Kenneth Rijock

Kenneth Rijock

Friday, October 20, 2017


Our recent article, about the New Brunswick, Canada-based Swallow Immigration Consultancy Ltd.,  which is selling CBI passports in Dominica, St Kitts & Grenada, according to its website, and its staff, included a telephone call to the firm's manager, Nusheen Pourjahani. She denied accepting any Iranians, unless they lived outside Iran, and maintained their wealth also overseas, claiming that her clients did not violate sanctions, and their money was clean.

Our follow-up call today yielded confirmation that her story was pure fiction. Pourjahani, according to her office, is traveling to Dubai, to meet clients, and after that, will be in her office in Tehran. That is where she really meets her Iranian clients, so she can obtain Caribbean CBI passports for them, and launder their money through her own accounts, prior to making payment for their passports.

You are looking at photographs taken outside Swallow's Tehran office. Note that there are no signs or indications that it is a business, because it is not open to the public; It is a covert location, to serve Iranian clients, in violation of American, Canadian and United Nations international sanctions. Does this look like a legitimate office ?


Nidal Abdul Waked Hatum, one of the leaders of Panama's powerful Waked Money Laundering Organization, has entered a plea of guilty, to a single court of conspiracy to commit money laundering, in US District Court in Miami. Waked, a Panamanian national, was extradited from Colombia, and originally charged with four counts.

The defendant has stipulated, in writing, to the facts surrounding his money laundering operation and the tradecraft he employed; the Wakeds moved and cleaned narcotics proceeds for Colombian & Mexican drug cartels, for more than a decade. They used a network of legitimate Panamanian businesses they owned or controlled, to launder the narco-cash.

His Guidelines is stated to be 41-55 months, but a provision states that it will ultimately be 30 months, provided that he makes full disclosure, and there is no provision in his Plea Agreement, requiring him to testify against others. It is believed that his information will greatly assist US law enforcement in the investigation of the narcotics trafficking syndicates his organization served, hence the short sentence, in such a massive case.

Thursday, October 19, 2017


SKN PM Timothy Harris Dominica passport

We recently discussed the uproar caused by the disclosure that the former Prime Minister of St Kitts, Denzil Douglas, not only obtained a diplomatic passport from Dominica, immediately after St Kitts was the subject of a scathing Advisory, issued in 2014 by the Financial Crimes Enforcement Network (FinCEN), but that Mr. Douglas was listed as a Dominican national. Obviously, powerful Kittitians, when faced with the prospect of detailed inquiry at Customs & Immigration, when they arrived in the United States, used their connections to obtain what are, frankly, illegal diplomatic passports that violate the Vienna Convention on Diplomatic Relations.

It has now gotten worse; a well-respected Caribbean media outlet has exposed yet another St Kitts politician holding a Dominica Diplomatic passport, also obtained right after the FinCEN Advisory on St Kitts. This one was issued to Timothy Harris, the sitting Prime Minister of St Kitts, and it also states that the holder is a Dominican national, a misstatement of a material fact. A copy of the document appears above. A spokesman for Dr. Harris has publicly disputed its authenticity, but the document appears to have anti-counterfeiting protection, as well as the enhanced features such an instrument is required to display.

Just how many of the estimated 500 diplomatic passports were handed out to St Kitts government officials, and politicians, by corrupt senior Dominica leaders ?  No wonder the Foreign Minister of Dominica has openly refused to publish the list of Dominica diplomatic passport holders; if the voters of Dominica ever read it, her tenancy in government will come to a swift end, and her arrest will be a foregone conclusion. The illegal passport factory that she commands is a racketeer-influenced criminal enterprise, a cash cow for corrupt politicians.

Denzil Douglas Dominica diplomatic passport
 These passports, which are reportedly sold for obscenely high sums of cash, or for the exchange of other, illegal, favors, are an insult to the United Nations, and pose a clear and present danger of being abused for money laundering and other financial crimes. We trust that compliance officers at the world's international banks take note, and conduct themselves accordingly. 
* If you take the two passport numbers 0000319 and 0000462, and the issue dates, Dominica issued over 150 new diplomatic passports in one year, between 2014 and 2015. Considering that Dominica only has a few embassies and bona fide diplomatic postings, who has all these prized documents ?

Wednesday, October 18, 2017


 Mehmet Atilla, the senior Turkish banker who was late to the party in the Reza Zarrab Iran oil-for-gold sanctions evasion case, presently pending in US District Court in Manhattan, continues to make bad decisions, with the expected outcome. Why isn't he paying attention to the consequences ?

First, he throws in his lot with Zarrab's criminal syndicate, forging and altering banks records, to cover the tracks of a billion dollar oil sanctions evasion operation. Why did the number two man at a major Turkish state-owned bank fail to consult a competent attorney in advance of entering into that sordid conspiracy ? If he had, he would have learned that being a foreign national, and conducting sanctions evasions totally outside the United States, does not save you from indictment.

Second, after seeing the primary defendant, his client, Reza Zarrab, make the fatal mistake of entering the United  States, for tourism of all things, when he knew or should have known he was exposed to being charged in America, given his extraordinary Iran-to-Turkey oil-for-gold operation, why on earth did Atilla voluntarily enter the US, on business ?

Finally, in the motion to dismiss his indictment, his attorneys chose to file the same legal arguments also advanced by Zarrab's counsel, and which failed. How can they prevail ?

Unless Mr. Atilla now makes the only intelligent decision left to him, to enter a plea, cooperate with the authorities, and end up with a sentence that he, and his family, can live with, he will face the full brunt of the steamroller that is the American criminal justice system when it targets a major violation.  I suggest he change his tactics, forthwith.


