Kenneth Rijock

Kenneth Rijock

Sunday, August 19, 2018


Nidal Waked Hatum

Attorneys for convicted Panamanian money laundering kingpin, Nidal Waked Hatum, have requested, and received, substantial additional time to file their brief on his behalf, in the pending Government appeal of the denial of entry of a $20m forfeiture order against Waked. The trial judge, after sentencing Waked to a term of imprisonment, which he has already served and been returned to his native Panama, declined to enter a fortfeiture for reason that the Government has contended was reversible error. The Government has made a convincing case for reversal.

What is troubling about the delay is the fact that counsel for Waked is not a sole practitioner, but a member of a major criminal defense law firm, with a number of other lawyers also available to be   attorney of record, any one of whom  is competent to write a brief. The longer a final decision on the appeal is delayed, the easier it is for Waked, shown to be one of Panana's most experienced money launderers, to move assets, and therefore to insure that the United States will never be able to recover on a forfeiture order, when it is eventually entered. 


St. Johns, Antigua

During my misspent youth as a money launderer, in the "Miami Vice" era of the 1980s, the US Government alleged that I had spent a couple of weeks operating from a Caribbean tax haven. It reached that conclusion based upon the fact that there was no evidence to show that I had exited that jurisdiction. In truth and in fact, investigators had simply failed to find the arrival/departure card that i had surrendered when it left,

What if law enforcement investigators were then able to track and trace my movements there, in and out of a dodgy attorney's offices, and into an offshore bank, with narcotrafficking clients in tow ? That may sound like science fiction, but due to the unique advantages offered by facial recognition software platforms, it is now within the ability of  law enforcement agencies, should they choose to avail themselves of its features.

To understand how this is a real possibility, we need first to be aware of the expanding global nature of the rapidly expanding use of CCTV, for the purposes of tactical crime suppression. You may not know that the coverage is no longer limited to Central London, which you certainly have seen up close when visiting, but it is now widespread:

George Town, Grand Cayman
(1) Caribbean tax havens, faced with an unwanted increase in street crime, have vastly increased the number of CCTV cameras in downtown urban areas. These also happen to be the locations of offshore banking facilities, attorneys' offices, and the financial services firms who form shell companies.

(2) The Peoples' Republic of China has the largest closed circuit monitoring system in the world, with over 170 million cameras; it is slated to expand to 400 million by 2020, and its system paid CCTV with an advanced facial recognition software platform that was able to locate a BBC reporter in seven minutes, in a test of its capabilities.

(3) China, as well as other countries, including the UK, Germany and several manufacturing centers in the European Union, are exporting vast number of surveillance systems to governments in the Middle East, Asia, and Latin America. The result will eventually be a global network of CCTV  footage potentially available to law enforcement agencies looking for specific money launderers and financial criminals.

Basseterre, St. Kitts

Will the US Drug Enforcement Administration (DEA) soon be tracking the movements of a known money launderer, as he traverses the downtown area of a tax haven jurisdiction's capital city, in and out of offices, on a particular day, to prove that he was engaged in bulk cash smuggling ? What about the FBI, actually following a Ponzi schemer down the street of an offshore financial center, in real-time ?  These are not sheer fantasies, but the artful use of facial recognition software programs to conduct successful money laundering investigations. It could vastly improve the ability of law enforcement to track and trace criminal activities abroad.

Saturday, August 18, 2018


Rather than relying upon the minimal details regarding the lies that Trump foreign policy advisor George Papadopoulos told the Federal Bureau of Investigation, readers should review the complete facts that are only available in the ten page Government's Sentencing Memorandum. You may access it here.


The Government of India is relying upon the United Nations Convention against Corruption to compel Antigua & Barbuda to extradite the $2bn fugitive fraudster Mehul Choksi from Antigua, where he has been evading arrest, based upon a CBI passport he reportedly bought for $2.5m.  The UN treaty, of which India and Antigua are signatories, applies where the crimes charged are offenses in both countries. Choksi was the alleged mastermind of the billion dollar scam perpetrated against state-owned Punjab National Bank, and if India had a "Most Wanted" list, he would be the number one target.

