I am still troubled by the Get-out-of-jail-free treatment afforded REZA ZARRAB, who was one of the kingpins in the billion dollar Iran oil sanctions evasion program he operated with ALI REZA MONFARED and BABAK ZANJANI, among other conspirators not yet brought to justice. Zarrab, instead of receiving a long sentence in Federal Prison, basically walked out of jail a free man. Obviously, his Substantial Assistance was substantial; it most likely involved assigning over millions of dollars in illegal oil profits, which Zarrab and his partners had diverted from Iran, and kept for themselves.
But in and of itself, turning over funds is generally insufficient to result in no prison time, which leads me to believe that there was much more involved, specifically incriminating information against others who were Iran sanctions evasion participants. My best guess is that the Iranian businessman ALI SADR HASHEMINEJAD, the Chairman and owner of Malta's Pilatus Bank, was the targeted individual, and that he hinself later admitted that he operated his portion of the sanctions evasion scheme through Pilatus. Zarrab gave up Ali Sadr and the bank, and Ali Sadr filled in the blanks on Pilatus' role. No other individual has been indicted by the US since Zarrab cooperated.
Any intelligent observer of the Pilatus Bank scandal knows that there appears to exist a unified and consistent scheme, among both local law enforcement as well as the regulatory and investigative agencies, to block any and all possible forward movement of charges against the bank, and its officers and directors, for money laundering and terrorist financing. That could only be so strictly enforced by the agencies if there was a primal fear of the consequences. American targeting of the Iran oil sanctions evasion pipeline, especially the payment sector, is powerful enough to frighten any foreign players into circling the wagons, so to speak, in order to insure that they were not targeted for OFAC and other sanctions that could essentially turn Malta in another Libya during the Gadaffi era, isolated, sanctioned and regarded as a pariah by new offshore clients.
Therefore, there must have been a significant level of culpability on the part of Pilatus Bank, in the Iran oil sanctions evasion scheme, regarding the circuitous funneling of illicit payments to Iran. We can only assume that the evidence and testimony contributed by Zarrab has now been supplemented by the cooperation displayed by Ali Sadr, who also walked away from his criminal case with no conviction. What's wrong with this picture ? Seized money trumps justice.
So, who will be the next individuals linked to Pilatus Bank to be indicted ? We cannot say, but I promise you it will be interesting. Stay tuned.