Tuesday, October 17, 2017


 Law enforcement mining of social media through platforms that can access information which might otherwise never be uncovered has moved from the primary role of understanding criminal networks to a broad range of applications involving ongoing investigations. Many are using their social media programs as a real time monitor of a wide variety of criminal activities, as well as the acquisition of information.

Some of social media monitoring uses reported by investigators at law enforcement agencies:
(1)  Using information obtained from social media as Probable Cause to obtain a search warrant.
(2)  Identifying associates affiliated with or linked to Persons of Interest.
(3)  Identifying the location(s) of criminal activity.
(4)  Identifying criminal activity.
(5)  Gathering photographs or statements to corroborate evidence.
(6)  Identifying Persons of Interest.
(7)  Identifying the location of Persons of Interest.
(8)  Anticipating or identifying crimes that may be in the early stages.

Innovative law enforcement agencies will continue to find new uses for their social media platforms in both violent as well as white collar crime investigations. Social media resources, whose initial application was solely on the civil side, when it was used to obtain data on "unbanked" individuals for money service businesses, has proven to be an extremely valuable tool in law enforcement investigations.


If you read yesterday's CNN  story, Hong Komg, Where North Korea Goes to Launder Money, you might have noticed that the authors made sure to point out that the Chinese national who allegedly is the principal front man for a sanctioned North Korean bank holds a Dominican passport. Whether it is a Citizenship By Investment (CBI) economic citizenship passport, or one of those diplomatic passports considered illegal under international law, the point is that Dominica documents are facilitating North Korea's evasion of international sanctions. While the extent of Dominica's relationship with North Korea is unknown, the continued  existence of the CBI program itself could be endangered, should major United Nations sanctions evasion activity be made public.

There's more: an examination of the North Korean Economy Watch, which publishes data from the annual Rason International Trade Fair, reveals that Dominica was one of the exhibitors. Considering that the country does not record that it exports anything to the DPRK , the obvious conclusion is that the government display is for the sole purpose of selling CBI citizenships. Dominican representatives have a history of hawking CBI products in the Peoples' Republic of China, and the Chinese reps are the likely people to be involved in North Korea. This matter is serious, and it requires further investigation.


Monday, October 16, 2017


This is Daphne Caruana Galizia, an investigative journalist in Malta. She was killed when a car bomb detonated, while she was driving her automobile. Mrs. Caruana Galizia, whose son was an ICIJ journalist involved in the release of the Panama Papers, exposed official corruption and money laundering,  at the cabinet level and above, when she extracted information implicating senior government officials for holding offshore corporations and hidden bank accounts abroad. That is what is left of her car, after the explosion.

The journalist, who also exposed rampant corruption among powerful figures in Malta, as well as activities of the country's organized crime syndicate, was killed while driving away from her home. If anyone still thinks that money laundering is a white collar crime, with no real victims, think again.


After our recent article, Dominica & St Lucia's CBI Programs have a CBI Consultancy in Iran, there was a denial issued, by the unofficial regime mouthpiece, Anthony "Tony" Astaphan, who has asserted that Swallow Immigration Consultancy, Inc., was not an agent for the Dominica CBI program, notwithstanding that the firm's website recites that it is. I therefore decided to settle the issue by contacting the consultancy's manager, Nousheen Pourjahani, via telephone at her office in Canada, and she was happy to confirm Swallow's status as Dominica CBI Agent & Promoter.
She admitted that she was in the business of selling CBI or CIP passports, from a number of East Caribbean countries, and that her targeted clients are Iranians, which raises multiple questions of whether international sanctions are being violated. She claims that she only sells to expatriate Iranians, who fund their passport purchases with funds held outside Iran. If that is the case, then why does Swallow maintain an office in Tehran ? One cannot sell to expat Iranians inside Iran; she lies about her clientele.

Enter the East Caribbean's dark CBI secret, that there are unlisted agents/promoters, in Dominica, and elsewhere in CBI jurisdictions, who funnel clients to the so-called "licensed" agents, and receive hefty commissions under the table for their trouble. You may recall our prior article about the unlisted Asian promoter who asked for an advance commission payment, to be sent to a Wells Fargo account in Singapore, when a person posing as an interested buyer contacted him. That individual was not named as an agent, but he was nevertheless acting as such. Do not expect anyone involved in the lucrative, and largely unregulated, international CBI industry to follow either local laws or the regulations.

Also, Ms. Pourjahani stated that she performed NO due diligence, upon neither her Iranian applicants, nor their funds, prior to taking possession of the money, in a third country, such as Dubai, as she expects that the CBI program will complete that task. What she is probably doing is engaging in money laundering for dodgy, or even criminal, clients, in a "don't-ask, don't-tell" scenario which the law refers to as willful willful blindness.

After she realized that she had given up far too much damaging information, she terminated the conversation, using an flimsy excuse of immediate travel for an extended period, but she did answer the telephone later that day, only to hang up when she realized who was on the line. Exactly how many Iranians now hold Dominica, St Lucia, Antigua, or St Kitt passports, thanks to Ms. Pourjahani's efforts during the past decade, we wonder ?


Sunday, October 15, 2017


A smart businessman knows to never express an opinion on any legal matter, if he is a non-lawyer, and a good attorney is aware of the risks when he talks to clients about legal issues in countries where he is not admitted to practice. Unfortunately, that is not the case when it comes to those CBI consultancies not actually located in the five countries of the East Caribbean that offer economic citizenship to affluent individuals from high-risk jurisdictions who are seeking a second passport. Those firms freely offer advice notwithstanding that they are no way qualified to do so, all to the potential damage of their clients.

