42 responses

  1. mjc
    20/03/2012

    And how does Bebe fit in with all this?

  2. Anne
    20/03/2012

    Extra Credit:

    How the layering process works through an actual Swiss money-laundering “bank”:

    One of the primary Swiss money brokers who laundered money for RJR was the organization created by Alfred Bossert, located in and around Lugano, Switzerland. Mr. Bossert’s primary company, “Intercambi S.A.,” received large cash payments stemming from the criminal activity of various criminal organizations.

    These payments would be received by the Bossert organization in Switzerland, the sums would be counted, and the person to which the funds belonged would be credited with the appropriate amount. The Bossert organization would then, either directly or through a variety of money-laundering “subcontractors” such as “Enrico Rosini” and/or “Gecap S.A.,” change the various currencies (i.e., Italian lira, Spanish pesetas, and others) into U.S. dollars, and would hold those dollars in several accounts created and/or controlled by the Bossert organization or its “subcontractors”.

    On a monthly basis, the Bossert organization would send a “statement” to the various owners of the funds, such as the organization created by Corrado Bianchi, a major RJR customer, indicating the dates and sums received on their behalf from mafia-type criminal organizations. Furthermore, the Bossert organization would receive instructions from its various clients, including Corrado Bianchi, to make payment out of their informal “account” to a variety of destinations, including directly to RJR and other providers of cigarettes.

    For example, these money broker organizations would make payments to a Swiss company called “Maxim SA,” which would then distribute RJR cigarettes to Italian criminal organizations. Similar payments were made to numerous different cigarette distributors, all purportedly located in different countries, all of which were selling RJR cigarettes to the Italian mafia. Examples include:

    Rosacta Co. Ltd., located in Cyprus, through .an account at Helenic Bank Ltd.,also in Cyprus

    Namari Holdings Ltd., located in the Channel Islands, through an account at Harris Bank International Corp in New York, which then transferred the money to Namari through a second account at the Royal Bank of Scotland International PLC, in the channel islands.Account name: “Nama Hold-USD1”.

    Corlett Trading Limited located in Cyprus, through .an account at Anker Bank Genf Postfach in Switzerland

    Old Navy Trading, located in Cyprus, through .an account at Union Bank of Switzerland,

    Icosa A.G., located in Switzerland, through an account at Banque Vanorient in Switzerland.

    Rowill International located in Belgium through an account at KBC Bank, located in Rotterdam, Netherlands, and additional payments were made to a second Rowill account at the KBC Bank located in Antwerp, Belgium

    All of the aforesaid companies ultimately delivered these criminal proceeds to RJR, and RJR cigarettes to the Italian mafia in exchange.

  3. Anne
    20/03/2012

    Extra extra credit:

    Money laundering by the Russian mafia through the legitimate banking system:

    RJR was also involved in money laundering for the Russian mafia, through a financial institution known as “Sinex Bank,” which was incorporated in the country of Nauru. However, according to the EU, this bank was actually created almost exclusively for the purpose of laundering the proceeds of Russian organized crime.

    Just to give you a general idea of exactly how much criminal money the Russian mafia is moving through these networks, between 1996 and 1999, Sinex Bank laundered up to Seven Billion Dollars in criminal proceeds.

    Sinex bank did business in the United States by way of an office maintained in Queens, New York, by Aleksey Volkov, one of its directors. Sinex’s criminal customers initiated bank transfers that were sent to Depozitarno Kliringovy Bank (DKB). Transfers to DKB Bank were cleared through DKB’s accounts at the Bank of New York in Queens. These payments were then sent to accounts at Credit Suisse First Boston in Geneva, Switzerland, which were held by a company owned by RJR. .

    These payments were made to purchase RJR cigarettes, which were ultimately distributed to the Russian mafia. On payment detail forms, Sinex Bank identified itself as the Ordering Customer. However, it’s quite obvious that a Russian bank is not going to be distributing RJR cigarettes. By identifying itself as the “Ordering Customer,” Sinex Bank was concealing the true identity of the entities that were paying for the RJR cigarettes.

  4. nicky
    20/03/2012

    Anne,
    After ploughing awestruck through your post PLUS the additional comments, NEVER will I accuse the fairer sex of not understanding the offside rule in football OR the lbw law in cricket.

