Hey, FBI & SIGTARP: Can Corporations Be Money Mules, Too?

Not just your bank account could be fueling crime, but also your church, your investment broker, your 401K, any and all public & state pensions, and of course, federal pensions.

In Detroit I like to call this creature of stealin' the children, land & votes, or rather the Detroit Land Bank Authority.

Either way, stop funding crime, particularly the foreign invasion of our great nation.

Praise the lord.

But, if humans can be money mules, is there a possibility foreign corporations, functioning under fake ass Public Private Partnerships, like the Detroit Land Bank Authority, can, also, be placed in such a similarly constructed class based animus, too?

I officially decided today to be "Pick on SIGTARP" day, because there was a fleeting moment in House Judiciary Impeachment Hearings - Day 2 - where the powers of the U.S. Treasury accidentally, slipped from the tongues of the members, but that moment was quickly remedied when Matt Gaetz dropped Hunter Biden's crackpipe.

So many artifices, so many machinations of gerrymandering...

Your Bank Account Could Be Fueling Crime
Money Muling Is Illegal and Helps Criminals

Like many Americans, Aaron Cole and his wife had been able to save up a nest egg through the rising value of their home. But after six years there and the births of their two children, the Oregon couple decided to sell and use the equity they had built up to purchase a slightly larger place.

After they had sold their current home, Aaron Cole received word that his title company would be in touch soon with the wire instructions for sending the down payment required to close on the new house. When an email arrived on December 4, 2018, from what appeared to be the title company, Aaron's wife went to the bank and sent $122,850 to the account number provided in the message.

A few days later, the title company called to tell Aaron Cole it was time to wire over the down payment. Was he ready for the account information?

It took the representative from the title company just moments to figure out what had happened: The Coles had been the victims of a business email compromise scam and had wired their money to a criminal who had spoofed the title company’s email address and sent them fake wire instructions.

The family’s savings was gone. Their down payment had been funneled into one account and then broken up and sent to four other banks. Within days, the money would be on its way out of the country and into the control of those who carried out the scheme.

The Cole family had already sold their existing home with a move out deadline of December 23. Now, they couldn’t complete the sale of their new house, had little left in savings, and in a few weeks would have nowhere to call home.

“I’m never at a loss for words,” said Aaron Cole. “When this happened, I couldn’t come up with the words to tell my wife.”

What happened to the Coles was due to the deliberate actions of the online criminals who compromised an email account to steal from them, but the criminals could not have carried out the scheme without the involvement of money mules.

The FBI defines a money mule as a person who transfers illegally acquired money on behalf of or at the direction of another person. Money mules often receive a commission for the service or provide assistance because they believe they have a trusting or romantic relationship with the individual who is asking for help moving money.

“Mules are laundering money for people who have done some major damage. Who’s losing the money? It’s average people. It’s small companies.”
Yaqub Prowell, special agent, FBI Portland
Money mules may or may not be aware of the role they are playing in a crime, but the actions they take do serious harm to people like the Coles and millions of other innocent victims of online scams and frauds.

The FBI’s Internet Crime Complaint Center (IC3) received more than 20,000 complaints in 2018 from victims of business email compromise alone. These victims reported losses of more than $1.2 billion.

“Mules are laundering money for people who have done some major damage,” said FBI Special Agent Yaqub Prowell, who worked the Coles’ case through the FBI’s Portland Field Office. “Who’s losing the money? It’s average people. It’s small companies.”

Aaron Cole will be the first to tell you how devastating the loss was. “The equity in the house was our way to move forward,” he said of the theft. “I put myself back 15 years.”

In the Coles’ case, the title company generously helped the family cover their down payment in exchange for Aaron Cole’s help alerting others about business email compromise. The title company was seeing homeowners hit with this crime despite the warnings about fraud and account security they put on every document they send to clients.

Aaron Cole, like many people, skimmed right over those messages in the mass of paperwork that accompanies the process of buying and selling a home. Cole said, “I grew up with computers. I know not to click on anything suspicious. Nothing about this looked suspicious.”

The title company hopes that a human face and a very human story about what can happen will make more people aware of the crime and on guard against it.

Prowell, who spent days tracking the path the Coles’ money made from bank to bank, was successful in seizing some of the assets and saving about 30 percent of the funds the Coles lost. But those assets, because of the legal process involved, would not have made it back to the Coles fast enough to save their home. “The quickest forfeiture process I’ve seen has been about 12 months,” said Prowell.

