Kenneth Rijock

Kenneth Rijock

Sunday, December 17, 2017


Attorneys for Mehmet Hakan Atilla, the Halkbank Deputy CEO who is being tried, in the massive New York Federal Iran sanctions case, have moved for a Judgment of Acquittal*, asserting that the evidence is insufficient to sustain a conviction. Atilla is the only defendant, among many, who is actually in trial. The primary defendant, Reza Zarrab, one of the principals in the oil-for-gold billion dollar scheme, has changed his plea, and is cooperating with the Government.

 Counsel makes these points in their letter motion: (1) "All of the charges must be dismissed because the Government has failed to prove that Mr. Atilla knew of any US connection to Zarrab's scheme."
(2) "The conspiracy charges in Counts 1,2,4, and 6 must be dismissed on an alternative ground; because the Government has charged multiple conspiracies, on one of which Mr. Atilla, at best, has been shown to be a participant."

The US Attorney's Office has filed a response:

(A) "The evidence demonstrates that Atilla knowingly participated in conspiracies to violate US sanctions, defraud US financial institutions, and engage in Promotional Money Laundering."
(B) "Atilla's attack on Count One is meritless as a matter of Law and Fact."
(C) "The evidence shows that Atilla was part of a single conspiracy."

The Court has not yet ruled on the motion. We shall continue to update our readers on the progress of the trial.
* The Government has rested. A prior defense motion, for a mistrial, was denied.


Reports from Grenada indicate that there are additional foreign nationals who have purchased illegal Diplomatic passports, from Government officials, and are using them to circumvent customs & immigration officers at international borders, in violation of the Vienna Convention, a binding United Nations treaty, and may be employing those privileged documents to facilitate the commission of financial crime. An investigative article, by a local Grenadian newspaper, The New Today, detailed the story.

A Pakistani national, Fahad Sultan Ahmed, residing in the United Kingdom, reportedly obtained a Grenada diplomatic passport two years ago, during the present administration of the reigning New National Party. He is not named in any official diplomatic capacity at the Grenada High Commission in London, nor does he hold any other portfolio or assignment, anywhere, for Grenada. His Pakistani passport appears at the beginning of this article, though it is not know under what name he acquired the Grenada diplomatic passport.

Ahmed is apparently a Pakistani businessman residing in the UK, by virtue of a visa reportedly obtained for him by Mishcon De Reya LLP, which is the law firm that represents Henley & Partners Ltd. Regular readers of this blog will recall that it was a Henley & Partners officer that Grenada CIP Chairman Kaisha Ince stated she was going to contact, to get one of our recent articles, (which detailed the efforts of a Ukrainian national to also obtain a Grenada passport) removed from the Internet. That same conversation, to which the Prime Minister, Keith Mitchell, was a party, indicated that the PM feared the news would damage his reelection chances.

Keith Mitchell ( photo courtesy The New Today)

All efforts to obtain comments, or denials, from the Government of Grenada, regarding the existence of the Ahmed diplomatic passport, have reportedly been ignored. The question remains: just how many Grenada diplomatic passports have been sold to foreign nationals ? The answer will affect how international banks treat Grenada passport holders, and large financial transactions originating from there, and how Country Risk on Grenada is assessed.

Thursday, December 14, 2017


The Foreign Minister of Dominica signing the $3m Military Aid grant from China
 The Commonwealth of Dominica, formerly a democracy located in the East Caribbean, has deteriorated into a strongman dictatorship, where the regime's periodic reelection is guaranteed through the rampant payment of voter bribery, and bringing in expat voters via jet airliner, is fast becoming a high-risk jurisdiction, where any foreign investment, or even the physical presence of foreign managers and staff, is dangerous.

We have previously expounded, at length, upon the sale of hundreds of Dominica diplomatic passports to dodgy foreign nationals (violating United Nations treaty law), and the persecution of Opposition leaders, be they official party members, or simply citizens unhappy with the mismanagement of their nation by obviously corrupt officers, at the highest level. The country's Foreign Minister refuses to disclose the names of the foreign diplomatic passport holders, alleging that they cannot perform their "diplomatic duties" if publicly named. This excuse is not only legally insufficient, it insults the intelligence of all Dominicans. The foreign diplomatic passports holders are not performing any diplomatic duties whatsoever.

The latest news is, frankly, the last straw. Dominica signed a number of agreements with the Peoples' Republic of China, and one in particular is extremely disturbing. It is a three million dollar military aid grant; What's wrong with this picture ?

The Chinese Embassy in Dominica
Dominica has had no standing army since the 1980s; it does have a rather large paramilitary unit, technically the special response team attached to the Dominica Police, known as the Special Service Unit, or SSU. This armed unit, when it turns out, upon the orders of senior government officials, wears battledress camouflage, carries military weaponry, and is not your typical law enforcement  SWAT Team. Its training schedule is military in nature, and not limited to crowd control or emergency response. Incidentally,  it provides security for the Chinese Embassy, which is extremely large, given that there is virtually no trade or tourism between the two countries.

