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Webber account were removed from that account by way of a single
check in the amount of $1,151,627 payable to “Global Capital
Enterprises, Inc.”.4 This check was hand-delivered by Bussell to
Beaudry, who deposited it into an offshore bank account (CITCO
account) maintained in the Netherlands Antilles by an entity
named CITCO Banking Corp. The purpose of making the Paine Webber
check payable to Global Capital Enterprises, Inc., and then
depositing that check into the CITCO account was to conceal the
location of the funds. Pursuant to petitioner’s instructions,
Beaudry then transferred the funds from the CITCO account to the
Syntex account by way of two separate transfers of $820,000 and
$331,616.5 These transfers were made separately because
petitioner was concerned about the security of the transfers.
On March 25, 1996, Beaudry made the first transfer, of
$820,000, from the CITCO account to a Medifor, Ltd. account in
Hong Kong (Medifor account). In April 1996, Beaudry instructed
an entity named TrustNet Group to obtain a cashier’s check for
$820,000, payable to Syntex. This cashier’s check was deposited
into the Syntex account on or about April 9, 1996. Bussell then
4 The $2,579 difference between the $1,149,048 deposited
into the Sanwa account and the withdrawn $1,151,627 was
presumably attributed to income earned on the deposited funds.
5 We note the $11 discrepancy between $1,151,627 and the sum
of $820,000 and $331,616 ($1,151,616).
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