Sunday, June 30, 2024


In our search to obtain further information on specific cases involving the illegally discounted sale of Citizenship by Investment (CBI/CIP) passports by the St. Kitts CIU at the price of $80,000, we were contacted by an individual who stated that she has seen correspondence and evidence confirming that her husband paid that amount, and that he obtained an SKN CBI passport for their minor son totally without her knowledge and consent. This is an extremely disturbing development, and indicates that the approval process contains a fatal flaw which could facilitate parental kidnapping, which is often conducted across international frontiers, and is a serious felony.

This is relevant because the parties are in the middle of a contested divorce, and parental kidnapping, the illegal removal of a child by the non-custodial parent, is every mother's nightmare. We constantly see stories where Western mothers, married to a father with Middle Eastern background, learn that their minor child has been taken, without their authorization, to the father's birth country, and that he thereafter refused to return him to the custodial parent, in a country where the mother has little or no rights in court to secure his return.

To accomplish this crime, the father would have had to have had the complicity of both the passport vendor/consultancy, and the St. kitts CIU agency, for the mother's verified signature for a minor child is a legal requirement on an application. The fact that this was accomplished covertly means that the CBI application process could be accomplished without a face-to-face with both parents, which is a recipe for fraud, or worse. We wonder how Les Khan could approve such negligent conduct, and must assume it was intentional. Faron Lawrence also owes us some answers.

If the St. Kitts CBI agency can issue a passport to a minor without the mandatory consent required, we are now wondering what other illegal "shortcuts" the individuals responsible for processing and approving the applications engage in, in their quest to collect the government charges in the lucrative program. Is it not time for an external audit of all St. Kitts CBI passport application files, to ascertain whether other illegal tactics the CIU engaged in are illegal, immoral, Human Rights violations, or represent a Clear and Present Danger to applicants, third parties, the global banking structure, terrorist financing, or other threats to peace and security?


If you follow litigation in Latin America, you know that the trial judge dismissed all the charges against twenty eight defendant in the PANAMA PAPERS case, including those pending against the surviving owner of MOSSACK & FONSECA, the infamous corporate service firm responsible for facilitating many of the world's most corrupt PEPs seeking to conceal bribes and kickbacks from the citizens of their countries.

The laughable grounds cited by the Court in Panama, that the Chain of Custody in the evidence seized at the M & F offices by the authorities had been broken, and therefore, it was not admissible, are a cruel legal joke being played on the compliance world. Panama's utterly corrupt judicial system has failed in its most significant case of the decade. Compliance officers now have no choice but to raise Country Risk on that nation to the highest level, which means no wire transfers to or from its banks over $2000, or any new clients onboarded during Customer identification Procedure, if you are truly operating a risk-based compliance program at an American financial institution or broker-dealer.

Anyone who declines to red-line Panama, for their clients and customers seeking to place investments could themselves end up in litigation, when the client suffers a loss, and finds out that Panama is just too high risk to do business in. This is definitely willful blindness territory. Govern yourselves accordingly.


As we fully expected, once one East Caribbean CBI state declared that there would be a thirty-day delay in enforcing the uniform minimum $200,000 investment requirement contained in the Memorandum of Agreement signed back in March, others chose to follow that dIlatory path. St Lucia's CIU has announced it will also give its passport vendors & consultancies the month of July to process what it claims are "pending" applications.

Remember, the Memorandum was issued back in March, and there is no excuse for all this last-minute delay, confirming Bad Faith on the part of the beleaguered St. Lucia Government, who is, like Antigua, not offering any reason other than legislative process. If this was not an absolute priority, given threats by the UK and EU to drop the hammer on visa-free access without true and effective reform, I don't know what is. Senior officials, already seen to publicly exhibit fear and loathing about transparency, continue to drag their heels on CBI,

While we completely understand that filed but not yet processed CBI economic citizenship applications should receive some sort of consideration, St. Lucia has declared that unfiled applications would be honored so long as the CBI consultants advise that they have the client's deposits on hand. In our humble opinion, such is a recipe for disaster, for far flung CBI vendors, who are generally not licensed professionals, but only sales agents working on commission need only report their possession of deposits, which cannot be independently verified by St. Lucia or any third party.

One last delaying tactic we have observed. St. Lucia officials announced that they are closing government forthwith, as a Tropical Storm approaches the Caribbean, A direct hit by hurricane force winds appears highly unlikely for the island nation, and we therefore the question; is this but another dilatory move, to avoid answering how many CBI passport files were transferred to Caribbean Galaxy (7,000 perhaps) , and how long will the government delay in reopening the CIU after the storm passes? Bad Faith appears to be the order of the day in St. Lucia.

