Kenneth Rijock

Kenneth Rijock

Wednesday, April 18, 2018


Leroy King, the former head of Antigua's Financial Service Regulatory Commission, and a six-year fugitive from American justice in the Allen Stanford billion dollar Ponzi scheme Federal criminal case, is reportedly contemplating cooperation with the US Attorney's Office, in order to obtain a favorable plea agreement. Should King be ultimately extradited, and tried, he could end up with what amounts to a life sentence in Federal Prison. Therefore, his reasons for cooperating are understandable.

Should Mr. King provide Substantial Assistance to the United States, there could be additional indicmtents in the Stanford case.  Antiguans believe that he would implicate a former Prime Minister, the current Prime Minister, other ministers, and two prominent East Caribbean attorneys, for their alleged role in Stanford's massive Ponzi scheme, involving the now-closed Stanford International Bank, whose headqurters was in Antigua. The former regulator has openly discussed the possibility of his cooperation with associates and friends, but there is no information currently available regarding whether he has, or has not, formalized any plea negotiations.

Tuesday, April 17, 2018


 A US District Judge in Florida has granted the motion, filed by the US Attorney, to withdraw the Rule 35(b) motion to Reduce Sentence that his office filed on behalf of the attorney/Ponzi schemer Scott Rothstein. The defendant's attorney, and later the defendant himself Pro Se, opposed the motion, and filed  memoranda of law, contesting the Government's right to withdraw its motion. Rothstein perjured himself, wheh he sought, unsucessfully to assist his wife in concealing and selling their valuable jewelry collection, a clear violation of his obligations under his Plea Agreement.

The Court, in a 9-page opinion, with extensive citations to authorities, held that existing case law interpreting the provisions of the Rule 35 motion, favored the Government's position. The ruling was no surprise, given that the preponderance of decisions supports the Government's sole discretion expressed in the motion.

 Scott Rothstein, whose 50-year sentence for running a bogus investment scheme, claiming to sell out-of-court settlements for sexual harrassment and employee discrimination claims, must now serve 42.5 years for his crimes.

Monday, April 16, 2018


When then-Foreign Minister Charles Fernandez received the fifteen million dollar upfront payment from Chinese billionaire (and then-fugitive from justice in China) Xiao Jianhua, where did all that money go ? It apparently was never properly accounted for, and it was never deposited in the official treasury, according to CBI program guidelines. The expanding scandal has increased the Antiguan public's perception about systemic corruption, at the ministerial level, and could topple the present government, unless true reforms are implemented, due to malfeasance in office. Remember well the case of former Prime Minister Patrick John of Dominica, where mass protest caused his resignation.

The money was prepayment for a total of two hundred A & B CBI passports, but the passports were never delivered, and later disappeared under circumstances that lend themselves to the presumption of official corruption. A page thought to have been taken from one of the passports was found in the possession of a senior St Vincent police officer, when he was himself arrested by the SVG Drug Squad, which led to the subsequent dismissal of an Antigua Police Inspector, and the targeting of two diplomatic professionals, as suspects in a major passport fraud scheme, being conducted in SVG, with assistance from greedy and amoral Antiguans.

So who else was the fifteen million distributed to ? Reliable sources in Antigua assert that certain senior government officials in Antigua received portions of this money, as did the participants in the scheme to create counterfeit passports abroad, all of whom were in the same criminal conspiracy. Their identities are known, and if any of them were foolish enough to deposit those criminal proceeds into a financial institution, or move it into the United States, and/or spend any of it there, a 20-year sentence for money laundering could be in their future, and their "diplomatic status" will not save them; look at the late lamented President Manuel Noriega. He served that sentence, and later died a prisoner in the Republic of Panama.

Sunday, April 15, 2018


A powerful South Korean-based organized crime syndicate has large quantities of the most dangerous version of the North Korean-made USD$100 "Supernote," the counterfeit one hundred dollar bill. Should it be released, in bulk, into the global economy, it could wreak havoc with international trust in American currency, and possibly even economic damage.

The bills, which were made on or about 2006, and reportedly stored since then in the Peoples' Republic of China, and later smuggled into the Republic of Korea, have been withheld from circulation, but one example was found in a bank in Seoul, in late 2017. It took a team of experts at KEB Hana Bank to ultimately conclude that it was a counterfeit, which is testimony to the  accuracy of the counterfeits. One South Korean source claims that the plates for the Supernote were made in the ROK, and smuggled north, but there has been no independent confirmation of this to date.

The Series 2006 was the last issue of the US one hundred dollar bill made prior to the insertion of a number of advanced anti-counterfeiting features, though examples of counterfeits from the later era have also been seen, and photographed, in South Korea.

The powerful organized crime sydicate, which has reportedly long had ties to the South Korean military, allegedly used the counterfeits as collateral for large bank loans, by claiming that the money was genuine. It holds these counterfeits in a number of guarded warehouses, some in locations that corroborate the claims of military protection of the syndicate. Previous links to the country's intelligence community have also been verified.

The organized crime group also holds large quantities of counterfeit currency of a number of Asian countries, but whether these bills were printed in North Korea has never been verified, though they are also suspected to be of DPRK origin. There are, literally, pallets of these bills, in secure storage.

The syndicate also holds quantities of bogus bonds, also purportedly of US Government origin, but which must be forgeries, due to the fact that such financial instruments, in those specific amounts, were never issued. It also, strangely enough, holds US currency which was never printed, such as a well-made $10,000 bill, ostensibly printed in 2006, using the image of Benjamin Franklin, or a million dollar bill, using the George Washington inage.