Antigua's "Jabba the Hutt" Mehul Choksi
Antigua appears to be already sowing the seeds of delay; it is refusing to move forward with the extradition until the Public Prosecutor is back on duty, and he has curiously been allowed to take an extended holiday. Also, an attorney closely connected to the government, David Dorsett, is presently representing Choksi, and since he has denied that his client was involved in any criminal conduct, you can expect his representation to include diatory action. It is believed he will follow the decade-long pattern employed by lawyers for the fugitive former Antigua banking regulator, Leroy King, who faces a probable life sentence in the United States, in the Stanford International Bank billion dollar Ponzi scheme.

The Choksi case is the latest in a long line of scandals  involving Citizenship by Investment (CBI) passsports being sold by Antigua to fugitive career criminals, money launderers, international sanctions evaders, and corrupt foreign government officials, who run afowl of the law. Antiguans fear that their country's passport will eventually become unwelcome in Europe and North America, due to the increasing number of CBI passport holders who commit global offenses, and the continual failure of the country's government to approve only legitimate applicants.

Friday, August 17, 2018


With all the negative press surrounding  cases where financial criminals obtain a citizenship by Investment (CBI) passport from one of the East Caribbean states offering these economic citizenship programs, and then are accused of criminal acts, you would think that the remaining Caribbean jurisdictions might choose to avoid CBI altogether. Unfortunately, the lure of what looks like easy money is still attractive to their governments, due to budget shortfalls, dysfunctional economies, and the desire to attract the foreign capital that often accompanies economic passport applicants.

Over in the British Overseas Territory of Anguilla, the local government is ramping up what it refers to as a Residence by Investment, or RBI, program, whereby legal residence will be conferred upon individuals making a large financial investment there. Successful applicants will, after a time, become elibigle for British Overseas Territory Citizen (BOTC) passports, according to the press releases.

This is where a serious potential problem emerges. Holders of a BOTC passport, which you can see is similar to a British passport, enjoy visa-free entry into the United Kingdom; they may remain there for up to six months and even longer stays are permitted, assuming they can prove financial security. While Caribbean CBI passport holders have visa free access, due to the Commonweath of Nations membership their new nationalities possess, a BOTC passport holder will be regarded as British, and routinely admitted, CBI passport holders are recently subject to scrutiny. Which one would you prefer, if you were a money launderer needing assured access to the UK financial structure, without being questioned or searched ?

Now, on to the secondary concern: British Overseas Territory Citizens can apply for British passports; though it is not a routine matter, we imagine a top-flight UK immigration attorney, suitably retained, can succeed for clients sufficiently motivated to obtain one.The holder of a British passport is usually waved through upon arrived in the UK, and that document is priceless in the hands of a financial criminal moving money on a global scale.

Therefore, Anguilla's seemingly innocuous Residence by Investment program could spawn a group of BOTC passport holders, with free and easy UK access, some of whom might actually seek to upgrade to a British passport, but even if they don't they have achieved their goal of the ability to enter the United Kingdom, for the purpose of committing financial crimes, terrorist financing, laundering of the proceeds of corruption, and facilitating international sanctions evasion.

BOTC passports from the Caribbean

We trust that Anguilla's leaders will read this article, and govern themselves accordingly. No RBI applicants can graduate to BOTC status, nor be issued any passports; give the applicants solely legal residence, without granting any passports to them, to prevent their possible criminal misuse.


The large number of financial crimes being committed globally by Citizenship by Investment (CBI) passports holders, and foreign nationals who have bought diplomatic passports sold by the five CBI East Caribbean states, have now caused real problems for bona fide Caribbean nationals arriving in the United Kingdom, who have nothing to do with the criminal activities of others.

West Indians are reporting that their luggage is receiving special scrutiny from the UK Border Agency, and they are being questioned extensively, under circumstances some are calling interrogations, about their visit, as well as their background, and planned activities in the UK and elsewhere. UK sources are reporting that the reason is the well-founded fear, on the part of UK authorities,that undesireable foreign nationals are accessing visa-free entry into the UK through CBI passports issued by Commonwealth of Nations states.

Additionally, UK sources have confirmed that the Border Agency is not accepting ANY Caribbean diplomatic passports at face value, unless and until the "diplomat" is duly qualified as an accredited  envoy or emissary to the UK. This means previously accepted by the UK Foreign Office, which rules out all those "pay-for-play" bogus diplomats buying their credentials in the East Caribbean. We have previously detailed specific cases where accused financial criminals have attempted to evade arrest in the UK by brandishing diplomatic passports issued by the five CBI East Caribbean states; in every instance, British law enforcement agencies have refused to accord diplomatic status to the holders.