The SSU already has state-of-the-art equipment and supplies, furnished by the Government of the Peoples' Republic. So why do they need a $3m military grant ? For surveillance equipment, armored vehicles, or aircraft ? We cannot say, but given the fact that the SSU has repeatedly turned out soldiers when any Opposition leaders wish to be heard in public, it may be for increased intimidation power, or if Constitutional rights are limited or terminated.

 For all of the above reasons, it is suggested that compliance officers at North American and EU financial institutions that handle Dominican transactions raise Country Risk on Dominica to High.

Monday, December 11, 2017


Remember when the journalist seeking information about the bearer share companies of the British Virgin Islands was denied entry into the BVI, by local immigration authorities ? It looks like the next time a journalist from the ICIJ tries to get some straight answers in Bermuda, he'd best stay away.

An ICIJ journalist has reported that his visit to Appleby's Bermuda headquarters, where staff had refused to answer questions submitted in advance, meet with him, or even identify themselves, was a total waste of time. When he returned to DC, some officer from the Bermuda Immigration Service, armed with his direct line, contacted him and asked him questions about the purpose of his trip. It was reportedly not a friendly call. Only Appleby had received a business card from the journalist; you do the math.

So, is there any difference between the treatment the BVI-bound journalist, who was run out of town, and the "Big Brother" telephone call the ICIJ journalist received ? No much.  Only time will tell whether the Paradise Papers will have the same effect upon Appleby as the Panama Papers had on Mossack & Fonseca only time will tell.

Friday, December 8, 2017


A US District Judge in Miami has set January 9, 2018 for oral argument, on former Panamanian President Ricardo Martinelli's Petition for a Writ of Habeus Corpus, challenging the Magistrate Judge's order for his extradition. Martinelli remains in Federal custody, amid rumors that his extreme efforts to obtain bond, pending the resolution of his extradition, were made because he intended to flee to the Dominican Republic, where rampant corruption could delay any legal action to remocve him for years.

Curiously, there is still no public access to any of the filings in the Habeus proceeding, giving rise to the suspicion that some of the facts alleged by Martinelli may reveal sensitive information about Martinelli, or Panama, that law enforcement does not want publicly released, including about ongoing criminal investigations. Court files are rarely sealed in this manner. We are still unable to analyze any of his arguments, to determine whether they are legally sufficient, or even valid arguments, to be made by his counsel.

The public, in the Republic of Panama, now fears that their former president, alleged to be the most corrupt in Panamanian history, will never see the inside of a Panamanian courtroom. The Miami proceedings have dragged on for months, and some are beginning to wonder whether some government agency, with a prior relationship to Martinelli, is involved.  


Thursday, December 7, 2017


I am still wondering why the Office of Foreign Asset Control, OFAC, never levied a Civil Penalty against Range Developers or Range Hospitality,* for offering or selling time-share investments in the US, to the Al-Randatain residences, located in Karbala, Iraq, due to the fact that the contractor, and later owner, of the project, was an OFAC-sanctioned entity named Tadbir Construction Development Group. Readers who did not see our prior article may access it here: Americans Sending Time-Share purchase deposits to sanctioned Iranian Company.

I have confirmed that OFAC received actual notice of the ongoing violation, but action was ever taken to levy a monetary fine, or name & shame the offending entity, or its officers or principals, and to compel the company to build an effective compliance program. Of course, the fact that Tadbir was an Iranian entity, and on the OFAC sanctions list, would have been apparent to anyone who Googled it.

How did the time-share deposits wind up in Tadbir accounts in Iran, I wonder ? Whether Range, which has a number of corporate identities, in different jurisdictions, ran afoul of international sanctions against Iran is yet another issue that OFAC seems to have overlooked. Who is watching the store, Mr. Director ?
* Range Hospitality WLL, incorporated in Bahrain.
   Range Hospitality, ltd., incorporated in the United Kingdom.
   Range Hospitality (Cayman).


In a much-publicized manner, the European Union this week named & shamed a number of jurisdictions, for their lack of international cooperation. Grenada immediately characterized its failure to comply as " inadvertent," and hastened to clear up the problem, hoping to reverse the blacklisting forthwith, though the government's failure to act was about as accidental as Antigua's "delays" in extraditing its former (and eminently guilty) banking regulator, to face American justice in the Stanford International Bank criminal prosecution. There are no accidents in the East Caribbean, when it comes to governance.