 While no Western banker would ever accept such financial oddities, they could possibly be used  for fraud, as potential bogus collateral oveseas, or in private criminal transactions, especially involving the storage of wealth* obtained in narcotics transactions. Also, remote areas, where American financial instruments are rarely seen, and unfamiliar to businessmen there, might be a ripe area for massive fraud. A five hundred dollar bond, with the image of Ulysses S Grant thereon, and attached interest coupons, could result in a hige payday for the seller, even if heavily discounted. 

What is not known is whether the South Korean organized crime syndicate has any direct connections to the DPRK government, other than as a buyer of counterfeit instruments.  That is a matter for further investigation.

The clear and present danger that the Supernote poses to the United States cannot be underestimated. Givewn that there has been no US Treasury alert posted, either publicly, or to the financial community at largemay indicate that details of this threat are either discounted, or that the information has been classified, due to concerns that it might damage the image of the US Dollar overseas, and also its value on international markets. Whatever the reason for a virtual US news blackout on the subject, the latest iteration of the $100 Supernote deserves attention, before some Korean mob boss decides to open the doors of one of those warehouses, and starts offering them in bulk, as was recently seen in Singapore, at 50 cents on a dollar of face value. Once the genie is out of the bottle, it will be imposible to put him back.
* Selling bogus high-value instruments to criminals is not a stretch, though inherently dangerous. There are nearly one million Canadian $1000 bills still in circulation, most of whom are believed to be held by criminal organizations there We note that Canada is seeking to pass legialation to declare its $1000 and $500 notes as no loner leal tender. Most of the €500 notes in the EU are in the hands of organized crime, largely in Spain.

Saturday, April 14, 2018


As more information becomes known, regarding the Antigua stolen passport scandal, one recent episode starts to finally make sense. When former Minister of Tourism, Economic Development, Investment & Energy, MP Asot Michael was detained & interrogated by British law enforcement, upon arrival in London, he was abruptly and immediately relieved of his ministerial portfolios. Why did that happen ? He was not charged with a crime.

Though there were accounts that he had Antigua passports in his possession when detained, they were curiously not on the inventory. Antigua spokesmen said he had no access to passports, so therefore, he could not possibly have any. Other sources, however, stated that he did, indeed have several passports on his person.

Here's a clue ; MP Michael is a cousin of one of the Antigua diplomat players in the 200 stolen passport scandal. We believe that some of those blank passports could easily have ended up in his hands, and had their existance in his bags been revealed , the cover-up would have been exposed. No wonder he was quickly, but quietly, cashiered, while retaining his seat in the Parliament of Antigua.

This brings up our pending question of the week: who in Antigua government knew about the stolen passports and when did they know it ?


A prominent member of the Antigua diplomatic corps has been identified, by reliable sources, as one of the three local partners in an international scheme to sell counterfeit passports to foreign nationals, using authentic pages extracted from stolen blank passports. This individual, whom we choose not to name until his arrest or indictment, has served Antigua in a number of international diplomatic postings and missions. It is believed that he used his position, and family relationships, to facilitate the illegal diversion of the missing two hundred blank passports, and shared in the criminal profits.

What is most disturbing about this individual is that he is also known to be receiving unlawful compensation from an international consultancy that services Antigua's Citizenship by Investment (CBI) program, which is a clear conflict of interest, and a violation of the laws concerning corrupt acts. His connections with senior government officials are believed to have given him virtual immunity from criminal prosecution, but his most recent scandal, involving the arrest of his counterfeit passport scheme co-conspirators in Saint Vincent, may strip away the official protection that he has enjoyed to date. His biography does not show any professional or educational preparation for diplomatic service.

The Antiguan public's strong reaction to the counterfeit passport scandal could signal a genuine need for comprehensive government reform in Antigua & Barbuda in the Ministry of Foreign Affairs, to include actual professional and educational requirements for serving diplomats, disqualification of applicants with close family relationships in government, and ethics and corruption continuing education. Finally, the issuance of diplomatic passports, to anyone willing to pay cash for them, should be discontinued, lest the United Nations Office of Legal Affairs agrees to take action.


We are concerned that the fact that two hundred blank Antigua passports that were assigned to a Chinese billionaire, to vend in Hong Kong. and never delivered to their owners, allthough they were thereafter to be delivered to individual Chinese recipients, ended up in the hands of criminal elements. If the SVG Drug Squad had not arrested two suspects, and seized all the necessary components they had to create bogus Antigua passports for illegal global use, the truth might never have been known.

So the question must be asked: how long did the Government of Antigua know that the passport pages were being sold, and when did it know that ? Obviously, the two hundred passports were in the custody and control of the Ministry of Foreign Affairs, but never released to Xiao's clients, and then mysteriously stolen; two individuals that are, or were, part of that ministry are the other local suspects in the Antigua-based passport smuggling scheme, whereby the genuine personal history pages were removed, and sent to the Saint Vincent-based passport sales gang.

Given that the 200 passports were never delivered to Xiao's clients, did the then-Minister of Foreign Affairs notify senior government oficials of this fact ? It is reasonable to suspect that notification was made, especially after Xiao diaappeared from Hong Kong under suspicious circumstnces that led most to believe that he was kidnapped by agents of the Peoples' Republic of China for alleged financial crimes. Who released those passports ? What about the so-called "Inventory Control" that was purportedly in force in Antigua ?