  5. Anne
    20/03/2012

    @Nicky:

    Why thank you. Although I must admit, while I fully understand the offside rule in football, I have no idea what the lbw law in cricket is 🙂 Care to enlighten me?

  6. nicky
    20/03/2012

    Anne,
    When I recover from the grovelling position I will attempt to
    explain the lbw law. 😆

  7. Anne
    20/03/2012

    @mjc:

    You wouldn’t have asked me that, I don’t think, if you didn’t already have a theory. I would be interested to hear it.

    Bebe is a 3rd party ownership case, which means that money from signing or transferring him can be easily diverted to pretty much anywhere, creating high vulnerability to money laundering. I don’t know anything specific about him, though. Do you?

  8. Anne
    20/03/2012

    @Nicky:

    Lol. Ok. Just see that you do, because you actually have me curious about it now 🙂

  9. Anne
    20/03/2012

    Not a very good day for Barca, is it?

    “Syrian TV have accused Barcelona of helping rebels smuggle arms to try and overthrow President Bashar al-Assad…They allege that passing patterns during a match with Real Madrid were planned to show rebels where weapons were hidden.”

    http://sportwitness.ning.com/forum/topics/syrian-tv-accuse-messi-and-barcelona-of-helping-arms-smugglers

    So, this is an interesting twist. Does this mean that Barca could actually be laundering blood money for international arms traffickers?

    Oh, no, wait, hang on… I’m thinking of someone else. Someone else who was definitely not mentioned in this article, though.

  10. Yommex
    20/03/2012

    I think this explains why Arsenal would just not be allowed to win the epl again since 2004. All the attacks from the media have been masterminded to get him to resign from Arsenal which he has refused to do. It is now better understood why terms such as stubborn, obstinate, belligerent, to mention a few are used to describe him since he would not succumbed to Arsenal being used as a conduit pipe for these laundering schemes. If things have been allowed to run its course according to these scoundrels, Arsenal would have won the league at least a couple more times since 2004. Added to this is why the media continue to slate a manager that has been consistently performing at such a high level without these big name (?) transfers. I believe part of the money find their ways back to some of these journalists that are in the know with majority of them ignorantly repeating what they have heard from a few of their colleagues benefitting from the scheme.

    Also, a clear understanding why RvP had to be sent off against Barcelona last season since he was bent on derailing the anointed ones’ coronation as European Champions – one of the things Sandro Rosell must have been promised as the new President of the club given his connection with those that matter in the game!

    *I may be wrong on this but I’ll not be surprised if certain web sites providing detailed analyses of matches and rating of players are not in on this scheme as they could be used to provide empirical backings to why some players should be worth certain amounts. I find their ratings questionable as I don’t ever see objectivity in their submissions. Some rubbish players are awarded so high ratings that one will begin to ask if the rating is a reflection of the performance in the same match watched. I don’t know if any Arsenal player has ever been awarded a 10 on this site even when RvP scored 3 and assisted 2 against Blackburn he didn’t score a 10. Why? I think Arsenal players are not lucrative enough to be marketed for as long as Wenger is at the helm of affairs there simply because he’d not play game.

  11. Anne
    20/03/2012

    @Yommex:

    We’re thinking along similar lines, it seems. Arsenal definitely has a lot of money, and in my opinion, someone wants to get their hands on it.

    Your point about player ratings is interesting. Just in general, there seems to be a real disconnect between the skill level of an EPL player and the accolades that player gets from the press. (Rooney anyone?) There must be a reason for that.

    It’s worth noting that one way money is laundered is by overpaying a player, or paying too much for a transfer, and skimming the excess off the top.

  12. bjtgooner
    20/03/2012

    Anne, this is a magnificent article and very informative. The comment you made about FIFA’s accounts was interesting – if I wanted to look up the published accounts of FIFA, UEFA, FA and PGMOL is there a handy link? The PGMOL is particularly interesting – I would like to see what happens to their £6.8m declared income.