What we are seeing is an appropriate law enforcement response to the many threats posed by the individuals who seek the protection, and privileges, of CBI and diplomatic passports, for illicit purposes, The UK doesn't want them coing for a visit and committing crimes while there. No wonder they are giving the third-degree to arriving Caribbean nationals. So long as the East Caribbean states continue tosell their passports to career criminals, sanctions and tax evaders, and corrupt Politically Exposed Persons (PEPs), you can expect the UK Border Agency to look very closely at every arrival from the region.  

Thursday, August 16, 2018


If you are the director of compliance at a financial institution, your organization may very well have to face one or more of the following circumstances:

(1) Your bank has become the subject of a regulatory action, which happened as the direct result of non-compliance wirh specific BSA/AML regulations.

(2) Your bank is undergoing a regulatory examination, or recently completed an examination.

(3) There is regulatory activity that indicates a heightened focus on a specific group of regulations in the industry.

(4) There have been a number of publicly-disclosed regulatory civil fines and penalties, which include mandatory look-backs and remediation.

Whether look-backs and remediation ordered by a regulatory authority, or initiated by your bank, in the light of ongoing industry or law enforcement developments, effective look-backs and remediation efforts, which review prior bank actions, for a specific extended period, are vital, as they will clean up your past compliance errors, and missed transactions.

To more effectively locate, and identify, prior issues, it is suggested that you avail yourself of facial recognition software, which can show you where your prior compliance efforts may have fallen short. You employ it to verify these customer identities:

(A) Run facial recognition software on your clients' government-issued photo identification documents on all new accounts opened during the look-back period.

(B) Run facial recognition software on all your clients who closed their accounts during the look-back period.

(C) Run the facial recognition software on all your clients that your investigation concludes may have had suspicious transactions.

The object is to absolutely confirm client identity, and to uncover, through the use of facial recognition software programs, those career criminals, OFAC SDNs, PEPs, and users of bogus passports whom your compliance staff failed to spot at account opening, or closing.

The identification of these criminal elements will show regulators that you are assessing the causes of your prior compliance breakdown, have analyzed the situation, and have positively identified your remediation approach, using improved technology, including but not limited to the use of facial recognition platforms, as part of Enhanced Due Diligence.

Although most compliance officers are familiar with the customary applications of facial recognition software, at account opening, to check counterparties, and to avoid sanctioned individuals, its use in look-backs illustrates that there are a large number of additional potential uses by compliance, which will result in a larger number of users, and eventually its universal deployment, as a required component of their Enhanced Due Diligence procedures.

Wednesday, August 15, 2018


Trump and Martinelli at the Trump Ocean Club
 While corruption prosecutors in the Republic of Panama joust with Ricardo Martinelli's criminal defense team, there's some nasty unfinished business back in Federal Court in Miami, where Martinelli's closed Habeus Corpus extradition case remains strangely unavailable to the press and public. What are they hiding ?

The Martinelli District Court case, which he filed to stop the enforcement of a Federal court order requiring his extradition, to face criminal chages in his native Panama, where he had served as perhaps the country's most corrupt president, was, from the beginning, not available to view. It was not done through a sealing order, but through a curious administrative act: someone at the District Court simply denied total access to the public, to the pleadings and documents on file.

Observers in Panama have long asuspected, ands have repeatedly alleged, that there are two embarrassing reasons why the United States doesn't want the press, and the public to see this information in Martinelli's petition. Exactly how Martinelli was able to enter the US, due to the rampant corruption allegations in Panama is also an open question. The allegations:

(1) Ex-President Ricardo Martinelli was a confidential informant for a US law enforcement agency, or an intelligence service, and he detailed that relationship in his petition, and in subsequent filings.

(2) Then private businessman Donald Trump, when visiting Panana City in support of the Trump Ocean Club Hotel and Resort, participated in certain "extra-curricular leisure activities" which Martinelli's national security agency had captured on video, and Martinelli disclosed this fact in the petition.

(3) Martinelli also holds recordings of actions taken by US Government agencies in Latin America that would severely damage American diplomatic relations with its regional allies.

Is the public being denied access to the court file, long after it is closed, to save embarrassment to President Trump and/or US Government agencies ? We cannot say, but there has never been any mainstream press coverage of the mere fact that the file has never been available. It makes you wonder what is in that file.


