were also involved in setting up anonymous entities for TGRO and NHUR which would both become future stock promotions.  TGRO by Stock Tips and NHUR by the Billionaire Stocks group (both of which have their roots with the old Hack the Stock Market crew).

Some of that old research posted on the IHUB can be read here, here, and here.

In that old research from 2012, I made it very clear that SNPK, ROSV, and NTRO were all linked sharing some of the same insiders including: Robert Shull (and the Shull family), Douglas Roe, Harry Lappa, Luis Carrillo, and Wade Huettel.

SNPK became a big Awesome Penny Stocks promotion which I was already linking to John Babikian back in that April 2012 post.

Luis Carrillo and Wade Huettel also played big roles in two other major pump & dump scams that showed up in SEC litigation, TSHO and PBEC.  TSHO and PBEC were both entities controlled by John Kirk and Benjamin Kirk.  The Kirks used offshore entities to hide their share ownership similar to the Belize scheme outlined in today's SEC and DOJ reports only back then it was Gibraltar Global Securities out of the Bahamas run by Warren Davis that was used for the money laundering scheme.  Gibraltar was shutdown in 2012 after being used for years to launder hundreds of millions of dollars through penny stock manipulation schemes including many of the early Awesome Penny Stock promotions.  Following the closing of Gibraltar Global, Awesome Penny Stocks went over to the Bandfield and Godfrey and their Belize organization for their next promotion, SNPK.  Gibraltar/Davis had taken over where Dominion Investments Ltd/Martin Tremblay had left off before that.  The Kirks also ran a spam penny stock promotion company called Skymark.  When Skymark got shutdown by the regulators back in 2011 its list was passed over to Awesome Penny Stocks (Eric Van Nguyen, AJ Thompson, Jay Fung, Kevin Sepe) as were their attorneys, Luis Carrillo and Wade Huettel.  Read some of our past Awesome Penny Stock research here, here, and here.

In that old research from 2012, I also made it very clear that TGRO and NHUR were both linked to Kenneth Liebscher, Lionel Welch, Kevin Murphy, Peter Hewitt, and Jake Bottay.  This very same group of individuals led by Kenneth Liebscher were once involved in a company known as ThermoElastic Technologies Inc which was named in Operation Bermuda Short in 2001.  Operation Bermuda Short was set up as an undercover operation to bust a money laundering scheme involving offshore entities and offshore bank accounts and the manipulation of several penny stocks using stock promoters and offshore brokers. Sound familiar?

In this September 2012 report for National Graphite Corp (NGRC) published by Promotion Stock Secrets we mapped out the connections between Andrew Godfrey, Robert Bandfield, Liebscher, Welch, Murphy, Hewitt, Bottay, and others even further and pointed out the similarities to the Operation Bermuda Short allegations.   NGRC would end up being the last promotion done by the Hack the Stock Market group with their old websites.

The very next ticker promoted by the Hack the Stock Market group would end up being Northumberland Resources Inc (NHUR) but using new websites like Billionaire Stocks and OutoftheBox stocks.  NHUR had all the same insiders as NGRC as detailed in this March 2013 Promotion Stock Secrets report.

Later Tiger Oil & Energy Inc (TGRO) would become a Stock Tips promotion.  TGRO had all the same insiders as NGRC and NHUR including Bandfield and Godfrey.  Read more in our December 2013 TGRO report.  Since we linked Stock Tips to the Hack the Stock Market group in this very detailed Stock Tips research report (opened for the first time tonight for non-Promotion Stock Secret members) it was no surprise to us that it became a Stock Tips promotion.

It should be noted that when you call Legacy Global Markets you get a law office run by Marilyn Williams.   Up until December of 2013, Marilyn Williams headed Belize’s Financial Intelligence Unit.  The law office run by Marilyn Williams used to be run by Lionel Welch before his death in February of 2014.  The very same Lionel Welch linked to stock promotion tickers NGRC, NHUR, and TGRO.




Despite implying that several penny stock companies were used as part of the Bandfield/Godfrey scheme, the SEC only identified one company by name, Endeavor IP (ENIP).  ENIP was yet another Billionaire Stocks/OutoftheBox Stocks promotion in October of 2013 as detailed in this October 2013 Promotion Stock Secrets report.  