In truth and in fact, none of the principal international consultancies have qualified attorneys present on premises, in Europe,  the Middle East, Asia or elsewhere, who are admitted to the practice of law in the East Caribbean. Why is is important, you ask ?

 If your European "legal consultant," who professes to have all the answers, regarding the jurisdiction he is directing you invest your money, to obtain a second passport from, does not know the local law, how can he correctly navigate you through a potential minefield, specific to that country, such as:

(1) The possible future revocation of your citizenship, as well as your prized passport. Antigua is presently discussing passing such a law, but does the country recommended to you have the right to do so, at this time ? Remember the case of the Iranian Alireza Monfared, and his two passports, obtained from Dominica.

(2) Will the country recommended to you "lower the tax boom" at a later date ? Are those permanent assurances of tax holiday in the country's laws, and have you received an opinion, from a local attorney duly qualified, about this issue ?

(3) What are the possible tax ramifications, to your present nationality, if you get that second passport, and move assets offshore ?

(4) Has the selected country ever been, or is it now, a Blacklisted jurisdiction,  from any regulatory agency, which could put you in the cross-hairs of US, or EU law enforcement agencies in the future ? You do not want to become  a Person of Interest, simply because of the misconduct of others.

(5) Is the country selected for you by the consultancy, only a nominal democracy, but actually a dictatorship, which could conceivably be overthrown, and your status simply terminated, with no legal recourse ?

(6) Does the local court system regularly follow the Rule of Law, or are decisions handed down, based upon political pressure of the ruling party ? In that case, you may not be able to have legitimate business grievances addressed to your satisfaction.

(7) What about the country's criminal justice system ? Is it fair and impartial, or could you end up in jail, without a trial, for years, if anything you do incurs the wrath of local leaders ?

The bottom line: if your mind is made up about obtaining a CBI passport, by all means, go to the jurisdiction, and engage a local attorney to answer those questions, in advance, prior to investing. To do otherwise is literally playing with fire.

Saturday, October 14, 2017


The Government has filed its Brief of Appellee, in the DC Appeal of the District Court summary judgment, entered against the Waked family, seeking to remove the OFAC designation entered against those Panamanian nationals known to be involved in money laundering operations.

The issues discussed are no surprise:

(1) OFAC's disclosures satisfied its notice obligations, under both the Due Process Clause, and the Administrative Procedure Act.
(2) OFAC is not required to disclose evidence that would reveal confidential investigative sources and methods.
(3) The District Court's decision does not produce absurd results.

The case law aptly cited shows that, only in the rarest of circumstances, and then only where there is real OFAC misconduct or error, do the courts take action, regarding OFAC sanctions. We note that the only Waked family member actually in custody, has recently indicated, through counsel, his intention to enter a plea to the money laundering charges fled against him, in District Court in Miami. he is not a party plaintiff in the DC case.

Friday, October 13, 2017


  A review of the list of companies eligible to direct Citizenship by Investment clients to St Lucia and Dominica includes the Canadian consultancy, Swallow Immigration Consultancy, Inc*.  Swallow lists a Tehran office in its information, a disturbing fact, buried at the bottom of the page, but which poses not only a clear and present danger to the CBI programs of both countries, due to international & US sanctions, but will definitely expose external due diligence firms to major OFAC sanctions.

Swallow is owned by an Iranian national that advertises herself as an "immigration consultant." her name is NOUSHEEN POURJAHANI.

Swallow, whose addresses are listed as:
28 Saunders Street
56 Aviones Court
Fredericton, New Brunswick, Canada

Swallow logo

Also shows an Iranian address:
Unit 36, Mahtab Building
Livarchi, Villa St,
Tehran, Iran

Don't the CBI units in Dominica & St Lucia realize that there is a high risk that they may be accepting individuals who are government officials, individuals working in the sanctioned WMD or ballistic missile programs, Islamic Revolutionary Guard Corps agents, or other Iranian nationals who are internationally sanctioned. Can't they foresee the inevitable public relations nightmare when one of the clients they accept is exposed ?

There's another problem: If the outside due diligence firm handling the vetting of any Iranian nationals is either American, or a foreign subsidiary of an American company, there is strict liability for OFAC violations. See OFAC fines American Firm that conducted CBI Due Diligence for Iran Sanctions Violations, on this blog, August 19, 2017, Note that the due diligence firm fined $259,200 is IPSA, listed as a due diligence contractor at St Lucia.

Both countries should now take a hard look at whom they "qualify" as CBI consultancies, lest they get burned. In their eagerness to attract CBI clients, they license (I use the term loosely) salesmen, not the legal professionals who should be advising prospects. The firms listed are located in Moscow, Dubai, Pakistan and other other high-risk jurisdictions.

How many more Iranian nationals must be arrested or indicted, complete with East Caribbean CBI or diplomatic passports, before another FinCEN Advisory is issued ? Canada would do well to close Swallow immediately, as it is suspected of being a facilitator for Iranians seeking second passports, without any significant due diligence being performed upon them.
* There is also another CBI firm, owned and operated by Pourjahani, known as Parastou Company, also offering East Caribbean passports, in this case from Dominica, Grenada and Antigua & Barbuda. Parastou's webpage also features the "Swallow" logo shown above.



Quick: what's the most effective, and often safest, way to place the proceeds of crime in North America ? Answer: avoid the banking system altogether, and bulk cash smuggle the loot out of country on a private jet. Bulk cash smuggling of the proceeds of crime remains a major method through which money launderers repatriate bulk cash. Now, the US Congress is attempting to close some of the loopholes that foreign money launderers, and their clients, have employed for years to allow them to own, operate and control N-numbered (US registration) business jets.