When looking for ways to achieve an effective Enhanced Due Diligence solution, regarding Ctizenship by Investment (CBI/CIP) programs, we must be mindful of the profiles of the applicants:

(1) If you are aware of the public statistics, released by the five East Caribbean CBI states, you know that one-half of the CBI passports issued by Antigua & Barbuda have been to applicants from China, and allmost one hundred per cent of the CBI passports issued by Grenada have gone to individuals from China.

(2) Many of the other successful applicants for CBI passports, whether they choose European or Caribbean jurisdictions, are from countries using non-Latin alphabets, such as the Middle East (Arabic and Farsi), and East Asia (Korean, Malaysian and Thai, to name a few).

(3) When transliterating applicant's names, from the non-Latin characters, into the English language equivalent, there are universally accepted translation norms to guide us. Therefore, any number of correct variations on an English language name are deemed acceptable, which is a recipe for disaster.

CBI applicants, most of whom come from countries of elevated risk, often include financial criminals, assorted other bad actors, fugitives from justice, and international  sanctions evaders. Others are PEPs, Politically Exposed Persons, who are artfully concealing their PEP status, whether because they are corrupt bribe or kickback recipients, or tax evaders at home, or are closely associated with one who is such. He may have even come to you with an alias, all properly documented by his government, but accomplished through corrupt payments for a bogus passport.

So, you end up with an individual being arbitrarily assigned what you hope and trust is the genuine English equivalnt to his original name, which may mean that his high-risk status is never discovered through normal data inquiries. How do we identify him ?

The answer is to employ a facial recognition software platform, which will cull through news photographs, passports, social media images, newspaper and magazine articles, CCTV footage and other sources, and extract from them your target's image, verifying his stated identity, or show him to be a completely different person altogether. Without facial recognition confirmation, the chances that the CBI jurisdiction has issued a passport, under a clean alias, to a career criminal, foreign intelligence agent, or other unsuitable party, is unfortunately good. Due to the elevated level of risk with CBI applications, it has become a necessary, and yes, even mandatory, element of their Enhanced Due Diligence efforts. Let us hope that the agencies operating these programs get the message, as facial recognition software is the only effective solution.

Tuesday, August 14, 2018


Industry reports confirm that the European Commissioner for Justice, Vera Jourová, has made a public announcement that the upcoming agency report on Citizenship by Investment (CBI) programs has been advanced several months. There are rumors that the new report will attempt to set down specific guidelines, for national security reasons, for CBI programs.

Nonprofits and industry advocacy groups are expected to present comprerhensive responses to any negative findings and conclusions, especially in the area of due diligence, which to most objective observers has been an intentional failure, allowing career criminals, terrorist financiers, international sanctions evaders, and other unacceptable risks to acquire CBI passports. Without Enhanced Due Diligence (EDD), unsuitable applicants will continue to acquire CBI passports, and use them to launder the proceeds of crime.

We hope that the Commissioner's recommendations result in the passage of regulations that will result in the actual imposition of EDD requirements on all CBI passports, whether they are issued in the European Union, or the Caribbean, and in the event that this is not strictly adhered to, visa-free entry will be terminated, and visa procedures will be strict.


Former Fort Lauderdale attorney/fraudster Scott Rothstein, who is currently in the Federal Witness Protection Program (WITSEC), and serving a fifty year sentence for  a billion dollar Ponzi scheme, simply refuses to face the fact that he will not be receiving a Rule 35(b) sentence reduction in his case. He has filed an appeal from the District Court's order granting the Government's motion to reduce his sentence, and to also deny him an evidentiary hearing on the matter.

You may remember that the Government asked that the pending, generic motion for reduction of Rothstein's sentence be withdrawn, on the grounds that he engaged in misconduct, in connection with his former wife's efforts to hide their jewelry from being used to reimburse victims of the Ponzi. Considering the Government's sole discretion, in considering whether to reduce a sentence, Rothstein's contract argument was weak at best, and now he is appealing what appears to have been a sound judicial decision, based upon the rule of law. Nevertheless, the appeal is proceeding.

While the Appellate Brief has not yet been filed a proposed draft, presented to the Court in connection with a request to file it late indicated these are the issues presented:

(1)  The Court erred when it rules that the Governmen's sole discretion to file a Rule 35 motion includes the discretion to withdraw it.

(2) The Plea Agreement does not give the Government the right to withdraw a previously-filed Rule 35.

(3) The Court erred when it refused to give the appellant an evidentiary hearing on the issues.

Rothstein's counsel has requested Oral Argument.