Grenada & St Lucia may have a bigger problem than they believe; Country Risk will certainly be raised upon both jurisdictions, as the direct consequence the EU action. Compliance officers, in North America as well as in Europe, are taking note of all countries named by the EU, and irrespective of what consultancy firms say, when they trumpet the CBI virtues of both countries, their programs becomes less desirable than those of, say Antigua or St Kitts-Nevis.

Therefore, the EU action appears to have served the purpose for which it was taken, to focus compliance attention where it is sorely needed, and to stimulate jurisdictions that choose to ignore international norms, in a way that they immediately recognize, in their pocketbooks.


Wednesday, December 6, 2017


The recent media coverage, detailing the role of reputed Russian Organized Crime members, who were purchasers of most of the condominium apartments at Panama's Trump Ocean Club, fails to explain precisely how the developer, Roger Khafif, the CEO of Newland International Properties Corp., was able to obtain $220m in construction bond financing for the project. No discussion of the Trump Ocean Club International Hotel & Tower is complete without that information, as it reveals the presence of seed money of yet an additional organized crime group.

Mr. Khafif, who was obsessed with creating a Trump building in Panama City, swapped a property he owned for the tract that became the hotel site. He then needed to convince Bear Stearns & Co. to underwrite the bond issue, and for that he had to have purchase contracts, or options to purchase, in hand, with deposits, to demonstrate that he had buyers ready to close.

Though he we do not know how he accomplished this feat, he soon had a sufficient number of signed agreements to obtain the needed financing. The trouble is, most of the purchasers have been identified as members of Panama's powerful Syrian organized crime syndicate, which hides in the shadows, but influences much of what goes on, behind the scenes, in Panama.

This organization, whose members are descended from immigrants who came to Panama from a specific area in the Middle East, consists of seven major families, whose intermarried reach extends into every major bank, and every government agency. Roger Khafif's family is reportedly from Aleppo; connect the dots.

These individuals later sold their contracts at a huge profit, after Alex Ventura suggested that prices at the Trump be doubled. Without their seed money, and support, the Trump Ocean Club would have never been built.   

This is the first of a series of articles exposing details of the Trump Ocean Club International Hotel & Tower project that have not been covered by conventional media.



It is being reported that customs & immigration officers in the United States and Canada are detaining holders of CBI and Diplomatic passports from the East Caribbean countries participating in Citizenship by Investment programs. Passports are being photocopied, mobile telephones inspected, and questions asked about business activities of the holders. Some reports state that the delays were extensive.

Readers who wonder how immigration officers can identify CBI passport holders, the answer is simple. If the holder's listed place of birth is found to be NOT in the country from which he or she has a passport, in most cases the passport is CBI. Commentators in the Caribbean have long warned that CBI & diplomatic passports issued to career criminals, individuals from sanctioned nations, and those from high-risk countries, will result in increased scrutiny, by North American law enforcement agents. When they photocopy your entire passport, and cross-examine you in depth, you have become a Person of Interest to law enforcement.  Their question: Are you using the CBI passport to evade detection of your true identity and nationality ?

Whether all nationals, entering the US & Canada from CBI jurisdictions will ultimately face extended questioning, and temporary detention, while their possessions are searched, is the question being asked. That lucrative CBI income may come with a price that is to be paid by every national from those countries, when he engages in international travel. We have repeatedly advised that this might occur, but to date our warnings have fallen on deaf ears. Perhaps now they will be taken seriously. 

Tuesday, December 5, 2017


Al-Randatain residences, Karbala, Iraq.
Most of us know where Karbala is in Iraq; in 2003, the 101st Airborne Division shed a lot of  American blood when taking the city from the Republican Guard. Karbala is an important destination for Shi'ite Muslim pilgrims, and several years ago, the Dubai-based project developer, Range Developments/Range Hospitality broke ground there for a timeshare project, a $100m hotel, called Al-Randatain Residences.

Range, which is familiar to those of us who focus upon the Caribbean, as the developer of several 5-star hotel and resort projects, in jurisdictions where Citizenship by Investment laws require investments of some kind, such as in St Kitts and Dominica, chose as its principal contractor in Al-Randatain the Tadbir Construction Development Group, which is an Iranian company. What's wrong with this picture ?

Tadbir is not only owned by the senior leadership of the Islamic Republic of Iran, it is part of an elaborate Iranian plan where profits are kept from the Iranian government treasury, and distributed to those groups at the top of Iran's power structure, and yes, it is also OFAC-sanctioned.

How does a non-US corporation, with a project outside the United Stated, run afoul of American sanctions ? it's simple:

(1) First,  Range offered investments, in Al-Randatain, to American Muslims, from two of its US-based offices, and through at least seven sales promotions, all conducted inside the United States. Purchasers were sending pre-construction deposits, some of which were obviously turned over to Tadbir, for constriction costs. Was American money going into the accounts of an OFAC-sanctioned entity from Iran ? Tadbir was to receive units in the project, as part of its compensation.