  13. Mandy dodd
    20/03/2012

    Fantastic article, very interesting examples, funny how certain names come up, wonder if the England kingmakers agree, I have a hunch they might be at least aware. I cannot see much hope for the game in its present form, it is corrupt right at the top, then there are the lower levels that will feed off this corruption and invent some more of their own. FIFA running football is like the Mafia running the European investment bank for reconstruction and development. Until they become accountable and audited by truly independent bodies, nothing will change,an ambitious ref on £60g pa is easy meat, as we are seeing. The problem is there are many on many levels who have transgressed, once they do that they are owned. An amnesty is a possible way for any body who wanted to confront this, assuming such a body exists, but spilling the beans would put one up against some very worrying organisations. And why do that if you are being paid and promoted.
    The fact is, the game we love is bent. All our team can do is what they did against dean/spurs, and that is not always easy. The game is bent, but not in our favour, which to me increases my respect for our club. We have nothing to do with it, and unfortunately pay the price on a regular basis.

  14. Goona Gal
    21/03/2012

    @ Anne, much food for thought, great article.

  15. Gf60
    21/03/2012

    Very thought provoking. Wasn’t Texeira (Barcelona Case 3)linked with FIFA?

  16. Kentetsu
    21/03/2012

    Teixeira resigned two days ago as board member of FIFA, after stepping down as president of the Brazilian Football Confederation a week before, both allegedly due to corruption allegations.

  17. Kentetsu
    21/03/2012

    Anne, another great article. I’ll have to read it again to digest all the information, but it is very intriguing.

    Considering that anyone can open a bank account anywhere it may not make much of a difference, but would you say that football clubs (or companies in general) that are registered in so-called tax heavens, like the British Virgin Islands, or whose owners are from there – such as Birmingham FC’s Carson Yeung in Hong Kong – are more likely to be involved in money laundering?

  18. Kentetsu
    21/03/2012

    In fact, I think Birmingham City FC and Carson Yeung might be an interesting case study.

    – Birmingham City FC is registered in the Cayman Islands
    – placed under transfer embargo because they failed to submit the financial results of 2010-11 on time (before March 2012)
    – wealthy foreign owner – who started his career as a barber
    – Yeung has been arrested on allegation on money laundering
    – he owns a casino – always helpful for trafficking large amounts of money

  19. Laundryender
    21/03/2012

    @Anne

    You have entered the UA Hall Of Fame.

    Football has always been rotten, I remember my early days in the seventies, as a fan i would go to watch Charlton Athletic on the weeks i could not get to Highbury, or Arsenal were away. The Charlton ground the Valley was the biggest in the country with massive crumbling concrete terracing, http://www.bbc.co.uk/london/content/image_galleries/valley_old_gallery.shtml?4 it was also very easy to “bunk in” which i did on many occasions, often hours before K/O hiding in the filthy toilets until the gates opened.

    You would get used to the size of the crowd, and be able to estimate the size of the crowd based on the gaps in the crowd and the density of the crowd. You could also do this remarkably accurately at Highbury, and even now at the Emirates.

    What was so evident at the Old Valley was how often the size of the crowd bore no resemblance to the figure that was released to the press, for the following days match report. A crowd that looked like 12,000 would be reported as 6,000, and a crowd that looked like 6,000 suddenly was 3,000 in the press. Football was a cash industry in those days, and obviously much of the money was filtered of by the club for dubious payments one way or another. It was in those days seen as legitimate practice, but the tax man started to clamp down on it in the eighties, which funnily enough saw a sudden increase in attendances at some grounds.

    On another subject, last night here in the UK channel 4 news reported on this, http://blogs.channel4.com/alex-thomsons-view/rangers-saga-hide-deeper-corruption-football/964
    Basically it is a confession that Rangers have been corrupt for years and that the SFA are powerless to do anything about it. Just in case you cant access the link here is the text.

