Monday, September 30, 2019
If you still had any illusions about Malta's Individual Investor Program, discard them. There is zero due diligence performed upon wealthy applicants. Take the case of the fugitive Russian billionaire Oligarch Boris Mints. He recently acquired Maltese citizenship, notwithstanding that he was at the time wanted in his native Russia for a €1.2bn bank fraud, that he was listed as an "Oligarch" close to Russian President Vladimir Putin, by the United States Treasury, and that he had fled Russia to evade arrest.
There are reports that the Central Bank of Russia has gone to the UK High Court to freeze €500m of his assets in the United Kingdom, and the latrst rumor is that he has since fled to Israel.
Please tell me how, by any stretch of the compliance process, he was deemed acceptable for a Maltese passport, under its IIP program; perhaps it was the reported €1.15m he paid for the passport, which allowed him entry into the EU. Malta's compliance program for IIP has become little more than a joke between Russian organized crime figures, and Iranian money launderers seeking to evade international sanctions.
No wonder the EU wants Malta to abandon the IIP; it has become a magnet for white collar transnational criminals seeking a safe harbor within the EU Schengen Zone, which is a guaranteed visa-free trip to holders of a Malta passport. Since Malta will not police its IIP, perhaps the European Union should take drastic steps to terminate it.
The widespread use of facial recognition technology for client identification, by compliance officers who realize that commercial-off-the-shelf databases of high-risk individuals are no longer effective tools for due diligence and customer identification purposes in the 21st century is encouraging, but an accompanying tool is mandatory, if a facial recognition search is to be effective: real-time access to a photographic database of images of high-risk individuals to locate and identify your target.
Too many facial recognition software providers, some new to the compliance industry as well as the technology, are marketing their products, without reference to explaining precisely where compliance officers will find those elusive images of their targets. Some point their clients to social media and social networking resources for a solution, or the Internet, but the quality, as well as intrinsic shortcomings of social media and Internet images, often result in a less than satisfactory result.
Images from other than photographic databases may result in reduced accuracy, due to factors affecting face recognition, such as facial expression, pose variation, partial occlusion, and the effect of illumination, among other factors not usually present in photographs taken in an official or professional capacity or setting, such as passports, drivers' licenses, government identity cards, visa photos, professional licenses and other official images.
Focusing your facial recognition software upon social media, as well as on casual photographs appearing on the Internet, will often return false positives, or simply no results at all. Online images, many of whom are casual and not formal and structured, are rarely of such quality that they will consistently identify your subject. Many observers who are critical of the effectiveness of facial recognition platforms are basing their conclusions on efforts that use what are really substandard images, in seeking to identify their targets.
Having ready access to a quality image database is the only solution that will repeatedly return satisfactory results. Insure that your facial recognition technology provider has that feature available to make your choice an effective one. Do not accept assurances that open-source images freely available will do the job; they will fail to deliver the results you require.
Sunday, September 29, 2019
Legal observers, who were eagerly anticipating the sentencing of convicted FIFA Vice President Jeffrey Webb recently, are still trying to figure out what on earth is going on with his case. Webb's attorneys reportedly were able to secure a highly unusual tenth postponement of his sentencing date, in this case, all the way to March 2020, but there was no press release or other indication as to why he is allowed to evade sentencing for five years. What's wrong with this picture ?
Webb entered a guilty plea way back in 2015, and he has been living in the United States, with his American wife, in a house bought with the proceeds of crime, under House Arrest (Home Detentio) since that time. Obviously, the early delays in his sentencing were requested by the US Attorneys handling his case, to allow him to provide what is known as Substantial Assistance, meaning he be available and prepared to testify at any trials of other corrupt FIFA officials, or those who bribed them for monetary gain, Now, however, the FIFA case appears to be over, and unless there is a pending investigation, so many years later, that will survive a Statute of Limitations defense, what's left to do ?
Is Webb the beneficiary of some sort of backroom sweetheart plea arrangement that his attorneys were able to wrangle out of government prosecutors, which, if made public, will embarrass them ? The public wants to see justice done, and justice delayed is justice denied. Additionally, down in his native Cayman Islands, where Webb faces not just one, but two serious criminal cases unrelated to the FIFA bribery scandal, Caymanian prosecutors are anxious to obtain convictions against him. Unfortunately, so long as his US case is pending, he is not going to face the music at home.