(2) Then, Range ran into serious cash flow problems, at the Al-Randatain site. Some reports allege that the financial difficulties were due to corruption, and the illegal diversion of funds, but Range ultimately sold its entire interest to Tadbir. Were the deposits of American purchasers not now flowing into Tadbir's accounts, with Tadbir an OFAC-sanctioned entity ? Of source they were.

(3) Other analysts fear that, when cash flow became a real problem at Al-Randatain, some of the deposits, made by Americans, for the Park Hyatt (St Kitts) might have found their way into the Karbala project, and its Iranian contractor. We cannot confirm whether this occurred, but a routine audit would certainly put to rest this nagging question.

So, the question remains, where was OFAC in all this ? They were alerted, I can tell you from personal knowledge. Americans sending funds to Iraq would certainly ring bells in my shop, I assure you. Were Suspicious Activity Reports (SARs) filed in some of these transactions ? Were the US sales promotions, of an Iraqi project publicly known to be under construction by an Iranian contractor, red flagged by anyone in US law enforcement ? Obviously not, because there have been no OFAC Civil Penalties levied in this matter, against Range, or any other entity.

We wonder whether there were political considerations involved; Iraq is stated to be an ally of the United States, though realistically, it is now within the Iranian sphere of influence. We hope this was not some well-intentioned State Department decision that resulted in Americans funding Iran.

Tadbir group in Iranian network


As promised, below you will find the third of three groups of images displaying actual text messages from Grenada head Kaisha Ince's telephone. Please be warned that they include crude and discriminatory statements, which are grossly insulting to the people of of Grenada. No public servant, elected or appointed, should ever remain in office after venting such anti-Black prejudice, whether in the Caribbean, or elsewhere.

These messages are between Kaisha Ince, and a trusted friend.

Kaisha Ince is not serving the people of Grenada well as CBI head; demand her resignation, and send her back to Trinidad, so that she can face the issues she left behind there.

Monday, December 4, 2017


We do not ordinarily discuss marital infidelity on this blog, but when it involves a married Prime Minister and his CBI protege, and these arrogant individuals attempt to censor news about Grenada's illegal diplomatic passport sales scheme, and threaten defamation suits, when we literally have the smoking gun in hand, the evidence is going to be published.

Is this what we call "Sexting" ? Read it and judge for yourself what these two people are planning.


Computer hackers, reportedly based in the United Kingdom, and in Grenada, have sought, over the weekend, to crash websites carrying this blog's articles on official corruption in Grenada, centering around the role of the Prime Minister, and the head of the country's CBI program. Fortunately, those attacks were unsuccessful, and the articles remain available to the public, on this blog, and elsewhere in the World Wide Web.

Sunday, December 3, 2017


Christopher Willis, the cashiered Managing Director of Henley & Partners Caribbean, Ltd.

Government-controlled media in Grenada is claiming that the quotes from recent articles, exposing an illegal diplomatic passport scheme, rampant corruption, marital infidelity, and anti-Black prejudice, are not genuine. Readers should judge for themselves, after reviewing the images appearing below.

The Prime Minister sends CBI head Kaisha Ince a hyperlink to my original article, detailing the $1m charge for the purchase of a Grenada diplomatic passport, naming Willis as the central figure. The PM demanded to know how this blogger obtained the information. The PM orders her to speak to Chris [Kallin], as Mitchell "cannot afford this kind of information to come out before the election."


Ms. Ince indicates that she has already spoken to people at Henley, who are " already aware of it and will put pressure on this blog writer [yours truly] to take the article down." I will leave it to the opinions of attorneys in Grenada to decide whether Ince, and indeed the PM himself, committed three criminal acts, or only two. Grenadians deserve honest public servants, not these two manipulators.


 After Reza Zarrab, the Iranian trader who used Turkish banks to evade international oil sanctions against, testified that his criminal acts were approved at the highest levels of Turkish Government,  including Erdogan, Turkey acted to seize all of Zarrab's assets in that country. What effect, if any, will the seizure have on who is indicted next, by US prosecutors, for facilitating the sale of billions of dollars of sanctioned oil, and covert payment for that contraband. Zarrab is now effectively banned from returning to Turkey, and he certainly has taken offense to this betrayal.

The questions now to be considered:

1. Will more Turkish bankers be implicated by Zarrab, and indicted ?

2. Will Turkish cabinet members be charged ?

3.  What other nationals (Iranian, Chinese, Malaysian or Dominican) will be charged sooner, rather than later ?

The case has become even more interesting to students of global financial crime.

Saturday, December 2, 2017


Kaisha Ince, the head of Grenada's CBI program, has issued a blanket denial of the damaging facts presented here on this blog yesterday, entitled Will Grenada Sack its CBI Head for Misconduct and Corruption ?, choosing to attack this blogger, rather than reply on the merits. The truth obviously hurts.