The Federal Aviation Act requires that foreign nationals may hold no more than twenty-five (25%) per cent of the shares of a US corporation that owns an N-number business jet, but laundrymen use trusts, business associations, shell companies, partnerships, and other private entities to control American-registered aircraft, whose regular traffic in and of the Continental United States is not monitored to the extent that foreign-flag aircraft often are. In truth and in fact, foreign nationals who are career criminals control US-registered aircraft.

The US Congress is seeking to clean up those "opportunities,"through The Aircraft Ownership Transparency Act of 2017.* This legislation forces the disclosure of Beneficial Ownership, with acceptable evidence of identification, of any individual who exercises control over any entity, or receives substantial economic benefits from its operation. These disclosures must be made in advance, before a purchasing entity may obtain a Certificate of Registration, under this legislation.
* H.R. 3544 (2017).


In the aftermath of hurricane damage, and ostensibly to make needed repairs and reconstruction, the Government of St Kitts & Nevis has proposed, as a fundraising measure, to issue 4000 new Citizenship by Investment passports to new applicants. Has everyone in charge in Basseterre totally lost it ?

The estimate of 44 new due diligence investigations, per day, which will be required to be completed, to meet this governmental goal, simply cannot be attained, with any degree of effectiveness, given the size of current staff. Also, even if a boatload of new, qualified & experienced compliance officers arrived to handle that astounding workload, the pressure to complete files in record time, including overseas queries that generally take days to receive back, would crash the effort.

Remember, we are talking about enhanced due diligence, not the ordinary variety, and that type of inquiry of necessity is dependent upon multiple outside queries, not just reference to a database, and "check the box." Frankly, turning out reports at the 44-per-day rate would result in inferior, failed compliance products, meaning that criminal elements, individuals from high risk countries who require serious checks, and even terrorist financiers, wouls get those prized CBI passports.

I once served as a compliance officer, performing exclusively enhanced due diligence, at what was then the largest company of its kind in the world, offering insurance investment products, and I know how long it takes to properly vet one individual in that manner. I understand that St Kitts wants to raise $150m, in record time, but please, not at the expense of arming scores of criminals and terrorists with Kittitian passports.

Thursday, October 12, 2017


Attorneys for Nidal Ahmed Waked Hatum, the Panamanian business owner who is facing seventy years in Federal Prison, for money laundering and bank fraud, have indicated that their client intends to enter a plea of guilty in the case pending against him, in US District Court in Miami. He is accused of operating a massive money laundering syndicate for Colombian and Mexican narcotics traffickers, employing a network of Panamanian businesses his family owned.

The defense attorneys have notified the Court that they are withdrawing the following pending motions:
(1) Motion to dismiss for lack of jurisdiction.
(2) Motion to dismiss indictment as being time-barred.
(3) Motion to Exclude Wiretap Evidence.

A decade ago, when Panamanian law enforcement was notified of the Waked Organization's money laundering operation, by a whistle blower, that information was illegally passed on to the Wakeds by José Ayú Prado, then a government prosecutor, and now the Chief Magistrate Judge of Panama's Supreme Court of Justice. We hope that, as a part of his cooperation, that Waked implicates Prado, so that he can be removed from office, and extradited to Miami to face justice, as a part of Panama's judicial reform efforts.


If you are following events in the East Caribbean, you know that not only did the US Ambassador for the region visit St Kitts & Nevis recently, she stated that, while it is under study, there are no current plans to remove the 2014 FinCEN Advisory, which referred to the misuse of Kittitian CBI passports, and warned international bankers to beware money laundering, other financial crimes, and terrorist financing, by St Kitts CBI passport owners. Native Kittitians, especially those who have political or economic power locally, have taken note of their increased risk levels, and some have chosen to game the international document system, in a dangerous way.

The recent dust-up in St Kitts, when local media proved that the country's former Prime Minister* obtained a diplomatic passport in the Commonwealth of Dominica, which actually falsely recited therein that he was a Dominican national, may only be the tip of the iceberg. Those holding St Kitts passports might have problems in making large deposits in North American or European financial institutions, so you should anticipate that Kittitian politicians, also including those presently in office, have acquired Diplomatic passports from Dominica, where, frankly, anything goes, if we take the example of the known foreign career criminals found to be in possession of them when arrested elsewhere.

Compliance officers at international banks should remember that St Kitts was forced, due to global public pressure to restore the "Place of Birth" information to their passports. Should you EVER find that the holder of any kind of St Kitts ( or Dominica or Antigua or Grenada or St Lucia) passport, initiate enhanced due diligence immediately, prior to account opening. You must immediately  demand, and obtain, Drivers' License, voter registration card, even birth certificate, evidence, to rule out the holder as unsuitable.
* Spin masters in St Kitts have tried to explain away this scandal by stating that a government officials in the former PM's cabinet had their diplomatic passports cancelled when they fell from power, but private politicians in the East Caribbean have a long and sordid history of holding such diplomatic documents, even when not in government. They also failed to explain why the ex-PM misrepresented his nationality. Truth seems to be in short supply in St Kitts political circles.

Wednesday, October 11, 2017


The American Rewards for Justice Program has posted five and seven million dollar rewards, respectively, for two prominent Hezbollah leaders, FU'AD SHUKR and TALAL HANIYAH. Shukr is alleged to have been the planner of the terrorist bombong of the US Marine Corps Barracks in Lebanon in 1983, which resulted in the deaths of 241 servicemen. Haniyah is alleged to be the supervisor of Hezbollah terrorism outside of Lebanon.

The announcement comes on the heels of two major statements, by the opposing sides of the Lebanese-Israel border:

 The president of Lebanon, on Egyptian television, stated that Hezbollah was a part of the Lebanese Army, and it was needed to defend itself against the Israeli "occupation" of the Syrian Shebaa farms area, which is the Hezbollah bogus territorial claim it uses to defend  its failure to follow the UN Resolution, and disarm.

