Kenneth Rijock

Kenneth Rijock

Saturday, January 20, 2018


The trial judge in the Iran Oil-for-Gold sanctions evasions case, where gold trader Reza Zarrab entered a plea, and Halkbank deputy CEO Mehmet Atilla was found guilty, has made a special request to all counsel of record. He has demanded specific details of all contacts between counsel and both the Turkish and the American governments, where not attorney-client related.

The complete text of the order follows:

                   "In connection with the upcoming sentencings in this case, and the Court's 18 USC  §3353 (a)*  analyses, the parties are directed to include in their written submissions a description of all non-attorney client privileged contacts  (i.e. meetings, calls, texts, emails, etc.)  by all counsel, including Turkish counsel, with any officials or the United States and/or Turkish governments, and relating to the prosecution and/or disposition of this case. Please include 1) the date of such contact(s); 2) t   the names of those present, or otherwise involved or copied; 3) the purpose of the contact. and; 4) the outcome of such contact." Order entered January 18, 2018.   

Is the Court going to take the actions of defense counsel's "outside consultants," the former US Attorney General and the former Major of the City of New York & ex-US Atty., who met with Turkish government officials, seeking a possible political solution to a Federal criminal case ? We cannot say, but expect the unexpected at the time of sentencing, and it may prove costly for the defendant.

* The factors involved in sentencing determinations.

Wednesday, January 17, 2018


The Minister of Foreign Affairs of the Comoros Islands, Souef Mohamed El-Amine, has revoked and cancelled 170 Comoros passports, all issued by Albert Karaziwan's Semlex Group, to foreign nationals, on the grounds of abuse. Additionally, he has cancelled Karaziwan's diplomatic passport, which names Karaziwan as a traveling Ambassador and Counselor to the President of the Comoros Islands. as well as all those passports issued to his wife and child.

El-Amine, whose announcement was carried on public media of the Comoros Islands, also cancelled all appointments of Honorary Consul, Vice Consul, and Investment Counselor, that were illegally conferred by Karaziwan and Semlex Group, his company, which printed and sold the passports to foreign nationals, including the brother of Iran oil sanctions evader, Reza Zarrab, who recently pled guilty in US District Court in New York.
Albert Karaziwan, owner of Semlex Group

All revoked passports were cancelled of record as of January 15, 2018. The Government of the Comoros Islands has demanded further information, from Semlex, on 158 passports it issued and delivered to foreign clients. It is not known whether criminal charges will be brought.

We recently published an article detailing Karaziwan's dark past, and the fact that a large number of bribes and kickbacks have been reportedly paid, by Semlex, to obtain lucrative passport and ID card business in several countries in Africa. Many of the passport applicants in countries where Semlex operated reported clearly excessive fees being charges to consumers, with little of those fees ending up in the treasuries of each country that granted Semlex the contract.

We wonder whether the Commonwealth of Dominica will now cancel its massive ID card project with Semlex, due to this new development. It is suspected that a very large bribes or kickbacks were paid to insure acceptance of the contract, and we are curious about who in Government signed that contract.

© Kenneth Rijock 2018. Contributed by Kenneth Rijock.

Tuesday, January 16, 2018


Semlex Group, the Belgian biometric passport and ID card firm that is currently working for the Commonwealth of Dominica, and whose goal is to create ID cards for all citizens there, has a dark reputation in Africa, where it vends passports, and provides other ID services. Simply put, it pays substantial bribes & kickbacks to government officials, to obtain the business.

Additionally, it intentionally charges individuals in those countries for whom it is manufacturing passports clearly excessive fees, and then passes on only a small fraction of its profits to the countries that it services. Some of the passport charged are so exorbitant that they are not affordable to the average individual.

We have previously detailed the scandal in the Comoros Islands, involving Semlex, and its owner, Albert Karaziwan, a Syrian national who is believed to have funds the company's startup operations through an extended period of criminal activity, a decade ago, where he sold counterfeit diplomatic passports in Europe.