    At 86 former Rangers director Hugh Adam may be hard of hearing, but hard of recollection and understanding he most definitely is not.
    Meeting at his house just outside Glasgow for his first TV interview since the current Rangers implosion began, he is precise in what he wants to say. He’s made notes in preparation for our visit.
    After some time on camera it becomes clear Mr Adam wants to go significantly further than in a couple of previous, ground breaking interviews with the Daily Mail.
    He already told that paper that there were, double contracts to pay players under the so-called Employee Benefit Trusts (EBTs) introduced by Sir David Murray who lavishly expanded Rangers on borrowed money until its spectacular collapse and sale for £1.
    Murray flatly denies double contracts, saying there were just discretionary payments.
    But speaking to Channel 4 News Hugh Adam goes further.
    He’s clear that these other payments to players were not declared to the football authorities the Scottish FA (SFA) and Scottish Premier League (SPL): “No I ‘m quite sure they didn’t declare them. I’m quite sure. The SFA isn’t pure in all this you know either. If something was put in front of them they’d have to examine it. It’s not a standard business.”
    The SFA says it followed the rule book and denies wrong doing (blog to follow).
    Now until the SPL inquiry is complete we don’t know whether or not the payments were declared. If they weren’t every player Rangers fielded with out telling the SFA/SPL full details of their money, would be ineligible and Rangers have to forfeit the match 3 – 0 to the other side. A lot of silverware in Govan could end up being moved and re-engraved. But like I say, it is all an if at the moment, assuming the SPL can be trusted competently to investigate itself in effect, over all this.
    Is it cheating, I ask: “It is. It is. But in football it’s standard practice. I mean it’s not serious cheating in that they were not putting money into their own pockets. The point is nobody really knew it was going on. You were a director and that was because you wanted to get a seat in the directors’ box.”
    And he paints a bizarre picture of life at Ibrox across the past fifteen years or more. A club where few – if any – of the directors were, he says, interested in directing Rangers at all. Everyone more or less happy to leave things to Sir David Murray and hop along to Ibrox to enjoy the box and the hospitality and that was really the meaning of being a director at Ranger PLC and that was it, beginning, middle and end. On that Hugh Adam is quite open.
    Of the EBT scheme itself he confirms again there were other payments made to players but nobody knew much and nobody asked.
    All in all it paints a strangely autocratic picture of a football club that was for some time expanding, winning and living the football dream. Sir David Murray came, expanded the business, talked big then crashed and burned
    And all the while everyone just seemed prepared to go along with the dream on borrowed time and a vary large amount of borrowed money.

    Sadly the sport I love, and put much of my hard earned cash into is rotten to the core, and always has been. I do believe our club is a shining beacon above the cess pit, and that Arsene Wenger is a highly moral and principled man. On those grounds alone he is worthy of admiration from not just me but everyone in sport. Sadly by too many he is just seen as an oddball who is up his own arse.

    Keep up the great work Anne, Fucking fantastic!!!!!

  20. WalterBroeckx
    21/03/2012

    What a great article and some great comments. Like someone said in the comments: this is something one has to read a few times before you can digest it. I will read it again a few times in the next days.

    Utterly remarkable article and comments. Thanks folks.

    The UA Hall of Fame… I like that phrase, Laundryender

  21. nicky
    21/03/2012

    @Laundryender,
    I recall watching Arsenal in the 1940’s at the Valley and being impressed at the size of the ground which, unfortunately, dwarfed the attendance. It was though, as you say, the biggest ground in the country. 😆

  22. Jitty
    21/03/2012

    Hi Anne

    You would no doubt love this book
    http://www.amazon.com/Thirty-Pieces-Silver-Anthony-Mollloy/dp/0958371717

    For anyone who doubts whether large scale fraud could exist in a western nation with full complicity of politicians, blue chip advisors and media – this is the book 🙂

    Well respected throughout the Commonwealth, Anthony P Molloy QC is New Zealand’s leading authority on Tax Law. In “Thirty Pieces of Silver”, Molloy examines the events surrounding New Zealand’s infamous “Wine Box” tax frauds of the 1980’s, and in particular he examines the legal ethics of one of New Zealand’s premiere law Firms in setting up, administering, and then covering up the transactions that made up the “Wine Box”.

    Molloy pulls no punches, but instead makes serious allegations, challenging both the reader to understand the scope and nature of often complex transactions, as well as challenging the law Firm to respond. Molloy names names and makes specific accusations — this would have been a very brave book to write, requiring Molloy to be absolutely dead-certain of each of his facts, at peril of finding himself on the wrong end of defamation suits. It is seldom that such books are written.

  23. Jitty
    21/03/2012

    @ Laundryender

    To be honest the deeper corruption at the SFA/Rangers is not even hidden.

    Its the best example yet of how a league is tilted via a corrupt body with complicity of media figures.

    More significant in my view is how the SKY Leagues have simply become product rather than a real sport.

    The product is of course not the football, but the viewing audience that is to be reached. In this , the twin engines of the industry are Media plus Gambling.

    Even United as a business is a tiny enterprise with not even 0.5Bn turnover.

    But once you start thinking about the engaged audience as the ultimate product, then you see how big this business really is.

