Kenneth Rijock

Kenneth Rijock

Saturday, December 3, 2016


Andrew Coumo, the Governor of the State of New York, has ordered that certain specified European financial institutions, and corporate entities, be hereafter off limits, for any business purpose, to all state agencies, bureaus and offices. the reason for this blacklisting is the determination that these  sanctioned entities are participating in a BDS program, which involves boycotting goods and services from Israel, divesting themselves of any investments in Israel, and supporting anti-Israel sanctions targeting activities.

The institutions and companies named are:

(1) ASN Bank NV
(2) Betsah SA
(3) Bersah Invest SA
(4) Cactus SA
(5) The Co-operative Group
(6) Danske Bank
(7) FreedomCall UK
(8) Guloguz Dis Deposu Ticaret ve Pazarlams Ltd.
(9) KLP Kapitalfortvaltning
(10) Kommunal Landspensjonskasse (KLP)
(11) Royal Haskoning DHV
(12) Triodos Bank
(13) Vitens NV

Please note that some of these entities are also subject to similar state sanctions, in Florida, and other states. Whether you choose to elevate risk levels involving the financial institutions named above is your decision, but given that Hamas is deeply involved in global BDS anti-Israel operations, it is prudent to consider doing so, for you do not want to later learn, too late, that your bank is under investigation for providing material support to a designated terrorist organization.

Readers who wish to confirm the names of the financial entities and companies may do so by accessing the State of New York Office of General Services webpage here.


The trial judge in the Iran sanctions violation case, against the Iranian-Turkish gold trader, Reza Zarrab, his brother, and others, has changed the January 23rd trial date; the case will now be heard on October 17, 2017. The new trial date was granted at a hearing on other matters, on November 30, after the defense represented that it would not be adequately prepared for a January trial, in light of a recently-filed Superseding Indictment, which added additional charges against their client.

The new indictment, which added Zarrab's brother, Mohammad, to the case, also alleges that both brothers were deeply involved with the Iranian carrier , Mahan Air, an OFAC-sanctioned entity that transports troops and military equipment, for both the sanctioned Iranian Revolutionary Guard Corps (IRGC), and the sanctioned Lebanese Shi'ite terrorist organization, Hezbollah.

It is also, when considering whether the rescheduling of the trial date was necessary, important to note that the defense has three major pretrial motions pending; two suppression motions, regarding discovery issues, and a Conflict of Interest motion, filed against the defense law firm of Kirkland & Ellis. All pretrial matters must be resolved in advance of trial, and appeals of decisions on them, including potential interlocutory appeals, could derail the trial at the last moment.

The conflict motion, which Kirkland & Ellis sought to resolve, by filing consents, from firm clients, Bank of America, and Deutsche Bank, has now gotten more complex, after the Government disclosed that additional banks clients of K & L have suffered damages, and could testify at trial. Those clients are:

(1) JP Morgan Chase Bank.
(2) Citibank.
(3) HSBC Bank USA.
(4) UBS.
(5) Wells Fargo Bank.

The Court exempted the period from January 23 to October 16 from Speedy Trial computation. This means that the defense cannot move to dismiss the case, for failure to bring the matter to trial within 70 days of the filing of the Superseding indictment, pursuant to the Speedy Trial Act.

The pending motions are all scheduled for hearings during the month of December, but the issues presented are complex, and they may not be resolved at that time.

Thursday, December 1, 2016


A suit has been filed, by an Arab Chilean of Palestinian extraction, against three present and former justices of the Supreme Court of Israel, alleging war crimes and crimes against humanity. The claim is based upon the fact that the justices approved the construction of a separation barrier, a wall, between Israel and the territories of Judea & Samaria.

While the legal basis for the suit is clearly questionable at best, and most likely barred by law, the fact that it was filed at all is a cause for concern, on the part of compliance officers. Chile is home to more Palestinians, and their descendants, than any country outside the Middle East, and they claim to wield substantial political power in Chile. In recent years, they have become more vocal and militant, in their opposition to Israel.

Many Palestinians do not support the Palestinian Authority, and Fatah, the reigning political party; they support Hamas, which is designated SDGT by OFAC. Hamas' charter calls for the destruction of the State of Israel, by military means, for the occupation of all its sovereign territory, and the removal of its Jewish citizens.

 If Arab Chileans of Palestinian descent start actively supporting Hamas, in addition to the financial assistance they already send to it,  they will be guilty of providing material support to a terrorist organization. If they employ US financial institutions for that purpose, any banks that fail to interdict transactions involving the purchase of goods or services, for Hamas, could be subject to serious fines & civil penalties, or worse, indictment in Federal Court

 Companies in the United States and Chile enjoy a healthy trading relationship, and Chile is regarded, compliance officers in the US & Canada, as low risk, for Country Risk and AML/CFT purposes. Should  Chileans of Palestinian descent initiate the purchase of dual purpose goods, or engage in other material support of Hamas, then Country Risk must be elevated accordingly, and profiling of Chileans with Arab surnames, to rule out terrorist supporters, could become standard operating practice.

Given the US position on Hamas, and the threat of sanctions for failure to act as a gatekeeper, on a real-time basis, compliance officers should become alert to any increase in anti-Israel activity originating in Chile, and to take steps to identify possible high-risk Chileans, who pose a greater risk that they will engage with Hamas, or are already doing do.