Albert Karaziwan

Some of the illegal countries where bribes & kickbacks, or other illegal acts of Semlex Group,  are  known to have taken place:

(1) A $700,000 bribe paid by Karaziwan, to get the government passport business in the Democratic Republic of the Congo.

(2) Collecting such clearly excessive fees, from passport applicants, in Mozambique, that the contract was terminated. The citizens could not afford the fees.

(3) Bribes paid in Guinea-Bissau.

(4) Excessive passport fees charged in Madagascar.

(5) Bribes paid in Chad.

We wonder exactly how much  Semlex, through Karaziwan, is kicking back to individuals in the government of Dominica, and whether ID cards will end up for sale to foreign nationals, at high prices, to establish a bogus identity.
©2018 Kenneth Rijock; contributed by Kenneth Rijock.

Sunday, January 14, 2018


Malta's problems with the backgrounds of the dodgy characters to whom its scandal-ridden leadership is selling EU citizenship continue to damage its already tawdry reputation. Recently, an Iranian national gained entry into Canada, on the strength of his Maltese CBI psssport, where he sought to purchase a property containing six residences. Enhanced Due Diligence was performed on this individual by the bank, in connection with the sale, and it was learned that the person was on the US Office of Foreign Assets Control (OFAC) sanctions list.

Shortly after he was exposed as a designated OFAC national, the "Maltese citizen" abruptly left Canada. Why did the citizenship consultancy, the due diligence firm responsible for vetting applicants, and lastly, the Government of the Republic of Malta, on this compliance malpractice ?

If this is an example of the quality of applicants accepted by Malta for its passports, which carry Schengen Zone privileges, then ALL Maltese passport holders, whose place of birth is shown to be outside the country, should be subject to Enhanced Due Diligence investigation, by compliance officers, as well as customs & immigration officers when they seek entry to The United States and Canada. Perhaps Malta should suspend its CBI program, until they clean it up.


© 2018 by Kenneth Rijock; contributed by Kenneth Rijock.

Saturday, January 13, 2018


Insiders in Antigua have alleged that unknown government parties there have engaged a prominent international hacking firm, which ostensibly will check Antigua's online security levels. Given the fact that a number of sitting governments in the East Caribbean have been accused of using hackers to attack their Opposition,  reports of additional covert acts must be taken seriously, noting that the ongoing corruption matters have given many other East Caribbean states a black eye, in the view of many North American-based compliance officers.

 Some Antiguans are concerned that government-funded Internet manipulation and anonymous attacks upon individuals that anyone considers a threat to elected officials might be employed to damage opposition leaders, and impact their effectiveness as whistle blowers of misconduct. There are persistent rumors that the hacking firm is not only protecting websites for clients, but is also engaged in illicit activity, as ordered by a number of their government their clients, and that this is the true nature of their engagement. This has not yet been confirmed.

It is not known what the response will be when Antiguans are fully informed about such questionable activities, it is expected that they will voice their concerns to government.Who really hired the hackers ?

Last year, we reported on similar covert (and illegal) Internet projects, targeting Opposition figures and parties, in the Commonwealth of Dominica. That illicit program is believed to be still in operation there.

Friday, January 12, 2018


Compliance officers at international banks know that a major component of Country Risk calculation is a country's court system. Will a foreign financial international institution, or its clients be able to trust a nation's courts to follow the Rule of Law.  Is justice consistently served there regarding bad actors, financial criminals, or corrupt officials who break the law, in the event a civil suit, or criminal action becomes necessary to protect interest, or recover losses ?

We regret to report that, in an action in the Commonwealth of Dominica this week, a sitting judge released criminal proceeds, previously frozen at the request of the US Securities & Exchange Commission, in a case against the prominent international fugitive and fraudster, Spanish national Pedro Fort Berbel. Berbel, who operated a major Ponzi scheme in Florida and Spain, has been literally hiding out in Dominica, having fled there to evade justice, after defrauding investors of $38m. He is now protected by the corrupt local government, which has repeatedly given safe harbor to career criminals on the run, most recently international sanctions evader, the Iranian Alireza Monfared, whose case permanently gave Dominica a black eye.

