Kenneth Rijock

Kenneth Rijock

Tuesday, October 16, 2018


 Take a close look at the image on this Commonwealth of Dominica diplomatic passport. You should recognize the face; it is Alireza Monfared, the suspected Iranian intelligence agent who, with Reza Zarrab, and Babak Zanjani, ran the multi-billion dollar Iran oil-for-gold sanctions scheme. He is currently being held, indefinitely, in a Tehran prison, facing the death penalty, after Iranian agents took him into custody in the Caribbean, on corruption charges.

Why is the image a drawing, instead of a photograph ? You can clearly see that his Iranian passport, which contains a photo, betrays the fact that the drawing is a little bit off from a true life image.

Now look at his son's Dominica CBI passport; even he has a photograph.

For these reasons, we must assume that Dominica assisted Monfared in an attempt to make his passport confusing to facial recognition software programs. Perhaps someone should tell the individuals in Roseau, at the Citizenship by Investment Unit (CIU) that facial recognition software can identity, and has been used specifically for, identifying images that appears in painted portrtaits , through the application of facial recognition algorithms.

In fact, facial recognition software has been used, successfully, to identify unknown subject in some of the world's great paintings and portraits. Many paintings, over the course of time, pass through many hands, and in the case of some, the names of subjects, as well as minor figures, are lost. Facial recognition software is now employed to identify unknown faces in portrait art.

Lorenzo de Medici

The next time some bright soul in the East Caribbean CBI states thinks that he can outwit facial recognition software platforms, through portraits, and color drawings, of dodgy CBI passport holders, he might want to reconsider.

Lorenzo de Medici (posthumous portrait)


Attorneys for Mehmet Hakan Atilla, convicted of assisting Reza Zarrab's oil sanctions evasion syndicate in illegally selling Iranian oil, have filed their initial brief. The appellant received a 32-month sentence after his conviction.

Cousel for Atilla has framed these issues on appeal:

(1) The trial court erred when it instructed the jury that it could convict Atilla of violating the International Emergency Economic Powers Act (IEEPA) if it found that he conspired to evade ort avoid the imposition of secondary sanctions.

(2) The appellant should be entitled to a Judgment of Acquittal, because the Government presented no evidence that he know the alleged scheme would involve US banks.

(3) The defendant should be acquitted because of the Court's  interpretation of IEEPA sanctions regulations.

(4) The Court abused its discretion by precluding the defense from introducing recorded jailhouse conversations of Zarrab.

Most Federal criminal appeals statistically are affirmed, save obvious reversible error, as the courts generally do not wish to disturb a jury verdict, which in this case was unanimous.

As for Zarrab, he was seen by journalists staying in a downtown New York City hotel, under an alias, and not in law enforcement custody. This is extraordinary considering his previous guilty plea to criminal charges, which bring a possible life sentence. Given the strict nature of post-conviction policies, he may be cooperating with the intelligence services, who are more flexible in how they treat cooperating individuals.

 He is known to be assisting the Office of Special Prosecutor in its ongoing investigations, but whether his assistance involves Russian interference in the US 2016 Election, or some other issue, is not known. Zarrab is known to have shipped large sums to Russia, one of which was seized by Turkish authorities, in the possession of Zarrab's driver.

Monday, October 15, 2018


The first time that I attempted to purchase a ticket on the Heathrow Express, and learned that one cannot use a £50 note for that purpose, I realized that the fifty was not generally accepted in the UK for all purposes. Recently, government officials have decided against eliminating the fifty Pound note, in what I regard as a wise move, for such an action will not take a bite out of money laundering.

Yes, money launderers engaged in bulk cash smuggling, tax evaders, and those who engage in illicit business, use large denomination currency, but the £50, which is presently worth slightly less than $66, is not a favorite vehicle for that purpose. Frankly, it is too small a value. In Europe, the  €500 note is favored; outside the EU, it is the USD$100 bill that, due in part to its hard currency status, is preferred. In short, the removal of the fifty Pound note from circulation will not seriously suppress money laundering activities.