Saturday, June 29, 2024


TIMOTHY HARRIS, the former Prime Minister of St. Kitts & Nevis, and who previously filed a Defamation proceeding against Philippe Martinez and MSR Media SKN, has replied to MSR's Renewed Application to Conduct Discovery for Use in Foreign Proceedings, in a US court.

The Response:

(1) Asserts that all the procedural requirements of §782 have not been fully complied with.

(2) Cast doubt on whether a court in St. Kitts will admit any bank records obtained in this manner, in the Defamation proceedings, under Kittitian law.

(3) Requests a protective order barring any evidence so obtained from Public Disclosure, and from being used in any other legal proceeding.

Please note that MSR Media and Mr. Martinez have filed a $150m civil RICO suit in US DIstrict Court in Tampa, seeking Treble Damages.This is obviously the proceeding that Harris seeks to deny access to any and all evidence obtained in this separate proceeding. Additionally, there could be other civil suits brought by parties alleging that they are victims, and of granted, such a protective order would be applicable to their cases as well.

Obviously, Harris greatly fears the publication of U.S. bank records that could prove the illegal transfer of hundreds of millions of dollars to the United States, China, and Dubai could implicate him in a major bribery and kickback scheme, and possibly show illicit payments to other government officials and Politically Exposed Persons in St. Kitts and elsewhere.

We shall continue to monitor this proceeding on a daily basis, and report on all developments as they occur.


Tomorrow, 30 June, Is the deadline imposed by the jointly-signed MEMORANDUM OF AGREEMENT that imposed strict conditions upon the East Caribbean states that sell Citizenship by Investment (CBI/CIP) economic passport sales schemes. This week, the Government of Antigua & Barbuda, one of the signatories to that Agreement, announced that it will require an additional thirty (30) days to implement the new conditions, which include a Standardized Minimum Investment of USD$200,000, citing the need for Parliamentary (legislative) approval, in due course, under procedural rules.

We wish to point out that the Agreement was signed by Antigua, and three other EC states, on March 20, more than 90 days ago, and we are just now, immediately prior to the Effective Date, hearing that Antigua needs more time, for what is represented as purely normal legal reasons. Given that the country's government has had several months to prepare for June 30, but has ignored the upcoming deadline, it appears that, for purely unacceptable financial reasons, it has intentionally delayed implementing the relevant legislation. Why wasn't the law changed earlier?

We will now explain why we consider that Antigua's actions were undertaken in Bad Faith. CBI vendors of Antigua's passport sales schemes are openly, and our opinion desperately, advertising that "Prices are Doubling on July 30," the date when the country has promised it will abide by the Agreement. These vendors are telling consumers that they can now "Save $150,000" acting now to apply to an Antiguan CBI citizenship & passport program. Note that Antigua could, if it quickly passed legislation through its Parliament, conform to the next program requirements as early as next week, but it says it needs thirty days. Now you know why.

If this is an indication of how Antigua intends to abide by the terms of the Memorandum of Agreement it signed, after the US & UK demanded that the region raise standards, or face sanctions, such as the loss of visa-free admission to the UK & EU, and US tourist visa eligibility, we wonder which other requirements the country will choose to evade, or totally disregard in the future. Let's put Antigua's CIP program under close observation, please.

Friday, June 28, 2024


Given the unfolding scandal regarding the illegal use of St. Kitts CBI passports, we are again asking the hard questions about one of the Federation's most notorious Iranian holders of its tools allowing visa-free entry into the EU, UK and the Commonwealth of Nations. Let's revisit the story.

Questions have been raised as to precisely why Ali Sadr Hasheminejad, the owner of Malta's notorious  (and now shuttered) money laundering financial institution, Pilatus Bank, chose to employ one of his four St. Kitts & Nevis Citizenship by Investment (CBI) passports when applying for a banking license? Compliance officers will recall that the American regulator FinCEN had warned, in a sharply worded Advisory, that SKN CBI passports were "attractive to illicit actors, " and therefore high-risk for financial institutions and other agencies. The SKN passport acquired even more notoriety when an obvious non-diplomat showed up in Canada with a diplomatic passport, seeking admission, and sputtering some nonsense about how he was going to see the Prime Minister. 

 After that Canada basically redlined SKN nationals and passport holders. If St. Kitts was a known international problem, why on earth would Ali Sadr select it for both his EU bank application, and as an identifier when opening bank accounts in Switzerland and Turkey, claiming that he was a resident of Dubai, UAE? That is the issue. Add to the mystery is the fact that he most certainly could have gone to a less controversial jurisdiction. In truth and in fact, the only other Iranian national who was an officer or director at Pilatus, Hamidreza Ghanbari, had a CBI passport issued by the Commonwealth of Dominica, and not St. Kitts. Why was this the case, we wonder aloud? 