How did those passports end up in the hands of a controversial Police Inspector ?  The Ministry of Foreign Affairs has a lot of explaining to do, the public in Antigua deserves to know what senior government officials know about the 200 passports, and when did they know it. 

Friday, April 13, 2018


Sources inside Antigua have advised that the Royal Police have, in the course of this week's search and seizure raids, all of which are seeking evidence from the local members of an international gang making couterfeit Antigua passports, have seized cash totalling approximately USD$115,000. It is not known precisely where the seizure of cash ocurred; one reliable source stated that it was at a residence of a paramour of Police Inspector Ray John. It was John's own residence that was the first focus of the police seasrches.

There is apparently an expanded operation, being conducted by the Royal Antigua & Barbuda Police Force, to locate the the missing two hundred (200) blank Antiguan passports, which were supposed to have been entrusted to a Chinese diplomatic passport holder, but which now appear to have been taken by two individuals from the foreign affairs sector of government, and sold to criminal elements, with the alleged assistance of Inspector John.

The Government of Antigua, in a press release, appeared to try to minimize the number of Antiguan passport pages seized by the authorities in St Vincent, when the Drug Squad arrested two individuals. in possession of special printers, memory sticks, and other incriminating items, all of which indicate that the detainees are engaged in a majior Antiguan passport coiunterfeiting scheme, but thousands of bogus passports were allegedly manufactured and sold to foreign nationals throughout the globe.


The Royal Police Force of Antigua & Barbuda, serving a search warrant at the residence of prominent Police Inspector Ray John, removed two large evidence bags from the premises, in a case said to be closely related to the recent arrest of two passport fraudsters in St Vincent. Those arrested in St Vincent had, in their possession, legitimate personal identification pages from Antiguan passports. The were part of a ring known to have illegally sold bogus Antigua passports to foreign purchasers, using generic blanks purchased from an identity document factory located in Europe, to craft credible counterfeits.

Inspector Ray John

Antigua insiders assert that the missing two hundred blank Antigua & Barbuda passports, scheduled to be given to the missing Chinese billionaire Xiao Jianhua, holder of an Antigua diplomatic passport, were never delivered, and three conspirators, including Inspector John, and two other individuals connected to the Foreign Ministry, obtained them and sold them to the passport fraudsters. That is why the  pages seized in St Vincent are genuine, and not counterfeit.

Inspector's rank insignia

 Nobody is in custody in Antigua at this time, but arrests are believed to be imminent.

Thursday, April 12, 2018


The Boston Marathon Bomber

 There are serious concerns expressed recently about applicants for CBI programs who proffer legitimate proof of identity, including passports, birth certificates, and drivers' licenses, using aliases, thereby denying that any effective investigation will occur, since the true legal name of the applicant is never disclosed. The documents, which are generally obtained through bribes, from cooperating individuals at official government agencies, are real. 

Additionally, as we have again seen this week, in the case involving the arrest of individuals who allegedly have created counterfeit Antigua & Barbuda passports for clients, there are forms of identity in circulation, which appear to be completely legitimate, bearing aliases of the holders. How can the true identity of the holders of these bogus passports be ascertained ?

First, it is well-established that the traditional due diligence investigations are now obsolete, and it cannot solve the two problems mentioned above. Furthermore, any Enhanced Due Diligence program, to be completely effective, must contain a Facial Recognition Software component, capable of identifying or verifying an individual, from the images he or she presents. These programs compare the applicant's images to a database of digital images and video frames from video sources. 

When you have career criminals, corrupt Politically Exposed Persons (PEPs), international sanctions evaders, and even individuals named by OFAC, seeking CBI passports, it is necessary that effective Facial Recognition Software be an integral component of the vetting process. Additionally, it is advisable that a look-back be performed in all existing CBI passports holders, to identify those who managed to gain a passport using documents that do not contain their legal names.  

Wednesday, April 11, 2018


The Prime Minister's Order cancelling the CBI passports

For some reason, none of the articles covering the recent revocation of the CBI passports of six individuals have mentioned that all of them are Iranian nationals. The grounds for the abrupt cancellation of the passports have not been made public, other than a vague statement that they "have committed acts which may bring St Lucia into disrepute." It could be participation in Iran's international sanctions evasion schemes, espionage, terrorist financing, or criminal conduct; we do not know their offenses.

 Most CBI insiders know that the vast majority of St Lucia CBI passport holders are Iranians, and it has been estimated that they constitute more than 90% of all the country's issued and outstanding CBI passports are held by Iranians. Given existing international, US  & EU sanctions, and the potential for armed conflict in the Middle East, involving Iran, St Lucia's government must be seriously lacking the ability to foresee the probable unintended consequences of their giving passports to members of a regime whose nationals are carrying out foreign policy goals contrary to Western values, laws and ethics. Do they know how to spell Enemy Aliens ?


Two suspects were arrested recently in St Vincent by the Drug Squad; they were found to be in possession of a special printer, memory sticks, and personal information pages from a number of what appeared to be biometric passports from Antigua & Barbuda. The pages, which identify individuals from Australia, Dubai UAE, and Egypt as Antiguans, are evidence of a massive passport fraud scheme that offered bogus A & B passports to foreign nationals. Extradition to Antigua is expected to occur shortly.