There are concerns that deserve public attention:
(1) Do prosecutors have an unrealistic expectation that Webb will still deliver evidence against a yet uncharged big fish in the FIFA case ? Sentence the defendant, let him commence his prison time, and give him a Rule 35 sentence reduction down the road; don't give him a long-term pass on starting his sentence. This man facilitated a culture of corruption that cost the world's football (soccer) fans more money to attend World Cup events, due to the obscene bribes and kickbacks paid to senior FIFA staff, which payments were factored into ticket prices, the cost of official souvenirs, and other hidden costs.
(2) Given the fact that all the details of favorable Federal plea deal are often quietly kept from the public and journalists, who must ferret them out from court records, is there something important here that needs to see the light of day ? For example, though Federal case law generally excludes Home Detention from credit towards jail-time, but what if there is such an understanding with Webb's attorneys ? By the time Webb is actually sentenced, he will have have six years of house arrest. Will he simply be sentenced to "Time Served," meaning crediting his house arrest time towards a lenient sentence, and evade any Federal prison time?
Federal prosecutors often obtain long prison sentences for offenders, and then quietly ask the Court to reduce that sentence later, after Substantial Assistance is rendered, but there is no press release notifying the public of this event. Does Jeffrey Webb have some sort of deal that the public might not appreciate, given the severity of the corruption charges against him ?
Posted by Kenneth Rijock at Sunday, September 29, 2019
Saturday, September 28, 2019
MONEYVAL RAPPORT ANNUEL: LES RISQUES ACCRUS DE BLANCHIMENT DE CAPITAUX ET DE FINANCEMENT DUE TERRORISME REQUIERENT UNE ACTION RAPIDE
Rapport annuel pour 2018, publié aujourd'hui, 25.09.2019.
US THREATS TO SANCTION MORE HEZBOLLAH FINANCIERS DRIVE LEBANESE TO STORE BILLIONS OF US DOLLARS UNDER THEIR MATRESSES
Fearing that US sanctions will be imposed upon more banks in Lebanon for providing financial services for Hezbollah, in the aftermath of the JTB Bank scandal, many Lebanese have been drawing their money out of the banks, in US Dollars, causing the exchange value of the Lebanese Pound to decline around ten per cent against the Dollar. Additionally, a parallel market has emerged for trade at this unofficial exchange rate, which is troubling, though the Pound appears to be stable at this time.
Obviously, the currency of preference is not the Dollar, as a hedge against Pound value decline. One source claims that cash, especially foreign currency has become difficult to obtain in some locations, though government has denied it. Allegations that some of the cash is going to Syria, which is under major US and international sanctions, have been made.
Reports from Lebanon estimate that $2.5bn has been stored within the homes of Lebanese who are uneasy about the increased threats to their banks, due to the threats that more local banks will be sanctioned by OFAC for terrorist financing, forcing their closure or liquidation, due to the inability of sanctioned entities to access the US banking system.
Hezbollah agents in particular were ordered to obtain cash from their banks, leaving us to conclude that Jammal Trust Bank SARL was not the only Beirut-based financial institution servicing Hezbollah, so expect further OFAC actions against Lebanese banks, or foreign banks operating in the country.
There will also be sanctions against non-financial Lebanese targets, as an Assistant Secretary of the US Treasury visiting Lebanon recently warned that entities and individuals otherwise providing support to Hezbollah will also be sanctioned, which threatens Hezbollah's political allies, who are supporting the global terrorist organization in other, non-financial, ways. How far this expanded US Treasury policy will go is not known, but political parties allied with Hezbollah are definitely at risk.
In the high-tech world of international money laundering the crude method of bulk cash smuggling is looked upon as primitive, and generally too high-risk, but apparently a pilot living in New Jersey didn't get the message. Khamraj Lall, a Guyanese businessman and pilot who operated a jet charter service in Gainesvlle, Florida, using it as a cover for a cocaine and cash smuggling operation, has been sentenced to thirteen years in Federal Prison.
According to information released by the US Attorney, Lall smuggled in hundreds of kilograms of cocaine, from his native Guyana, into New York and New Jersey smurfed much of the criminal proceeds into US banks, and bulk cash smuggled the rest out of the country, into Guyana, where he built a $12m hangar with cash.
Lall, curiously enough, boldly or recklessly, depending upon your perspective, made 1287 cash deposits, all under the ten thousand dollar reporting requirement, totalling over $7.5m, into more than 20 bank accounts. Much of that cash was in twenty dollar bills, a definite red flag for compliance officers, indicating it was constituted the possible proceeds from street-level drug sales, even if he was operating cash-intensive legitimate business to cover those deposits, as legitimate bulk cash deposits generally come in a variety of denominations, not just twenties.
