Monday, February 13, 2017


I have been reading, over and over again, that the due diligence investigation, conducted upon applicants of Dominica's diplomatic passport program, was more than adequate; it searched all the sanctions lists, and failing to find any negative information, approved an Iranian national, living in Malaysia, with a Malaysian passport, and engaged in massive international trade. Attorney Anthony Astaphan, himself without any experience or training, in the field of compliance, says everything was properly done.

Nothing could be more wrong. Iranian nationals, given international sanctions, including strict US sanctions, in force upon Iran , are by definition high-risk, which means that Enhanced Due Diligence is required. EDD demands actual inquiries, in the real and virtual worlds, be conducted, and one never, ever limits such searches to obsolete sanctions list. To try to claim that all which should have been done, was done, is bloody insulting to the intelligence of compliance officers.

As I have previously stated, US regulations, effective in 2010, call for accessing any information that is "knowable," which I personally did in 2011, when checking out Reza Zarrab. I found that his associates, Babak Zanjani, and Alireza Monfared, were his partners in an illicit oil sales operation. I did not use any restricted information to arrive at that conclusion, just a few well-placed emails and interviews, conducted by others. If I knew these facts, then they were in the public domain, and definitely knowable. So why did the large search firm not catch it ? Obviously, someone did not want the truth to come out, so it did not.

As a former compliance officer, I know a compliance failure when I see it. Mr. Astaphan, apologist for a government which issued a diplomatic passport to a member of one of the most dangerous criminal organizations on earth, is beginning to sound more like a propagandist, than a lawyer who deals in facts.

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