Wednesday, October 28, 2026

CHECK OUT THESE RESOURCES AND LINKS TO DOMINICA'S EMERGING ALTERNATIVE INVESTMENT ECONOMY

If you read our most recent article on the Commonwealth of Dominica https://rijock.blogspot.com/2026/10/dominicas-alternative-national.html you may be looking for more details, as well as links, to the economic developments we described in that story. Below are a number of primary references to assist you in your journey of discovery.


                                              https://www.projectceti.org/dominica



https://www.worldbank.org/en/news/press-release/2024/01/26/world-bank-supports-clean-energy-generation-dominica



                                                https://www.oceansforward.org/






                                                    https://www.wilddominique.org/



                                     https://rezdm.org/projects/turtle-protection-program/




                                                 https://www.gems.dm/foundation/




















WITH AMERICA'S CIA, SOUTHCOM AND STATE DEPARTMENT ALL SEEKING REGIME CHANGE IN CUBA, ARE THE EASTERN CARIBBEAN STATES NEXT?

West Indians, who generally devote all their attention to local domestic and regional news and the accompanying bareknuckle corrupt politics which the Eastern Caribbean states are known for, most likely are not aware of the media reports detailing how the Central Intelligence Agency (CIA)is openly soliciting, in Spanish, insiders within the Cuban regime who wish to "break away from Communism."Instructions on how to contact the Agency without being discovered by Cuban authorities are being supplied to prospective cooperating individuals. Similar action has also been reported by SOUTHCOM, the U.S. military's Southern Command, which has its headquarters in Miami, and the U.S. State Department is currently engaged in a massive sanctions pressure campaign against several aspects of Cuba's economy.

 Clearly, the United States intends to foster regime change in the communist state, as part of what has been described as the Trump Corollary to the Monroe Doctrine, which seeks to remove all Chinese, Russian and Iranian influence from the Caribbean region. Individuals who reside in the Eastern Caribbean states whose Labour Party leaders in government have close political and economic relationships with Cuban and Chinese leaders should take note of these new developments, and expect that, so long as their governments continue to move their nations closer to China, through economic, social, cultural, political and even linguistic ties, they should expect the U.S. to take similar action to destabilize their hold onto power, and to result in governments more friendly and politically connected to Washington.  America has valid  Nationa' Security grounds to seek this endgame.

Whether there is already action behind the scenes to accomplish regime change in the five Eastern Caribbean states that are currently in the news, due to an existential threat to their Citizenship by Investment (CBI/CIP) programs by the European Union, all of whose pro-China governments have spurned closer ties with the US, we cannot confirm, but covert American influence in the region, including but not limited the deployment of resources from the American intelligence community, and providing material support to Opposition movements that publicize money laundering, fraud and official corruption, should be taken as a given. Antiguans and Saint Lucians should particularly  understand the geopolitical consequences of the actions of their national leaders.

Will the authoritarian left-leaning governments of the Eastern Caribbean be replaced through the efforts of an unhappy Uncle Sam, through the "Donroe Doctrine?" We cannot say, but we will be watching. 

Tuesday, October 27, 2026

WILL WE SEE FURTHER ARRESTS FOR CONTEMPT OF COURT IN THE NEVIS OFFSHORE BANK SCANDAL?

BONI's James Simpson

As we approach the twenty-ninth day of October, which was designated by the High Court in Nevis as the date payments are due on the 222-page Omnibus Judgment entered against HAMILTON RESERVE BANK (HRB) and the BANK OF NEW INNOVATION (BONI) on September 15, in the unfolding Nevis offshore banking scandal, legal observers are wondering aloud whether the current sitting Justice will see fit to find senior executives at either or both banks responsible for Contempt of Court for failure to obey the terms of the judgment, and have them detained and imprisoned.

The possibility has arisen because, last year JAMES SIMPSON, the acting CEO and Director of BONI was jailed for several days on the grounds of Contempt of Court. While the Court of Appeals later held to be error, on procedural due process grounds, not on the merits. The appellate court ruled that none of the required conditions precedent to arrest had been followed. This raises the question whether the High Court will choose to meticulously follow the law in any future similar action. Simpson has been making noise about filing suit for damages, but there are valid questions regarding Sovereign Immunity, blocking his ability to file such a suit.