He stressed that even though it was a good ending for the Cole family, the title company will absorb the rest of the losses. “This is a small title company,” Prowell said “But it was a small company with a heart.”

Prowell is also hopeful Aaron Cole’s story will raise awareness about business email compromise and the need to be vigilant about online security.

Cole said he used the same password for several email and social media accounts and hadn’t changed them for a while. The criminals could have been monitoring his accounts for years using a simple software that watches for keywords that may indicate money is about to move.

In addition to strong passwords and better awareness, Prowell says people should revert to old fashioned means of verification before sending money. “Go check in person,” he said. “Or pick up the phone and make a call.” 

But Prowell also wants those who act as money mules to understand the harm they are doing to others and the peril they are exposing themselves to. First and foremost, acting as a money mule is illegal. Those performing the function can face criminal prosecution, damage to their credit standing, and financial liability for the money they move.

Money Mule Awareness Booklet
People who agree to allow others to use their bank accounts or open new accounts for these purposes are also linking themselves to criminal organizations. One of the money muling groups involved in Aaron Cole’s case was part of a separate FBI investigation into financial and violent crimes. “These groups are not always just fraudsters,” Prowell said. “That particular group was also dangerous.” 

“If you send and receive money at someone else’s request—especially someone you’ve never met—you are likely helping criminals to steal from hardworking people, senior citizens, and small businesses,” said Supervisory Special Agent James Abbott of the FBI’s Money Laundering, Forfeiture, and Bank Fraud Unit.

During a recent eight-week campaign to combat money mules, the FBI partnered with other federal law enforcement agencies to interview more than 550 individuals. They served more than 500 warning letters on individuals who served as money mules for fraud schemes. The letters informed recipients that they could be prosecuted if they continue.

Additionally, more than 30 individuals were criminally charged, in part, for their roles in receiving victim payments and providing the fraud proceeds to accomplices. Abbott stressed that banks and law enforcement take note of unusual account activity: “Anyone who continues to participate in this type of activity should be prepared to hear from the FBI or our partners.”

Learn more about money mules and help raise awareness by sharing the facts through #DontBeAMule.

Signs You May Be Acting as a Money Mule

• You receive an unsolicited email or contact over social media promising easy money for little to no effort.
• The “employer” you communicate with uses web-based email (such as Gmail, Yahoo, Hotmail, or Outlook).
• You are asked to open up a bank account in your own name or in the name of a company you form to receive and transfer money.
• As an employee, you are asked to receive funds in your bank account and then “process funds” or “transfer funds” via a wire transfer, ACH, mail, or money service business (such as Western Union or MoneyGram).
• You are allowed to keep a portion of the money you transfer.
• Your duties have no specific job description.
• Your online companion, whom you have never met in person, asks you to receive money and then forward the funds to an individual you do not know.
• How to Protect Yourself
• Do not accept any job offers that ask you to use your own bank account to transfer their money. A legitimate company will not ask you to do this.
• Be wary when an employer asks you to form a company to open up a new bank account.
• Never give your financial details to someone you don’t know and trust, especially if you met them online.
• Be wary when job advertisements are poorly written with grammatical errors and spelling mistakes.
• Be suspicious when the individual you met on a dating website wants to use your bank account for receiving and forwarding money.
• Perform online searches to check the information from any solicitation emails and contacts.
• Ask the employer, “Can you send a copy of the license/permit to conduct business in my county or state?”

How to Respond

• If you have received solicitations of this type, do not respond to them and do not click on any links they contain. Inform your local police or the FBI.
• If you believe that you are participating in a money mule scheme, stop transferring money immediately and notify your bank, the service you used to conduct the transaction, and law enforcement.

How to Protect Yourself Against Business Email Compromise
Improve account security: Create strong passphrases for all online accounts. Do not use the same passphrase for more than one account. Change passphrases frequently.

Verify email addresses: Carefully check the address of any message that contains a link, attachment, or instructions. Criminals will make small changes to email addresses to make them appear as if they have come from a trusted source.

Double check: Never make a purchase, send a payment, or make a financial transaction based on email instructions only. Follow up on such requests by checking in person if possible or making a phone call. Do not use the phone numbers provided in the email in question.

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DOJ: Assistant Attorney General Brian A. Benczkowski Delivers Remarks at the 20th Annual Pharmaceutical and Medical Device Compliance Congress

Remarks as Prepared for Delivery

Good afternoon, and thank you for inviting me to speak at the 20th anniversary of this important forum, which brings together compliance experts across the pharmaceutical and medical device industries.  It is truly a pleasure to be here on behalf of the Criminal Division of the Department of Justice.  