Ponzi schemer Pedro Fort Berbel
  Monfared is believed to have been an intelligence agent of Iran, who went rogue, and stole billions in illicit oil profits from his country, with Reza Zarrab and Babak Zanjani. Monfared had an illegally-obtained diplomatic passport, in violation of a United Nations treaty on diplomats. There are an estimated five hundred such illicit Dominica diplomatic passports in the hands of financial criminals, Middle Eastern terrorists, and Chinese & Russian Organized Crime members.

The SEC, which has a major civil suit* pending against Fort Berbel, in US District Court in Miami, sought to recover funds for investor victims, by obtaining an order from the High Court of Justice, without notice, to freeze funds in several accounts in Dominica banks.**The funds had apparently been hastily transferred to accounts of Fort's local attorneys, including Kondwani Williams, whom we have covered in earlier articles. Williams allegedly represents fraudsters who own Inter-Oceanic Bank of the Caribbean, a virtual bank whose headquarters is actually located within Williams' seedy law offices in downtown Roseau. The bank closed up its website as soon as we reported on its activities; it was seeking investor capital of a minimum of USD$100,000, but it appears to also be a Ponzi scheme.

The judge in Dominica, who by reputation is closely associated with the corrupt local government of Prime Minister Roosevelt Skerrit, unfroze the accounts, in clear disregard for the massive amount of incriminating evidence, and the Rule of Law. The claims of Dominica attorneys linked to the regime, that the SEC failed to controvert self-serving affidavits, filed by Williams and others, is merely an attempt to justify what was truly a political ruling, intended to favor the sitting government, who has reaped lucrative profits, by its relationship with Fort, who allegedly holds both CBI and diplomatic passports from Dominica.

PM Roosevelt Skerrit & Attorney Kondwani Williams
The action of the Court is not only a setback for the SEC enforcement and collection action, it demonstrates that the judiciary, as we have seen repeatedly in Venezuela, an ally of Dominica, acts according to the demands of government officials, and not pursuant to the Rule of Law. What subsequent action the United States takes, including but not limited to OFAC sanctions, passport restrictions on Dominica passport holders, or criminal indictments, is not known at this time, but expect some blowback to the unexpected, and utterly corrupt, court decision.

Judge Birnie Stephenson

Since we cannot trust the court system to be fair and impartial, and to follow decisional and statutory law, we must now raise Country Risk to its highest level, into the plateau where no financial transactions should be either initiated, or even contemplated, due to the clear and present dangers present in Dominica at this time.
*Securities & Exchange Commision vs. Pedro Fort Berbel, et al, Case No.: 17-cv-23572-FAM (SDFL).
**  All the banks that accepted Fort's Ponzi profits were subsidiaries of Canadian banks:  Nova Scotia Bank, First Caribbean International Bank, and Royal Bank of Canada. Serious questions have been raised by compliance officers familiar with the region, as to how these banks allowed funds from a known Ponzi schemer to be accepted, and why the attorneys accounts were not closed.

Thursday, January 11, 2018


 Don't be surprised if Panama's extradition request for Ricardo Martinelli is further delayed, or even declined, on procedural, rather than substantive, grounds, later this month. Rumors flying around Panama state that the fugitive former president has classified information about US operations in Latin America, the public disclosure of which could severely damage diplomatic relations between America and several Central & South American nations.

 Keeping those secrets is apparently more important than letting Martinelli face Panamanian justice; Panama's reformers will be unhappy, especially since Martinelli allegedly has incriminating evidence against the country's current president, Juan Carlos Varela, who was Vice President, and Minister of Foreign Relations under Martinelli.