In another obvious tactical error, one of many, he stopped for refueling in Puerto Rico, on an outbound flight, where law enforcement confiscated $620,000 on his aircraft. That aircraft was subject to a forfeiture case in US District Court there.
In addition to the prison time, the defendant received five years of Supervised Release, and a judgment in the amount of $9.3m . His two jet aircraft, two hangars, and numerous properties, were also forfeited to the United States. He was convicted of eight counts, including:
(1) Money Laundering.
(2) Structuring Monetary Instruments.
(3) Conspiracy to Distribute Cocaine.
(4) Conspiracy to Commit Money Laundering.
Given the seriousness of the charges, and amount of money laundered, the 13-year sentence should be considered to be light, as it is a fraction of the maximum amount allowed by law. The fact that a year elapsed between the jury verdict of guilty, and his sentencing, raises the possibility that the defendant has been cooperating with law enforcement. He did have a very experienced, and competent, attorney representing him and he was not charged with any counts indicating that he was a part of the wholesale distribution of the drugs. Did he give up his customers ? We cannot say.
|Entrance to defendant's privste hangar in Guyana.|
In the 21-century, where trade-based money laundering, international product diversion, the artful use of Citizenship by Investment passports and customs-immune bogus diplomatic passports, life settlements, and many, many other effective weapons in the laundryman's toolbox, it is a wonder that Mr. Lall was able to run his operation for a three a a half year period, without being shut down earlier. He may have thought his relationship with the President of Guyana immunized him to some degree, but in the end his American errors were his downfall.
Friday, September 27, 2019
Yesterday's announcement from Treasury, involving OFAC sanctions now placed against companies, individuals, and even the oil tankers involved, that supply fighter jet fuel to the Russian Air Force in Syria, could indicate that the United States is committed to punitive sanctions, directly intended to interfere with Russia's pro-regime policies in Syria. Whether this is merely the tip of the iceberg we cannot say, but the timing is peculiar . The President of the United States may be favoring Russia in his actions abroad, but these new, blunt sanctions imposed against it demonstrate that, when it comes to career government officials, they intend to put Russia's feet to the fire for its dangerous foreign policies.
Thursday, September 26, 2019
CBI CONSULTANCIES CONTINUE TO FLOOD THE INTERNET WITH DISINFORMATION ABOUT THE VIRTUES OF CARIBBEAN PASSPORTS
If you type "citizenship by investment' into the search box on Google News, you get dozens of what i can only describe as 'Informercials' extolling the virtues of the CBI sales programs of the five East Caribbean states. The articles, many of which were published on websites reportedly paid for or sponsored by international CBI consultancies, or on sites of industry associations whose members are the same CBI consultancies, mislead the public by neglecting to detail, objectively, negative aspects that occur when one acquires a CBI passport issued by one of the East Caribbean states.
Unfortunately, most, of not all, applicants for CBI passports are deluded into accepting the legal opinions of so-called "legal experts, " individuals who are NOT admitted to the practice of law in the specific jurisdiction, but who mesmerize the applicants with their supposed expertise in the field of immigration. These advisors, who are salesmen earning a commission, and not professionals acting as attorneys for each applicant, persuade the applicants to act, without independent legal counsel of their choosing; Hence the problem.
Money laundering is not necessarily a safe occupation. Aivar Rehe, the former CEO of Danske Bank's money laundering Estonian branch, was found dead; suicide is a possibility. Rehe presided over an estimated €200bn in suspicious payments flowing through the small Baltic branch.
Rehe, who had previously given testimony to law enforcement, had not been identified as a target of the pending criminal investigation. He had been declared missing prior to the discovery of his body in a remote area.
A number of Danske Bank staff members are reportedly targets of the investigation.
Wednesday, September 25, 2019
Chen reportedly used the Dominica CBI passport to engage in flight to avoid prosecution, and left the United States, allegedly for China, where she had perpetrated her EB-5 US Visa fraud for over 100 foreign investors. She remains a fugitive from a 14-count indictment filed in the US District Court for the Northern District of California.
Until and unless Dominica cleans up its CBI mess, we recommend that the program be suspended, as it is supporting white collar crime, in the United States, in the countries of the European Union, and elsewhere. Compliance officers should conduct enhanced due diligence upon any and all Dominica passports presented for account opening in Canada and the United States. Candidly, it is suggested that no Dominica national, whose place of birth is shown to be outside Dominica, not be approved as a bank client, due to the dysfunctional nature of the applicants approval process for CBI passports.