Despite implying that several penny stock companies were used as part of the Bandfield/Godfrey scheme, the DOJ only identified one company by name, Cannabis-Rx Inc (CANA) which surprise, surprise, was also a Billionaire Stocks/OutoftheBox stocks promotion in April of 2014.  Learn more about CANA in our February 2014 research report.

So we now have 5 tickers all promoted by the same related groups of promoters all linked to Robert Bandfield and Andrew Godfrey (NGRC, NHUR, TGRO, ENIP, and CANA).

The connections do not end there, however, as mentioned in this post on the CANA forum, one individual named Jim Decker was rumored to be linked to five tickers all promoted by the Hack the Stock Market promoter group, CANA, WTER, and KRED by the newer Billionaire Stocks/OutoftheBox Stocks sites, and JAMN and BGBR by the older Hack the Stock Market sites.   Read our WTER report here and our KRED report here.

Jim Decker has quite the history.  He is probably most notorious for the True Religion stock promotion which ties together many of the individuals that would later make up Bank Gutenberg AG - a night trading desk for penny stock promotions fronting as a bank in Zurich, Switzerland including Edwin Haas, Marc Peter, John Anastasious Collias, Norman Jeske, Maria Zaffaroni, Daniel Weinmann, and Ronald Bauer.  There were a big chunk of CANA shares and WTER shares held in an account at Bank Gutenberg AG.

That now connects 8 tickers promoted by the Billionaire Stocks/OutoftheBox Stocks/Hack the Stock Market group to this Robert Bandfield, Andrew Godfrey securities and tax law evasion scheme.  There is a good possibility that the other tickers in the following chart of tickers promoted by this group (SANB, TFER, and UOMO) were also involved:


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The links don't stop there. 

According to, documents reflect that FINRA had also already opened an investigation into Legacy Global Markets because of their involvement in past Awesome Penny Stock promotions as well as other pump&dump schemes. The list of other offshore brokers being investigated for their roles in pump&dump schemes include:

"Caledonian Global Financial Services Inc., Caledonian Bank Ltd. and Caledonian Securities Ltd. in the Cayman Islands; Clearwater Securities Inc. in Belize; Legacy Global Markets SA and Argus Stockbrokers Ltd. in Cyprus; CBH Compagnie Bancaire Hevetique SA and Bank Gutenberg AG in Switzerland; and Verdmont Capital SA in Panama."

Our research reveals that both Legacy and Caledonian were involved in the trading activities for Pingify International Inc (PGFY).  We would come to learn that Pingify International Inc (PGFY) had only one person that owned all of the free trading stock.  That person used anonymous foreign entities to divide the stock up and hide their ownership as part of the scheme.  PGFY would end up being a Stock Tips promotion (like TRGO).   Read our PGFY research report here.  Pingify International Inc (PGFY) was suspended by the SEC in the middle of the paid promotion.    That makes two of the Stock Tips promotions run through this Belize group.  It makes you wonder if any of the other Stock Tips promoted tickers from the following chart also were:


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Titan International Securities would also get a nice mention in recent SEC litigation against Michael Affa, Andrew Affa, Christopher Nix (aka Gabe Nix), Mitchell Brown, and Christopher Putman.  According to that Complaint, share ownership in Amogear Inc (AMOG) was divided up by Michael Affa and Andrew Affa between some foreign entities and then Titan International Securities was used to clear the certs and sell them through their US counterpart, Alpine Securities.  Promotion websites mainly controlled by Nix were then used to tout the stock while those shares were dumped into the market.  Learn more about Nix and his promotional company, Global Market Media, in our old research report found here.

We've seen this same type of scheme repeated hundreds of times with hundreds of penny stock through the years.  Another notable example is Biozoom (BIZM) which at one time also had Belize accounts through Andrew Godfrey and Robert Bandfield.  See some of our past BIZM research here and here.  Other paid promotion tickers we researched that included the names Bandfield and/or Godfrey include DIMI and IDNGOur DIMI report does a nice job of laying out in detail how Godfrey used offshore accounts to hide shares that would later be dumped into the paid promotion.  Earlier this summer Caroline Windsor (aka Caroline Meyers aka Caroline Danforth) was arrested for her involvement in selling shares through foreign entities in multiple paid promotion tickers.  We detailed her involvement in the OCTX paid promotion in great detail in our OCTX report.  Windsor held OCTX shares in several Belize accounts.

