Kenneth Rijock

Kenneth Rijock

Monday, June 18, 2018


I have been reading a number of articles of late, in the Caribbean media, bitterly complaining abut rampant de-risking at North American banks, and making all sorts of arguments for continued access to US & Canadian financial structures, through correspondent accounts. Whle some of the arguments certainly have merit, the de-risking situation in North America, where compliance officers at international banks are under increased pressure, and even fear the imposition of personal liability, for perceived ineffectiveness in their AML/CFT compliance programs, is only going to get worse.

North American banks will only retain their correspondent acounts at Caribbean banks if they are afforded a window into the local accounts of the offshore banks, which means Know your Customers' Customer, or KYCC. This means having softeare installed in each Caribbean bank, that will allow the bank in New York or Toronto to examine their correspondent bank's local accounts in depth, with the same access as the local bank has. It is as simple as that.

There's no great mystery about how this is accomplished; the Csribbean bank, and its Northern correspondent both download commercially-available software. There's even one created locally*, by IT techs in the Cayman Islands, for that express purpose. The problem is, in the Caribbean, with rare exceptions, no banks are willing to do it,  notwithstanding that the cost to the banks are minimal.

Why the hesitation ? I am afraid the most likely excuses are also the reasons that the North American banks want to close those correspondent accounts in the first place. The Caribbean banks say that they do not want to expose the privacy of their customers. In plain English, they do not want these types of customers/clients exposed:

(1) Accounts of corrupt government officials,and their political allies. An examination of such accounts could show deposits far in excess of an official's known salary and minimal assets.

(2) Accounts of dodgy tax evaders, drug traffickers, or individuals engaged in illegal activities.

(3) Accounts of individuals from sanctioned countries, deposited without any verification of Source of Funds, and who may be internediaries, or terrorist financiers.

(4) Accounts that hold income from Citizenship by Investment (CBI) applicants. Knowing how many deposits, and their country of origin, could provide clues to foreign law ernforcement aencies as to the volume of CBI passports issued, and what countries they ase coming from.

Unfortunately, unless true KYCC capability is granted to the onshore banks, you can expect increased de-risking, forcing the losing banks to funnel US Dollars through third parties, at increased cost, and with additional delays for clients. If KYCC does not come to the Caribbean, you can count on an eventual deterioration in local economies, and the reinforcement of the perception that bank secrecy exists there only to keep illicit clients out of the sunlight. The banks must choose KYCC to survive.
*Readers who are not familiar with the software I am describing may email me for details. As this is a non-commercial blog, we do not promote specific goods and services.

Sunday, June 17, 2018


Donald Trump, Andrey Bogdanov, Ivan Kazan, Phil Shloesenberg

  There has been zero coverage, by any media, of the curious fact that both former Panamanian president Ricardo Martinelli's District Court extradition case, as well as his subsequent Eleventh Circuit appeal, were effectively sealed, and remain unavailable to the public and press. Nobody has questioned why the courts have denied access to the pleadings in the files; indeed, we have not even seen any ruling or order that has closed these files to inspection. Why was the appeal also restricted, which is an extremely rare occurrence ?

While national security is a valid reason to restrict Federal Court files, there has never been a whisper out there that this is the reason. To the contrary, reliable sources abroad, as we have previously reported, confirm that it is common knowledge in the Republic of Panama that Donald Trump, and one of his sons, engaged in conduct in Panama City that would be extremely embarrassing if disclosed in the media. There appears to be a news blackout in place.

Longtime Panama watchers know that one of the charges that Martinelli has been exrtradited for include widespread illegal video and audio surveillance of powerful people, caught in private and intimate moments. Martinelli used tapes and videos to blackmail his victims, and the word is that two Trumps are allegedly on the tapes. Is that really why the Martinelli court files were restricted ?

Given the wide-ranging Russian election influence investigation conducted by the Office of Special Counsel, and the Russians involved in both sales, as well as purchasers, of the Trump Ocean Club in Panana City, we wonder whether its investigators have read those files.


Back in October, 2017 the principal defendant in the Federal Iran oil-for-gold sanctions evasion case, Reza Zarrab, waived the filing of an Indictment in his case, and a Superseding Information was filed against him. This is an indication to the Court that the defendant is rendering Substantial Assistance to US law enforcement; in truth and in fact, he did testify against his former Turkish banker, Mehmet Atilla.

Eight months later, Zarrab has not only not been sentenced, his sentencing date has not even been set. His cooperation, which could include Grand Jury testimony against others in his sanctions evasion organization, making incriminating documents available, and placing recorded telephone calls to targets, must be extraordinary. Does he have so much critical evidence, or is the US Attorney waiting for the next trial, where he will again testify, before setting his sentencing date, so that he can get sufficient credit for his cooperation ? I believe this is so.