A senior Israeli military official recently affirmed that since Hezbollah is now virtually the same as the Lebanese Government, any future Hezbollah-Israel hostilities will include all of Lebanon  as legitimate targets. Such an action may destroy the critical Beirut financial center, as well as vital infrastructure throughout the country, and Lebanon should be aware of these consequences.

Tuesday, October 10, 2017


HAO FAN 6, registered in St Kitts & Nevis

If you were still harboring any illusions about St Kitts actually performing adequate due diligence on anybody or anything, read this. The United Nations Security Council has issued a global port ban on the vessel HAO FAN 6, IMO862597, a bulk carrier of goods, for transportation of prohibited goods to and from the Democratic Peoples' Republic of Korea, more commonly known as North Korea. The Hao Fan 6 may not enter any seaport in the world, for violating UN sanctions on North Korea.

This vessel is currently registered in St Kitts & Nevis. Given the universal sanctions imposed upon North Korea, and the fact that anyone with a computer can access the complete travel history of any documented vessel, how on earth is the St Kitts Government allowing their flag to fly on a vessel that delivers, as well as loads, goods in North Korea. How was the registration approved in the first place ? Why is it not now revoked ?

If St Kitts can facilitate violations of sanctions on North Korea, we are wondering whether North Korean nationals, with the appropriate aliases, are traveling on St Kitts CBI passports, or SKN diplomatic passports, masquerading as Chinese citizens.  DPRK agents are notorious for vending counterfeit US Dollars, selling counterfeit prescription drugs, as well as Soviet-era small arms. Is St Kitts now facilitating their criminal activities ?

Whether the United Nations should now impose sanctions on the Government of St Kitts is a discussion that needs to take place at the Security Council. 


The Colombian representative of the Panama law firm of Mossack & Fonseca, Juan Esteban Arellano Rumazo, has reportedly been arrested, together with a number of prominent Colombian businessmen, and charged with money laundering, fraud, and illicit enrichment, in a massive tax evasion scheme orchestrated by Mossack Fonseca's Colombia office, in coordination with its Panama headquarters.

The law firm set up an elaborate scheme, with lawyers, accountants and tax auditors, using front companies in Panama, Costa Rica, Spain & England, who sent bogus invoices to Colombian companies, for non-existent services. According to the Attorney General of Colombia, a bank in the Bahamas was involved. Documents were falsified by individuals at the companies involved in the fraud. Accountant and auditors were employed to manipulate income statements, and evade taxes, all through Mossack's scheme; the law firm reportedly received a fee of 4% to conduct the criminal enterprise.

 It is not known whether name partners, Jurgen Mossack, and Ramón Fonseca Mora, will
be charged in Colombia, with their participation in this tax evasion and money laundering scheme, but their attorney's arguments, that the law firm merely opened corporations for foreign clients, and do nothing more, have now been seen as outright misrepresentations of fact. The Mossack firm ran a racketeering operation, and a continuing criminal enterprise, and was not a legitimate law firm.


Seeking desperately to avoid execution of the extradition order entered by the assigned US Magistrate Judge, Miami attorneys for the fugitive ex-president of Panama, Ricardo Martinelli,  have filed a Habeus Corpus petition, challenging the order, in US District Court.* The defendants are US Attorney General Jeff Sessions, US Secretary of State Rex Tillerson, and Miami Federal Detention Center Acting Warden Robert Wilson.

Access to the contents of the petition has been restricted by the Clerk's Office, and we are thus unable to review it for our readers, to ascertain whether it contains any new issues not previously dealt with by the Magistrate. The Court has set dates by which time the defendants must file their responses. The Secretary of State, due to the existence of the order of extradition, may order Martinelli's immediate removal to the Republic of Panama, at any time, hence the filing of the within petition.
* Case No: 17-cv-23576 -MGC (SD FL).


 Our recent article on Felix Sater, whose business card lists him as a "senior adviser" to Donald Trump and the Trump Organization, was hacked, when it was republished on another website. The Sater/Trump business card was removed. and two-thirds of the article was destroyed. Do you think that we hit a nerve somewhere in the power structure ?

Sater, a twice-convicted felon, is reviled here in South Florida, due to his criminal conduct, which was accomplished in no small part because a judge in New York sealed his criminal file, while he was a CI, denying the investing public the truth about his dark history, resulting in their placing investments with him, which they lost, due to his fraud.

Monday, October 9, 2017


The Government of Turkey has arrested a member of the staff at the America Consulate, on what appear to be political charges. As the result, the US State Department has announced that there will be no more non-immigrant visas issued to Turkish nationals, which means that no tourist visas, or visas for business travel into the United States. The relationship between the United States and Turkey has deteriorated of late, but this is a new low.

In rapid response, Turkey immediately reciprocated, announcing that no visas will be issued to US citizens. Given that not only would you be unable to appear in Turkish courts in support of any civil litigation, especially at trial, but any Turkish nationals that you might need to testify in a US court proceeding, also could not obtain a visa, your options, in the event of dispute, unpaid debts, or even a false criminal charge filed against your staff in Turkey, you would be severely handicapped.

Remember also that an American minister working in Izmir, Turkey has been arrested, and that alone raises risk levels. For all these reasons, raise Country Risk on Turkey at this time.