Shoot the messenger will not work here, especially since Ince's previous message to the Prime Minister clearly indicated that she was trying to bring pressure to bear upon me, to remove these articles. Ince was more concerned about the source of the leaks, and neither individual denied the truth contained in the articles.

We do not make statements without a factual basis; this blog has screenshots showing ALL the statements quoted in the last article, and we will make that information available to any US law enforcement agency investigating corruption in the CBI and diplomatic passport programs. It is certainly not "fake news" in any form.

These arrogant Grenadian government officials obviously do not care that their telecommunications are not secure, especially at the receiving end, when they discuss corrupt activities, marital infidelity, kickbacks & bribes, and anti-Black prejudice. Does the Prime Minister know where his telephone is at this moment ?

Perhaps the voters in Grenada will take note of this scandal in the next election. While I have no interest in any political party on Grenada, or its officials and candidates, I am opposed to the "Banana Republic" corruption that the CBI and diplomatic passport programs has spawned in Grenada.

Friday, December 1, 2017


In addition to the information contained in yesterday's article, Grenada's Prime Minister tried to have our Article Exposing Million Dollar Diplomatic Passport Fee taken down, there are a number of other acts of misconduct or corruption, attributed to CBI Head Kaisha Ince, which, when taken together, justify her immediate removal for cause. Confirmation of these conversations can be easily obtained, through either the telephone utility, or Ms. Ince's telephone itself.

These are some of the grounds, which have surfaced of late, together with verbatim statements she made, via text message, with either the country's Prime Minister, or a close personal friend of Ince. You are warned that some of these conversations may be disturbing, vulgar or crude, but the offensive language needs to be seen. It appears that they are reluctant to discuss personal issues on the telephone; one conversation included a query regarding whether a voice telephone call was appropriate ("PM can I call you ?").

(1) There is a ongoing intimate affair between the Prime Minister, Keith Mitchell, a married man, and CBI Head Kaisha Ince:

PM:  ... "When are we going for another meeting then ?"

Ince:  "Ha ha, that's what we are going to call it 'Meeting ?'
          I was thinking Tuesday, let's do
         You'll have free house".

PM:  "Yes, dinner at mine ?
          I like the sound of that
          Will there be my special dessert ?"

Ince:  "Pick up where we left off last week ?"

PM:   "You are funny".

Ince: "Funny ?"

PM:  "You know, naughty, funny."

Ince: "Call me."

(2) Ms. Ince, who is of East Indian origin, originally from Trinidad, is prejudiced against Black Grenadians. This is a conversation between Ince and a friend: WARNING- DISTURBING.

Ince:  ... "this place drives me [Emoticon for crazy]".

Friend:  "U stressed with it ?"

Ince:  "Just lot of work, and they're not professional."

Friend: "Yep, I know that - local workforce got bad attitude."

Ince: "Damn, surrounded by them "!

Friend:  "Why do a black man drive with his windows up ?
              They think the smell is coming from outside. 
              That'll cheer you up [Emoticon]."

Ince:  "It smells in my office, too."

Friend: "What are the three things you can't give a black person ?
              A black eye, a fat lip, and an education."

Ince:  "LOL" [ laughing out loud].

(3) Grenadians also have two unanswered questions about their CBI chief:
 (A) Is it true that her daughter's British education is being paid by Henley & Partners ?
 (B) Is the reason Ince is retaining outside professionals for the CBI agency, kickbacks she receives ?

Will Grenada terminate Kaisha Ince as CBI Head,. given the seriousness of the above violations ? We cannot say, but we shall continue to cover the issues. 




Thursday, November 30, 2017


 Reza Zarrab, the Iranian oil sanctions evader who was the principal defendant in the New York Federal criminal case, but is now cooperating with the authorities, is presently testifying, this week, against the remaining defendant in custody, Halkbank Deputy CEO, Mehmet Atilla. Zarrab will most likely be benefiting from his testimony at trial, through Government motion, when he is eventually sentenced.

Thereafter, his defense team, who are charged with assisting Zarrab navigate the complex Sentence Reduction minefield, will thereafter be seeking to have their client give evidence that will persuade the US Attorney to seek a reduction in the sentence that was pronounced, through testimony that will result in Grand Jury indictments of yet more defendants.

Some of the possible new defendants:

(1) Zarrab's two partners in the oil-for-gold Iran oil sanctions evasion scheme, Zanjani & Monfared, both of whom are known to be in custody in Iran, and facing the death penalty.

(2) Individuals, in Malaysia, specifically Labuan, the country's offshore financial center, who assisted Alireza Monfared, and Babak Zanjani, in the illegal sale of sanctioned Iranian oil.

(3) The other Turkish banks & bankers who participated in Zarrab's massive oil-for-gold scheme.