Given that many of the senior figures of both banks reside outside Saint Kitts & Nevis, the individuals which most observers believe are responsible for the victims' losses cannot be detained, although the Justice did ask for a criminal investigation to be initiated, including parties who are abroad. Right now, we await the 9A.M. Atlantic Time 29/10 deadline, to see what action the Court takes to enforce its mandate.

Sunday, October 25, 2026

IMMINENT NOVEMBER 12 SUSPENSION OF CARIBBEAN CITIZENSHIP BY INVESTMENT PASSPORT SALES PROGRAMS, AFTER THE EU FORCES A DECISION IF EC STATES WANT TO KEEP THEIR PRESENT VISA-FREE STATUS


This week's announcement by Antigua Prime Minister GASTON BROWNE, that the ruling Labour government may suspend the country's CIP (Citizenship by Investment economic passport sales program) on November 12, 2026, in accordance with EU demands that it obey EU Regulation 2025/2441, is the first of what will most likely be five such public statements. Leaders of the Eastern Caribbean CBI states have apparently decided that the wrath of their native-born citizens, who would lose their prized visa-free status to visit the members of European Union, is too politically costly for them to continue to operate CBI programs.

It is noteworthy that Antigua, considered by the United States to be one of the worst offenders in the issuance of economic passports to known wanted economic criminals, sanctions evaders, citizens of terrorist states, and other sordid individuals who should never have received identity documents giving them visa-free entry into the EU, and the ability to apply for a visa for the United States, appears to be the first to recognize its dire situation, and submit to EU law, which states that without any direct residential, economic, social, and cultural connection to a country, one does not qualify as a bona fide citizen. We welcome the end of all five rogue Caribbean economic passport programs, which have become a financial crime nightmare for the world's financial institutions, law enforcement agencies and counter-terrorism authorities.

We do caution though, that a mere suspension, rather than a termination, of a passport sales program, still poses a threat:
(1)Caribbean Governments backdating CIP passports to previous years, and continuing to issue them, for cash, indefinitely, especially to purchasers who will never qualify for economic citizenships at any other CBI-issuing jurisdiction anywhere in the world. We know that Russian and Belarusian purchasers were routinely sold Caribbean CBI passports, covertly, even when prohibited by local law.
(2) Operating "black" passport sales sites, using existing blanks and equipment, after hours and in high-security locations, not government offices.
(3) Switching over to the extremely lucrative business of issuing diplomatic passports to individuals not qualified under the Vienna Convention, which has been done on a smaller scale by Antigua and Dominica for decades, but could now be ramped up to serve their CIP clients, making them bogus "diplomats."

Unless these CBI and CIP agencies are dismantled, and their unissued passports destroyed, bad actors, even those inside government, could abuse them in the future. Let's clean up these targets of opportunity for the world's smugglers and money launderers, for once and for all, and end SKN Ambassador Billy Herbert's dark concept.








Saturday, October 24, 2026

REPORT ON ALFA NERO SUBPOENAS IN SDFL §1782 CASE DUE NOVEMBER 9



If you are not following the developments in the §1782 Discovery case captioned " IN RE GASTON BROWNE CORRUPTION DISCOVERY APPLICATION," be advised that a Report to the Court on the status of the subpoenas it ordered served on PM Browne's South Florida resident son, and the marine companies involved in the Alfa Nero money laundering, fraud and corruption scandal are due "on or before November 9."

As there have been reports that Gaston Browne's son, who the PM named as the purchaser, in a cash transaction of expensive real estate in Florida far in excess of his reported income and assets, has been evading service of process, we are most anxious to learn which subpoenas has been served, and which remain outstanding. The Alfa Nero scandal, which remains as a stain upon Antigua's reputation in the international financial world, continues to be denied by Browne, in the face of overwhelming evidence of his alleged participation in the illegal diversion of millions of dollars from the bogus sale of the luxury yacht, in clear violation of international law and procedure. Whether any criminal indictments will result from the money laundering that occurred with the transfer of proceeds of crime is an open question Antiguans keep asking.