A confederate, operating out of Antigua, allegedly assisted with the acquisition of the format of biographical pages, which were then created and inserted into passport blanks in St Vincent. His identity is reportedly known. One source stated that thousands of  passports have already been created and delivered, using sophistocated techniques. It is not known where the bulk blank passports were manufactured, but a company in Europe, already under law enforcement investigation, may have been the source.

Did the gang manufacture counterfeit passports from other jurisdictions ? There is insufficient information available from the initial arrest reports, but the generic passports they had acquired could be used to create authentic-looking documents for most countries.  

Tuesday, April 10, 2018


Chinese military vehicles, delivered to Dominica this week.
 This week, armored cars and other military vehicles arrived in the Commonwealth of Dominica, courtesy of a multi-million dollar grant from the People's Republic of China, which previously has supplied arms & ammunition, and even camouflage uniforms and equipment, to the country's Special Services Unit, its paramilitary police. For a nation with no external or domestic national security threats, Dominica is becoming an armed camp, with military capabilities that far exceed its law enforcement needs.

Last year, the country's  Minister of National Security, Rayburn Blackmoore, ordered the Chief of Police to ascertain which members of the force were "for or against the government," to weed out any officers whose political leanings were not in favor of the ruling Dominica Labour Party, and the present Prime Minister, Roosevelt Skerrit. The increase in the number of sworn law enforcement officers, past the point where an objective observer would consider their numbers clearly excessive, the only conclusion one can draw is that it is being augmented to be able to physically suppress any possible organized protests, on the part of the Opposition, during the next national election, which will feature massive election fraud, as has happened for the past fifteen years.

The influence of the Peoples' Republic of China should not be underestimated; China's massive embassy, which is believed to be monitoring United States military activity in the Caribbean, and conducting electronic surveillance of communications in the region, as well as a base for intelligence officers in the field, is furthering China's global ambitions in the Caribbean, which the US generally ignores, and takes for granted as allies. Remember, the Prime Minister of Dominica is a hardline Socialist, whose mentor was Hugo Chavez, and who identifies with the regime in Cuba. He is no friend of the Wesrtern democracies.

Additional Chinese miliotary vehicles, now delivered to Dominica.
 A final note, and a disturbing one, when China evacuated its embassy staff from Dominica, in the aftermath of Hurricane Maria, in 2017, 462 Chinese nationals were removed from the country. Since China has neither any trade, nor tourism, with Dominica, what are all those Chinese nationals doing in the embassy ? Where is Dominica heading ?


As the liquidation of two insolvent Cayman companies owned and controlled by a fugitive, the Canadian fraudster Ryan Bateman, proceeds, government officials are alleging that no victims have ever come forward, to make a formal claim of loss. This information is totally false, and efforts to circulate this blatant lie, calculated to cover-up one more major financial scandal in a long line of cases where foreign investors lose everything, and Cayman residents who are guilty are never charged with criminal conduct. 

Our previous coverage of the case, where the fraudsters were named the "Cayman Gang of Four" by the media, detailed what the Cayman Islands Monetary Authority (CIMA) estimated was a $400m loss, sustained by approximately sixty Canadian retirees and pensioners, which was stolen by Bateman and the other gang members, Sharon Lexa Lamb, Derek Buntain, and Fernando Moto Mendez. None of the fraudsters was ever brought up on charges in the Cayman Islands. It was the thirteenth reported major fraud in the Cayman Islands, involving foreign investors who sustained a total loss, due to fraud and theft on the part of Cayman Islands residents, where zero dollars were recovered for the victims.

Now, government is claiming that NO investors ever filed a claim with CIMA or the RCIPS. I personally know of filings with both agencies, and still maintain copies in my files. The untrue allegations were meant to bury a major scandal, so that future prospects are not deterred from participating in the next Cayman-based investment sheme.

Monday, April 9, 2018


 For those who believe that all the Dubai-based immigration attorneys who specialize in assisting clients in obtaining Citizenship by Investment (CBI) passports are benevolent legal advisers, allow me to interject.There are a number of such lawyers who, in addition to handling legitimate CBI matters for clients, are engaged in illegal global Iran sanctions evasion operations, on a massive scale, using their legal practices in neutral Dubai, to conceal their dark deeds.

If you were wondering how this information came to surface at this time, look closely at the latest Iran sanctions evasion case to be filed in New York District Court against Ali Sadr Hashemi Nejad, of Malta's Pilatus Bank, and at the Reza Zarrab case, also pending in New York. These individuals possessed CBI passports, and both were advised by Dubai-based attorneys, none of who has been publicly named, or charged, at this time, though they may be the subject of sealed indictments. The lawyers' identities, due to their overlapping associations with clients across the spectrum of illicit Iran sanctions evasion operations, have become known to us.

There are several Iranians fully engaged in Iran sanctions evasion activities; evidence of that is the Death Row inmate, Babak Zanjani, and his partner Alireza Monfared, also somewhere in custody in Iran. Note that several of their partners have approached the Government of Iran, with the goal of paying off Zanjani's missing billions, to have his execution cancelled. Those individuals are still active, regretfully, and continue to operate their sanctions evasion criminal enterprises.

Reliable reports from the Middle East advise that there are seven, independently run, sanctions evasion programs, which are supervised and managed by their Dubai lawyers, in a continuing criminal enterprise. While those attorneys are known for their CBI and passport practices, their covert activities continue unabated, due to the curious "hands-off' policies the UAE states observe, regarding their large Iranian expat population, and violations of international sanctions.