Monday, August 13, 2018


The Government has filed its brief in the the 11th Circuit appeal it brought after the trial judge declined to enter an Order of Forfeiture against convicted Panamanian money launderer Nidal Ahmed Waked Hatum. It claims that the Court committed reversible error, by refusing to order Sr. Waked to forfeit properrtty, or by failing to enter a forfeiture money judgment, even through he had laundered over $10m.

The issues presented on appeal:

(1) Criminal Forfeiture is mandatory pursuant to US law. The Court apparently considered that the statutory $520m sum would violate the 8th Amendment's Excessive Fines Clause.
(2) The fact that Waked no longer possessed the funds involved in the money laundering conspiracy does not preclude forfeiture judgment of an equivalent amount.
(3) a forfeiture amount for Waked's money laundering conspiracy cannot be reduced or eliminated merely because Waked had repaid the defrauded bank. (The banks sustsained no losses).
(4) The District Court's subsequent misinterpretation of language in the Plea Agreement to forego entry of a forfeiture order against Waked also is reversible error.

The brief detailed how Waked moved funds, through wire transfers, from Panama to Miami, and back to Panama, outward bound from International Commercial Bank of China (ICBC) to Ocean Bank of Miami, and return to ISBC. He gave bogus invoices to the banks in support of the criminal money laundering scheme, in an amount in excess of $10.4m, to draw on lines of credit.

At sentencing, the Government requested 51 months' imprisonment, but the Courrt only imposed a sentence of 27 months, noting that the banks had suffered no losses, and that Waked's role was not paramount. Legal observers have been puzzed about the length of the sentence, the fact that he was not obligated to testify against any other individuals, and the lack of a forfeiture judgment against an individual who is known to have been a major player in the Waked Money Laundering Organization.

The Waked MLO operated openly* for more than a decade in Panama, and Central America, reportedly cleaning narco-profits for Colombian and Mexican cartels. Waked has since served his short sentence and returned to Panama, through still personally sanctioned by OFAC. Why was a member of a prominent money laundering organization not sentenced to 20 years ? Justice does not appear to have been served in this case, as the punishment did not fit the crime.
* The authorities in the Republic of Panama had overwhelming evidence of money laundering in the Waked companies for at least eight years prior to Waked's arrest in Colombia on US charges,, but corrupt officials in government there protected him and his associates.


The District Judge in the DC case involving Russian-linked companies involved in the social media campaign to affect the 2016 Presidential Election, Concord Management & Consulting LLC, has refused to dismiss the charges, due to the alleged unauthorized appointment, (and therefore lack of authority) of the Special Counsel.

 Above are the first and last pages of the 41-page Memorandum Opinion.

Sunday, August 12, 2018


Although there has been no press coverage of the New York Federal case against Reza Zarrab since his Turkish banker, Mehmet Atilla, was convicted earlier this year, the investigation continues. The fact that Zarrab, months after he agreed to cooperate with prosecutors, has not yet been sentenced, speaks volumes about the extensive debriefings that he must be undergoing, and those are strictly for the purpose of obtaining indictments against others in the multi-billion dollar oil sanctions evasion conspiracy.

If you need an indicator of the zeal with which the Government continues to act in this case, look at this. Although it has not been reported, a search of the docket of the Second Circuit Court of Appeals reveals that The United States Attorney in the Southern District of New York has quietly appealed the 32-month sentence handed down against Zarrab's Turkish banker, Mehmet Atilla. Only if Atilla is facing a long prison term will be be more inclined to implicate others.

Whether Zarrab's information has resulted in additional indictments is not known, but there are a large number of sealed filings in the case, which can mean indictments of individuals out of the reach of the long arm of the US Justice Department, be they in Turkey, Iran, or elsewhere.

(A) The sanctions evasion syndicate, in which Zarrab was a principal player, has a number of members active oustide Iran.Who are the other members, and have they been indicted yet ?

(B) No further information has been made public exactly how the syndicate was able to accomplish its goals of covert sales, outside of the details appearing regarding Alireza Monfared, the Iranian holding a Dominica diplomatic passport, and working out of Labuan. Are there other counterfeit diplomats in the network, and what Diplomatic and CBI poassports are they employing to cover their operations ?

We will continue to look for signs of progress in the continuing investigation of the Iran Oil-for-Gold sanctions evasion scandal. 