At the outset, I would like to commend you for the important work that you do.  The Department greatly values the role of the corporate compliance community.  Every day, you work hard to reinforce legal and regulatory compliance and ethical behavior in business organizations, work that benefits all of us. 

The role of the federal prosecutor is, of course, different from that of a corporate compliance professional, but in many ways our goals are aligned.  We both want to deter corporate criminal misconduct, and we both want to detect such misconduct when it does occur, holding wrongdoers to account in our respective ways. 

With apologies for repeating a cliché -- the corporate compliance function is in some ways more important than the prosecution function. 

It can actually prevent misconduct in the first place through robust systems of controls, and by fostering a culture where compliance is valued and rewarded.  And while this aspect of corporate compliance is always important, it is especially important in the industries in which you operate, where the health and safety of patients often are at stake.

I came to my current role as the head of the Criminal Division from private practice, where I worked on investigations and compliance reviews for numerous life sciences clients. 

I know first-hand – both from that experience and my time with the Department – that the good corporate citizens within the pharmaceutical and medical device industries invest heavily in their compliance programs.  And they need to do so.  Most of you operate in a heavily regulated space, and the risks of non-compliance are high.

For at least the last two decades, the Department has made it clear that it expects companies to invest in effective compliance programs.  But I don’t think the Department has always been as clear about what that means – both in terms of what the Department would look for in an effective program, and with regard to how the Department’s prosecutors would factor compliance into resolving their corporate cases.

Over the last few years, including before I arrived, the Criminal Division has worked to be more transparent about how it approaches its evaluation of compliance programs, including developing new policies and guidance designed to help encourage responsible companies to fully invest in compliance, but also to invest wisely and efficiently.

Building on past efforts, in April of this year, the Criminal Division issued a newly expanded and refined guidance document for our white-collar prosecutors clarifying how to evaluate corporate compliance programs. 

This guidance promotes greater transparency in the specific factors we will use to evaluate the design and effectiveness of a compliance program.  It spells out numerous factors that the Criminal Division has frequently found relevant, but organizes them around three fundamental questions, which are always at the heart of our inquiry: 

1) Is the compliance program well designed?

2) Is the program being implemented effectively and in good faith?

3) And does the compliance program work in practice?

In setting forth these various factors, we were not seeking to be prescriptive.  We are not regulators, and we recognize that every company and industry is different. There is no such thing as a one-size-fits-all compliance program, nor should there be.  

We also know that no compliance program is 100% effective.  No system of controls is absolutely bulletproof.  

Corporations employ people, and not all of those people are going to be uniformly law-abiding and ethical.  Bad actors in a company will work to identify and exploit weak controls and compliance structures. 

The Criminal Division’s policies need to reflect that reality, especially because our prosecutors will invariably find themselves assessing a compliance program’s adequacy in hindsight, after a problematic event has already occurred. 

The policies and tools they bring to their analysis need to account for the fact that misconduct is sometimes going to happen, even within good organizations.  Our prosecution efforts need to differentiate between companies that are investing adequately in compliance and working hard to build a strong culture, and those that are not. 

Our written compliance guidance is crafted to avoid being overly rigid, allowing for each company’s program to be evaluated based on its unique risk profile. 

But the Division’s written guidance document is only part of what we’ve done to improve our prosecutors’ understanding of corporate compliance programs. 

In concert with our development of written compliance program guidance, we also trained all Criminal Division attorneys who work on corporate investigations to give them a range of perspectives on compliance program effectiveness. 

As part of that training, we brought in experts from inside the Department of Justice, as well as outside voices from industry and the accounting profession to share their views on various compliance challenges and how industry is confronting them. 

We looked at compliance challenges in high-risk markets and industries, as well as challenges that come with M&A due diligence and post-acquisition integration. We also focused on an area of growing attention in your industries, namely the evolution of compliance technology and data tools. 

All of this is part and parcel of a common effort in the Criminal Division to promote effective compliance regimes.  By training our prosecutors, we are making them better able to objectively assess the role of compliance in any corporate resolution, including whether to impose a monitor.  And by providing written guidance, our prosecutors should be working from a common understanding of how to do those assessments. 

But we also want you all to have a window into our thinking, so you can make wise, informed, and cost-effective decisions about whether and how to develop, grow, and enhance your compliance programs. 

This transparency hopefully will foster better alignment of the common goals I mentioned at the outset – deterrence of corporate crime on the front end, holding bad actors accountable on the back end, and doing so in a way that is fair and objective.     

