REZA ZARRAB/RIZA SARRAF: ACCUSED SANCTIONS VIOLATOR/MONEY LAUNDERER HAD FOUR NATIONALITIES

Reza Zarrab, the Iranian national charged in US District Court with conspiring to evade American sanctions against Iran, Money Laundering, and bank fraud, was less than truthful, when the issue of his nationality, and passports available to him, came up after his arrest. Buried in the court filings is the Government's statement that he only admitted to two passports, from two jurisdictions, but, in truth and in fact, his attorneys said he had three. It is not known whether they were turned over to his 12 attorneys, in anticipation of his release on bond.

Which passports he holds, and how he acquired them, seems to be a bit of as puzzle. Born in Iran, he holds an Iranian passport. he lived in Turkey for several years, while a child, and much later returned there as an adult. the legality of his acquisition of Turkish nationality has been questioned, in Turkish media, for the procedure that resulted in the issuance of his passport did not follow the law, and raises the presumption it was obtained through influence. Add to that the fact that he was given a passport in a deceptively similar name, Riza Sarraf, and you have a potential problem.

Some sources state that he also holds a third, an Azerbaijani nationality, and passport, this is said to be due to his ethnic origin; some sources say he lived in Azerbaijan, for an unspecified period, while others say his residence outside of Turkey, was limited to the United Arab Emirates.

The fourth reputed passport is from Macedonia, and is said to be an economic, or investor, citizenship; Therefore, assume that there are others.

Compliance officers, faced with the challenges of dual citizenship, economic passports, and even bought-and-paid-for diplomatic passports (remember the St Kitts and Antigua scandals), must tread carefully, to separate the wheat from the chaff.

Remember these red flags, at account opening, of international clients:

(1) Was he born in the country where his passport says he is a citizen ?
(2) Is the passport relatively visa- and entry stamp- free ?
(3) Is the passport newly issued, or does it look brand-new ?
(4) is the passport from a jurisdiction where economic citizenships exist, or a developing country jurisdiction where corrupt government agents are well known to sell them ?
(5) Does the passport holder fluently speak the language that goes with the passport, including the unique colloquial expressions, or slang, for that country ?
(6) Does he, perchance, have a valid driver's license from that country, and one that is not brand spanking new ?

Now, ask him to produce the passport that goes with his place of birth.