There were a number of defects, ostensibly under Panamanian law, that Martinelli's attorneys have asserted could provide the legal basis for a Federal Court ruling rejecting Panama's extradition request. Most legal observers in Panama City has opined that they are without any merit, but it may provide some cover for a ruling. Did he have diplomatic immunity from extradition, due to his contrived appointment in the Latin American Parliament ?

Exactly how did Martinelli acquire this classified information is not known, but his illegal electronic surveillance program reportedly included the US Embassy in Panama City. There's got to be a violation of US law in there somewhere. Why hasn't he been charged in the United States, where he has been living since Panamanian justice starting making a move against him ? Perhaps he was a Confidential Informant for a US agency after all.


Readers who have accessed our recent article Alert on Dodby Brass-Plate Bank in Dominica offering "Investments," might be interested to know that, right after our article appeared, the bank took down its entire website. It seems that these fraudsters could not handle being exposed. I wonder if they have fired their sleazy Dominica attorneys, who are now Persons of Interest to the US Securities & Exchange Commission, due to their representation of the fugitive Spanish fraudster, Pedro Fort Berbel ?

Tuesday, January 9, 2018


An investor from Singapore, who has inquired about placing his money into Inter-Oceanic Bank of the Caribbean, Inc., an offshore bank organized and reportedly operating in the Commonwealth of Dominica, has exposed a newly emerging* financial entity, but one with more Red Flags than compliance officers will ever be comfortable with.

This is the principal office of the bank, as listed on its website, which is quite professionally done, but which tells the visitor absolutely nothing about the bank, its officers and directors, history or correspondent affiliations. There is no sign, or other indication that there is a bank on the premises, meaning that it is what we used to call a brass-plate, and now designate a virtual, bank. There is a sign there, as you can see below, but it is not a banking sign.

the Shingle at 24 Hillsborough

It is the chambers of a local law firm,  Williams & Horsford; Partner Kondwani Williams has been in the news of late, as the reputed lawyer of the fugitive international fraudster, and SEC target, Pedro Fort Berbel. Readers who are unfamiliar with that case may wish to access this article: Kondwani's Neck in the Noose.

Roosevelt Skerrit & Kondwani Williams

The property, by the way, fronts on two streets, and also has an address of 30 Great Gorge; the tyre store appears to come back to Lennox Lawrence, a lawyer known to represent the Prime Minister of Dominica, Roosevelt Skerrit, whose sins & transgressions have appeared on this blog many times,

Does this look like a bank??
 Getting back to the bank itself, there is no information available as to the identity of Inter-Oceanic's beneficial owners, but reliable Panama sources assert that it is Russian Organized Crime, and point to its deceptively similar cousin, Inter-Oceanic Bank of Panama, a fraudulent institution whose banking license was revoked. The Panama bank, now defunct, was owned and controlled by Russian Organized Crime.

The UK telephone number listed on the bank's slick website betrays the fact that it is a virtual bank, run from the United Kingdom, by person or persons unknown, and therefore immune from prosecution. This is a bank that is asking foreign investors for $100,000 minimums, paying interest only for two years, with the entire principal to be returned at that time. Can anybody say Ponzi scheme ? Risk levels are through the roof, if not in the Stratosphere.

Should anyone be foolish enough to risk their capital by investing at Inter-Oceanic Bank of the Caribbean, given this information ? Caveat Emptor.

* The bank was reportedly organized and incorporated in 2015, but never listed on the government website until recently. Was this a shelf bank, incorporated earlier, and sold by Williams' law firm in 2018 ? Aged entities are used by many fraudsters to confer legitimacy upon very new operations.

Monday, January 8, 2018


Remember Francisco Illarramendi, who ran two unregistered hedge funds in Connecticut, which soon became massive Ponzoi schemes that cheated PDVSA pension funds out of millions ? Convicted, even after he changed lawyers more often than anyone in recent Federal memory, he still takes up the Court's time with filing totally devoid of legal merit except now he does it Pro Se.

