“We are unaware of any activities in which the above client [Batbold] engages which leads us to suspect that the client is involved in money laundering.” In fact, on the day the letter was written Batbold was a Member of Parliament and between 2004 and 2006 was Cabinet Minister of Trade and Industry (here). In money laundering terms he was a “politically exposed person.” As a consequence, Deutsche Bank was required to scrutinize his past activities before creating the trust and to closely monitor all future transactions with the bank or the trust to ensure they were lawful. There is no evidence Deutsche Bank ever conducted what the money laundering law terms this “enhanced due diligence.”

Two weeks ago Batbold denied ever having “any open or hidden accounts, money, apartments or property in the offshore zone” (here), but as the letter and other documents made public last Friday show, he is at least prevaricating if not lying. He has or has had numerous accounts and properties offshore. Batbold’s representative ducked questions GAB has asked (here) about the trust and Batbold’s offshore properties, issuing a short, blanket denial reprinted below.

The documents were disclosed in a filing in federal court February 12. Three agencies of the Mongolian government there ask the court to order JPMorgan Chase Bank to produce records they believe will help establish how much Batbold and his accomplices have stolen from the government through their corrupt activities. The Deutsche Bank Hong Kong letter is one of several documents that constitute exhibit seven to the affidavit of British lawyer Sarah Walker submitted in support of the request. The others are emails sent July 14-15, 2015, between a Deutsche Bank employee in the Guernsey trust division and an employee of Trident Trust.

Trident is a British firm renowned for its expertise in setting up offshore corporations and trusts that can disguise an asset owner’s identity, and Deutsche Bank was asking Trident to undertake an action involving Premier Edge Ltd, a BVI company that owned apartments in London.To comply with Trident’s obligations under the anti-money laundering laws, the Trident employee asked Deutsche Bank to send certified copies of the passports of the beneficial owners of Premier Edge (page 8 of exhibit 7). In response, Deutsche Bank provided one passport, that pictured below —

In the email to which Batbold’s passport is attached, the Deutsche Bank employee stressed that the fact Batbold owned Premier Edge was not to be shared with anyone without Batbold’s approval, writing that “this client has high confidentiality requirements” (page 2 of exhibit 7).

(The authenticity of Batbold’s passport is certified by two Deutsche Bank employees in their capacity as directors of Regula Limited. Regula is a shell company created by Deutsche Bank. The International Consortium of Independent Journalists reports that it has been implicated in Deutsch Bank’s money laundering activities.)

Upon discovering the documents in the court filing, GAB wrote Batbold’s representative to ask if the passport pictured above was indeed Batbold’s, if Batbold had in fact created the Quantum Lake Trust, whether he was the beneficial owner of Premier Edge, whether Premier Edge owned two luxury London flats, and whether he had “high confidentiality requirements” concerning his asset ownership. The representative’s answer is below:

“This is part of an ongoing political campaign to smear Mr Batbold’s well-earned reputation internationally and in Mongolia. As it has been stated before neither Mr Batbold nor anyone affiliated to him owns the apartments in question. As required by Mongolian law, he has no offshore assets either. As you seem little interested in presenting any accuracy or balance regarding Mr Batbold, we will conclude this exchange by stressing that Mr. Batbold will continue to vigorously fight the smear campaign as he has successfully done in the New York court.”

Earlier posts recounting a case in a New York state court where allegations of Batbold’s corruption can be found are here, here, here, and here.

Editor’s note. This post initially stated Batbold was Chief of the Mongolian Cabinet Secretariat at the time he asked Deutsche Bank to establish an offshore trust for him. As a reader noted in a comment, it was Sunduin Batbold not Sukhbaatar Batbold that was the secretariat chief. Sukhbaatar was a senior member of Parliament and according to Wikipedia was or had just been Minister Trade and Industry at the time he requested formation of an offshore trust.