Will the guilty lawyers be exposed (and indicted), and their sordid acts ever see the light of day ? We cannot say, especially since they do not seem to be entering the United States of late, where they could be detained, and indictments unsealed. Should they be named ?


Rather than reform their programs, the majority of the five CBI East Caribbean States continue to improperly vet applicants from high-risk jurisdictions, and jurisdictions known to be State Sponsors of Terrorism. One new CBI construction project appears to have totally disregarded risk issues, and plans to sell its residential units, which come complete with a CBI passport offering visa-free entry to over 135 countries.

The UAE-based developer is reportedly marketing the project exclusively to Iranian nationals,  a high risk group for whom effective Enhanced Diligence is extremely difficult, if not impossible, due to:

1. A lack of available English language comprehensive data on Iranians. A lack of useful open-source databases on Iranian nationals and expats.

2. The risk that names, places of birth, and date of birth may have been altered on identity documents presented to CBI unit staff, or clever, and authentic, aliases provided on official documents.

3. The risk that applicants may be Politically Exposed Persons (PEPs), who have access to government funds and accounts, and who could be using the Proceeds of Corruption to make their CBI purchase.

4. The lack of any database that could be used to run Facial Recognition software against the images of the Iranian applicants, to confirm identity.

5. The difficulty in correctly transliterating Persian (Farsi) names into English equivalents that will be properly formatted to check against sanctions lists, and databases of high-risk individuals.

Marketing to Iranians, knowing the difficulties involved, will result in up to one hundred and eighty unknown Iranian nationals, that are not properly screened and cleared by Due Diligence, obtaining completely new, and clean identities, with which to visit the Commonwealth, the EU Schengen Zone, and other visa-free jurisdictions. The potential for the facilitation of money laundering, terrorist financing, moving the proceeds of corruption, and espionage, by Iranians using these passports, is huge.

The legal, political and diplomatic consequences of this project cannot be predicted, especially whether it will result in blacklisting of the entire country, or all its passports by North American or European immigration officers, or their banks. Is the proverbial straw that will break the CBI camel's back, with blunt American pushback, by the banks or the government ? We cannot say, but the arrogance of those who conceived of this project may result in painful pushback.

Sunday, April 8, 2018


A Federal corrections official, Victor Casado, was charged with multiple counts, involving delivering contraband to Iran sanctions evader, Reza Zarrab, while he was incarcerated. Zarrab received contraband while in prison, inclding alcohol concealed in water botles, cellular telephones, food and non-prescription drugs, for which it is alleged Casado was paid $45,000 .

The corrections officer has been the subject of a Criminal Complaint, alleging:

(1) Bribery.

(2) Providing Contraband in prison.

(3) Conspiracy to Commit Honest Services Fraud.

(4) Honest Service Fraud.

A number of unidentified co-conspirators appear in the Complaint, including an attorney, and the attorney's driver. Considering the reputation of Zarrab's eminent criminal defense counsel, it is impossible that any of them would stoop to bribing a jailer to send contraband to a client in prison and they have denied any role in the crimes, nor even knowing about it.

One report, however, asserts that a "Turkish lawyer" who was assisting Zarrab in prison was involved in the corruption. This means that a foreign attorney, not admited to practice in Federal Court, and not part of the defense team, made the illicit payments. Unfortunately, the Complaint does not further identify him. It is not known whether Reza Zarrab implicated Victor Casado, or any of the other uncharged co-conspirators. For readers who require more details, the case number is 18-02826-UA (SDNY).

Zarrab is believed to be the Office of Special Counsel's major witness against former National Security Adviser Michael Flynn.



Hamas agents in Gaza, burning American flag.

The display of a Nazi swastika, alongside the Palestinian national flag, during this week's chaotic efforts to violate Gaza's border with the State of Israel, is a reminder that Middle East terrorist organizations pose a clear and present danger to the Western democracies. For that reason, the overt solicitation, by the East Caribbean CBI states, to apply for CBI passports, could result in unintended consequences not foresseen by the East Caribbean leadership.

To be blunt, there are precious few Palestinians who are wealthy enough to have six figures in extra cash, in US Dollars, on hand, who are not either affiliated with terrorist organizations, such as Hamas, or the Palestinian Islamic Jihad, or PA officials, who will be paying for their passport with the proceeds of corruption. The first time a Hamas official is discovered using his CBI passport for terrorist financing purposes, the CBI nightmare will begin:

 Nazi swastika flying between two Palestinian flags at border demonstration

(1) The issuing state could find itself on the wrong end of major OFAC sanctions. There still is a Global War on Terrorism, though the Caribbean countries sell passports to Iranians & Syrians.

(2) All the local banks in that jurisdiction could be themselves sanctioned, or have all of their US correspondent relationships abruptly cancelled.

(3) The negative media coverage could drive down foreign tourism, and result in the flight of a mass of depositors from your indigenous banks, moving to local branches of North American banks. Foreign airlines will scale back their schedules to a country where tourism substantially declines.

(4) A messy terrorist financing criminal case, filed agasinst trher CBI passport holder, in either the US or Europe, where the CBI jurisdiction must endure repeated allegations of negligence.

(5) An increase in the presence of foreign intelligence agents in-country, who are engaged in covert counter-terrorism operations.