Examine these potential red flags:

(1) Was the individual born, according to his passport, in the Middle East ?
(2) Did he change his name ?
(3) Is his dress, and that of his wife or companion, consistent with that of a typical Latin American ?
(4) Is he fluent in Spanish, and does he use another language, when conversing with family members ?
(5) Is he engaged in international trade ?
(6) Does he have traditional Latin American physical features ?
(7) Does he show multiple trips to the Middle East in his passport ?


Lawrence Heath QC, the retired Canadian attorney who is suing Northland Wealth Management, Inc., to find out why the $13m, that was entrusted to Northland, as his advisers, is missing, is suffering from declining health, as the direct result of the extensive delays Northland has inserted in his pending civil suit against the company, according to sources close to the victim. The delays, which have been characterized as intentionally dilatory, and made in bad faith, have resulted in scant progress during the past six months, and some of the legal tactics definitely are borderline unethical.

The plaintiff's counsel, according to the victim, has been presented with a very large number of unexcused delays, in returning telephone calls, as well as correspondence, in making defense counsel available for conference calls, available for hearings, and for examination for discovery. Every dilatory effort to delay the progress of the case has been made, or attempted, to the extend that allegations of bad faith have a factual basis, in the history of the case.

For example, the defense has never filed a response to the Statement of Claim, filed six months ago, which is due, pursuant to the Rules of Civil Procedure, twenty days after service is effectuated. No Statement of Defense can be found as having ever been filed. Without a filed Defense, the plaintiff cannot respond and reply to the same, and also cannot create a written discovery plan.This is prima facie evidence of a deliberate intent to delay and hinder the proceedings.

There have been several months of repeated delays, all of which have adversely impacted the plaintiff's health, and he has suffered damages as the direct result thereof. So, in addition to being without his assets, his overall health has declined substantially, the proximate cause of which is the intentionally dilatory conduct of the defense, by Northland Wealth Management, Inc.

One wonders what the judge presiding over the case, at the Superior Court of Ontario, will say about this misconduct, when it is brought to his attention.


Compliance officers at New York City-area banks would do well to examine their client lists, for the Palestinian Return Centre PRC, a UK NGO that has had consultative status at the United Nations since 2015, has at least three known Hamas officials as directors. Banks that cater to United Nations members should be especially concerned, because the NGO has UN identification documents, due to its status there, and new accounts staff at such banks may consider them to be a low-risk, even quasi-diplomatic entity. Nothing could be further from the truth.

Hamas is a specially-designated global terrorist organization, under OFAC regulations, and its members are banned from any type of account relationship with any US entity or person. For the names of the specific individuals, and their sordid records as terrorists, see the white paper link at the end of this article*. Israel banned the Palestinian Return Centre, as a Hamas front organization, in 2010.

The entire premise of the PRC is flawed; Arabs who lived in the British Mandate of Palestine do not have any legally recognized "right to return" to the homes that they abandoned in 1948, on the advice of their leadership, which was allied with the six Arab countries who unsuccessfully attempted to wipe the newly-formed nation of Israel off the map, through a military invasion that failed.

The Balfour Declaration of 1917, which recognized the ancient right of the Jewish People to their ancestral home, reserved the rights of other residents, but did not give them national rights in what is now Israel, and in 1920, the UK spun off 77% of the Mandate for the Arab nation of Jordan. Palestinian efforts to force the UK to "apologize" for Balfour are historically inaccurate, and frankly, insulting.

To return to the present, NYC bankers are invited to review the linked document, to insure that they are neither  the PRC, nor its Hamas leaders.
*The Palestinian Return Centre


The legendary Cayman football fIgure, and ex-VP at FIFA, Jeffrey Webb has obtained a six-month delay in his sentencing in his American Federal criminal case. Should Caymanians be worried ?

Webb, whose May 2017 sentencing will be two years after he pled guilty in the massive FIFA corruption scandal, is most likely rendering Substantial Assistance to US law enforcement, which explains the delay, and his cooperation is not completed

Webb is probably either:

(1) Going to testify against former FIFA associates, at their trials, or
(2) Making new cases against others, which may not be FIFA-related.

Given that Webb, now under house arrest in a luxurious home he built in the US, with the proceeds of corruption, is also wanted in a Cayman Islands case, he may have evidence against his fellow Caymanians, which could result in their indictment, thus qualifying him for a probable shorter sentence in May. Most media don't like to discuss such matters, but they are part of the reality, when an individual is looking at 20 years on a money laundering charge in US District Court. Who will be next in the dock and in which country, the US or the Cayman Islands ?

Wednesday, November 30, 2016


The thrice-convicted fraudster, Okke Ornstein, now transferred to Panama's El Renacer prison, to begin serving a 40-month sentence, for two of those convictions, simply cannot stop defrauding victims. he has enlisted a number of associates, some of whom are also involved in his child pornography industry, to plead for monetary donations, ostensibly for upcoming legal fees. Ornstein has several pending criminal cases, one of which has been set for trial in December.

The problem is that a public defender has been appointed to represent him; any money donated by well-meaning individuals, taken in by his ficticious tale of "journalist" going to prison for writing articles, will be going right into the pockets of Ornstein and his confederates. Ornstein's co-conspirators have written a number of articles on the Internet, seeking financial support, though there is no factual basis for their stories; it's all an elaborate fabrication, designed to persuade readers to send in money.

Some of the additional white-collar charges that the Dutch fraudster skipped out on when he fled Latin America two years ago will now be heard in Panama's courts, and we trust that they will result in sufficient additional prison time to keep one of Panama City's most prolific criminals imprisoned for this decade, and the next.

Ornstein has civil judgments on file against him, for $5m and $1m, respectively.