The political tensions in St Kitts & Nevis are running high, after local Kittitian media reported that former Prime Minister, Denzil Douglas, holds a diplomatic passport from Dominica, and actually published a copy online. Even more outrageous is the fact that a fair reading of the passport lists Douglas as a citizen of Dominica, even though this is patently false, and Douglas himself has denied that he holds a CBI citizenship in Dominica.*

Sources in St Kitts indicate that Douglas' Kittitian diplomatic passport was voided when he left office, several years ago. How on earth was he permitted to obtain a Dominica diplomatic passport, especially one which fraudulently showed him as a Dominican citizen ? The passport must be regarded, as a matter of law, as void ab initio, not merely voidable.

How many other East Caribbean politicians have diplomatic passports from St Kitts ? There is no legitimate reason for them, other than the maintenance of a corrupt "old boy network" of politicians in the region, exchanging favors, at the expense of those they govern, and raising the risk levels for money laundering, as the use of diplomatic passports can allow the holder to evade customs officers at ports of entry.

Perhaps the question we should be asking is when will the complete list of non-Dominican holders of that country's diplomatic passports be made public; this is known as government in the sunshine, and unfortunately, when it comes to play-for-pay passports, it does not exist in the Commonwealth of Dominica.
* Contrary to popular belief, a diplomatic passport does NOT confer citizenship in Dominica. In truth and in fact, the application form for a diplomatic passport, which we have published here on this blog, required the applicant to indicate precisely how he or she is a national of Dominica.  

Sunday, October 8, 2017


 The obviously forced resignation of a major media co-host, who was critical of the Mexican Government, has exposed  what amounts to self-censorship of negative news about Mexican Government and political party activities. Apparently, a large segment of the media revenue in Mexico comes from Government advertising, and this situation interferes with the unfettered ability to air official corruption, undue influence, and other governmental misconduct.

Compliance officers seeking to perform due diligence upon Mexican PEPs, political parties, and entities are advised to look primarily at media and investigative reporting that originates from non-Mexican media.

Saturday, October 7, 2017


Gal Vallerius a/k/a OxyMonster
When the French national Gal Vallerius flew into Atlanta's Hartsfield-Jackson Airport en route to an international beard competition, he was certain that his online alter ego as the infamous and anonymous "OxyMonster" in the drug trafficking Dark Web was safe, and that he would be considered just another European tourist and routinely passed through immigration.

What was waiting for him, though, was a sealed indictment charging him with Conspiracy to Distribute Controlled Substances with Intent to Distribute, for his secret identity as a major vendor on Dream Market, an eBay-like narcotics supermarket operating on the anonymous Tor network, had been uncovered by the Drug Enforcement Administration (DEA), using a social network platform.

The DEA had targeted a major narcotics vendor and Dream Market drug forum administrator as OxyMonster, with major drug shipments into the United States, but were unable to name him. One of the individuals receiving payments through electronic wallets was identified as a French national, Gal Vallerius. Could he be the elusive OxyMonster ?

A page from the Dark Web drug supermarket

Applying a social media platform to the problem, investigators located Instagram and Twitter accounts of Vallerius, and "compared the writing style of "OxyMonster" on Dream Market forum while in Senior  Moderator role to the writing style of Vallerius in his public Instagram and Twitter accounts. Agents discovered many similarities in the use of words and punctuation* ...."

Armed with that evidence, an Indictment was issued, and Vallerius was arrested when he arrived in the United States on August 31, 2017. Information recovered from his seized laptop computer confirmed his identity as OxyMonster.

While Social media platforms are generally employed to identify previously unknown relationships, or those that are several degrees of separation from a targeted individual, they may also be used to acquire additional information from the target which were previously impossible to detect, on a near real-time basis. They are an invaluable investigative tool that identifies key connections.

The defendant has been transferred to the Southern District of Florida, where the case was brought; he faces a potential life in prison if convicted. His laptop held $500,000 in Bitcoin value, and the US Attorney is seeking forfeiture of the same. Only a redacted version of the Indictment has been publicly released, indicating that there may be additional defendants not yet in Federal custody.

As new criminal cases that demonstrate the successful sue of social media platforms by investigators appear, we shall make that information available to our readers on this blog.

Vallerius as OxyMonster on the Dark Web
*  Affidavit of DEA S/A Austin D. Love at 13-14. United States vs. Gal Vallerius a/k/a/ "OxyMonster," Case No.: 17-cr-20648-RNS (SD FL).


Friday, October 6, 2017


The defense attorney for Scott Rothstein, who is confined to a cell in a secret location, while serving a 50-year Federal sentence for his billion dollar Ponzi scheme, has "strenuously" objected to the motion recently filed by the US Attorney for the Southern District of Florida, to withdraw its pending Rule 35 Motion for Reduction of Sentence.

Rothstein's counsel's arguments:

(1)  The Government breached its obligations under his Plea Agreement.
(2)  The Government has abused its discretion in denying Rothstein his opportunity for a sentence reduction, in violation of his Constitutional rights.
(3) Rothstein did not provide material false information to the Government.
(4) Rothstein deserves a full and fair hearing on the merits.
(5) The complex issues to be presented require at least 60 days in which to respond.

The Court has granted the request for the extension of time for the defendant's attorney to reply to the Government's motion.

Thursday, October 5, 2017


Many Panamanians are uneasy, due to the fact that their indicted, fugitive former president, Ricardo Martinelli, remains in the United States, notwithstanding that a Federal Magistrate Judge ordered his extradition to Panama more than thirty days ago. Given the massive amount of Congressional, Senatorial, and Special Counsel investigations into the Trump campaign's relationship with the Government of Russia, and the fact that the Trump Ocean Club, located in Panama City, had several Russian nationals as salesmen, and now has a huge amount of Russian condominium owners, is there a connection ?

Is Martinelli to be a witness against Trump ? Remember, it is the Secretary of State who gives the final approval for extradition of a foreign national.