Saturday, August 11, 2018


While corrupt Caribbean officials wonder whether they are next, details surrounding the Federal money laundering charges filed in New York, against Donville Inniss, a prominent former minister and ex-Member of Parliament in Barbados, in a bribery scandal involving a Bermuda-owned insurance company, remain a mystery.

Inniss was arrested in Florida, and posted a $50,000 bond in Federal Court in Tampa; the case is pending in the Eastern District of New York. The court file remains sealed to the public, which is a good indication that there are addditional named defendants outside the jurisdiction of the Court, meaning overseas, and the US Attorney in that district does not wish to alert them before they are in custody.

The fact that there will be additional parties defendant in the Inniss case will only serve in increase the fear of arrest for corruption among East Caribbean government officials with something to hide, meaning the acceptance of bribes or kickbacks, especially if they were careless about moving those criminal proceeds through the US financial system, which confers jurisdiction in the United States.


Have you ever seen the motion picture Groundhog Day ? In that film, actor Bill Murray is forced to repeat the same day's bad events, over and over again, ad nauseum. That is what is happening again in Antigua, where the government sees to it that that fugitives from foreign extradition requests never see the inside of a criminal courtroom, anywhere, so that Antiguan corruption is never publicly exposed abroad, or bad actors charge with crimes there.

In the United States, we are painfully aware of this sordid fact; for a decade, Antiguan courts, which follow the lead of their senior government officials, rather than the Rule of Law, have prevented the extradition of the country's former banking regulator, Leroy King. Mr. King artfully, and illegally, kept US regulators from the truth of Allen Stanford's billion dollar Ponzi scheme for years, and reportedly financially benefitted royally at the time, as did Antigua's power structure, from his actiions.

Fugitive Leroy King

When the US Department of Justice sought his extradition, the local court system began a campaign of engaging in extremely dilatory measures, all designed to keep King out of an American courtroom indefinitely. Many in Antigua have stated that, should he be extradited, and eventually cooperate with Stanford case prosecutors, he will implicate many of Antigua's present, and former government leaders, including members of the Bird family, Bird's alleged fixer, Asot Michael, and current Prime Minister Gaston Browne.

Disgraced former minister Asot Michael

 The legal tactics, which are obviously intended to interpose delay, include these dodgy tricks:

(1) The Court repeatedly changes the judge or judges assigned to the case. Each time, the newly-appointed member of the judiciary claims that he or she needs sufficient time to "review" a routine extradition request, adding six months to year to the already lengthy time frame.

(2) The Court assigns judges from other countries in the East Caribbean to hear the multiple, and meritless, appeals, filed by King's legal team, who allegedly have their own schedules and workload, which also extends the time they require to respond.

(3) The sitting judges grant King repeated, and legally improper, appeals and further proceedings, long after two court rulings have ordered his extradition to the United States. Many of his legal arguments to the local courts, and appellate courts, are totally bogus, but they are not dismissed out of hand by the cooperating members of the judiciary.

(4) The defense brings in prominent additional local, as well as regional, attorneys, who have immense influence upon the local judiciary. They file Constitutional motions and briefs, endlessly challenging the right of the US to extradite King; still more delays ensue.

Asot Michael and PM Gaston Browne
Most legal observers believe that King, who travels around Antigua with several bodyguards, to avoid being detained and removed to the United States by bounty hunters or US Marshals, will never be extradited. He has reportedly declined settlement offers from the United States.

Now, this legal nightmare is happening again, in a new case involving the fugitive Indian billionaire Mehul Choksi. India correctly fears that Antigua will delay his extradition, which is duly authorized from one Commonwealth country to another, while it enjoys the financial advantages of a free-spending financial criminal's immense pocketbook. Also, many Antiguans are concerned that the Choksi case will focus so much negative attention upon their country's rampant corruption, that foreign investment, which is in serious decline, will completely dry up.

Antigua has already planted the first intentional legal obstacle to Choksi's extradition. Governement sources have told local media that the Public Prosecutor, who overseas extradition rerquests, is conveniently on vacation for 30 days, and that the matter must be handled by him alone. Are there no other government attorneys on staff in Antigua, we wonder ? It seems to be legal Groundhog Day all over again in Antigua, where justice delayed and therefore denied is the only thing on the menu.

Friday, August 10, 2018


It's the Leroy King scandal all over again; a prominent fugitive from international justice,  India's most wanted financial fraudster, the billionaire Mehul Choksi, having obtained a CBI passport in Antigua, is openly living a lavish lifestyle there. He has been boasting that he is protected by senior officials in the Antiguan government, and is enjoying fine dining there, and all that Antigua has to offer. What happened to PM Gaston Browne's statement that Antigua extradites it foreign criminals ? Leroy King is proof positive that such statements are outright lies.