Two Venezuelan nationals were arrested at Fort Lauderdale Executive Airport, when they attempted to smuggle in five million dollars in gold. Arriving on a private aircraft from Caracas, Customs was alerted when its agents noticed that rivets on the nose of the aircraft had been disturbed, and found the ingots inside the nose.
|Jean Carlos Sanchez Rojas and Victor Fossi Grieco|
Air Malta, the country's national carrier, has announced that it will expand to nonstop air routes into Canada and the United States in the near future. Plans to obtain an extended range version of the Airbus A321 have appeared in the media; that variant can fly nonstop between Malta and Toronto or New York without refueling. These new airline routes unfortunately could facilitate both money laundering as well as international sanctions evasion, and might increase the number of applications, by North American residents, for Malta's dodgy Immigrant Investor (CBI) Program.
Compliance officers in North America have the same standing concerns about Malta that the European Union has:
(1) Official corruption, verified by the "Panama Papers," and other leaks from offshore tax havens, exists in Malta, unchecked by local law enforcement.
(2) Money laundering, conducted through Maltese financial institutions, especially those formed by foreign interests (e.g. Pilatus Bank, Satabank) is an ongoing problem, and local regulatory agencies are ineffective in AML/CFT. Iran and Russian organized crime have access into, and also through, Malta's banks and non-bank financial institutions.
(3) The Immigration Investor Program, which has routinely approved applicants from high-risk countries, has allowed white collar criminals, terrorist financiers, and a broad range of definitely undesirable categories of applicants to obtain Maltese passports, which allow visa-free entry to the Schengen Zone.
Compliance officers should alert their front line teller and new accounts staff when the Malta nonstop flights to North America are operational, lest they unwittingly accept a new account, holding a Maltese CBI passport, seeking to move criminal proceeds into the United States or Canada.
Tuesday, September 24, 2019
A new Executive Order issued last week by the White House expands counter-terrorism powers at Treasury and State. While other events have focused attention upon specific global terrorist groups, these new powers should be closely examined by the compliance community, and anyone with counter-terrorism responsibilities.
In essence, the changes:
(1) The State Department now has the explicit authority to designate "'leaders of an entity, " and the Secretary can designate individuals who have "participated in training to commit acts of terrorism."
(2) Treasury and State now have the ability to take action against bankers and account managers who permit, or suffer, their services to be utilized by terrorist organizations. This action could include a loss of access to the US Dollar if they provide correspondent banking services to terrorists.
Readers are urged to review the complete text of the Order here:
Executive Order on Modernizing Sanctions to Combat Terrorism
Attorneys for Meng Wanzhou, the CFO and deputy chairwoman of Chinese telecom Huawei, who is fighting extradition to the United States from Canada, are scheduled this week to be heard in their Motion to Stay the proceedings, using a familiar dilatory tactic; delay and hope that other events intervene to save their client from being transferred to the United States, where her conviction on bank fraud charges is a likely outcome, given the facts that have been disclosed to date.
Counsel for Meng are asserting that the extensive, pre-arrest interrogation that she was subject to by Canadian authorities raise a number of serious issues, and the Court needs additional time to resolve them. Given that extradition proceedings generally involve confirmation that the party sought in the extradition documents is one and the same as the party under arrest, attorneys are often quite inventive in creating issues to delay the matter, and that appears to be the case in the Meng matter.
Meng is scheduled to have a final extradition hearing in January, 2020. She faces bank fraud, wire fraud, and related conspiracy charges, in the United States. While Huawei is a private corporation, it is believed to be acting in concert with the political, diplomatic and intelligence aims of the Peoples' Republic of China. Meng's eight known passports included one issued only to individuals acting on behalf of the government, meaning a passport indicating that the holder is an officer in the Chinese Government.
One aspect of the American case deals with Huawei fronting for a subsidiary that was scheduled to sell goods to Iran, which is barred by US & EU sanctions, and using the American financial structure to move payments for Huawei products sold to the Islamic Republic.
Monday, September 23, 2019
If you saw the recent story, about a journalist whose tough questions posed to the leader of Grenada were shouted down by the government's press representative, and the resulting outcry from the press association,, you have seen the tip of the iceberg, regarding the status of press freedom in the Caribbean. Experienced compliance officers, when conducting enhanced due diligence investigations, know to ignore much of what appears in local media in the Caribbean, due to the restrictions journalists face daily in the region.