Legacy Global Markets, Titan Securities, Robert Banfield, and Andrew Godfrey would all come up in our Cynk Techologies (CYNK) research.  

This is how we believe that the CYNK scheme was created to work:

1) IntroBuzz is formed as a Nevada business entity on April 30, 2008.  The shell isn't used for anything for a very long time, but then the anonymous insider that really set the entity up decides to initiate an plan to make lots of money using the shell.  One key individual, Phil Kueber, catches our attention for his involvement with the shell.  Phil Kueber can be linked to several past pump&dump schemes.

2) An S-1 filing is done on January 20, 2012 using attorney Harold P Gewerter to provide the legal opinion and accountant Peter Messineo to provide the accounting services to help take the shell public.  The S-1 is used to register up to 2,000,000 shares for sale to some hand picked anonymous insiders at $.05/share. 

3) Despite only a forward looking business plan and a suspicious set-up, the SEC approved the S-1 filing on June 1, 2012.

4) 1,086,000 of those 2,000,000 registered S-1 shares ended up getting sold to some anonymous insiders at $.05/share.

5) We believe that Robert Banfield (aka Robert Bandfield) and Andrew Godfrey may have been used to help set up the nominee offshore accounts to hold those free trading shares for the CYNK insiders through through their Belize business called IPC Corporate Services Inc.  IPC Corporate Services Inc is located in the same building as the CYNK corporate address.

6) We believe that Legacy Global Markets SA and Titan International Securities were hired as the dirty offshore brokers to help clear the shares and facilitate the dumping of those shares into the market.  It is common knowledge that Legacy is controlled by Gregg Mulholland in the background and Brian DeWitt on paper.  Both Mulholland and DeWitt are close friends with Joseph Padilla.  Joe Padilla is perhaps the most well known pump & dump broker in the business (now banned from being a registered broker).    Some say Padilla is still involved in these pump&dump schemes secretly backing an offshore brokerage company located in Panama.  Learn more about Padilla in this report.  It is also common knowledge that Titan is controlled by Kelvin Leach and Rohn Knowles.

7) IntroBuzz eventually changed its name to Cynk Technology Group and applied for a new stock ticker symbol but that isn’t all. They also issued a 75:1 forward stock split. 

8) FINRA approved the name/symbol change and forward split despite the suspicious set-up and all the free trading stock being owned by anonymous insiders.  The new ticker and split became effective on July 15, 2013.  The anonymous insiders now had 81,450,000 free trading shares costing just $.001/share.

9) Starting on June 17, 2014 CYNK became the center of market manipulation including in our opinion wash trading and other forms of market manipulation pushing the share price up from $.06/share to $21.95/share and drawing the attention of the mainstream media and earning the ticker an SEC suspension.


Gregg Mulholland (mentioned in part 6 above) is no stranger to the SEC.  He was named in litigation in the past for his role in the Rudy Nutrition (RUNU) pump & dump along with Pawel Dynkowski, Joseph Padilla, Chad Smanjak and others.  RUNU used anonymous Panama business entities to hide ownership of stock dumped during its paid promotion.  It has long been known about Mulholland and Padilla's involvement in helping clear certs for Awesome Penny Stocks and other stock touts.

It has now been confirmed by the SEC, FBI, IRS, and DOJ in a joint sting operation that this same scheme was run on several penny stocks many of which became paid promotions going back well more than 2 years (consistent with our research).


Jim Can (aka Cem Can)

Besides Jim Can's involvement helping to sell shares through his Belize based firm, Unicorn International Securities, we also know that Jim Can is from Calgary.  We are very familiar with the name Jim Can because of he was a key figure in several past paid promotion tickers including BLUF, MULI, and GBEN as detailed in several reports published by found here, here, here, and here.  GBEN takes us full circle back to Robert Shull, Luis Carrillo, Harry Lappa, and that group.

Both BLUF and MULI were promoted by Best Damn Penny Stocks in 2013.  The founders of Best Damn Penny Stocks, Eric Cusimano, Jessica Cusimano, and Jamie Boye were arrested earlier this summer.  Read our old research about the formation of Best Damn Penny Stocks here.  We have no doubt that the Bandfield/Godfrey bust and the Best Damn Penny Stocks bust have many overlapping qualities.


I know the Bandfield/Godfrey Belize operation is way bigger and has been going on for longer than I can even comprehend but they have come up so often in my research that I just wanted to organize it all some.





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