Informed sources within Antigua have confirmed that Choksi reportedly paid USD$2.5m for his CBI passport, which was obtained when anyone who searched the Internet would have learned of his involvement in criminal activities, as Indian media has repeatedly asserted. Also, India's principal law enforcement agency denied that INTERPOL had ever been contacted it about him, which conflicts with Antiguan assurances that it cleared him prior to the issuance of a passport. It is doubtful that Antigua's CIP Unit did any more than check for a Red Notice online, which constitutes compliance malpractice.

Fugitive Leroy King and convicted fraudster R Allen Stanford
Apparently, the Government of Antigua is betting that its unexplained delay in extraditing this master criminal will be ignored by both the United States and the EU, as his crimes occurred in Asia, but the US is reportedly looking into the matter. Sources in Antigua have also reported that Choksi moved some of his illicit wealth through Antigua, using locally formed companies; inasmuch as the American financial system probably had a role in the transference of funds, which invokes US jurisdiction for, among other things, money laundering. The Antiguan attorneys who formed those shell companies might want to consider engaging their own lawyers at this time, given the international attention given to the Choksi case.

Choksi has been a familiar figure in Antigua of late, but as he is currently unescorted, will he be detained, and removed to face justice in India ? We cannot say, but his fellow fugitive Leroy King, wanted in the US for a decade, in the Stanford International Bank scandal, has 24-hour bodyguards, protecting him from being taken to Texas, to face a Federal criminal trial. We wonder if Mr. Choksi believes the promises of protection, given to him by some officials in Antigua's leadership, are real.  

Thursday, August 9, 2018


There has been much made in the Caribbean of late about the alleged lack of interest, on the part of US law enforcement agencies, in the rampant corruption that occurs among many senior government officials that hold high public office in the East Caribbean states. Fortunately, there truly are pending investigations, and we recently have seen one emerge, when an Indictment was filed in US District Court in New York*. Inniss is a permanent resident of the US, living in Florida.

Donville Inniss, the former Minister of Industry, and Member of Parliament, in Barbados, was charged with Conspiracy to Commit Money Laundering, and Money Laundering. Inniss accepted bribes totalling $36,000 from a Bermuda-based insurance company, after which he approved a renewal of insurance contracts. The US nexus occurred when Inniss laundered the bribes through a third company in the State of New York, showing them as "consulting contracts."

Readers who wish to review the complete text of the Indictment may access it here. Go to the EDNY page on the link, and download the Indictment under "attachment."

The penalty for violations of the Barbados Prevention of Corruption Act is sadly only a misdemeanor, meaning less than one year of incarceration, but the Federal penalties for the three money laundering changes could result in decades of inprisonment in the United States for the former minister. Let's hope the East Caribbean politicians all get the message loud and clear.
* United States vs. Donville Inniss,  Case No. 18-cr-00134 (EDNY).

Sunday, August 5, 2018


The Chief Judge in the DC District Court filed a Memorandum Opinion, holding that  the appointment of the Special Counsel by the Deputy Attorney General, then as Acting AG, because the Attorney General had recused himself, was proper. The Court, in an extensive 92-page opinion, held that the DAG had statutory authority to appoint, direct and supervise Special Counsel, in the ongoing investigation of Russian interference in the 2016 Presidential Election.

Though a portion of the opinion was redacted, it appears that the issue was presented in connection with an unnamed Witness' Motion to Quash a Grand Jury Subpoena. Readers who wish to review the complete text of the Memorandum Opinion may access it here.


The publication of Europol's European Union Terrorism Situation and Trend Report 2018  has focused attention upon*, among other issues, the actions of Lebanese money launderers performing illicit services for European organized crime groups, and then using the income they derive from those activities to deliver financial support to Hezbollah, which is a Specially Designated Global Terorist (SDGT) organization in the US, and also sanctioned in the EU.

Readers who wish to review the complete text of the 70-page Report may access it here.
See Page 11.

Saturday, August 4, 2018


Immigration consultants, whose task it is to guide clients to succesful results in their applications for residency or citizenship, sometimes run into a legal obstacle that their clients do not anticipate; The client fails his final government due diligence investigation. When this happens, not only are the clients disappointed, but the immigration consultants, who have  worked diligently for months on their behalf, are usually not paid for their efforts.

