CBI ELIGIBILITY FOR IRANIAN NATIONALS IN DOMINICA AND GRENADA REMAINS A CLEAR AND PRESENT DANGER REGARDING SANCTIONS EXPOSURE BY GLOBAL BANKS

While the five East Caribbean states that offer Citizenship by Investment (CBI/CIP) passports openly trumpet the statement that their programs are not available to Iranian nationals, a little-known loophole does indeed exist that allows Iranians to apply for, and to receive, those prized CBI pasports in Dominica and Grenada. Unfortunately, this "exception" is broad enough to drive a truck through, should you be an Iranian intelligence agent assigned to engage in espionage overseas, or merely a career white-collar criminal running a government-approved sanctions evasion program, acquiring parts for Iran's illegal WMD and ballistic missile programs, or selling Iranian oil, in violation of US and international sanctions.

How can this be true, you ask ? Well, provided that Iranian nationals meet these requirements, Dominica and Grenada will take their CBI appications:

(1) The applicant must have resided outside the Islamic Republic of Iran, for an extended period, typically ten years.

(2) Have no "substantial assets" in Iran.

(3) Are not performing, nor have not performed, any business activities with Iran.

Taking them one at a time, any respectable intelligence agent, money launderer, or white-collar criminal worth his salt, can easily provide "evidence" on long-term residence outside Iran, simply deny that he has any assets within Iran (though the term 'substantial' appears open to abuse), or any business with Iran, then or now.

Given that the Financial Action Task Force (FATF) has recently named Iran to its Blacklist, a category previously only occupied by North Korea, the potential punishment that could, and will be, visited upon a bank in North America or within the European Union, or the UK, for allowing a "Caribbean national" with a CBI passport to provide financial assistance to illicit Iranian operations, is now increased. it may be that ANY Dominica or Grenada passport holder, not born there, nor an obvious West Indian due to race, accent & slang, must be denied access to any banking services.

Western banks that do not want to be made an example of by US law enforcement or regulatory agencies must now, regretfully, take sufficiently strong steps to ensure that no Iranian agents, armed with CBI passports, penetrate their Customer Identification defenses. To do any less will invite fines, civil penalties, and that all-important Reputation Damage, which drives customers to your competition. Take your Gatekeeper responsibilities seriously,

ARE YOU BANKING ANY OF THESE WANTED IRANIAN HACKERS ?

CONTROVERSIAL COMMONWEALTH SECRETARY-GENERAL PATRICIA SCOTLAND MAY NOT SERVE ANOTHER TERM

Scotland

UK attorney, Baroness Patricia Scotland of Asthal,  the beleaguered Secretary-General of the Commonwealth of Nations,whose term of office is now at an end, may lose her office, due to rampant allegations of conflict of interest, out-of-control spending, and other misconduct.  Several Commonwealth members have withheld funding to express their dissatisfaction with her professional conduct, and a candidate from Kenya has been mentioned as a qualified replacement.

Her dark role in the acquisition, in London of a Dominica diplomatic passport, by Nigeria's former Minister of Transportation, Diezani, Alison-Madueke, when Madueke was implicated in a multi-million theft from government funds, remains an unresolved issue currently under investigation. She allegedly instructed Dominica PM Roosevelt Skerrit to hand-deliver it to London; thereafter Madueke improperly attempted to assert diplomatic immunity when UK law enforcement officers sought to arrest her for corruption in Nigeria. It is not known who, if any, received direct or indirect illegal compensation for the sale of passport.

Alison-Madueke

Scotland, who was improperly nominated for the job from the Commonwealth of Dominica, although she left her native country at the age of two for the UK, defeated frontrunner, the diplomat Sir Ronald Sanders of Antigua, who was thought to be more qualified. After taking office, Scotland, her excessive spending habits, using official Commonwealth funds, especially for her residence, have been the subject of major UK media attention.

Additionally, the Secretary' General award of a lucrative £250,000 contract to a fellow Labour Party member alleged to be insolvent, without competitive bids, has drawn attention to Scotland's reputed mismanagement of her office.

PM Roosevelt Skerrit

Scotland's role, together with Skerrit, in the Madueke diplomatic passport scandal, focused global attention upon a covert program in Dominica, which issues diplomatic passports to foreign white-collar and career criminals, in violation of the Vienna Convention, adopted by the UN, without any oversight or control. 

