Wednesday, February 1, 2017


According to the US Money Laundering Control Act of 1986, and the court decisions interpreting it, any efforts to hide, secrete, or invest, the proceeds of criminal activity, including embezzlement, constitutes money laundering, or conspiracy to commit money laundering. Considering that a number of individuals who obtained diplomatic passports from Dominica, in an off-the-books, non-public operation, which is definitely not a part of the country's Citizenship by Investment (CBI) Program, were later either charged with crimes, found to be engaging in criminal activity, or wanted by the authorities, meaning that the fees and costs that they paid for the passports, as well as the fees paid to their local attorneys, might very well all be considered money laundering acts.

For those who are unaware how serious American money laundering laws are, the maximum punishment is 20 years in Federal Prison, and a fine which could reach the tens of millions or dollars, plus forfeiture of criminal profits. Has anyone in the Chambers of the Attorney General consulted with competent, experienced, American counsel, I wonder ? Anyone participating in the approval, issuance, or delivery of diplomatic passports to foreign nationals, and those who accepted payment, and deposited the same in bank accounts, could potentially be liable, under US law, for money laundering offenses.

A final note: US federal decisional law has consistently affirmed that there is extraterritorial jurisdiction for money laundering offenses, and the mandatory transit of US dollars through the New York banking center, when passing from the Caribbean, to Europe, or Asia, is another act which confers jurisdiction upon foreign nationals, even if they never enter the United States.

It appears that a number of Dominicans may wish to consult American criminal defense lawyers, so avoid the nightmare that occurs when they arrive in Miami with their families, to visit Disney World, and learn, to their horror, that there has been a sealed indictment pending against them, as they are taken into custody, in what will be a life-changing experience that I do not wish on anyone.

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