We’ve made other policy changes as well that align with these goals.  Deterrence, of course, also is the objective behind applying the FCPA Corporate Enforcement Policy in all of our corporate criminal cases, including health care fraud cases.  Under this policy, a company receives the presumption of a declination if it voluntarily self-discloses the misconduct, fully cooperates with the Department, and engages in timely and appropriate remediation.   

Even if aggravating circumstances call for a criminal resolution, companies can get up to a 50% reduction off the bottom of the applicable fine range if the conditions of voluntarily self-disclosure, full cooperation, and timely and appropriately remediation are met. 

In a nutshell, the policy makes clear that when a company is serious about maintaining a culture of compliance, it can enjoy the peace of mind that the government will recognize that fact, and treat it fairly. 

Deterrence is also the objective behind the so-called “anti-piling on” policy.  That policy encourages enforcement components inside and outside of the Department of Justice to coordinate with one another when imposing penalties for the same conduct. 

Coordination includes crediting and allocating financial penalties and forfeitures to avoid disproportionate punishment.   

The “anti-piling on” policy is designed to encourage companies to aggressively root out perpetrators without fearing that they later will be subject to multiple penalties from multiple regulators. 

Deterrence is likewise the common thread behind our decision to be more transparent about corporate declinations under the enforcement policy. 

We now routinely publish corporate declinations on our website so that defense attorneys and corporate counsel can refer to these declination memoranda to understand the analysis behind our decision to not bring criminal charges.      

 All of these efforts have been geared toward enhancing transparency and fostering ethical corporate practices and behaviors so that companies will have the tools and information needed to invest fully in compliance, and so that criminal wrongdoing is deterred before it ever calls for the attention of the Department of Justice.

Enforcement

A few words about enforcement.  White-collar criminal enforcement and health care fraud continue to be a top priority for the Department of Justice and the Criminal Division.  

In 2018, our Fraud Section posted record numbers of white-collar prosecutions in a number of categories. 

In one year alone, we brought 10 corporate enforcement actions and recovered more than $1 billion in corporate U.S. criminal fines, penalties, restitution, and forfeiture, as part of resolutions that returned $3 billion globally. 

We also held individuals accountable for their criminal acts.  In 2018, the numbers of individuals charged increased by 33% from the prior year, and we convicted 40% more individuals at trial.

And as we near the end of 2019, we are on track to surpass many of those 2018 benchmarks.

In addition to general corporate enforcement, we have been laser-focused when it comes to combatting health care fraud and opioid fraud and abuse schemes that have destroyed so many lives across the United States. 

Health care fraud is a betrayal of the public trust -- it robs American taxpayers of billions of dollars every year and threatens our most vital federal programs, all while driving up the cost of health care and insurance. 

Illegal opioid schemes exploit the disease of addiction and corrupt the time-honored relationship between doctors and patients. 

During my tenure, we have brought the full power of the law to bear on the perpetrators of all these schemes.  

Over the last several months, we have announced indictments charging a variety of health care fraud, Anti-Kickback Statute, money laundering, and Controlled Substances Act violations in a number of regions of the country from Tennessee, Kentucky, West Virginia, and Ohio to Texas, California, New Jersey, and elsewhere. 

These indictments resulted from the successful work of our Strike Force model that combines seasoned prosecutors from the Criminal Division and U.S. Attorneys’ Offices, analysts, and law enforcement agents in federal districts across the country.

The Strike Force model has proven to be highly successful in combatting health care fraud and opioid abuse by combining data analytics and the use of traditional law enforcement investigative techniques.

It has allowed us to shine a bright light on dirty doctors, clinic owners, pharmacists, and others who long believed they could perpetrate their frauds and exploit their patients for personal financial gain without visibility. 

The data in our possession allows us to see them, however remote or rural their corner of the country.  With the overlay of traditional investigative techniques, we are able to use data analytics to track down the worst of the worst offenders and quickly build strong cases against them. 

In the past year, we expanded our Strike Force program to the Appalachian region to target opioid abuse related crimes and in the Rio Grande Valley and San Antonio, Texas.  We now have 15 total Strike Forces operating in 24 districts.

In just 2019 alone, the Criminal Division’s Health Care Fraud Strike Forces have brought charges against 354 individuals with a loss amount of over $4.1 billion. 

I’d like to highlight for you some of the schemes that we have uncovered and prosecuted which exploit new medical technology, like telemedicine, and use sophisticated money laundering to facilitate and disguise fraud. 