Readers may recall his port-conviction  §2255 petition, his quest to vacate  his sentence and conviction. In that filing, he sought to be released from custody, into Supervised Release, which is a form of supervision, akin to parole, that Federal inmates must serve after they complete their incarceration. It is not available for any other purpose, other than to keep tabs on former inmates, lest they re-offend.

As expected the Court denied Illarramendi's motion, holding " The Court has no authority to grant Supervised Release to a sentenced inmate," on December 22, 2017. Illarramendi then took an Interlocutory Appeal*, claiming, his 2255 petition was in a nature of a Habeus Corpus, as he is contesting his sentence and conviction, and therefore, the Court had the inherent right to release him.

Illarramendi's jailhouse attorneys are either seeking to create new law, in good faith, or merely pacifying a "client" who simply will not accept the finality of his sentence & conviction.In any event, they appear to be wasting the Court limited resources. Are sanctions applicable here ?
* An appeal from a non-final order or judgment; can only be taken from certain specific orders.

Sunday, January 7, 2018


The list below comprises the non-governmental organizations, chartered associations, nonprofits, and unincorporated associations whose members have been banned from entering, and conducting any activities in Israel. This is due to the fact that these entities are engaged in BDS operations, which attempt to discourage foreign firms from transacting business with Israeli companies, or the Government of the State of Israel.

Inasmuch as the funding sources of many of these entities is suspect, compliance officers should treat all of them as high risk for account opening, international wire transfers, letters of reference, or any other purpose which will expose the bank to potentially lethal levels of risk. This due to Hamas, a Specially Designated Global Terrorist Organization (OFAC SDGT), which is funded by Iran, to the tune of hundreds of millions of dollars each year. Proceed to conduct business with any of these banned entities at your own risk, due to the clear and present danger of terrorist financing.

Note carefully the use of abbreviations identified with many of these organizations, which serves to further anonymize them in the eyes of the legitimate financial world.





If you have been following the extradition proceedings of Ricardo Martinelli, you know that they appear to have been unnecessarily delayed a number of times. We have reportedly on the repeated rescheduling of Oral Argument, the failure of the Attorney General to order extradition, following the Magistrate Judge's order, and the painfully long time it took to actually take Martinelli into custody, when his location in Miami was well known. See "Yet another Delay of Martinelli Extradition Hearing Points to Trump, "January 6, 2018, available here.

New Panamanian sources allege that Ricardo Martinelli, who reportedly maintained a stable of call girls, for VIPs he wanted to cultivate, had one of his sons escort Donald Trump, then a private citizen, to the Le Palace Nightclub, more than once. If these sources, who allege that they were physically present, are being truthful, then the rumors that Martinelli is threatening to expose that story, should the US Government proceed with his extradition to Panama, may have a basis in fact. Whether there are video recordings of Trump is not known.

Again, we ask that Martinelli's Habeus Corpus petition, and the rest of the court file, be released to the public, so that there rumors can be put to rest, once and for all.  


Friday, January 5, 2018


 The US District Judge assigned to hear the Habeus Corpus petition, filed by the fugitive former president of Panama, Ricardo Martinelli, has again rescheduled oral argument on the petition, this time to January 23, 2018.  This is the third time that this hearing has been scheduled in the month of January, a clear indication that something major is afoot.

Rumors are flying, in official circles, in the Republic of Panama, concerning the true cause of the multiple delays, and the reason why the entire court file is restricted, and unavailable, meaning that access is denied, although the file has not been formally sealed by the Court, an effective way to conceal information that should be available to the public. What is going on ?

Sources within Panamanian government circles have been reminding us that Martinelli's illegal electronic surveillance programs, both with audio & video capability, not only eavesdropped inside the US Embassy, it had eyes and ears inside the Trump Ocean Club, as well of other hotels, and even houses of ill repute. Now you may begin to understand the gravity of some of the surveillance tapes.

In addition to illegal surveillance of US diplomats, law enforcement agents, and intelligence agents engaged in covert operations out of the embassy, the tapes and recordings are said to have captured Trump family members, and President Trump himself (in Panama without his wife) . Some of the illegal recordings allegedly shows some individuals engaged in "R" rated activities, in a specific location that Martinelli'a nationals security division had under constant surveillance.

