IRANIAN SANCTIONS EVADERS USED TWO ST KITTS CBI PASSPORTS TO FACILITATE $115m SCHEME IN SWITZERLAND

 A Federal Indictment against an Iranian national resident in Canada, charging him with funneling over $115m out of Venezuela, through the US banking system, and into Switzerland, is yet another confirmation that white collar criminals and sanctions evaders employ CBI passports issue by the five East Caribbean states to commit transnational offenses, including Iranian sanctions evasion. Many of the cases involving money laundering and sanctions evasion involve the use of a CBI passport to conceal the true nationality of the criminal actor.

The indictment charges BAHRAM KARIMI with several offenses:
(1) Conspiracy to Commit Bank Fraud.
(2) Bank Fraud.
(3) Making False Statements.

The maximum penalty for the above counts is 65 years in Federal Prison.

To quote the indictment:

"On or about 2010, CC-1 and CC-2, incorporated two entities outside Iran using
 St. Kitts passports and a Dubai, United Arab Emirates address, for the purpose
 of, inter alia, receiving US Dollar payments related to the Venezuela project."
 United States vsd. Bahram Karimi, Case No,: 18CR-224 (AJC) (SDNY).

The abuse of Citizenship by Investment (CBI/CIP) passports continues to raise risk levels
at banks handling international transactions, as they are unable to correctly identify the
nationality, and at time the name, or bank clients using CBI identity documents. Please note that the two principal jurisdictions where CBI passport holders use them to evade identification as Iranians are DOMINICA, and ST KITTS. Compliance officers at financial institutions who service clients from those countries would be well advised to consider ALL those customers to require Enhanced Due Diligence, at account opening, and during transaction monitoring.

Readers who wish to review the indictment may access the complete text here.