While attorneys often differ, when offering legal opinions on important issues, the consensus, at least from the vantage of the United States, is that those government officials, and associated Politically Exposed Persons (PEPs), who are operating Dominica's diplomatic passport scheme, have committed money laundering, under US law, in the Reza Zarrab case, and may also be culpable in general, due to the fact that the scheme has no basis in law, for their other passport sales to dodgy foreigners.
The awarding of diplomatic passports, pursuant to the 1961 Vienna Convention on Diplomatic Relations, which was adopted by Dominica, as well as the United Nations, does in no way authorize any nation to sell such important instruments, which confer diplomatic immunity, to anyone. Additionally, designated diplomats must accept duties and missions, to specific countries, The failure of scheme operators to fulfill both of these requirements, makes the documents they issue void, not voidable.
Therefore, inasmuch as the issuance of these suspect passports constitutes a crime, and is a Predicate Act, whosoever who receives, controls, accepts, or otherwise has any contact with the illegal US Dollars paid out for them, some of which thereafter has entered the American financial structure, has committed the crime of money laundering. See the Money Laundering Control Act of 1986, 18 USC Section 1956 et seq.
Subsequent Federal Court decisions have established Extraterritorial Jurisdiction; in plan English, this means that any Dominican who has participated in a money laundering conspiracy, actionable under the Act, can be indicted, even though he or she has never come into the United States.
In the Reza Zarrab case, now pending in US District Court, Alireza Monfared, a known participant in Zarrab's Iran sanctions evasion operation, illegally purchased a Dominican diplomatic passport. Both the sales "fee," and any commission paid out, in connection with that transaction, are Predicate Acts. The document itself, which was used by Monfared to evade arrest, is part of the broad conspiracy to evade US and international sanctions. Everyone involved, from the most senior government officials in Dominica, to the Dominican attorneys who advised them, and received fees from that money, to the administrative staff who created the passport, are all now part of the Zarrab case, whether they like it, or not.
Given that the new US Attorney General has instructed the Department of Justice to bring the maximum criminal charges possible, against offenders, and seek the longest sentences available, under the US Sentencing Guidelines, there are a number of Dominicans who now face the imminent threat of indictment, in the United States, for their role in illegally selling a diplomatic passport, to an Iranian national, known to be a player in the world's largest Iran sanctions evasion syndicate.