Your Past will always follow You by COSIMO

One possible reason is that, amongst his four SKN passports, all of which were reportedly valid, is one that we understand contained permission to enter the UK visa-free. Although all St Kitts passport holders as a group have that right, we have to assume that he wanted to insure that he would never be stopped, questioned, and possibly searched, when arriving at Heathrow. Remember, the bank "branch" that he set up, located inside a front company facility on Old Park Lane in the upscale Mayfair district, appears to have been little more than a funnel for moving illicit cash. Perhaps he feared being searched by UK Customs, whilst carrying suspicious and large financial instruments that violated UK law.

Alternatively, he may have created an ironclad front, regarding his business origins, in St. Kitts, with the artful assistance of a consultancy, that could withstand routine due diligence inquiries at those Swiss and Turkish banks that he opened accounts at. In any event, we would most certainly like to see what is on file in Basseterre. Hopefully, the unfolding scandal in Malta's courts, regarding that country's refusal to move forward with money laundering charges against Ali Sadr, might eventually provide answers to our question.

Thursday, June 27, 2024


ERNEST HILAIRE, the deputy Prime Minister of St. Lucia, who also holds the portfolio for Investment, and who runs the country's controversial Citizenship By Investment Program (CBI/CIP) has publicly declined to disclose how many files were allocated to Caribbean Galaxy. It has been claimed by the Opposition that 7,000 files, which could be used to issue 28,000 passports, were assigned to Galaxy. Hilaire, who claims he must first obtain permission from Galaxy, prior to naming how many were transferred, as it is a commercial matter. It is not known why the Government has never requested this information before.

When a sovereign government refuses to disclose relevant information to its constituents on demand, it must be presumed that such data, if released, could so damage the sitting government as to bring it down in disgrace. All the allegations that appear in the American RICO case, MSR Media vs. Les Khan, appear to have a basis in fact, as government officials in two CBI jurisdictions hasten to find ways to ignore their admission of painful truth about illegality, bribes & kickbacks, and corruption on a grand scale.


Financial institutions in the United States have a mandate to conduct a Risk-Based Anti-Money Laundering Compliance Program. Their compliance departments are required to assess potential risk, and recommend adjustments accordingly. The filing of a civil RICO complaint in US District Court in Tampa, alleging money laundering and rampant corruption within the operation of the Citizenship by Investment (CBI/CIP) passport sales programs of the Federation of St. Christopher & Nevis, and St. Lucia has caused compliance officers at U.S. banks to take a close look at whether they have issues regarding correspondent accounts of Caribbean banks, whether they must reexamine Country Risk, and whether their loan portfolios or bank customers engaged in international trade transactions could be affected.

While we generally deal strictly in facts in our AML/CFT coverage of developing financial news, today we will be detailing why we believe these recent events support the probability that a number of present and former government officials in those two East Caribbean states, as well as Politically Exposed Persons, more commonly known as PEPs, and others, will eventually be indicted under Federal Law, for violations of the Money Laundering Control Act. The potential impact of such an action on American banks is an issue which compliance officers should consider at this point, so that they can consider what steps are necessary and proper to protect their bank, and when they are best applied.

Therefore, I have listed a number of subjects which have led me to the conclusion that it is more likely than not that we will see money laundering indictments handed down, as early as 2025, against the individuals alleged to be the bad actors in the CBI programs at St. kitts and St. Lucia.

1. THE DESIGNATED CURRENCY FOR INVESTMENT IN ALL THE CBI PROGRAMS IS THE U.S. DOLLAR: The creator of the first CBI program in 1984, the late William V. Herbert, Jr., then the Foreign Minister of St. Kitts ignored the use of the local East Caribbean (EC) Dollar, as well as the Pound Sterling  (£), both of which were far more convenient, as well as more familiar to West Indians. I am acquainted with his reasons, but they are not relevant to this discussion. Anyway, his choice of a currency, which would in due course generally be processed and transit through the New York financial center, and therefore does invoke the extraterritorial jurisdiction of U.S. courts, even for foreign national, "if the conduct occurs in part within the United States," is a significant factor.

2. THE TRANSFERS OF DOLLARS THROUGH THE UNITED STATES WERE THE PROCEEDS OF A "SPECIFIED UNLAWFUL ACTIVITY." The passport sales are alleged to have been made at an unauthorized, and unlawful, discount. It has been asserted in the RICO case that they constituted fraud, and that also that there were illegal bribes & kickback allegedly paid. The payments appear to satisfy the requirements of the law under the Money Laundering Control Act.