In April of this year, we announced the takedown of one of the largest health care fraud schemes ever investigated by the FBI and HHS-OIG, and prosecuted by the Criminal Division and U.S. Attorney’s Offices. 

The takedown resulted in charges against 24 defendants, including the CEOs, COOs, and others, associated with five telemedicine companies, the owners of dozens of durable medical equipment (DME) companies, and three licensed medical professionals, for their alleged participation in health care fraud schemes involving more than $1.2 billion in loss. 

Significantly, as part of this operation, our partners at the Center for Medicare and Medicaid Services’ Center for Program Integrity took simultaneous adverse administrative action against 130 DME companies that had submitted over $1.7 billion in claims and were paid over $900 million.   These actions resulted in the immediate suspension of payments from the program and/or termination of the companies’ rights to bill the program at all.

As alleged in the indictments, DME companies paid illegal kickbacks and bribes in exchange for the referral of Medicare beneficiaries by medical professionals working with fraudulent telemedicine companies for back, shoulder, wrist, and knee braces that were medically unnecessary.  

Additionally, an international telemarketing network lured hundreds of thousands of elderly and/or disabled patients into a criminal scheme that crossed borders, involving call centers in the Philippines and throughout Latin America. 

These defendants allegedly paid doctors to prescribe DME either without any patient interaction or with only a brief telephonic conversation with patients they had never met or seen. 

The proceeds of the fraudulent scheme were then allegedly laundered through international shell corporations and used to purchase exotic automobiles, yachts, and luxury real estate in the United States and abroad.

The Criminal Division coordinates closely with its law enforcement and agency partners to ensure that we are proactively identifying and addressing the most serious threats to the Medicare program.  And this forward-leaning approach has led us to tackle health care fraud in new frontiers of medicine. 

Within just months of announcing the DME indictments, the Criminal Division unveiled another significant enforcement action involving fraudulent genetic cancer testing, in partnership with the U.S. Attorney’s Offices for the Southern and Middle Districts of Florida, the Southern District of Georgia, and the Eastern and Middle Districts of Louisiana

As part of that operation, we charged 35 defendants associated with dozens of telemedicine companies and genetic testing laboratories for their alleged participation in one of the largest health care fraud schemes ever charged – a scheme involving more than $2.1 billion in fraudulent Medicare billings.

This investigation targeted an alleged scheme involving the payment of illegal kickbacks and bribes by genetic testing laboratories in exchange for referrals of Medicare beneficiaries.  The referrals were made by medical professionals working with fraudulent telemedicine companies.  And the referrals were for expensive cancer genetic tests that were medically unnecessary. 

Indeed, often times the diagnostic results were never even provided to the beneficiaries or were worthless to their actual doctors. 

In addition to our efforts to combat health care fraud and opioid fraud and abuse on the home front, I want to highlight a recent corporate resolution that demonstrates our efforts to hold providers accountable for paying bribes to foreign government officials to gain a competitive advantage in the medical services industry. 

In March, I announced that the Fraud Section had entered into a corporate resolution with Fresenius Medical Care, one of the leading providers of dialysis products and services in the world.

The company had agreed to pay $231 million to resolve investigations by the DOJ and the SEC into violations of the FCPA in connection with Fresenius’ participation in various corrupt schemes to obtain business in multiple foreign countries. 

Fresenius admitted that between 2007 and 2016, it paid bribes to publicly employed health and/or government officials to obtain or retain business in Angola and Saudi Arabia, as well as in Morocco, Spain, Turkey, and countries in West Africa.  Fresenius also admitted that it knowingly and willfully failed to implement reasonable accounting controls over financial transactions and failed to maintain books and records that accurately and fairly described the transactions.

This resolution, under which Fresenius agreed to retain an independent compliance monitor for two years, reflects the Department’s firm commitment to rooting out bribery and promoting the kind of effective compliance programs that will prevent misconduct going forward.

****

It’s been a pleasure to speak here today.  As I hope you can tell, the Criminal Division will continue to aggressively investigate and prosecute health care and other frauds in the drug and device sectors.  I also hope my remarks give your industries some comfort that when we do investigate and prosecute, we will do so fairly, pursuant to clearly identified policies. There should be no mystery about how and why we bring and resolve enforcement actions.  And hopefully this transparency will help you prevent corporate crime, and help you make wise decisions about how to best deploy your compliance resources.  

Thank you very much, and I wish you the best for the remainder of the conference.

Voting is beautiful, be beautiful ~ vote.©

DOJ Forgot About Foster Care & Adoption In Its International Child Kidnapping Guideance

This is odd.