Thursday, October 22, 2026

DOMINICA'S ALTERNATIVE NATIONAL DEVELOPMENT MODEL


A close examination of the Commonwealth of Dominica reveals its natural capital as a productive national asset - its whales, reefs, forests, rivers, biodiversity and renewable energy. Science and technology linked to local capacity rather than imported as a spectacle. Entrepreneurs and communities as protagonists, not dependents of the State. External partnerships that strengthen standards, institutions and accountability. Conservation treated as an economic strategy and an intergenerational responsibility. Let's look at some of the noteworthy developments:

1. The Sperm Whale Reserve and Project CETI

Dominica has become a globally important centre for sperm-whale conservation and research. The Sperm Whale Reserve gives the country a genuinely distinctive conservation asset, while Project CETI brings together artificial intelligence, machine learning, robotics, linguistics and marine biology in an effort to understand sperm-whale communication. Just as important, CETI is developing local capacity through marine conservation fellowships and collaboration with Dominicans.

Why it matters: The larger story is how a unique natural asset can be connected to science, education, conservation and high-value tourism. Dominica is not merely protecting whales; it has the potential to become a global centre for marine science and ocean intelligence.

2. Geothermal Energy as a Governance Case Study

Dominica’s geothermal programme is significant not only because of renewable energy, but because much of its development has been financed and supervised through multilateral institutions, including the World Bank and other development partners. That framework brings prescribed procurement processes, environmental and social safeguards, reporting requirements and external scrutiny.

Why it matters: The useful comparison is not simply “geothermal versus CBI.” The deeper question is why the institutional discipline expected by multilateral partners should not become the normal standard for every major public project in Dominica, whatever the source of financing.

3. A New Generation of Dominican Entrepreneurs

Young businesses such as ShopDM, Bee Natural, Jaydee’s Naturals and Hey Mama demonstrate what an empowerment-based economy can look like. They are building brands, creating products, using technology, solving local problems, reaching new markets and taking entrepreneurial risk rather than waiting for state employment or political patronage.

Why it matters: The policy question is how Dominica creates thousands more businesses like these: easier access to finance, transparent procurement, better logistics, digital payments, export support, skills development and a business environment based on merit rather than connections.

4. Coral Restoration and Marine Conservation

Simon Walsh and the coral-restoration work associated with Oceans Forward and Nature Island Dive are examples of citizens using science and practical conservation to protect one of Dominica’s most valuable natural assets. Coral nurseries, disease response and reef-restoration work create a direct connection between environmental stewardship, scientific knowledge and the long-term viability of diving and marine tourism.

Why it matters: This is the “nature economy” in practice: protect the asset, develop local expertise, involve communities and create economic value without destroying what makes Dominica different.

5. Jeanelle Brisbane and Environmental Leadership

Jeanelle Brisbane and WildDominique represent a younger generation of environmental leadership focused on biodiversity, wildlife conservation, public education and community participation. Her work illustrates that environmental advocacy is not anti-development; it is about safeguarding the natural capital on which Dominica’s future development depends.

Why it matters: Dominica should be capable of becoming a country where environmental defenders, scientists, entrepreneurs and government institutions work together — rather than treating development and conservation as opposing forces.

6. DomSeTCO and Sea Turtle Conservation

The Dominica Sea Turtle Conservation Organization (DomSeTCO) is a strong grassroots example of citizens protecting nesting beaches, monitoring turtles, supporting research and educating communities. It shows the extraordinary amount of voluntary and community effort taking place outside the political spotlight.

Why it matters: The broader lesson is that Dominica already has people willing to protect the country’s natural inheritance. Public policy should empower and resource such stewardship rather than centralize every initiative through government.

7. GEMS Foundation: A Private-Sector-Led Non-Profit Model

The GEMS Foundation is a Dominican non-profit organization focused on environment, entrepreneurship, education, and arts and culture. Its significance is that it converts private-sector resources into structured programmes that build local capacity, rather than one-off charity. Operating through its own board, initiatives include the GEMS Entrepreneurship Challenge, which provides grants and mentorship to businesses in the hospitality and tourism supply chain; the GEMS Hospitality School and internship partnerships for practical skills training; the GEMS Artisan Market for local artists, artisans and performers; scholarships and graduation awards at Dominica State College; support for the Waitukubuli Artist Association and a permanent seed hub; and community-led environmental and eco-tourism projects. 

Why it matters: This is another example of civil society and the private sector investing in people rather than dependency. It shows how tourism can create wider development value when resources are deliberately circulated into entrepreneurship, skills, culture and environmental stewardship — and raises the question of how Dominica can encourage many more foundations, businesses and civic organisations to become active partners in national development.

