 Some of this information allegedly actually appears in Martinelli's habeus court filings; now you understand the sensitivity of all the materials in that file, and why it is sealed. No wonder the Government is hesitant to hold the hearing. Will the courtroom be sealed, and any press or spectators barred ? We cannot say, but apparently there is a lot more of the story (under the sheets ?) than the Court is willing to show the press and public.

Wednesday, January 3, 2018


A Federal jury in the landmark Iran oil-for-gold sanctions evasions case against Mehmet Atilla, the Turkish Halkbank executive, has entered a guilty verdict against him, on five of the six charges. The case, more commonly known as the Zarrab case, after the original primary defendant, Reza Zarrab, the Iranian-Turkish gold trader who ran the massive operation from Turkey, involved defendants who had never entered the United States, nor had companies there, but were charged nevertheless, upon the theory that American banks were defrauded, when the defendants evaded US & international sanctions against Iran, and moved  US Dollars through banks in the New York financial system.

Atilla was found guilty of:
(1) Money Laundering Conspiracy.
(2)  Conspiracy to Defraud the United States.
(3)  Conspiracy to Defraud the IEEPA.
(4)  Bank Fraud.
(5)  Conspiracy to Commit Bank Fraud.

The jury found him innocent of the money laundering charge. Sentencing has been set for April 11, 2018. We note that Reza Zarrab's sentencing date (he pled guilty just before the trial) has not been sent, which indicates that the Government probably has plans for him to render additional Substantial Assistance, before his case is scheduled for sentencing.

Zarrab could potentially have spent the rest of his life in an American prison, due to the charges against him, but his cooperation will, most likely, result in a greatly reduced sentence, provided it result in new indictments, or recovery of criminal profits by the Government.

A large number of possible additional defendants could be indicted, based upon Zarrab's forthcoming probable Grand Jury testimony, including Zarrab's former partners, Babak Zanjani, and Alireza Monfared, though both are in custody in Iran. Other possible defendants are located in Malaysia, Iran, Turkey, and the Commonwealth of Dominica. 


Our article,  Is Ricardo Martinelli Attempting to Blackmail the United States to Avoid Extradition ? in which we questioned why Martinelli's Habeus Corpus petition file is not available to the press or public, has resulted in substantial feedback from our trusted Panama sources. You may not like the answer.

By way of background, remember that the Panama criminal charges that Martinelli is desperately seeking to avoid or evade, deal with his massive illegal electronic surveillance of Panamanians, which was conducted by his national security agency. Some victims have claimed that he subjected them into sexual blackmail, using the tapes, forcing certain female Panamanians caught in the act by his cameras and tapes, to have sexual relations with him, or face public exposure of their infidelity to powerful husbands or paramours.

Reliable Panamanian sources have now stated that Martinelli's electronic spies also eavesdropped on the US Embassy, its staff and officers, and that Martinelli thereby received classified data on covert US operations in Latin America. He is now allegedly threatening to expose these extremely sensitive matters, unless his extradition is denied by the District Judge in Miami who is handling the case.

One source went so far as to state that some of the information regarding data Martinelli claims to hold was actually included in a filing one of Martinelli's attorneys made, in the Habeus case, and that is why all the pleadings are not available to the public. We are unable to confirm this specific fact, as access to the entire file remains off limits, for some unknown reason.

Is Martinelli actually trying to blackmail the United States into turning him loose, to flee to a jurisdiction  from which he cannot be extradited by law ? We do not know, but we would certainly like to see the contents of that Habeus Corpus file.


 Panama's fugitive former president, Ricardo Martinelli is reportedly bragging to his supporters that he will never be extradited from the United States, to face justice in his own country. Admittedly, there have been unexplained delays in what is generally an efficient and smooth process in the US. What is taking so long ? 