(4) Senior officials in Dominica, who were responsible for Monfared obtaining a Dominica diplomatic passport, as well as a CIP passport. Possibly also individuals who sought, or obtained, additional economic passports for Zarrab and/or his crew.

(5) Iranian nationals who were part of the Zarrab/Zanjani/Monfared organization.

Who will be next to be charged ? We cannot say, but we will be monitoring the case closely.


Prime Minister Keith Mitchell
Regular readers of this blog will recall our August 18, 2017 article, Applicant for Grenada Diplomatic Passport sent Million Dollars to Wells Fargo Account of Agent, which recounted the tale of a Ukrainian businessmen who was ordered to send $1m to a Singapore bank account, in order to obtain a diplomatic passport from Grenada. Newly-discovered information, obtained through an official source in Dominica, confirms that the scandal caused a panic in Grenada's government.  

Keith Mitchell, the Prime Minister of Grenada, openly fearful of probable fallout in his next election, asked his CBI Head, and personal advisor, Kaisha Ince, if she could have the article deleted from the Internet, by having a CBI consultancy handle it.

CBI head Kaisha Ince

What follows is a verbatim transcript of text messages, between these two parties. it occurred on August 19, 2017. Mitchell first texted Ince the article.

Mitchell: Kaisha, what is this article ?

Ince: PM, let me speak to them.

Mitchell: Where did he get this information ? Talk to Chris*, to take action on this. 
                 I cannot afford this kind of information to come out before the election.

Ince:  Yes, I spoke to them. They are already aware of it, and will put pressure on this
          blog writer to take the article down.

The article remains online today, and will continue to be published on this blog. Please note well that nowhere in the conversation was there a denial of the accuracy of the information appearing in the article, only a demand to know where the information came from. Further, the Ukrainian applicant later not only confirmed his story, he disclosed that another businessman from his country had also applied for a Grenada diplomatic passport.

We will be publishing two additional articles on official misconduct in Grenada, again supplying complete transcripts of text conversations, and as they are extremely disturbing, we shall post a warning regarding their content.
* It is believed that this is a reference to a senior officer at Henley & Partners, Christian Kalin.


Wednesday, November 29, 2017


The US Treasury Office of Foreign Assets Control has issued a Finding of Violation against Dominica, specifically the government agency responsible for maritime affairs, the Maritime Registry, which is an international ship registry.

 The Commonwealth of Dominica Maritime Registry, Inc., (DMRI) violated the Iran Transactions and Sanctions Regulations (ITSR), by entering into what OFAC described as a "binding Memorandum of Understanding with The National Iranian Tanker Company, a Specially Designated National (SDN), which is owned by the Government of Iran, and is therefore sanctioned.                                                                          

                                                                                                                                                          OFAC noted in its Enforcement Information press release that DMRI failed to report the offense to regulators.The Finding requires it to create an OFAC compliance procedures program, as well as an employee training program, because senior DMRI staff simply ignored US sanctions law.

If you were wondering how OFAC has jurisdiction over a foreign government, Dominica employs a Delaware Corporation, registered to conduct business in the State of Massachusetts, and which is reported to be operated by American citizens, from its office in Fairhaven, Mass.


We see that the DMRI uses only the abbreviated name of Dominica Maritime Registry Inc., which appears to the public to be a US corporation for profit, rather than an official government agency. I leave it to our readers to decide whether this is deceptive.


Tuesday, November 28, 2017


 The trial judge in the Reza Zarrab case has declined to grant co-defendant Mehmet Atilla's motion to adjourn the trial for two weeks. The Court noted that defense counsel for Atilla had repeatedly opposed earlier rescheduling of the trial date, and observed that there were a sufficient number of attorneys to review the massive discovery furnished, though it also ordered the Government to act diligently with respect to the Discovery.

The Court also all but declared that co-defendant Reza Zarrab was to be the "mystery witness" at Atilla's trial. Zarrab's letter to a Middle Eastern regulator, containing the term "economic Jihad," has already been admitted by the Court, notwithstanding its likely prejudicial effect at trial.

We shall be following the trial, on a daily basis, to update our readers.


Monday, November 27, 2017


Counsel for Mehmet Atilla, the Deputy Halkbank CEO, has asked for a two-week delay, on the eve of trial, and they have asserted several major issues in support of their request.

To summarize the grounds alleged:

(1) There are Brady and Jencks Act violations, including exculpatory evidence, specifically public testimony of a Treasury Undersecretary, which were not produced as required by law.

(2) The massive last-minute document production, by the Government, requires a trial continuance.

(3) There was a belated production of the specific trial exhibits.

(4) There was an enormous amount of 3500 material produced.

(5) There was a "facially unwarranted redaction of 3500 material."

(6) There were logistical delays arising from the Protective Order, and the defendant's incarceration.