READ A RESTATEMENT OF THE FACTS IN THE ALFA NERO CASE; IGNORE THE PROPAGANDA IN THE CAPTIVE LOCAL ANTIGUAN MEDIA


Here is a factually accurate summary of the ALFA NERO scandal, taken from the latest court filing in the SDNY Discovery proceeding; kindly ignore all the inaccurate statements about the case, originating from the Government of Antigua, as it as repeatedly chosen to tell local media a flawed version of the truth. Prime Minister GASTON BROWNE has taken liberties with the facts; here is the unvarnished truth.






















Wednesday, October 21, 2026

GASTON BROWNE'S RECURRING DILEMMA: THE ALFA NERO CASES COMES BACK WITH A VENGEANCE


Antigua's beleaguered Prime Minister, GASTON BROWNE, reeling from the September resurgence of the ALFA NERO luxury super-yacht corruption fraud and money laundering scandal, has now been hit from the other U.S. District Court assigned to handle the Section 1782 Discovery requests. On October 19, Attorney Martin De Luca asked the SDNY court to authorize subpoenas for financial records as these three entities: The Clearing House Payments Company,  a/k/a CHIPS, the Federal Reserve Bank of New York and HSBC Bank USA. 

This is Browne's nightmare all over again; he is already facing subpoenas authorized to be issued against other entities and parties, by a Federal Judge in SDFL. He's getting hit from two sides at once, and who can say what these subpoenas will uncover? Whether the financial records ultimately produced in both cases result in the filing of criminal charges in the United States, as the funds claimed to have been illegally diverted were US Dollars, transiting the American financial system. Stay tuned, and things may soon get very ugly for any individuals found to be implicated in criminal activity in the United States.


 


Tuesday, October 20, 2026

ALVARO PULIDO-VARGAS PLEA HEARING SCHEDULED FOR NOVEMBER 4, 2026

The hearing where Alex Saab Moran's money laundering partner, ALVARO PULIDO-VARGAS will declare his plea to the multiple criminal charges pending against him has been set for November 4, 2026, in United States District Court in Miami (SDFL). Whether Pulido follows his associate into making a plea bargain with the Department of Justice, to avoid a potential sentence of Life Imprisonment without Parole is the question roiling all those who worked with Saab in Antigua, when he supervised a multi-bank money laundering operation for former Venezuelan President Nicolas Maduro's organization.

At the very least, Pulido can certainly count on the fact that Saab will be one of the primary witnesses against him, should he choose to go to trial, and there are several other Venezuelans already serving time in American prisons who would most likely be called to give incriminating evidence as well, and who could thereby reduce their own current money laundering sentences. The extent to which Pulido was directly involved in the Antigua phase of the racketeering enterprise is not publicly known, and will only surface in the event any of the bankers, financial service providers or government officials is indicted, and we are able to see a connection to his operation.

IN WAKE OF RECENT ARREST AND SWIFT EXTRADITION OF KEY PLAYER IN ALEX SAAB MORAN'S VENEZUELA-THROUGH-ANTIGUA MONEY LAUNDERING OPERATION, VENEZOLANOS AND ANTIGUANS INVOLVED WONDER WHO WILL BE NEXT

The threat of the as yet unfiled third major American indictment of the individuals and financial institutions that ALEX SAAB MORAN employed to clean and move millions of dollars of narco- and corruption profits for NICOLAS MADURO's criminal enterprise, reportedly has the targets on edge, both in Caracas as well as St. John's. While the sitting Labour Party government struggles to maintain superficially friendly relationships with the Trump Administration, senior officials from that party, both in and out of government, are known to be on tenterhooks, as they await the expected actions of the US Department of Justice.

There are, unfortunately. zero clues regarding the extent of cooperating testimony, which must surely be in progress, on behalf of Saab Moran, as Grand Jury proceedings are secret under the law, and there is a policy of declining any public announcement of pending investigations. The DOJ only speaks through indictments, which clearly worries the individuals who were involved in the money movement under Saab's direction will have to wait for the axe to fall.

Monday, October 19, 2026

HAMILTON RESERVE BANK SEEKS TO SUPPRESS REPORTING ON LITIGATION AGAINST THE BANK IN NEVIS



This is to notify our readers that I have received a letter threatening civil litigation against me for continuing to report on the lawsuit pending against HAMILTON RESERVE BANK of Nevis. The letter, which was sent from Thomas J. Ali, Esquire, a Florida attorney representing the bank and Benjamin Way, via email, giving me five days to retract the information in my articles, and claiming that I have defamed both the bank and Mr. Way. This is an obvious effort to interfere with my reporting of the Nevis cases, which I have covered in detail reporting on the findings of facts and conclusions of law. As the defense to allegations of defamation as truth, I hereby decline to retract my published articles, and I will not be tendering an apology for reporting the truth.