They also know the reasons why the local coverage is generally not to be relied upon. Media in many of the East Caribbean states are afraid to publish information critical of elected leaders, for these reasons:
(1) Local Caribbean media relies upon government advertising to cover its overhead. Stories critical of elected officials, and their policies, could result in the abrupt loss of that needed income. Therefore, many Caribbean newspapers avoid controversy, for their financial survival.
(2) Many local media in the Caribbean are owned or controlled by either pro-government elements, or businesses, such as Citizenship by Investment consultants, who skew the truth, and slant coverage to prop up their own financial interests. When a known corrupt jurisdiction, with a history of drug money laundering, is presented as a trouble-free island paradise, or user-friendly business environment, all negative information has been artfully suppressed, and the truth concealed from the reader.
(3) The threat of defamation lawsuits, filed by powerful pro-government attorneys, against investigative journalists, is a clear and present danger known to Caribbean journalists, especially those exposing official corruption.
(4) Physical danger, including death threats, is no stranger to crusading Caribbean reporters, and for that reason, many shy away from controversial topics, and file bland, pro-government pap daily. Self-censorship is often the order of the day.
Compliance officers should therefore carefully check out the political background of any Caribbean media outlet, before relying upon the facts presented in an article, for known transnational white collar criminals often are often allied with local government officials, leaving the reader with the mistaken impression that the subject is legitimate, when this is far from the truth. With Caribbean media, truth often takes a holiday.
Sunday, September 22, 2019
The United States is seeking extradition of a North Korean businessman living in Malaysia, to face what is reported as six counts of money laundering. Mun Chol Myong was detained in May, and his extradition approved, but his attorneys, hired by the North Korean Embassy, have opposed his removal, claiming his case is purely political in nature.
Mun has allegedly been shipping luxury goods to the DPRK, from Singapore, via China. The US asserts that he is the leader of an international organized criminal group involved in laundering the proceeds of bank fraud. He has denied the charges.
If Mun is sent to the US, it would be the first case where a North Korean national extradited to America on money laundering charges. He is appealing a decision to deny him bail, which will be heard in October.
Saturday, September 21, 2019
Due to the high level of reader interest in the US activities of Hezbollah agent Alex Saab a/k/a Alexsi Saab, we have published below those pages from the Indictment that detail the specific covert activities he conducted in America, and the places where he conducted surveillance for potential terrorist actions.
MOHAMMED ALI HAMMADEI, HEZBOLLAH HIJACKER OF TWA FLIGHT 847 IN 1985, ARRESTED IN GREECE; FBI MOST WANTED FUGITIVE
If you ever wondered why we often publish FBI Wanted posters on this blog, here's why. Greek authorities have announced the arrest of a Lebanese terrorist, identified by local media as Mohammed Ali Hammadei, the Hezbollah hijacker of Trans World Airlines Flight 847 in 1985. During the hijacking, an American US Navy diver, Robert Stethem, was murdered, after he was identified by his passport; after this incident, the State Department changed the way it issues passports to US servicemen.
Ali Hammadei has been on the FBI Most Wanted Terrorist List since 2001; the reward offered is up to five million dollars for information leading to his capture. He faces multiple terrorist charges in the United States.
Friday, September 20, 2019
Alex Saab, also known as Alexei Saab, a trained covert Hezbollah operative who entered America and later became a US citizen, was indicted in US District Court in New York on multiple terrorism charges. Saab fraudulently obtained American citizenship by failing to disclose his Hezbollah membership and terrorism weapons training, which included bomb making.
The defendant conducted surveillance operations upon many prominent targets in new York, Washington DC, and elsewhere, for potential future terrorist attacks. He was a member of the Islamic Jihad organization, Hezbollah's overseas operational arm, and allegedly attempted to murder an Israeli national in Turkey.
While a naturalized US citizen, Saab brought in a female Hezbollah agent, with whom he concluded a sham marriage, to allow her to enter the country and reside here. Saab, who is in custody, faces a potential 60 years in prison on the nine counts.
Posted by Kenneth Rijock at Friday, September 20, 2019
Thursday, September 19, 2019
Jammal Trust Bank, a/k/a/ JTB Bank, recently sanctioned by the OFAC, and reputed to be Hezbollah's bank of choice, has advised the Central Bank of Lebanon that it will close, and be liquidated forthwith. The new sanctions, which deny the bank total access to the American financial structure, operates as a bank death penalty, for it can no longer properly service its international clients.