Do the East Caribbean CBI States really want to incur the wrath of the United States, Canada and the EU, on an immigration level, where arriving visitors are subject to intense examination, and even interrogation, or visa cancellations. Selling CBI passports to obvious Hamas leaders, or Palestinian Authority officials, whio income and assets do not even come close to their declared legal income, is playing with fire.

 Don't you have enough trouble, of a public relations nature, when Russian organized crime members, Iranian sanctions evader, Syrians, Chinese tax evaders, and even North Koreans, show up with CBI passports ? Stay clear of Palestinains with dirty money.

Saturday, April 7, 2018


  Thirty-four years after St Kitts inaugurated the region's first Citizenship by Investment program, most compliance officers at international banks in North America or in the European Union still do not trust that adequate due diligence procedures have been performed on East Caribbean CBI passport holders. History tells us that there are many individuals, who were passed after only perfunctory checks on their background, who pose a threat for their money laundering, terrorist financing, or placing the proceeds of corruption, and of course for OFAC and international sanctions violations.

That is why there are a number of countries considering the elevation of visitor arrival procedures on CBI states,  making ALL inbound East Caribbean passport holders, seeking to enter North America or Europe, submit to high-risk procedures, which involve interrogation, examination of electronic devices, and extensive delays upon arrival.

To avoid this impending catastrophe, remedial action may be the answer. In the United States, banks that run afoul of Anti-money Laundering/Countering the Financing of Terrorism issues are frequently required to conduct what is called a Look-Back, meaning that past transactions are reviewed. so that any possible money laundering that the bank failed to catch in the past, is identified and the appropriate action taken.

 If the world's banks can look into the past, and fix their failures, so can the East Caribbean CBI States.  Here is a plan of action that will redeem these jurisdictions. through true reform, and which will return the CBI passports previously issued to low-risk, legitimate status, for compliance purposes:

 (1) Institute mandatory Enhanced Due Diligence on all CBI passport applications, effective immediately. Existing Due Diligence programs should be terminated as ineffective.

(2) Perform Enhanced Due Diligence upon all previously issued CBI passports; should any fail your rigorous, but fair, EDD investigation, cancel them forthwith.

(3) Publish the names of the newly-cancelled CBI passports, in a newspaper of general circulation, so that the holders cannot continue to use them for an illegal purpose. Anyone conducting an Internet search will easily find this information, and refuse to accept the void document for any purpose. The name of the game is total transparency, concerning passports you declare null & void.

(4) Advise the global banking community of your new EDD operation, and invite regulatory agencies, as well as international compliance organizations and NGOs, to examine & observe your new program in operation.

 Sometimes, radical measures are required to attain true reform to dysfunctional programs. We challenge the East Caribbean CBI States to take these reform measures, to forever clean up their numerous previous mistakes, and thereby greatly reduce the level of risk currently posed to the global banking community by CBI passports.


The defense attorneys for Paul Manafort, Jr., in the District of Columbia criminal case*, are seeking the names of individuals that the Government contends were his accomplices; they have filed a Motion for a Bill of Particulars, and included in that motion are demands for specific information about those individuals.

The motion states:
" Throughout the Superseding Indictment, the Office of Special Counsel refers to the defendant's alleged 'accomplices' and 'others' who purportedly helped him in the charged scheme, without identifying such individuals or companies. Accordingly, the Court should direct the Special Counsel to:

  1. Identify the 'accomplices' who purportedly opened 'foreign nominee companies and bank accounts' in nominee names 'in various foreign countries.'...

 5. Identify the 'others' that allegedly conspired with Mr. Manafort in Count One of the Superseding Indictment." Defendant Paul J. Manafort, Jr.'s Motion for a Bill of Particulars, at 3.

Who are those Accomplices and Others ? Most likely,  they include the pro-Russian Ukrainians that Manafort represented, and who were said to assist him in the alleged money laundering. What we want to know is whether the Special Counsel's Office has uncovered any Citizenship by Investment (CBI) passports, issued by the five East Caribbean States who operate such programs, that are held by any of the pro-Russian Ukrainian nationals whom it identifies as Manafort's accomplices.

Precisely whch East Caribbean state or states issued the CBI passports is also of major importance. Readers will recall our recent stories about two Ukrainaian nationals who sought passports in Grenada, and where one complained to a government official there, demanding a refund of his payment, creating a minor scandal when the official's embarrasing and incriminating communications with the Prime Minister were revealed, in text messages.

If not Grenada, the logical choice then would be either Dominica, which has already sold CBI passports to between two hundred and three hundred Russians, and whom those Russians would have recommended, or St Kitts & Nevis, which has provided "private" banking services to affluent Russians for decades, with no questions asked about Source of Funds.

Finally, where did these individuals allegedly assisting Manafort in moving illicit funds, both his and those of others, form shell corporations ? Some of Manafort's pro-Russian Ukrainians and Ukrainian industrialists reportedly used Mossack and Fonseca, which most likely means British Virgin islands (BVI) as their jurisdiction; one source names the Cayman Islands, but the Republic of Panama is also a possibility. Unfortunately, there is little information publicly available at this time on their corporate formation in the Western Hemisphere, in this case.

If CBI passports show up during the Special Counsel's investigation, in the hands of dodgy Ukrainians, who were engaged in money laundering for Paul Manafort, and perhaps even the Trump for President Campaign, trying to hide illegal contributions, it will only confirm again that some East Caribbean CBI jurisdictions will accept just about anyone, providing that they have ready cash in US Dollars in their briefcases.  _____________________________________________________________________________
* Case No.: 17-cr-0201-ABJ (D.D.C. 2017)


A US District Judge in Miami has ruled that the Federal Government is not entitled to an Order of Forfeiture against Nidal Waked Hatum, who previously pled guilty to a number of money laundering-related charges. Waked is known to be a senior member of his family's powerful Panamanian money laundering syndicate, whose extensive holdings have been sanctioned by OFAC.