ALI SADR HASHEMI NEJAD TRIAL SET FOR MARCH 2, 2020 AFTER MOTIONS RESOLVED

The Federal criminal case against the Iranian national who owned and operated Malta's dodgy Pilatus Bank, Ai Sadr Hashemi Nejad, has now been set by the Court to begin on March 2, 2020, A large number of defense Motions in Limine, seeking to stop the introduction of information that the defense asserted was prejudicial to their client, were recently denied. These motions required resolution prior to trial.

The Government is therefore free to introduce evidence and testimony that would appear to be seriously damaging to the defendant. The Court's rulings,entered on February 14, 2020, that were favorable to the Government:

(1) Statements of co-conspirators will be admissible.
(2) Most emails and attachments may come into evidence.
(3) Communications establishing Sadr's knowledge of US and international sanctions will be admitted.
(4) Evidence of purchase of a St Kitts citizenship will be admissible.
(5) Description of the housing project in Venezuela as "low-income."
(6) Evidence of  the revocation of an OFAC "U-Turn license."

"Shell" and "front company" may not be used in Opening Argument, nor references to the the Joint Comprehensive Plan of Action (JCPOA) regarding Iran. Sadr may offer evidence about the lack of risk of harm to the banks.

The Court has not yet ruled on whether it will admit testimony on whether the purchase of a St Kitts CBI citizenship "may be used to evade sanctions. " Heshemi Nejad, and others, allegedly used their SKN passports to conceal their nationality and citizenship abroad, and to acquire shell companies.

FRENCH "FAKE DEFENSE MINISTER" IMPERSONATION EMPLOYED TRADE-BASED MONEY LAUNDERING TO CLEAN PROCEEDS OF CRIMES

Gilbert Chikli, the career fraudster/leader of a French gang that defrauded wealthy individuals of a reported €73m, by impersonating the Minister of Defense, and asking for ransom money to free purported kidnap victims in Syria, used trade-based money laundering techniques to clean the criminal proceeds.

Chikli, who donned a mask, and sat in a room decorated to appear to be the Ministry of Defense office,  and claiming to be Minister Le Drian, contacted victims via Skype, asking for ransom money that, he declared, France could not be seen paying directly, appealing to the patriotism of the wealthy victims. Many of them bought into the story; more than €50 has not been recovered.

The case, which is currently on trial in Paris, with seven defendants, is of great public interest. we have reported upon the story in two prior articles. Compliance officers please note that Chikli, in an unguarded moment with a journalist, revealed how he launders the proceeds of his crimes: trade-based money laundering.

His technique:

(1) Send the proceeds of his fraud to China and/or Hong Kong.
(2) Purchase 20 tons of steel.
(3) Bribe the vendor to give him a receipt for 100 tons.
(4) Send funds corresponding to what profits on 100 tons of sales would be to Israel, together with the bogus receipt.
(5) The money is thereby laundered.

Chikli is not the only white collar criminal using China for trade-based money laundering; compliance officers would be well advised to closely examine any bank client who abruptly engages in large-scale international trade of goods with companies in China, as the transactions may be a front for trade-based money laundering.

Other fraudsters employ a variant known as Chinese Flying Money. The illustration below can be used to explain how it is employed. Compliance officers who encounter either of these techniques are urged to seek out competent financial crime advisers to assist them in deciphering the puzzle.

DANIEL ANDREAS SAN DIEGO - FBI MOST WANTED - DOMESTIC TERRORIST/BOMBER

GERMAN €100m CRYPTO CURRENCY FRAUDSTER HAS GRENADA CBI PASSPORT, PLANS TO EVADE JUSTICE THERE

Arthur Gehl

This is ARTHUR GEHL, Germany's €100m crypto currency fraudster, who promised his victims 250% return on their money. Gehl and his wife ROXANA are reportedly planning on leaving the European Union, and securing refuge from the law in Grenada, where the couple reportedly have obtained Grenada passports, secured through the Citizenship by Investment (CBI/CIP) program.

The CBI passports are said to be in the names of aliases, not the Gehl's true names. Given the legal obstacles which European (and American) law enforcement agencies have experienced, when seeking to extradite criminals who are East Caribbean CBI passport holders, the Grenada extradition process will be lengthy, and frustrating, as local attorneys, closely linked to Government, generally handle these types of cases, and delays that take years are not uncommon dilatory tactics.

Roxana Gehl

Will Gehl cheat justice by fleeing to Grenada, and hiding behind lengthy procedural delays ? We cannot say, but perhaps it would be best for his victims if he was arrested in Europe, rather than give him the opportunity to hide behind his Grenada passport. Otherwise, it may be years, if ever, before he sees the inside of German, or American, courtroom.