  24. LRV
    21/03/2012

    Wow! Anne, I bow. Like a few others, I am still gasping for breath after that maraton reading. I need to read again without a doubt. Kudos!

  25. bob
    21/03/2012

    Anne,
    Awe-some — and yikes, too true to be good.
    Very Special Work you do.

  26. Laundryender
    21/03/2012

    @nicky

    you predate me by quite some distance, but the Old Valley was a massive gound certainly, close to our origins and a big Arsenal support in SE London.

    @Jitty

    You are spot on, i just brought attention to the fact that football is and has always been rotten to some degree. what happens nowadays though is off the scale!!!! It is simply “as sad as fuck” that a game we love and are hooked into has become so corrupted.

    @Walter

    You have been in the Hall Of Fame with @Dogface for quite some time.

  27. Anne
    21/03/2012

    @bjtgooner:

    Good luck trying to find those accounts 🙂 If I knew how to link you I don’t know if I would even recommend looking. I only like to link our readers to information sources that I deem reasonably credible 🙂

  28. Anne
    21/03/2012

    @Mandy Dodd:

    Very informative and well thought out as usual. Yes, I agree that, to a certain extent, we’re any a very deep hole of corruption that we may be unable to dig ourselves completely. However, at the same time, as I’ve said before:

    “It’s in the best interests of cockroaches to keep the lights off… It’s a hell of a lot easier to hide.”

  29. Anne
    21/03/2012

    @Gooner gal:

    Thanks.

  30. Anne
    21/03/2012

    @Gf60:

    See Kentetsu’s response below your comment (thanks Kentetsu). The Teixeira case is quite an interesting one, but it was a bit beyond the scope of this particular article. Hopefully we’ll have the chance to look at that case at some point in the future.

  31. Anne
    21/03/2012

    @Kentetsu:

    I’m sure that Yeung’s case is interesting. It’s one that I haven’t had time to research much myself but I think the list of money laundering warning signs that you listed in your second comment is spot on.

    You raise a very interesting question on the subject of club ownership, where clubs are registered in offshore jurisdictions. First, about offshore bank accounts generally. When you’re dealing with an offshore bank account, the one thing that you can be sure of is that the holder of the account is interested in secrecy. There could be any number of reasons for that, money laundering among them, but there are other possibilities as well. But whatever you’re doing, if it’s above board, why hide it?

    I’m very interested in your comment about Carson Yeung, and other owners who are “from” tax havens. Now, in general, while people might bank in a tax haven, they very rarely live there. But one issue that particularly comes up with regard to football clubs that are registered in offshore jurisdictions is the question of:

    Who is the real owner and/or owners of the club?

    Because one of the possible benefits of registering a club in such a locale is that it can provide a certain level of secrecy about who the true owners and investors in the club are. If they’re registered in such a place, they might have reason to keep their identities secret. So, again, if whatever you’re doing is above board, why hide your identity?

    So, with regard to any particular owner who claims to be “from” an offshore tax haven, my first question would be “ok, so who are the real owners?”

  32. nicky
    21/03/2012

    @Laundryender,
    A little piece of Charlton history for you.
    In one of the pre-WW2 issues of (Ithink) Picture Post they ran a story of a new whizzkid who had signed for Charlton Athletic with pictures of his arrival, training, etc. His surname was Lancelot and I often wondered what happenend to the lad. It was just before the War so his football career was halted however good he might have been. 😆

  33. Shard
    21/03/2012

    I’m officially impressed 🙂

    I am still not sure EXACTLY how a money trail disappears but I guess to know that it does is enough, and actually isn’t that difficult depending on who’s keeping the accounts I guess.

    In the Porto example I am surprised that UEFA are that public about money laundering. I would think they would be unwilling to share that information. Maybe they are just indirectly advertising for their own banks which ensure that no action will be initiated against those who use them? 🙂

    FIFA pretend they are their to administer the game rather than act as parasites of it. Don’t get me wrong. I actually think administrators are important. But the powers they enjoy, they are a law (and a currency) all unto themselves. They are registered in Switzerland as well aren’t they? When did that happen actually.. I thought they were born in 1904 in Paris. Not sure about that though.