Marco Antonio Delgado, the prominent El Paso attorney who laundered an estimated $600m in narco-profits for a Mexican Cartel, had an illegal business relationship with the ex-wife of a Mexican president, and betrayed a US law enforcement agency for whom he was acting as a Confidential Informant, this week received a sentence of imprisonment in his second federal criminal case. Delgado, who had refused to enter a guilty plea in the first case, causing his defense attorneys to have his mental status examined, is now looking to serve a long term of incarceration, as he has reportedly refused to cooperate against his former cartel clients.

The defendant, who was caught laundering drug profits after he agreed to act as a CI, when one of his bulk cash couriers was arrested, had previously received 16 years on the money laundering conviction. The second case involved the illegal diversion of $32m, from a Mexican power plant contract, into his offshore accounts in the Turks & Caicos Islands, after he forged a signature, and used the money to purchase real estate, and kept the remainder offshore, top avoid detection.

The trial judge sentence Delgado to 10 years on the second case, in which he was charged with money laundering, wire fraud, and conducting transactions with criminal proceeds. In an unusual move, the Court ordered that one-half of the sentence, five years, is to run consecutive to his existing 16-year sentence, rather than the customary concurrent sentence arrangement. Delgado has been in custody since 2012.


A recent BBC article commented upon the use of facial recognition software by the Metropolitan Police of London to scan the crowd at the Notting Hill Carnival for fugitives from justice or individuals previously forbidden from attending that event. Video from the upcoming Carnival was reportedly going to be then checked by facial recognition software, on a real-time basis.

If you are a user of facial recognition software, whether for due diligence, in a criminal investigation, or for counter-terrorism purposes, you are aware that it has certain limitations. Image size, image quality, facial angle, and facial expression are among the many factors that often prevent positive identification of a subject. In order to improve the success rate, it is suggested that a social media platform be added to the investigative process.

The technique, which involves the use of a social media program that uses Artificial Intelligence and cognitive learning to identify unknown targets, starts by using the individual already known and previously identified, and who may be a leader.  For example, take a surveillance video, or casual group photograph, in which only one individual can be identified through facial recognition. Employing a social media platform, we may be able to identify the others in the photo, even though the relationship to the known individual is remote, indirect, or through third parties, which would preclude success through traditional identification.

Here are a number of relevant applications:

(1) A compliance officer at an international bank whose customers include nationals from a country known for its massive official corruption at the highest level could take a group photograph of a senior government official, which includes several unknown possible associates or friends, and search the official, using a social media platform. The positive identification of a number of the previously unknown faces on the photograph will be followed by a check to see whether any of them hold large accounts at the bank, as their relationship with the government official may make them Politically Exposed Persons, more commonly referred to as PEPs. Such PEPs must always be monitored to insure that they are not quietly moving funds stolen from government accounts, or bribes and kickbacks, by the official that they are associated with, do business with, or are distantly related to.

(2) Unidentified individuals, seen in a grainy tavern surveillance video, socializing with a corporate official who has inside information about his publicly-traded company's future activities, may be the "tippees" who received inside information and profited from it. Though facial recognition fails to name them, a social media program search often makes indirect connections, through prior employment, school, or recreational ties, between the insider and one or more of the people appearing in the background of the video.

(3) Unidentified drug trafficking gang members and associates, seen in a photograph seized during a search warrant of the residence of a ranking leader of the organization, are made through social searches of the leader's social media postings, which lead investigators to his wife's sites, to their girlfriend's sites, and ultimately to the identification of all the gang members pictured.

(4) In a counter-terrorism investigation, poor quality CCTV footage of a holiday march that ended in violence where a local incendiary religious figure was believed to be encouraging individual terrorist acts, was supplemented by a social media program search of the minister, which resulted in the identification of several of the parishioners who engaged in a terrorist attack upon an unarmed civilian.

To summarize, the use of a social media platform may result in positive identification of targets that appear in images, yet are unsuitable for facial recognition programs. If you only have a sole individual identified from the film, the platform can cast a wide yet completely focused net for the other targets, and often extracts their identities from publicly-available postings made by them or their friends and family.


A number of Panamanian Deputies, who serve in the nation's legislature, have gone public with their plans to change the existing criminal code, to allow cases to move forward when a defendant has voluntarily absented himself from the jurisdiction. Current rules of procedure mandate the defendant's presence at several stages of criminal proceedings, and if he or she has counsel, who is aware of pending charges, and then leaves Panama, such acts are an absolute bar to further action.

If the laws in Panama are changed, then a trial in absentia would not only become possible, it could become the preferred method of anti-corruption prosecutors, who might obtain convictions against targets, and then seek their extradition from abroad. Some observers believe that this movement is a reaction to the procedural delays, and obvious roadblocks, thrown down by ex-president Ricardo Martinelli, to frustrate anti-corruption prosecutors, who have cases pending against him.

Though US laws allow Federal criminal trials to be conducted in absentia, they are so rare as to be non-existent, as they are limited to cases where a defendant absents himself from court after the trial has commenced. The fact that Panama wants this right means that they want to obtain convictions against Martinelli, one way or the other, and even if the US fails to extradite him.

Wednesday, October 4, 2017


The recent European Parliament conference on Human Rights violations perpetrated by a xenophobic Spanish court in the Canary Islands has resulted in some relief for Russian businessman Vladimir Kokorev, who has been held for two years on a bogus material witness warrant. The alleged money laundering occurred fifteen years ago, and the target is the president of oil-rich Equatorial Guinea, whose natural resources are coveted by Spanish interests, in what is a purely political case, staining Spain's reputation as an adherent of the Rule of Law, and causing many in compliance to raise Country Risk on Spain.