Counsel wants a delay, until December 11, 2017.

Friday, November 24, 2017


Alberto Diamond Rodriguez

It appears that Alberto Diamond Rodriguez, the fugitive former Superintendent of Banking in Panama, is facing criminal charges in another country, El Salvador, where it is believed he fled to, after Ricardo Martinelli left office. Diamond is a relative if the former Panamanian President, and he was named for the superintendency, notwithstanding that he was totally unqualified for the job.

Panamanians will recall that he never filed one money laundering charge against any local bank while in office, and boasted that he brought in $17bn in cash, from Venezuela, to fill the coffers of Panamanian banks. He  is reportedly a target of the anti-corruption prosecutors in Panama City.

Diamond has been charged with Aggravated Fraud, and we are attaching a copy of a portion of a Salvadoran court document, for the benefit of our readers. If you are not familiar with this corrupt fugitive, kindly access our previous articles, detailing his corruption, conflict of interest, and criminal activities, some of which were allegedly conducted with his son, the banker Alberto Diamond Martinelli, who remains in Panama City, with substantial unexplained wealth.

Alberto Diamond Martinelli

Diamond actually had a local Panama attorney threaten me for my coverage of his client, who richly deserves a decade in one of Panama's notorious prisons, for all his sins. We trust that the Salvadoran authorities will see that justice is done.

Update: A hearing has been scheduled in the case for December 18, 2017.

Thursday, November 23, 2017


If you do not closely follow developments in the Middle East, you may not not know that the Real Admiral who commands the Islamic republic of Iran Naval Forces, in a recent public appearance, stated that due to the ongoing presence of the US Navy in the Persian Gulf, the Iranian Navy will be moving a significant number of its warships into the Caribbean, and the Gulf of Mexico, and that they will be making port calls in the region. The amount of global media that these Iranian ships will attract, together with the expected political, diplomatic and military response from the United States, will place the region under increased attention, which may result in a hard look at the risks presented by the economic and diplomatic passport programs being operated in the East Caribbean.

For several years, a reportedly large number of Iranian nationals have acquired Citizenship by Investment (CBI) status, or diplomatic passports, in the East Caribbean, among the half dozen countries that offer them, predominantly the Commonwealth of Dominica and St Kitts & Nevis, though there has been a small number off passports issued in the other four nations.  Will any of these Iranian nationals, with dual citizenship acquired in the East Caribbean, come ashore, which they have the legal right to do, and perhaps establish residence, or even a diplomatic presence at America's backdoor ?  

It is too soon to calculate whether Country Risk levels in the East Caribbean will increase, as the direct result of Iranian actions in the region, but American compliance officers charged with following OFAC sanctions would do well to monitor the situation as it unfolds, lest they later find their bank named & shamed by a civil fine or other penalty.

Tuesday, November 21, 2017


What's going on in the Reza Zarrab oil-for-gold Iran sanctions case ? Trial was scheduled to begin next Monday, November 27, but the Court has postponed the start for one week. Moreover, a recent two-hour pretrial conference was reportedly not only closed to the public, with the doors locked, but the live video feed was turned off. Plea negotiation, perhaps ?

One observer noted that orders in this matter, originating from the bench, now show the style of the case as US vs. Mehmet Atilla, rather than US vs. Rezas Zarrab et al. What has become of Zarrab ?

A final note, which deepens the mystery: An additional defense attorney has now appeared, literally at the last minute, on behalf of Atilla, who is not apparently the only defendant, in custody, that is going to trail. This lawyer has extensive experience, including time as a state and Federal prosecutor. Was he brought in to craft a plea agreement ? We cannot say, but wait for next Monday, it may reveal itself as both defendants enter pleas.


The new ICIJ project, commonly known as the Paradise Papers, has revealed that North Korean nationals, closely linked to the universally sanctioned DPRK regime, have formed offshore entities, operating in Malta. One of those entities is reportedly a joint venture with a Maltese businessman. Is nobody in compliance, banking, government regulators or private business, watching who is allowed to do business in Malta ? Apparently not; greed trumps effective compliance in Malta.

If Malta is covertly allowing North Korea, the most heavily sanctioned country on earth, to do business through its financial and legal system, then we wonder what else is going on in the only EU member to openly hawk its economic passport program. It is appropriate to raise Country Risk for Malta at this time, and to exercise extreme caution in all future dealings with Malta-based, or incorporated, entities or individuals.

Sunday, November 19, 2017


Gary James Lundgren
He is a businessman known to lie, cheat and even steal, and a known sexual predator*, but the true power broker at the Trump Ocean Club (TOC) in Panama is not the Trump whom you think he is. He is the American expat, Gary James Lundgren, whom neither NBC nor Reuters, nor Global Witness identified in their recent expose' about rampant criminal activity at the TOC, and the quintessential Ugly American.