When a Federal judge, in Florida, ordered Martinelli's extradition, months ago, the US Secretary of State failed to implement that decision, which is curious. Then, Martinelli's army of attorneys, including a former US Attorney, filed a petition for a Writ of Habeus Corpus, seeking, on procedural grounds, to block his extradition, causing still further delays. Oral Argument on the petition has been scheduled for later this month.

\Was the petition filed for purely dilatory reasons, as many Panama watchers believe, or is there something darker here ? Cynical Panama observers believe that the real reason the petition, and all supporting documents, are unavailable to the public and press is that some of the allegations in the petition are eight extremely embarrassing to the United States Government, or contain classified information which can not be exposed.

(1) Was Ricardo Martinelli, art some point in his dirty, corrupt career, a Confidential Informant for an agency of US law enforcement, or an intelligence service ? We know that many unsavory Latin American characters supply actionable intelligence to the United States, either to obtain immunity from prosecution, or for money, and his makes most Americans uncomfortable, as we then support what is generally a corrupt status quo.

(2) Or is it something even worse ? Has Martinelli, in his desperation to avoid Panamanian justice for his crimes, played his trump card, a disclosure that will shake the confidence Americans have in their government, and its operations overseas ? Will the hearing on the petition be closed to the press and public for that reason ? If so, what about government in the sunshine ?

(3) Lastly, is this simply a bluff by Martinelli, allegations made, in the petition, concerning disclosures that he has threatened to make, if extradited, which could harm American foreign policy goals in Latin America ? Is he threatening to expose some classified, dark American operation overseas ?

Alas, we cannot prove, or disprove, any of the above three theories, without access to the court files and the pleadings contained therein. Whether this is simply much ado about nothing, or a serious problem for the US Attorney General, we cannot say, but we will be watching.

Tuesday, January 2, 2018


If you read my recent article, Is St Lucia's CBI Program at Risk, Due to Dodgy Financial Advisory-turned Private Bank ?* you know that the UAE-based DevVere group has acquired the private banking arm of Dominica's Arton Bank. Given the many publicly known global sins and transgressions of Devere Group detailed in that article, ask yourself if the Commonwealth of Dominica Financial Services Unit, who totally failed in their legal responsibilities in approving the sale to such an unsuitable applicant, is useless as a regulator, and should have all its staff terminated forthwith, lest they commit any further acts of malfeasance, and the unit's responsibilities outsourced.

Whether bribes were paid would be the subject of a inquiry, in a normal jurisdiction, but rampant corruption drives the national economy, so do not expect to see an internal investigation.

The Offshore Banking Act of 1996, Chapter 17, details what acts and deeds disqualify any entity for qualification for an offshore banking license, and by my own count, the Devere Group, there are at least five grounds that prohibit DeVere from ever holding a banking license in Dominica. The statute can be found here, and readers are invited to review the complete text.

The question for 2018 is simple: if the Financial Services Unit approved the sale of a licensed entity, under its supervision, we question how many other offshore bank licenses have been awarded to financial gypsies, tramps & thieves. No wonder domestic banks in Dominica have been losing their correspondent accounts in Western countries; those offshore banks are nested in the local ones.

* Kenneth Rijock's Financial Crime Blog, January 1, 2018.


The US District Judge assigned to Ricardo Martinelli's Habeus Corpus petition, the fugitive Panamanian ex-president's last chance to avoid extradition to a very hostile Panama. has ordered that Oral Argument on the petition be rescheduled to January 16, 2018, at 2PM.

All the pleadings in the court file remain unavailable to the public, reinforcing the probability that the former president, whose corrupt actions while in office, eclipse all his predecessors in scope, has alleged sensitive and/or classified information in his filings, the public disclosure of which may severely embarrass the United States, or one of its law enforcement agencies.

Whether Martinelli was a  Confidential Informant remains an open question. The late General Noriega was a known asset of the United States intelligence community, and the convenient entry of Ricardo Martinelli into the United States, when corrupt foreign leaders are barred by statute, has repeatedly been an issue of discussion among Panama observers.