    Barcelona.. well first the ‘admission of guilt’ and now this. Not what will be called definitive about any criminal activity, but we already know they are morally corrupt, and also somehow financially bankrupt despite their success. Money mismanagement at Barca? Wouldn’t be a surprise now would it.

    But I must say, I have new respect for Harry Redknapp. It’s tougher than it looks and h obviously loves that dog. Go ahead..Try being in his shoes for a day.

    http://www.mousebreaker.com/games/bungabulldog

  34. Anne
    21/03/2012

    @Laundryender:

    “The UA hall of fame.” I like that one. 🙂 Thank you, and glad you enjoyed the article.

    That Rangers case is quite interesting, and is very similar indeed to the Portsmouth case. The question about that would be are the two cases similar because money laundering shares certain commonalities? Or could there be some more direct relationship? For example, could it be possible that the same criminal organization is actually operating through multiple football clubs?

    Also, since your link mentions a Trust, I thought I would provide a bit of background on that. Similar to an offshore bank account, a “Trust” provides a certain level of secrecy for those who would have occasion to need it. Because when money is invested, and business conducted, through a Trust, it’s possible to maintain the secrecy of who controls the Trust, who is investing money in it, and where the money comes from.

    And to repeat myself yet again, if whatever you’re doing is above board, why would you need to keep it secret? So, in that regard, whenever you hear mention of a “Trust,” you should keep in mind that, you don’t know exactly who it might be that is controlling it and putting their money in it. And you should also ask yourself whether this Trust might be linked to any activities that you yourself would like to avoid. Because you wouldn’t have any way of finding out if it was.

    Anyway, point is, always be weary of “Trusts,” and never assume that their stated goals are the actual reason they exist. And I’m including in that statement any Trusts that might be associated with Arsenal or other football clubs.

  35. Anne
    21/03/2012

    @Walter:

    Thanks, glad you liked the article. And don’t worry about not getting it immediately. After all, the process is designed for precisely that purpose 🙂

  36. Anne
    21/03/2012

    @Jitty:

    Thank you for the heads up about that book. It definitely does seem to be right up my alley. Law firms are legally protected against compelled disclosure of information to a certain extent, which means that they’re often used for concealing this and that.

    Although, honestly, I might have to take a look at the book just on the basis of this statement:

    “Despite the weighty subject matter — tax law — Molloy writes with entertaining charm and wit”

    “Tax law” combined with “entertaining charm and wit.” Ok… we’ll see about that 🙂 However, I’ve always enjoyed expanding my horizons,and re-defining the scope of what is and is not possible in this life… 🙂

    Also, very interesting comments about the meaning of the term “product” in the context of Sky. It has me wondering about all of the various ways that this “product” could possibly utilized to someone’s advantage. Although I must say, I don’t understand why any member of the public would want to gamble based on anything they hear on Sky 🙂

  37. Anne
    21/03/2012

    @LRV:

    Thanks. Glad you liked it.

  38. Anne
    21/03/2012

    @bob:

    Always good to see you around here 🙂 And I’m very glad that you liked the article. Thanks.

  39. mike in atlanta
    22/03/2012

    Anne, if you use your pads (inadvertently or otherwise) to prevent the ball from hitting the wicket, you are given “out”. you will probably require an explanation of “pads”, “wicket” and “out” but i must warn you, it’s a downward spiral from there. thanks for an entertaining read. see now why the media has had an agenda?

  40. Anne
    22/03/2012

    @mike:

    Thanks. That’s enough for me to follow 🙂

  41. Anne
    22/03/2012

    @Shard:

    For the most part, nothing to add, which means that you said it all very well, as usual 🙂

    Interesting point about FIFA being registered in Switzerland, though. You know, I had never really thought about it? But yes, that might say a few things about them that are quite interesting, I’m thinking.

  42. Mark
    21/12/2012

    Hello Anne , i have one simple question to ask. We know that , there have been a lot of corruptions cases in football industry . Money laundering in football can happen through various of ways like corrruptions , sponsorships , ownership and many more..

    I am not sure if you have came across the FATF recommendation 2001 and recommendation 2012. FATF produce 2009 Football GAfi report as stated football as a dangerous vehicle to be used as money laundering , however , FATF in 2012 did not cover the sport body as reporting institutions…? Why is that so? don’t you think is quite fishy , they were the one ( FATF) who said football is on danger , but they did not directly solve this issue in 2012 recommendation….what do you think?

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