Lundgren, who left a sexual assault charge in the State of Washington years ago, and relocated to Panama City, where he resides, and where he is apparently safe from the grasp of  US law enforcement agencies, engages in fleecing unsuspecting foreign investors, and laundering Cartel narco-profits. The American securities broker regulator, FINRA, stripped him, for life, of all his US licenses to sell stock, when he refused to open his books of account to it. He has been identified several times, by victims of sexual assaults he allegedly committed in Panama, and is known there as the "Bill Cosby of Panama, " due in part to his manipulation of the criminal justice system, when charged with sex crimes.

Lundgren owns, through a number of shell companies, at least fifteen condominium units in the TOC complex, and fifteen per cent (15%) of the outstanding bonds owned by the TOC developers. His wife, a Colombian national whose family is linked to the Medellin Cartel, convinced the Association to transfer the maintenance contract to her control. The Trump companies filed a $75m damage claim against her company, before a tribunal of the international Chamber of Commerce.

As we have previously reported, Lundgren is known to operate an enterprise that provides prostitutes to guests at the TOC Hotel; some Panamanians have derisively referred to him as "The Pimp at the Trump." No story about the Trump Ocean Club is complete without understanding that Gary Lundgren is a central player who assisted members of organized crime syndicates, from several countries, including Russia, in money laundering, through purchases at the Trump Ocean Club. 
* Steele vs. Lundgren, 982 P.2d 617 (Wash. Ct. App. 1999)


The ongoing controversy, and rivalry, among the half dozen nations in the East Caribbean that offer economic citizenship, totally ignores important negative aspects of these programs, which cannot be ignored, should an accurate calculation about which country's passports are superior to that of another, be made. Applicants should not rank one over the over, simply because of the number of visa-free nations that may be visited; that is hogwash, and misleading.

What about those negative, but not mentioned, aspects of these Citizenship by Investment (CBI) programs:

(1) Was the country ever, or presently, a known tax haven a/k/a offshore financial center ? If so, nationals from those countries may still be under law enforcement scrutiny, by US and EU law enforcement agencies, especially regarding money laundering, and other financial crimes.

(2) Have any high-profile economic passport holders from the country been arrested abroad, for serious financial crimes ? That fact that economic citizenship holders from a country have major felony convictions attracts even more unwanted law enforcement attention elsewhere. Do applicants really want guilt by association issues ?

(3) Is the Rule of Law not observed in the country's court system ? If so, applicants should fear that they are destined to lose any commercial dispute that arises there, as aggrieved parties, against locals or the government, even though the law is on their side.

(4) Does the government have a history of cancelling an economic citizenship, when the holder gets in trouble abroad ? If so, what is to stop it from taking that same step, for political or economic reasons, against innocent CBI citizens ?

Given the long and sordid history, of criminals abusing economic citizenship for illicit financial gain, applicants should NOT rely upon industry calculations, but seek out competent legal advice, regarding accurate assessment of risk, when seeking a second passport. To do any less invites a subsequent shock, when the new passport holder realizes that he or she has merely bought into a problem, not a solution.

Saturday, November 18, 2017


Panamanians are reportedly concerned about the fact that they cannot identify the ultimate owners of the iconic Trump Ocean Club International Hotel, which was sold earlier this year for $24.5m. Financing was arranged through Canal Bank. The purchaser was reported to be Ithaca Capital Partners and/or Ithaca Capital Investments, but information on those entities is minimal, and raises more questions than it answers.

Ithaca Capital Investments Ltd., SA is a Panamanian corporation. Ithaca Capital Partners Ltd., is a corporation organized and existing pursuant to the laws of the United Kingdom.

Ithaca Capital Partners website lists as its sole US address a residential condominium apartment in downtown Miami, but real estate records indicate that it was sold last month. A social media page states that the company is located in Cyprus, but only lists the US address, though it has not qualified to conduct business in the State of Florida.

 Partners' US-based director, Orestes Fintiklis, who is also affiliated with Dolphin Capital, a Greek-based firm with major interests in Cyprus, is a lawyer who previously worked in the UK. He is not admitted to the practice of law in Florida. There is no information regarding the company's business activities, if any, within the Continental United States, and why it maintains an office in Miami.

Ithaca Capital Partners Director Orestes Fintiklis
The owners of Ithaca Capital, according to its press release, are a number of "family offices" located on several continents. A family office is a group of legal and financial professionals who manage the investments of high net-worth individuals. As these professionals are most likely employing shell companies to make their investments in Ithaca, there is no accurate way to determine who their clients, the beneficial owners of the Trump Ocean Club Hotel, are.

The fact that both companies are closely connected to Cyprus, which is a known offshore financial center for wealthy Russian nationals, may be the reason for the Panamanians' concern about who the new owners of the Trump Ocean Club may be.