We trust that the much-delayed extradition will finally be concluded, and that the people of Panama will see that justice has been served, and the Rule of Law followed, in Martinelli's case.   

Monday, January 1, 2018


If St Lucia wishes to avoid the scandals that have permeated most of the other East Caribbean CBI programs, it had better start vetting companies that are seeking to establish a presence in their country, attracted by the prospect of lucrative CBI-related business. A dodgy financial advisory was allowed to purchase a private bank operating in St Lucia, and this act of due diligence malpractice, on behalf of the country's banking regulators, could result in grossly unsuitable CBI applicants, or even sanctioned terrorists, with CBI passports, as they might use this private bank to bring their illicit funds in.

The Dubai-based DeVere Group is a high-powered sales company, whose subsidiaries and affiliates have been sanctioned in several jurisdictions, including Singapore & Hong Kong,  an UK FCA Cease & Desist, and a pending SEC investigation, is owned by Nigel Green, who was formerly with the failed Britex International, and who later bought Britex. The DeVere Group purchased the private banking license of Dominica-based Arton Bank*,  naming it DeVere Group Bank.

Devere's aggressive sales staff, generally untrained in finance, have a long history of client complaints, closed offices, unhappy employees who had to quit, and misrepresentations of material facts to customers. It presents a clear and present danger to the CBI program, and its banking license should never have been approved for St Lucia operation.

Five seconds on any web browser would have informed St Lucia regulators that the DeVere Group should not have been approved to operate a local financial institution, where funds, coming from opaque sources in the Middle East, could support CBI applications from criminal elements, or even members of specially designated terrorist organizations.This is not only totally unacceptable, from a compliance standpoint, it indicates that St Lucia, in its zeal to get on the CBI cash flow bandwagon, has failed to act as a proper gatekeeper.

Given the new financial support, granted to Middle Eastern terrorist organizations, including Hamas & Hezbollah, by Iran, there is a danger that St Lucia CBI passports will end up in the wrong hands. Will the Government of St Lucia be the solution, or simply another bad CBI jurisdiction ?
* We wonder who in Dominica's banking regulatory agency approved the sale, given the buyer's history, but that negligence is a story for another time. It does validate claims that there are major due diligence deficiencies regarding offshore banking licenses in Dominica. 


Recently, when a firm exploring the waters off Grenada made what could be a significant discovery of a natural gas deposit, the government chose not to notify the public. The good news eventually leaked out, when a newspaper in nearly Trinidad broke the story, but Grenada's government officials quickly downplayed the event, warning that it was not conclusive proof that a major natural resource, which would benefit Grenada immensely, has truly been uncovered.

Would you like to know why ? I think the answer is buried deep within the Laws of Grenada, specifically Chapter 240, the Petroleum and Natural Gas Deposits Act, which deals with petroleum exploration and production. It was enacted during the prior administration of the country's current Prime Minister, Keith Mitchell, who stands for reelection in 2018, in the wake of multiple corruption allegations, some of which have been previously reported in this blog.

The act provides, in subsection 10, Contents of Exploration License, at 10(1)(c)(2):   "The Minister shall include, as a term or condition in an exploration license, a provision whereby the Minister* receives the right to acquire an interest, in any venture for or recover petroleum, which may be carried in any block in the exploration area".

This is the essence of Conflict of Interest; all private oil exploration or development projects must have a senior government official written in for a share. How on earth can he be objectively expected to make energy decisions for Grenada, when holding an ownership interest in companies locally involved in this industry ? He is disqualified by his share in the company. This is some sort of cruel joke played upon the people of Grenada by its corrupt & eminently greedy leader. No wonder PM Mitchell tried to keep the natural gas discovery quiet.

* "Minister" is defined in the the statute as the minister involved in petroleum matters, be advised that is the Prime Minister, Keith Mitchell, who also holds the portfolio as Energy Minister.