A relevant note; most international money laundering takes place using non-cash methods; wire transfers, trade-based money laundering, international product diversion, and real estate purchases and sales. Moving large amounts of value is simply too difficult a task, with elevated dangers of discovery and seizure. Laundrymen today choose methods that are lower risk than bulk cash smuggling. Therefore, we agree with the UK Government action, as the effect of eliminating a high value note would not effectively stop crime; it would just inconvenience consumers, forcing them to carry more notes, of lesser value, to transact legitimate business. 

Sunday, October 14, 2018


A Dutch businessman who was known to be a wealthy resident of Dominica, and who held a Dominica Citizenship by Investment (CBI) passport, has been returned to the Netherlands, where he is said to face major money laundering charges in Europe. He is the latest dodgy foreign national who obtained a CBI passport in Dominica to have been subsequently arrested on serious criminal charges abroad.

Ronald Pieter Nolen was taken into custody by Dutch law enforcement authorities in Sint Maarten, Netherlands Antilles, and transferred to the Netherlands, where he reportedly has been accused of being a major money launderer. Nolen, who lived in Dominica, by virtue of his CBI passport, maintained an affluent lifestyle there for several years. He was known for throwing lavish parties in his home, attended by members of the ruling Labour Party, including the Prime Minister, Roosevelt Skerrit.

Is this a photograph of Ronald Pieter Nolen ?

These upscale celebrations are said, by those familiar with them, to be just like those hosted by another CBI passport holder, Alireza Monfared, the Iranian national now in custody in his native country, on charges he, together with partners that included Reza Zarrab and Babak Zanjani, stole billions of dollars in illegal oil sales profits. The circumstances of Monfared's arrest, by Iranian law enforcement agents in the Dominican Republic, are strangely similar to those of Nolen, who also was close to Dominica's most senior government officials, until he was removed from the country, after pressure from foreign law enforcement.

Dominica PM Roosevelt Skerrit & Alireza Monfared at dinner
 Nolen reportedly imported into Dominica as least fifty automobiles, many of which were luxury Mercedes Benz vehicles, which he gave as gifts to a number of prominent Dominicans. Automobiles, especially high value premium vehicles, are a well-known method of money launderers, who are seeking to clean dirty money; Hezbollah, for example was engaged in a massive operation to purchase cars in North America, and transport them abroad, for that purpose.

Nolen owned two Dominica shell companies, and used Dominica nationals as front men, to pose as the individuals in control; these companies were engaged in import operations, but whether they were a part of any money laundering scheme is not known. In fact, no details of Nolen's criminal case are not publicly available, and they appear to have been concealed by Dominica government officials, who fear public response to yet another arrest of a CBI passport holder.

One source stated that the name appearing upon Nolen's CBI passport is not his legal name,* but since Dominica is not transparent about public disclosure of the names of CBI passport holders, we are unable to confirm this information.

An individual with the same exact name is listed as being involved with corporations in Switzerland and we are investigating a number of leads, regarding details of Nolen's alleged money laundering acitivities, which will appear here when the research is completed. We gratefully acknowledge the contributions of our Dominica sources in assisting with this article.
*Compliance officers have long known that neither East Caribbean CIP units, nor outside firms conducting due diligence, run applicant's photographs through facial recognition software programs, to confirm identities and legal names, and in truth and in fact, are complicit in allowing applicants to freely use aliases. There has never been a statement,  by any of the five East Caribbean states with CBI programs, that they employ facial recognition programs, notwithstanding the high-risk nature of most of the applicants, to confirm their identities.

Saturday, October 13, 2018


Prominent members of Panama's legal profession have stated that they have personal knowledge of the existence of an arrest warrant for Alex Saab Morán, the Colombian businessman wno is allegedly the source of kickbacks and bribes paid to many of Venezuela's senior government officials. The Government of Colombia this week arrested Saab's reputed accountant and auditor, and charged them with multiple felonies, including money laundering.

The Saab case has focused, once again, upon the sale for cash of bogus diplomatic pasports by corrupt East Caribbean officials to foreign nationals engaged in white collar crime, international sanctions evasion, narcotics trafficking, espionage, tax evasion and fraud. Saab has held a diplomatic passport from Antigua & Barbuda for several years, and the Antiguan government, rather than disavow him after the news about the arrests in Colombia leaked out, has chosen to ally itself with him, calling him the country's "Economic Envoy," though failing to disclose whether he ever performed any diplomatic duties on its behalf.