To illustrate this point, in Canada, the application of thirty percent of all those who seek residency are declined, after the country's law enforcement and intelligence community perform a routine inquiry for criminal convictions, or other serious negative information on an applicant's record. The immigration consultants who assisted these clients lose a significant portion of their projected income as the result, and the clients are unhappy.

There is a method of reducing the number of failed applicants; immigration consultants and firms must have a competent compliance professional undertake an Enhanced Due Diligence (EDD) investigation, before an application is even prepared and filed, on all new clients. EDD checks consist of exhaustive inquiries, on a global basis, into the client's civil, criminal and business background; the result is a profile on a level that will insure that, if there is any negative information on an applicant which would bar him from residency, the immigration consultant learns of it in advance, and thus futile and costly unsuccessful applications are eliminated.

When EDD is performed on all prospective residency applicants, in advance, there are no rejected applications, and the immigration consultancy receives its fees on literally 100% of its clients'  applications.  Both the clients, as well as the immigration consultants, are happy, due to successful outcomes.

Readers who find themselves in need of Enhanced due Diligence  may wish to access this company's solution. Canada Immigration Experts (CIE), which has a fifteen year record of success for its clients, and a licensed member of the Immigration Consultants of Canads regulatory Council, has selected EDDI-IQ INC. for all its Enhanced Due Diligence investigations. EDDI-IQ, which uses  its proprietary Second Generation, cloud-based system,. incorporating facial recognition software, a negative news platform, and social media resources, resulting in a superior product. It is specially designed for immigration and citizenship applications. For further information:  or  .   

Friday, August 3, 2018


The Office of Foreigh Assets Control (OFAC) has named Russia's COMMERICAL BANK AGROSOYUZ as a Specially Designated National (SDN), for moving funds for a DPRK bank, and for two front companies acting for the North Korean Government.

The bank's address us Ulanskiy Pereulok, Number 13 Building 1, Moscow 101000, Russia.  SWIFT Codes are AGSZRU31 and 33. Readers who require more detail please see the Treasury press release below.

Thursday, August 2, 2018


Earlier this year, the news from the Commonwealth of Dominica was the announcement that it had appointed an ambassador to the Russian Federation, who would be resident in Moscow. Four months later, Dominicans are reporting that they are unable to find any embassy or diplomatic office in the Russian capital. Futhermore, Internet searches of Commonwealth Government websites have failed to find any address or telephone numbers for any diplomatic office. Where is Dominica's Embassy in Moscow ?

The individual who has been awarded the title of Resident Ambassador is the principal of a private company that offers Citizenship by Investment (CBI) passport products, with offices in several countries including Dominica, and the other East Caribbean states which sell economic citizenships. Diplomacy is, by definition, a full-time occupation, which precludes operating a commercial enterprise at the same time.

Furthermore, the Vienna Treaty on Diplomatic Relations, of which Dominica is a signatory, severely restricts commercial activities of diplomats where they derive financial benefits as a result of their status. Inasmuch as Dominica chooses to ignore its responsibilities under international law, perhaps the United Nations, which has already revoked Dominica's voting privileges, for non-payment of dues, might want to impose additional sanctions.   

Wednesday, August 1, 2018


Media reports from the Palestinian Territory of Gaza have confirmed that it is awash with counterfeit currency, including copies of the US one hundred dollar bill. Reliable sources have confirmed that Hamas, which governs the territory with an iron fist, and controls all cash movement, is placing the counterfeits into circulation.

While this information may not be unexpected, given the reputed financial needs of that Specially Designated Global Terrorist (SDGT) organization, the specific item reliable sources have identified as the type of counterfeit is the elusive Series 2006 one hundred dollar bill. The last, and arguably the best, in a long chain of North Korean-manufactured bogus US hundreds, and popularly known as the "Supernote," this Series has been in cold storage in the DPRK, China, and in the Republic of Korea (South Korea), but it is not known to have been in distribution. Just how did it end up in Gaza ?

The most logical conduit is Iran, which distributes funds, as well as weapons and explosives, to Hamas, but precisely how the valuable counterfeits were delivered to it, and in what quantity, is not known. The release of quantities of the Supernote into the global monetary system could cause serious damage to international faith in the Dollar, and both Hamas and Iran have made no secret of their dislike of the foreign policy of the United States. Are they seeking to damage international confidence in the Dollar ?