The Central Bank reportedly has given its approval to the liquidation; it has publicly said that the bank's assets, and existing deposit guarantees, will be sufficient to repay all deposits. We have previously reported on the bank's off-the-book loans to Hezbollah, secured by gold.
Compliance officers please note that the bank has 25 offices and branches, located in Lebanon, Nigeria, the Ivory Coast and the UK. The African jurisdictions are all known for Hezbollah money laundering activity, as well as transit centers for its narcotics trafficking operation into Europe from Latin America.
Wednesday, September 18, 2019
If you are a compliance officer at an international bank whose clients trade with companies located in Spain, be advised that the Banco de España (Bank of Spain), the country's central bank, is promoting massive evasion of US sanctions by allowing firms trading with Venezuela to funnel their payments through its facilities. This means that, as UAE companies do for Iran with sanctions evasion support, the Government of Spain is doing for Venezuela, freely using its banking structure to allow Venezuela to conduct international trade around existing sanctions.
The Bank of Spain, where it has responded to the charges of sanctions evasion at all, has denied the allegations. Compliance officers in the United States should now secure from their banks' clients engaged in trade with companies located in Spain, sworn End User affidavits, attesting to the fact that Spain is the final destination for their clients' goods and services, and for payments as well. To do otherwise will expose your US bank to potential OFAC Civil Fines and Penalties down the road.
|BANK OF SPAIN|
Under the circumstances, you will probably also want to raise Country Risk for Spain, and conduct Enhanced Due Diligence upon the Spanish companies who your clients are trading with ? Are any of them owned or operated by Venezuelan nationals ?
Two Moroccan nationals, wanted in France on money laundering charges, were arrested when they arrived in Gibraltar from Tangier this week. Zakariaa El-Abdallaoui, and his wife, Chaimae El-Fahassi, were taken into custody, on the basis of a European Arrest Warrant.
The alleged launderers were arrested due to charges filed in Bordeaux, consisting of multiple money laundering and conspiracy counts. The wife is reportedly a resident of Gibraltar.
Tuesday, September 17, 2019
The fugitive Alex Nain Saab Morán, who is wanted by the United States and the Republic of Columbia, got some more bad news this week. OFAC sanctioned his brothers Amir Saab, and Luis Saab, and partner Alvaro Pulido's son David Rubio Gonzalez.
Additionally, all the companies these newly sanctioned family members operate were also sanctioned; located in Colombia, Panama and Italy, the companies can be found here.
Monday, September 16, 2019
BRITISH COLUMBIA SUPREME COURT ENTERS MAJOR JUDGMENT ADVERSE TO LAW ENFORCEMENT EFFORTS, RELEASES CAD$2m
The Supreme Court of British Columbia, dealing a major setback to BC law enforcement efforts against drug trafficking and money laundering, reversed an ex parte Interim Preservation Order (IPO) that resulted in a seizure of over CAD$2m, and other assets. The Judgment released the currency, upon the request of the claimants, who allegedly operated Silver International, an underground bank. Legal observers have commented that the adverse decision represents a loss to efforts to reign in rampant BC money laundering.
The court cited a number of issues that it relied upon in its decision, which might serve as a guide for what law enforcement would best NOT do:
(1) The duty to make full disclosure in the ex parte application for the IPO was not observed.
(2) A fair and complete legal basis for the seizure on an urgent basis was not provided to the Court.
(3) The law was misstated at one point in the application, in favor of the applicant.
(4) The attorney for the Civil Forfeiture Office made no efforts to brief the probable opposing position, and did not cite any opposing views.
Readers who wish to review the 36-page judgment can access the complete text here.
Monfared, as seen from these pictures, is appearing in open court in Tehran. Note the presence of news photographers. We wonder how this news is being treated in Dominica, where Monfared's high-profile business fraud, and his Dominica diplomatic passport, exploded when he was detained in the Dominican Republic, by Iranian agents, and transported to Iran, Via Havana and Moscow. Monfared's very public relationship with Dominica PM Roosevelt Skerrit remains a major embarrassment in Dominica.
The defendant most likely faces either life in prison or, like Zanjani, the death penalty, unless he surrenders the missing billions. Zarrab, who is cooperating with law enforcement or intelligence authorities in New York, may have already withdrawn some or all of the funds, in a settlement with the United States.