Will any of the officers at the Antiguan banks that work with Saab be charged with money laundering in the United States, due to the fact that the funds moved were largely US Dollars ? We cannot say, but we will be watching events unfold n the Saab case, and report bank on all developments as they occur. 


If you carefully read the $40m Consent Order issued by the New York State Department of Financial Services, against Dubai's Mashreqbank PSC, you know that a Compliance Consultant must now be engaged to perform, among other tasks, a Lookback for a six-month period in 2016. He or she must then submit a report on the Transaction Review to NYSDFS. The methodology for conducting the Transaction review must be submitted in advance, to the regulator, the the individual, who has been designated in the Consent Order as the "Lookback Consultant."

It is submitted since "The sole and exclusive objective of this review ... is to inform the Bank's remediation efforts by determining whether suspicious activity involving high risk customers, or transactions or transactions or possible money laundering at, by, and through the Branch, were properly identified and reported, in accordance with suspicious activity reporting regulations and  New York Law." Consent Order at 10-11, that the Lookback Consultant, to more effectively prove that proper reporting actions were taken, or alternatively to show that they did not occur, all the individuals whose accounts the Branch reported on SARs should have their identites verified using a facial recognition software (FRS) program. Additionally, any transactions that the consultant deems, after review, should have been the subject of a SAR, must include FRS checks on all individuals linked to those transactions.

The object of the use of an FRS program in a Lookback is to verify that the Bank properly identified their customer, counterparties, transferees, and any other party to high risk transactions that were reported on SARs. It also allows the consultant to verify identities, or aliases, in transactions that he or she considers unreported suspicious transactions, where the bank failed to catch it.

In essence, the use of FRS programs not only checks the accuracy of a bank's ability to conduct Customer Identification, it can also expose an operational money laundering network whose participants are employing clean aliases, so as not to give away their dodgy personal histories. They will either help clear a bank, or focus in on compliance failures. These results can only occur when an FRS program is employed. While some compliance officers may still consider them optional, the ability of an innovative financial criminal to achieve a new identity at will requires that you rule out such possible actions of bank customers.

 FRS programs be deployed whenever Enhanced Due Diligence procedures are necessary. One can no longer depend upon government-issued forms of identification to identify a client. In the Mashreqbank case, it may be the only thing that actually clears the bank's compliance staff; use FRS as often as you check a customer or client on commercial off-the-shelf databases, to avoid being  deceived by smart financial criminals. Let the Mashreqbank $40m fine speak for itself.


Friday, October 12, 2018


Our recent article,  Colombia arrests Accountant and Auditor of Alex Saab Morán, has generated an immediate reply from the Foreign Ministry of Antigua and Barbuda. Saab, who several investigative journalists, both in Venezuela and abroad, have accused of laundering the proceeds of corruption, for and on behalf of senior Venezuelan government officials, has never provided any proof that the transactions at issue were legitimate. Antigua claims that Saab has denied all allegations, but reports state that he is no longer in his native Colombia, and currently is living somewhere in Europe. We are therefore unable to verify whether the ministry was ever able to contact him, and assume that the denial it issued on his behalf was an unauthorized statement that purported to have come from Saab, but was merely a press release, attempting to place a spin on the arrests. There are close ties between senior Antigua government officials, and the corrupt Venezuelan officials Saab reportedly assists.

 The ministry, through a spokesman, stated to Carribean media that Mr. Saab, who holds a diplomatic passport from Antigua, is an "Economic Envoy." Our research has failed to find that he ever attended any economic conferences on behalf of Antigua, or assisted, in any way, in any economic matter involving Antigua. Saab has never presented his diplomatic credentials, and has never been appointed, as a working diplomat, to any state or jurisdiction. His title, which appears to be void under international law, allows him to circumvent customs inspection upon arrival at many international airports in the developing world.

Therefore, his diplomatic passport fails to comply with the requirements of the Vienna Convention, to which Antigua is bound, by virtue of its membership in the United Nations. Some legal observers are wondering why Antigua has not, of yet, revoked Saab's Antigua diplomatic passport, but cite the fact that he has an extensive relationship with at least two financial institutions in the country, as the reason he, and his business, are welcomed there. He is just the latest in a long line of dodgy individuals who come to the attention of the authorities for the wrong reasons, and who hold Antigua diplomatic passports.