There is nothing in this guidance publication that addresses corporate parental child kidnapping.

You do know corporations have parental rights, right?

Even States have parental rights.

Corporations Have Parental Rights

Foster Care and Adoption (including 'refugee' which is nothing but the international fancy term for foster care) is how they traffic tiny humans.

The terms "Foster Care", "Adoption", "Refugee" were ostentatiously omitted from the guidance because it illuminated each and every agency and organization that has their hands in the child welfare fraud cookie jar.

The guidance also presents legal pathways in dealing with child immigration, instead of throwing the kid in foster care, to have a concurrent plan put in place, which is expedited, under the States, to keep the kid in for as long as billablely possible, recognized are legal determinations for parental search and reunification, because many of these kids are victims of child trafficking, who, in turn, get caught up in the U.S. trafficking of tiny humans industry.

Now, let us see what the Congress is going to do.

OJJDP PUBLISHES INTERNATIONAL CHILD KIDNAPPING GUIDE FOR LAW ENFORCEMENT

         WASHINGTON – The Office of Justice Programs’ Office of Juvenile Justice and Delinquency Prevention today published guidelines to help law enforcement prevent and respond to cases of international kidnapping of a child by a noncustodial parent.

          In 2017 there were more than 900 cases of international kidnapping of children across 59 countries reported to the U.S. Department of State’s Office of Children’s Issues. Law enforcement agencies play a critical role in the prevention and resolution of international parental kidnapping.

           A Law Enforcement Guide on International Parental Kidnapping describes law enforcement’s role as initial responders and investigators of kidnapping crimes, discusses applicable laws and legal remedies for child recovery and reunification, and outlines considerations for criminal prosecution and extradition of offenders.

TITLE:	A Law Enforcement Guide on International Parental Kidnapping
AUTHORS:	OJJDP and the Federal Agency Task Force on Missing and Exploited

Children

DOJ: A LAW ENFORCEMENT GUIDE ON International Parental Kidnapping by Beverly Tran on Scribd

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U.S. Corporate Parents Say No To Breastfeeding

Drop that baby and get back out to the fields.

If the U.S. supports breastfeeding, then that means it would have to change its socio-economic policies and stop trafficking tiny humans of "The Poors" (always said with clinched teeth).

Corporations are parents, with parental rights, to decide the "best interests of the child", too, which is why the U.S. Senate Judiciary Committee is looking into this.

That is why being a wet nurse is no longer considered to be socially responsible.

From Nu Skin With Love: How Child Welfare Fraud Funded Political Campaigns & Human Trafficking

Learn more: BEVERLY TRAN: From Nu Skin With Love: How Child Welfare Fraud Funded Political Campaigns & Human Trafficking http://beverlytran.blogspot.com/2017/07/from-nu-skin-with-love-how-child.html#ixzz5Kgwq2vTX
Stop Medicaid Fraud in Child Welfare 

Breastfeeding in the U.S. impedes the industry of child welfare productivity, where poverty is the crime of abuse and neglect, subject to removal of the child by Child Protective Services, placed in Foster Care, then Adopted, with tons and tons of services billable to Medicaid.

If the U.S. promotes and promulgates breastfeeding, then it would have to stop snatching kids, and, in the event this happens, how are all those child welfare NGOs going to be able to launder money into those political campaigns?

It is financially savvy to keep those infant mortality numbers high to justify that Faith Based Initiative Funding to demonize the breastfeeding mother and keep those child welfare Social Impact Bonds producing dividends.

Children of "The Poors" (always said with clinched teeth) are now being codified throughout the States as a condition of disability, for the purposes of assigning a corporate parent through guardianship, which results in an automatic asset forfeiture and any inheritances or legacy.

The rest of you can pull yourselves up by the bootstraps and become a foster parent!

Depopulation policies at its best, but let us just sit back and see how these so-called child welfare NGOs are going to respond to this.

U.S. Opposition to Breast-Feeding Resolution Stuns World Health Officials

A resolution to encourage breast-feeding was expected to be approved quickly and easily by the hundreds of government delegates who gathered this spring in Geneva for the United Nations-affiliated World Health Assembly.

Based on decades of research, the resolution says that mother’s milk is healthiest for children and countries should strive to limit the inaccurate or misleading marketing of breast milk substitutes.

Then the United States delegation, embracing the interests of infant formula manufacturers, upended the deliberations.

American officials sought to water down the resolution by removing language that called on governments to “protect, promote and support breast-feeding” and another passage that called on policymakers to restrict the promotion of food products that many experts say can have deleterious effects on young children.