 Several of his associates, including Babak Zanjani and Alireza Monfared, both of whom are in Iranian custody, and who assisted him in selling sanctioned Iranian oil and laundering the proceeds of this criminal conduct, may already have sealed indictments on file against them, An examination of the court docket of late shows only that numerous sealed pleadings have filed.

How many individuals have been indicted already, but inasmuch as they are not yet in Federal custody, are unaware that they are defendants in America's largest Iran sanctions case ?

Saturday, June 16, 2018


Just when you thought that the corruption in St Kitts & Nevis couldn't get any worse, with the Peter Virdee scandal, it gets worse. The obviously politically motivated suit* against Opposition leader Denzil Douglas, seeking to have him removed from his seat in the National Assembly has itself a dark aspect which, when it becomes widely known, will result in the public conclusion that the Prime Minister is unfit to hold office.

According to reliable government sources, The Prime Minister has engaged Anthony Ross QC, to bring the suit, and has promised him a $3m fee to bring the action. The problem is that the PM is expecting a substantial kickback, which is not only unethical, according to the Law Society of Upper Canada, where Ross holds his law license, but could constitute a criminal act in Canada. Nonlawyers cannot receive referral fees from attorneys admitted to practice in Ontario.

We invite the public, whose taxes pay attorneys fees on outside counsel retained on behalf of the Government of St Kitts, to track and trace all payments to Ross that have already been made, and which will be made in the future, and to determine if your PM recorded a deposit from Canada during that time period.

With this obscene level of systemic corruption, it is easy to understand why both the United States and Canada want to look carefully at anyone holding a St. Kitts passport, before issuing them a visa to visit their country.
* Political case against Opposition Leader in St. Kitts could be Dismissed this Week


Maria Efimova
An appellate court in Greece has affirmed a lower court decision declining a request from Malta to extradite the Russian whistleblower Maria Efimova, the former bank employee who helped the assassinated journalist Daphne Caruana Galizia expose financial crime and Iran senctions evasion at now-shuttered Pilatus Bank. The Maltese government's petition for extradition was held by the lower Greek court to be vague and irregular, and found that she would neither get a fair trial in Malta, nor be protected while in custody.

The arrest warrant from Malta, which alleged that Efimova provided false evidence, false accusations, and theft, allegedly was politically motivated, and have no factual basis. Powerful politicians in Malta, some of whom have been exposed in the Panana Papers, and thereafter scalded by the media for reputed corruption, are believed to be behind the government's action.

The court system in Malta, whicb is regarded by many observers as corrupt, with two recent court cases involving judges accused of bribery, may have been a factor in the Greek court's ruling as were allegations of governmental corruption in Malta, irrespective of the law. The corruption, when paired with a citizenship by investment (CBI) program where effectiveness of the due diligence investigations of applicants has been questioned, has increased Country Risk for Malta among compliance officers in the EU, for valid reasons. Investigations by the EU, into both the CBI programs, and money laundering allegations, are pending.


Denzil Douglas, Timothy Harris
A civil suit, brought by a constituant against the leader of the Opposition in St. Kitts & Nevis, for having a diplomatic passport from Dominica, appears to be legally flawed, and could be dismissed as early as next week, as the two island nation continues to be roiled by a bribery and corruption scandal involving its prime minister, Timothy Harris.

At a recent hearing, several issues were raised by the Court, including whether there was legal standing, whether the plaintiff's expert witness on Dominica law was actually qualified to render an opinion,  whether the case should be decided based upon the Constitution, rather than the National Elections Act. The Court implied that the matter appeared to be ripe for dismissal, and an additional hearing on a pending motion to dismiss has been set for the coming week, on June 18th.

Most experts say the case is purely political, and brought by the PM to divert attention from his dire position, due to multiple scandals, the object being to attempt to drive the leader of the Opposition, Denzil Douglas from his seat in the National Assembly. Tony Ross, A Kittitian lawyer from Canada, who is counsel for the plaintiff, and is said to be commanding a huge fee at government expense, is, according to a Kittitian whistleblower, kicking back a portion of his fee to Timothy Harris .

According to local sources, several Cabinet members have called for Harris' resignation, as the financial records of receipts from the Citizenship by Investment (CBI) program are not being released for inspection, and there are issues of sexual misconduct in what is a very conservative nation. Their dismay is compounded by the Peter Virdee scandal, which has generated extensive negative press throughout the Caribbean. So far, Harris has refused to resign; Whether he will be forced from office by the people of St. Kitts is not known.

Friday, June 15, 2018


For those who predicted that the former president of Panama, Ricardo Martinelli, would never be extradited to face prosecution for the $13m embezzlement and massive illegal surveillance charges, here he is behind bars, where he will remain until trial.