WITH MILLIONS OF DOLLARS IN PAYMENTS DUE SOON, A STAY DENIED BY THE APPELLATE COURT, AND THE TRIAL JUDGE ADVISING BANK LICENSE SUSPENSIONS IN NEVIS' TROUBLED OFFSHORE FINANCIAL CENTER, PREMIER MARK BRANTLEY IS CAUGHT BETWEEN A ROCK AND A HARD PLACE




What will Nevis Premier MARK BRANTLEY do? Last week the appeals court declined to order a Stay of the Omnibus Judgment, requiring two of his island nation's offshore banks to remit millions owed by October 29, and the Court had also advised him to suspend them. At his latest press conference, Brantley stated that, so long as the appellate process was ongoing, he would not intervene, but he clearly counted on a Stay being part of the picture; when it was not ordered, he found himself without any reason or excuse to delay taking any enforcement action.
The Premier reportedly met virtually with his advisors, looking for a reason to ignore the increasing pressure to take action, but we have not seen any evidence that he has taken any affirmative steps to remedy what is a serious situation, threatening the very future of Nevis' offshore financial structure. If the deadline date for payment, the 29th, passes, and nonpayment is the outcome, he will be under even more pressure to act.

Thursday, October 15, 2026

DELAY TACTICS BY HAMILTON RESERVE BANK DENIED BY COURT


Efforts by attorneys from Nevis-based HAMILTON RESERVE BANK, to obtain a Stay from the September 15 Omnibus Judgment, which ordered the bank to pay its depositors USD$80.5 from their demand accounts, failed yesterday, when the Court denied their motion. The bank has been ordered to fully pay over this amount, in full, by no later than October 29, 2026.

The Court also ordered that certain of the disclosures it ordered to be made by the BANK OF NEW INNOVATION a/k/.a BONI, were not required to be made at this time, although other information the bank must disclose remain due by Monday, October 19. 

We note that Nevis premier MARK BRANTLEY stated, during his press conference, that while HRB applied for a Stay, which was denied, BONI never applied for one. Therefore, we ask the premier what is stopping him from following the judicial advice, revoking BONI's banking license, and appointing regulators to wind up its affairs? We consider that to be a fair question that deserves a response forthwith.


  • Kenneth Rijock sent the following messages at 10:35 AM

Wednesday, October 14, 2026

" ALL THE IRANIANS IN OUR COMPANY HAVE PASSPORTS FROM DOMINICA." HOSSEIN SHAMKAMI'S EVIL EMPIRE- THE UAE MEGA-SCANDAL



Here are ongoing developments regarding the commercial activities and sanctions-evasion network led by MOHAMMAD HOSSEIN SHAMKHANI. The organization is executing a rapid liquidation of its UAE entities, initiating mass terminations of local personnel, and transferring its command structure to China. Below is a summary of these actions. The Phantom Fleet: Inside the Terrifying Collapse of 'H' and the UAE's Billion-Dollar Shadow Empire. In the gleaming towers of Dubai, billions of dollars move in total silence. They flow through shell companies, phantom tankers, and offshore hedge funds. But beneath this veneer of corporate legitimacy lies one of the most sophisticated and dangerous sanctions-busting operations in modern history. 

At the center of it all is a man known in elite trading circles simply as "H", "Hector", or "Hugo Hayek". His real name is Hossein Shamkhani. As the son of Ali Shamkhani, Iran’s powerful former national security chief, Hossein didn't just inherit political connections—he weaponized them to build a staggering global enterprise. His syndicate—anchored by entities like the Milavous Group and the Admiral Group—controls a massive "shadow fleet" of tankers. This fleet doesn't just smuggle sanctioned Iranian and Russian crude; US officials have linked Shamkhani's maritime network to a terrifying "weapons-for-oil" pipeline, actively transporting drones, missiles, and dual-use components to fuel Russia's war machine.