When conference details were announced, Mr. Kokorev's aged wife was released from custody, but was prohibited from leaving the Canary Islands, and his bail was reduced, from €1m  to €600,000, but again he may not leave the jurisdiction. No action was taken regarding his son Igor, who also remains in custody. The High Court Judge who reduced the bail reportedly apologized to the judge handling the case. The presiding judge extended Kokorev's detention for another two years, which a number of Members of the European Parliament have declared a massive human right violation, and vowed to free him, through courts in Madrid.

No criminal charges have ever been filed, against any defendants, in this matter, which appears to be a combination of a corrupt plan to steal Kokorev's Spanish assets, and remove Equatorial Guinea President Obiang from office, for the monetary gain of wealthy Spanish and Italian interests. Many European media have taken up Kokorev's cause, calling for his release, and demanding that justice be served, by charging members of the Spanish judiciary in the Canary Islands with corruption.

Tuesday, October 3, 2017


On October 2, 2017, the United States Supreme Court denied, without opinion, the petition for Habeus Corpus, previously filed by Panama's fugitive former president, Ricardo Martinelli, who is contesting his extradition to his native country on massive corruption and illegal surveillance charges.

The Court had previously denied his petition to be released on bond, during the proceedings, which took place in US District Court in Miami. In that case, the Magistrate Judge ordered his extradition, a little over a month ago.

Monday, October 2, 2017


A face on the news today served as yet another stark reminder that St Kits has got a very long way to go before compliance officers can trust its government to properly operate its Citizenship by Investment Program. The talking head I spotted on the air is the son of an American expat who holds one of those SKN economic passports. (Yes, his two sons hold them as well.)

The expat is a former "corporate raider," who first served Federal time for securities and tax fraud, then years later was imprisoned for hiding assets during his bankruptcy, and also had a third time in custody. He owes the SEC tens of millions, and the debt has been reduced to a judgment. Those bright due diligence clerks in St Kitts still found him to be acceptable for CBI purposes, notwithstanding the fact that he has been convicted of crimes involving moral turpitude. He is currently living in St Kitts, gleefully giving interviews from time to time. We have featured this individual before on the blog, so you may know to whom I am referring.

How can any compliance officer take St Kitts seriously, when it accepts such dodgy applicants, and fails to revoke their passports and citizenship even after their sordid career criminal history is publicly exposed ? Please consider the 2014 FinCEN Advisory on St Kitts CBI program to be your primary guidance on the subject, and always verify the place of birth of any professed Kittitian, lest you unwittingly onboard a CBI passport holder.


Given the ongoing controversy about the relationship between President Donald Trump and the twice-convicted fraudster, Felix Sater, readers are advised to review this article, which appeared on the blog in 2012. Federal Judge Seals Criminal case, Fraudster steals millions from Investors unaware of his record.


The International Monetary Fund (IMF) has published a Working Paper entitled Loss of Correspondent Banking Relationships in the Caribbean:Trends, Impact and Policy Options. It is an outstanding study on the current situation in the Caribbean, and it is recommended reading for all North American compliance officers.

The primary reason cited for "de-risking" is AML/CFT compliance, and this blog has repeatedly opined that only KYCC, or Know Your Customers' Customers, programs will adequately address the valid concerns of onshore US, Canadian and EU banks. You are referred to our prior coverage of this issue for further information.

 Readers who wish to review the complete text can access it here.

Sunday, October 1, 2017


R. Allen Stanford, the convicted Ponzi schemer, presently serving 110 years for the Stanford International Bank scandal, cannot accept the fact that he has had his day in court, in both the criminal, as well as civil, sides. Even after his issues are disposed of, for being totally without legal merit, he continues to seek their rehearing, even when not permitted by the rules of procedure. The issues he presented, in his Certiorari petition, to the US Supreme Court, which was denied, had all been previously settled, adversely, in his trial, and Fifth Circuit appeal.

Stanford has filed a request for the appointment of counsel in the SEC civil suit against him, which resulted in a the entry summary judgment in  2013. Now, four years later, he seeks to have the Court appoint counsel, so that he can file a motion to dismiss. His jailhouse attorneys, who are obviously assisting him, as Stanford has no legal training or experience, ignored both the fact that his issues were already ruled upon, and that he cannot file his motion, as it was long ago filed, and denied. His filings have been totally devoid of legal merit, but he does not stop filing them.

Perhaps the District Court Judge in the SEC case should impose sanctions upon Mr. Stanford, for repeatedly wasting the Court's valuable time. His day in the sun, and in court, is over.  

Saturday, September 30, 2017


The Department of Homeland Security published a regulation effective October 18, 2017 adding social media information to the data collected on all new immigrants to the United States. This new requirement, which will result in additional information that can be used to determine possible connections to terrorist activity, underscores the importance the US Government attaches to social media background checks as a source of intelligence generally not available through conventional investigative procedures.

The specific items to be collected are stated to be:
(1) Social media handles.
(2) Aliases.
(3) Associated Identifiable Information.
(4) Search results.

Previously, USCIS has only reportedly collected social media information when specific Syrian refugees were flagged, or when question were raised during interviews with applicants. The DHS Office of Inspector General recently conducted a number of pilot programs concerning the use of social media to screen applications for immigration, and an unclassified version of the report can be reviewed below*. Platforms employed included one from DARPA and one, with its identity redacted, from the private sector, which may be from government contractor Giant Oak, Inc.

The new regulation recites that the sources of the information shall include "publicly available information obtained from the Internet, public records, public institutions, interviewees and commercial data providers."

Readers who wish to review the complete text of the document may access it here. The citation is 82 Fed. Reg. 43556 (September 18, 2017).
*DHS Pilots for Social Media Screening need Increased Rigor to Ensure Scalability and Long-Term Success