When that failed, they turned to threats, according to diplomats and government officials who took part in the discussions. Ecuador, which had planned to introduce the measure, was the first to find itself in the cross hairs.

The Americans were blunt: If Ecuador refused to drop the resolution, Washington would unleash punishing trade measures and withdraw crucial military aid. The Ecuadorean government quickly acquiesced

The showdown over the issue was recounted by more than a dozen participants from several countries, many of whom requested anonymity because they feared retaliation from the United States.

Health advocates scrambled to find another sponsor for the resolution, but at least a dozen countries, most of them poor nations in Africa and Latin America, backed off, citing fears of retaliation, according to officials from Uruguay, Mexico and the United States.

“We were astonished, appalled and also saddened,” said Patti Rundall, the policy director of the British advocacy group Baby Milk Action, who has attended meetings of the assembly, the decision-making body of the World Health Organization, since the late 1980s.

Michigan Surrogate Parents and Special Education Decision-Making Guidance 2017 by Beverly Tran on Scribd

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Corporations Have Parental Rights

Did you ever wonder why no one wants to talk about the residuals of the peculiar institution?

Well, it is because of child welfare.

Yes, that is correct.

Not only are children still statutorily codified as property, or rather chattel, but the 13th Amendment made sure that the best financial interests of the child were placed under the parental rights of corporations.

Yes, that is correct, corporations have parental rights.

Commercial Surrogacy: the new term for saying:
"Trafficking Tiny Humans"

According to investopedia, a parent company is:

What is a 'Parent Company'

A parent company is a company that controls other, smaller businesses by owning an influential amount of voting stock or control. Parent companies are typically larger firms that exhibit control over one or more small subsidiaries in either the same industry or complimentary industries. Parent companies can be either hands-on or hands-off with subsidiaries, depending on the amount of managerial control given to subsidiary managers.

BREAKING DOWN 'Parent Company'

A parent company is a larger corporation that has significant ownership over a subsidiary or group of subsidiaries. These partially or wholly-owned smaller companies are controlled by the parent, to varying degrees; however, all parent companies, for the most part, own more than 50% of a subsidiary's voting stock.

There is a new phenomenon called commercial surrogacy.

So, what exactly is commercial surrogacy?

According to surrogacy.com, defines commercial surrogacy as such:

Commercial surrogacy refers to any surrogacy arrangement in which the surrogate mother is compensated for her services beyond reimbursement of medical expenses.

The corporate surrogate parent model is currently being implemented on the state level as seen in the EPIC Foundation.

From 2004 to the present The EPIC Foundation has collaborated with the Hawaii State Department of Education in training and appointing Surrogate Parents to eligible children. Surrogate parents ensure that eligible children receive an education comparable to children without disabilities in all matters pertaining to their identification, evaluation, and educational program placement. The Surrogate Parent Program was established by the Hawaii State Department of Education to ensure proper representation and services for children with disabilities as mandated by the Individuals with Disabilities Education Improvement Act (IDEIA) and Vocational Rehabilitation Act of 1973 (amended by the Rehabilitation From 2004 to the present The EPIC Foundation has collaborated with the Hawaii State Department of Education in training and appointing Surrogate Parents to eligible children. Surrogate parents ensure that eligible children receive an education comparable to children without disabilities in all matters pertaining to their identification, evaluation, and educational program placement.

Eligible Children are those:

• Whose parents cannot be identified.

• Whose parents cannot be located

• Who are wards of the state under the laws of the state

• Those considered to be unaccompanied youth as stated under the Stewart B. McKinney-Vento Homeless Assistance Act

• That have no relative willing and able to serve as an educational representative for a student who has reasched the age of majority and lacks decisional capacity to provide informed consent.

According to beverlytran.com, commercial surrogacy is defined as  as such: The trafficking of tiny humans because every corporation should hire a child.

As seen here, corporations have parent disclosures but individuals do not, according to the Federal Rules of Civil Procedures.

According to the Federal Rules of Civil Procedure, Rule 7.1, a Corporate Parent Disclosure Statement is:

(a) Who Must File; Contents. A nongovernmental corporate party must file 2 copies of a disclosure statement that:
(1) identifies any parent corporation and any publicly held corporation owning 10% or more of its stock; or
(2) states that there is no such corporation.