But the walls are finally closing in. Following crushing sanctions from the United States Treasury and the European Union throughout 2025 and 2026, the Shamkhani syndicate is triggering a drastic, scorched-earth retreat from the Middle East. What is happening right now in Dubai is not just a corporate restructuring. It is a mass liquidation, a covert exodus, and a chilling reminder of how easily the architects of global conflict can vanish into the dark. 

The Corporate Facade: A Masterclass in Deception To evade international intelligence agencies, Shamkhani’s network operates through a labyrinth of rapid rebranding, Caribbean passports, and continuous corporate mutation. When one tentacle is severed by US authorities, two more grow in its place.Take Teodor Shipping L.L.C., a UAE-based vessel management firm explicitly sanctioned by the U.S. Treasury for orchestrating Shamkhani’s illicit shipping operations. To sidestep these penalties, Teodor was simply dissolved and quietly resurrected as Velora Shipping DMCC.

This same shell-game psychology governs the rest of his UAE portfolio: Greenharbour DMCC (Operating from the ashes of Helmatic Consultancy and Marvise Ship Management DMCC).Aureliun Management Consultancy (The financial nerve center pumping capital through the network). Lutris Consultancy LLC FZ (Previously Eastgate Consultancy LLC FZ). LX2303, API World Tower, Trade Center First, Dubai, United Arab Emirates. This acts as the syndicate's legal shield. The Head of Legal is UK national Edward Robert Newitt (Passport: 157159678), whose maritime expertise helps navigate the treacherous waters of international shipping law. Loamloaft Consultancy LLC & Irongate Consultancy LLC (Dedicated oil and gas logistics fronts).

As the economic crosshairs lock onto these entities, Shamkhani is burning the evidence. Several of his maritime operators—Glavos Shipping FZCO, Dezera Shipping FZCO, Limes Ship Management, and Bravos Ship Management—have already been quietly liquidated.

The Human Machinery: Huminara Consultancy LLC; Moving billions of dollars of contraband across oceans requires an army of brokers, logistics experts, and corporate operatives. Managing this sprawling, high-risk workforce is the sole responsibility of Huminara Consultancy LLC. Operating under Trade License (TL) 1552340 out of Office 301, Cayan Business Tower in Al Thanyah First, Dubai, Huminara is the beating heart of Shamkhani's HR infrastructure. Originally named Integraedge LLC, the firm was rebranded under the direction of its top executive to obscure its tracks as the network scaled across the UAE, Iran, and Pakistan.

The people running this HR engine are not standard corporate bureaucrats; they are the architects of a massive, multi-national shadow workforce:Sebastian Fuchs, CHRO (Passport: C4KN1TX3K): A German national serving as the Chief Human Resources Officer. Fuchs orchestrated the pivot from Integraedge to Huminara and currently oversees the entire cross-border workforce, engineering the logistics of their most dangerous move yet. Hao Wu (Passport: E96247688): A Chinese national handling the complex compensation and benefits structures that keep employees paid through a maze of sanctioned shell companies. Joyce Ann Irene Capili Oriel Bicua (Passport: P3336587B): A Philippine national serving as the on-the-ground HR Manager, handling the day-to-day administration of a workforce operating on borrowed time.

The UAE allows this activity to be conducted with impunity.









 




Tuesday, October 13, 2026

HOW DID BRITISH REGULATORS PERMIT A FOREIGN BANK IN EXTREMIS, WITH PENDING LITIGATION AND A SUSPENSION REQUEST, TO OPEN A REP OFFICE IN LONDON?

What on earth is going on with UK regulatory authorities? They have permitted Nevis-registered HAMILTON RESERVE BANK LTD. to open a representative office, notwithstanding protracted pending litigation against the bank, and a recent High Court Justice opining that its license should be suspended, pending a civil & criminal investigation. Doesn't anyone in the Financial Conduct Authority use Google for basic due diligence?

I realize that most of the media coverage of the multi-year civil litigation against the bank, filed by extremely unhappy clients who have been denied access to their deposits for several years, has been minimal, but even basic inquiries by the FCA would have revealed the problems. Who is watching the store there, please?

Also, given the listed address, it is obvious that the bank's rep office is purely virtual, no brick and mortar facility, with designated staff on site. Doesn't that further give regulators pause? Or was it the fact that there are British nationals on the Board of Directors sufficient to allay any suspicions? Is it the Old Boy Network again? Whatever it is, it smells of either undue influence or professional negligence. Not a good look for the FCA, to be sure.