The Court has not yet issued a written order on the matter, so we will examine the positions of the Waked defense counsel, and the US Attorney, as they presented them, in court filings.

The Waked position:

(1)  The imposition of a forfeiture money judgment in this case would be inappropriate because the laundered funds are no longer in the possession of the defendant.

(2) There is no legal support for the imposition of the money judgment and the imposition of one would render the defendant's sentence illegal.

(3)  Any In Personum fortfeiture money judgment would consititute an excessive fine that would violate his rights under the Eight Amendment of the US Constitution.

The Government's position on the issues:

(A) Possession of the laundered funds is not necessary for the entry of a judgment.

(B) The use of money judgments in criminal forfeiture cases is well settled.

(C) The proposed money judgment is presumptively constitutional, pursuant to all the factors used to examine Eighth Amendment challenges. It is not an excessive fine under the Excessive Fines Clause.

The defendant is accused of laundering more than $20,000,000 over a period of years. US press is not covering this news, but the Panamanian press is carrying it as a major development, though the  legal principle that the Court based its ruling upon is not yet known, and will not be known until the order is issued.

 Panamanians have been unhappy with the OFAC sanctions, entered against Waked's extensive empire of legitimate businesses, which employ a very large number of people. The Waked money laundering organization, which has been an open secret in Panama for many years, enjoyed immunity from criminal prosecution by local law enforcement agencies, who were repeatedly made aware of its operations by local whistleblowers, to no effect. Corruption is suspected as the reason for the inaction.

Friday, April 6, 2018


As more details emerge regarding a major investigation, by Special Counsel Robert Mueller, into the role that certain Russian-American nationals played in fronting for Russians making illegal campaign contributions to the Trump for President Campaign, the question must be asked: of those targeted wealthy Russian businessmen, just how many hold Dominica CBI or diplomatic passports ?

Dominica has long been a favorite money laundering destination for Russian organized crime, due to its "user friendly" attorneys and financial institutions. While most of the activity is covert, experts believe that 200-300 Russian nationals hold Dominica CBI passports, and the high-profile case of offshore banker Vladimir Antonov serves to remind us that Russian criminals have long been active in Dominica.

Mueller recently interviewed Russian-Americans suspected of making campaign payments to the Trump Campaign, using funds obtained from dodgy Russian nationals seeking to influence Trump, as well as the election outcome. When one drills down to the original source of this money, do some of the Russians behind the payments have Dominican passports in their briefcases, in case they have to flee, to avoid criminal prosecution ?

Thursday, April 5, 2018


The vetting of applicants for Citizenship by Investment (CBI) passports, in the five East Caribbean states that operate such programs, Antigua & Barbuda, Dominica, St Kitts & Nevis, St Lucia and Grenada, has sufered from uneven effectiveness, due in large part to the fact that only investigations  at the limited level of Due Diligence are being conducted. This is totally inadequate for CBI purposes, as many applicants are from high-risk jurisdictions, and jurisdictions with unique issues, all of which demand that Enhanced Due Diligence (EDD) investigations are a necessity to properly evaluate such applicants.

Why Enhanced Due Diligence, you ask. Here are some of the major challenges that EDD alone can meet:

(1) The majority of CBI  applicants are from Asian and Middle Eastern countries, where the official langauges are in non-Latin alphabets. This means that legal names of applicants must not only be expressed in English, they must be transliterated into the Western alphabet. This is a recipe for illegal alteration of the identity of the applicant, into an alias that will not come back to his history, defeating the invetigation's purpose.

(2) Several of the jurisdictions that are attracting many applicants to the CBI program contain internationally-sanctioned individuals and entities, terrorist organizations, sanctions evaders, organized crime syndicates, terrorist financiers, and countries that are state sponsors of terrorism. All applicants from these high-risk nations demand an extremely high level of inquiry, which can only be adequately addressed by the broad scope of Enhanced Due Diligence.

(3) Organized crime members from the high risk countries, as well as intelligence agents, may employ counterfeit or altered forms of personal identification, and Due Diligence-level inquiries do not examine, with attention to detail, such documents, to determine their validity. Only Enhanced Due Diligence procedures, which are sensitive to the probability of forged and counterfeit documents, will actually discern the bogus identity documents, whereas simple Due Diligence procedures will not spot them.

Only through Enhanced Due Diligence procedures can the East Caribbean CBI states separate the dangerous and unsuitable criminal elements from the legitimate CBI applicants. Anything less than EDD will result in continued compliance failures in the CBI republics, and the embarrasing public exposure of more CBI passport-equipped criminals and sanctions evaders in global media. The East Caribbean Stares must employ EDD to remove them during the initial application process.


 The Government of Panama has reportedly obtained the testimony of one of the individuals who alleges that he hacked into the electronic files of the law firm of Mossack and Fonseca, and turned over all that information to the International Consortium of Investigative Journalists (ICIJ). This news came out in the aftermath of a report that Panamanian prosecutors plan to charge the NGO with industrial espionage.