Individuals are granted the rights of custodianship and guardianship, where the parent disclosure is conferred upon the States Attorney General, by United States Code, 15 U.S.C. 15(c):

Any attorney general of a State may bring a civil action in the name of such State, as parens patriae on behalf of natural persons residing in such State, in any district court of the United States having jurisdiction of the defendant, to secure monetary relief as provided in this section for injury sustained by such natural persons to their property by reason of any violation of sections 1 to 7 of this title. The court shall exclude from the amount of monetary relief awarded in such action any amount of monetary relief (A) which duplicates amounts which have been awarded for the same injury, or (B) which is properly allocable to (i) natural persons who have excluded their claims pursuant to subsection (b)(2) of this section, and (ii) any business entity.

The "crime" for which the States Attorney General may bring forth on behalf of the Corporation of the State is now the crime of poverty, which is manifests itself in the form of asset forfeiture policies through privatization.

STATE CONSTITUTION (EXCERPT) CONSTITUTION OF MICHIGAN OF 1963 § 9

Slavery and involuntary servitude. Sec. 9. Neither slavery, nor involuntary servitude unless for the punishment of crime, shall ever be tolerated in this state. History: Const. 1963, Art. I, § 9, Eff. Jan. 1, 1964. Former constitution: See Const. 1908, Art. II, § 8.

Oh, but involuntary servitude is tolerated in Michigan, under Child Protection Laws, as "failure to provide for the necessary needs of the child" is poverty, which is abuse and neglect, grounds for a trustee corporation to state the "best interests of the child".

As we see the progression of the parental rights of corporations, policies are now being diffused across the nation, in those pilot model states, by amending language to include the terms "children" and"seniors" into term, "disabled", then creating and promoting a new nomenclature for chattel law, or rather "personhood".

So, if an individual must rely upon any form of social assistance, seen the mandatory Medicaid work requirement, the state assigns "custodianship & guardianship" to privatized contractors through case management, probably better understood as a Micro Emergency Manager of the trust fund.

The trust fund, in this instance is the Social Security Trust Fund, where corporations have parental rights seize these "assets" to for providing services to "The Poors", or rather the disabled.

Think about this policy as a new form of indentured servitude, but there is nothing worded in these new state laws where a time period, like the traditional seven years indenturtude or working off one's debt releases one from the default transfer to the privatized corporation.


MICHIGAN GENERAL CORPORATION STATUTE (EXCERPT)
Act 327 of 1931

450.157 Trustee corporation; hospitals; asylums; trustee instrument; indenturing or apprenticing destitute or foundling;children; withdrawal.

Sec. 157.

(1) In all cases where lands, or any other property, amounting in value to $5,000.00 or more, have been or are given, granted, devised, or bequeathed to 3 or more trustees for the purpose of founding or endowing a hospital or other charitable asylum for the care or relief of indigent or other sick or infirm or aged persons, or the care of minor orphans or children and youth with special health care needs or for the care and protection of unfortunate women, or any number of those purposes, the trustees may incorporate under this act as a trustee corporation. Unless restricted by the trust instrument, the trustees may unite in that incorporation with other persons contributing to the maintenance of the hospital or asylum, and all of those other persons shall become members of the corporation upon making the contribution as may be fixed and determined in the articles or by-laws of the corporation. However, any 3 or more persons may incorporate for any charitable purpose described in this subsection as a trustee corporation, where the hospital, home, asylum, or other institution to be founded by the corporation is to be constructed, equipped, and maintained principally by donations not made under any trust deed or other instrument in writing declaring the uses and purposes to which the property shall be devoted, and that corporation shall have authority to fix and prescribe the terms and conditions of membership in the corporation.

(2) The trustees of a trustee corporation described in subsection (1), or a majority of them, are hereby authorized and empowered to indenture or apprentice to responsible persons, any destitute or foundling children who now or later become under the charge or care of that corporation, until those children shall respectively become of lawful age, and to make that indenture in each case as binding and effective in all respects as if the trustees were the lawful parents or guardians of those children. However, the trustees shall have power to withdraw a child from any person to which he or she is indentured, when in their opinion the interests of the child require it.

History: 1931, Act 327, Eff. Sept. 18, 1931 ;-- CL 1948, 450.157 ;-- Am. 2015, Act 89, Imd. Eff. June 25, 2015
Compiler's Notes: The catchline following the act section number was incorporated as part of the section when the act was enacted.
Former Law: See section 10 of Ch. I of Part IV of Act 84 of 1921, being CL 1929, § 10086; and section 11 of Ch. I of Part IV of Act 84 of 1921, being CL 1929, § 10087.

So, now you know why corporations have parental rights.

An Examination of Foster Care in the United States and the Use of Privatization by Beverly Tran on Scribd

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