The hacker, who allegedly has a dark past, has said that he acted under the direct orders of ICIJ staffers, though no details or evidence have yet been produced . His incentive for cooperting with Panamanian prosecutors is reportedly that he was not paid for hacking into, and delivering, the Mossack data, which became the notorious "Panama Papers," bringing down more than one national leader whose secret bank Panamanian accounts were exposed in the media.

Whether this witness' claims are true, or a fabrication designed to damage the ICIJ's reputation and image, and aid Jurgen Mossack & Ramón Fonseca's criminal defense is not known, but there are suspicions that this is possibly an effort to "shoot the messenger," and derail the criminal case against the  MF name partners, at the same time, given Panama's corruopt court system.

Wednesday, April 4, 2018


In the midst of all the global furor over the illegal issuance of diplomatic passports (especially to criminal elements for large amounts of cash), by the five Eastern Caribbean states, led by the Commonwealth of Dominica, Turkish lawmakers from the ruling Truth & Justice Party are reportedly demanding lifetime diplomtic passports for themseles, their wives and children under 25. Obviously their arrogance knows no limits.

Will someone please tell these Turkish politicians, at least some of whom are lawyers and know better, that without an actual diplomatic posting abroad, a specific duty assignment and detailed mission, and approval from the receiving country, holders of diplomatic passports are NOT diplomats. They should not attempt to bypass Customs, have their bags considered exempt from search, and enjoy immunity from criminal prosecution. President Erdogan, please read the Vienna Convention on Diplomatic Representatives, which is codified for all members of the United Nations. The abuse of diplomatic passports raises risk levels for crime and terrorist financing.


Reliable sources in Panama City have stated that the Government of Panama intends to charge the International Consortium of Investigative Journalists (ICIJ) with Industrial Espionage, due to its acquisition, and publication of, the so-called "Panama Papers," certain client internal files of the now-defunct law firm of Mossack and Fonseca. The evidence published by the ICIJ, which implicates the Mossack firm in extensive money laundering, tax evasion, and movement of the proceeds of corruption, cast Panama's major corporate law firms in a dark light, which reportedly infuriated them.

Panamanians, already unhappy with the mysterious disappearance of several files containing pending criminal charges brought againt Panamanian President Juan Carlos Varela, and the failure of the Government to bring Jurgen Mossack and Ramón Fonseca to trial, suspect that this new action is evidence of Varela's efforts to distract attention from his many problems.

The Panama Papers were files of the Mossack law firm that were most likely hacked by experts, and turned over to ICIJ representatives. Those individuals obviously broke the law, but isn't charging the ICIJ with espionage a stretch ? Considering the current situation in the Panamanian system of criminal justice, political considerations may trump the Rule of Law, and allow the prosecution of the whistleblower NGO.

Tuesday, April 3, 2018


The Panama Papers and Paradise Papers scandals resulted in the closure of Mossack and Fonseca, and the placement of Appleby under the harsh glare of public disapproval. Issues of money laundering, the facilitation of criminal tax evasion, and the aiding and abetting of the proceeds of corruption swirling around the exposure of lawyers engaged in rendering borderline dodgy "offshore" legal advice may have consequences not previously contemplated

The European Union seems to have had enough; Will the European Parliament recommendations now be implemented, and thereby actually curtail the attorney-client (solicitor-client) privilege, to suppress illegal attorney activities ? Here is a summary of what is on the table:

(1) Require that the reporting of suspicious transaction or other potentially illegal activities trump the attorney-client privilege.
(2) Require that lawyers who are involved in activity that falls outside lawyer's specific duties of criminal defense, legal representation or legal advice should be required, in some cases, to report certain information.
(3) Hold lawyers legally responsible for designing not only tax evasion schemes, but a;so aggressive tax plans that are punishable by law.
(4) Advise EU governments to issue guidance on the interpretation and application of legal privilege.

These recommendations could result in European courts ordering international lawyers based in the EU to disclose information about their dodgy clients, and the sordid methods they employed to hide their dirty money. 

Monday, April 2, 2018


A senior representative from Canada Immigration has advised that the agency is, as a matter of policy, flagging incoming traffic from Dominica, St Kitts & Nevis, Antigua & Barbuda, St Lucia and Grenada, all the East Caribbean states with active Citizenship by Investment programs. Canada is unable to determine who is or is not a CBI passport holder.

This action is due to the agency's concerns about the identities of CBI passport holders, who may have had a different name, place of birth, and/or date of birth entered into the passport than the correct information. Whether the passport photograph is of the holder, or has been swapped out from the photo originally attached in the East Caribbean are also concerns, based upon what they have been seeing.

The agency is also examining the names of relatives that the arrivals are purportedly visiting, and the other visa data, to insure that the holder of the passport is truly the individual listed therein.

Probing interviews (are they really interrogations ?) occur after the arrival is detained. and often involve extensive waiting time, until an interviewer is available. Given the denial many West Indians are exhibiting about the consequences of operating CBI programs with defective due diligence investigations of applicants, this information may give them a dose of reality, before they arrive and find they are now considered high-risk in Canada, 


The United States Supreme Court today denied Certiorari in Mark Sokolow vs. Palestine Liberation Organization et al, Case No.: 16-1071, which lets stand the Second Circuit Court of Appeal reversal of a $654m District Court verdict against the PLO and the Palestinian Authority,brought by American victims of terrorist attacks in the Middle East. The Second Circuit held that the trial court had no jurisdiction over a civil suit, involving attacks overseas.