3. THE PRIMARY ROLE OF A CHINESE-OWNED AND CONTROLLED CORPORATE ENTITY IN THE PASSPORT SALES OPENS A PANDORA'S BOX OF NATIONAL SECURITY ISSUES: The funds were reportedly transferred through a number of American banks, to Hong Kong, under the custody and control of a Chinese company, allegedly linked to the Peoples' Republic of China. This raises a number of possible National Security issues for the U.S., including but not limited to China's expanding influence in the Caribbean republics, the application of American foreign policy regarding foreign influence, all the way back to the Monroe Doctrine of 1823, and even intelligence community issues. You can assume that the DOJ National Security Division has been consulted in what is obviously an ongoing investigation.

4. CARIBBEAN CBI PROGRAMS HAVE BEEN RIDDLED WITH CORRUPTION SINCE THEIR INCEPTION, AND THE ST. KITTS PROGRAM LEADS THE PACK WITH UNSUITABLE APPLICANTS RECEIVING PASSPORTS, INEFFECTIVE DUE DILIGENCE, AND INCOMPLETE CONSTRUCTION PROJECTS THAT ONLY BENEFITTED DEVELOPERS AND THE SKN GOVERNMENT: The U.S. State Department and American law enforcement agencies have had to watch the St. Kitts program's massive problems and shortcomings from afar, without having the ability to rein them in due, to questions of National Sovereignty, and the interest of America keeping good diplomatic relations with its Caribbean neighbors.

5. SENIOR GOVERNMENT OFFICIALS OVERSEEING CBI PROGRAMS HAVE USED THEM FOR PERSONAL ENRICHMENT, WHEN DEALING WITH CVI VENDORS SEEKING EXCLUSIVE ACCESS: CBI consultancies wishing to be exclusive representatives of a specific national program have been known to pay illegal compensation to secure that business, in violation of the Foreign Corrupt Practices Act (US) and the Bribery Act (UK).    

6. THE ST. KITTS CBI/CIP PROGRAM WAS FLAWED FROM THE INCEPTION: I personally was involved with the creator of the SKN program in the initial phase, and the fact is that it intended to, from the beginning, accept known criminal elements, and approve their applications, being wilfully blind to the unsuitable background of applicants who could pay the fees in cash. 

Compliance officers should review the facts, make their own independent inquiries, and govern themselves accordingly, to discharge their professional responsibilities as risk managers.

Wednesday, June 26, 2024


A magistrate judge in the Republic of Malta has found that there exists a prima facie case for money laundering and corruption against the disgraced former Prime Minister JOSEPH MUSCAT, and two of his former close associates in a prior Labour Party government. The case will now proceed to trial, although many legal observers in the EU believe the island's corrupt court system, which allows the defense to use archaic Compilation of Evidence proceedings to delay a case for years, if not decades, will defer justice to deny it. Indeed, Muscat is probably more likely to be indicted and go to trial in the United States before ever appearing in a courtroom in Malta.

Rumours continue to persist that there will be an American indictment handed down, charging Muscat as well as a number of American businessmen who were linked to the hospital scandal, in which Muscat allegedly received bribes and kickbacks in Switzerland. A Foreign Corrupt Practices Act case is believed to be the nature of a US Federal case reportedly in preparation.


If you monitor Caribbean media, you have read all those government press releases, from St. Kitts, Dominica, and elsewhere, declaring that any CBI passports sold at an illegal discount will be summarily revoked, and declared null and void. Although some more obtuse Caribbean government officials have asserted that the holders are entitled to some form of Due Process, which is doubtful, in most quarters there is a move to terminate those illegally-obtained identity documents. It's probably because a number of the Chinese purchasers of the discounted passports used fake IDs in their application, and went on to commit crimes in the US, UK and Singapore, that we know of, and probably elsewhere as well.

Assuming that up to 1000 CBI passports are revoked, what effect will such action have, you ask? Unfortunately, little to none. here's why:

1. When Caribbean CBI passports are revoked, it's done internally in the countries where the passports were issued. there is no master list circulated globally; therefore, how are authorities in other countries to know that a specific passport cannot be honored? The answer is, they don't.

2. The Chinese users of these discounted CBI passports have been shown to be international financial criminals,sanctions evaders, spies and intelligence agents.I can tell you from personal experience in the dark world of financial crime that all these people know how to quietly enter a country at an obscure airport or border crossing, where there is literally no checking of whether a passport is legitimate or not. They also, as I once did, choose to enter a country in the developing world where underpaid government officials have no time or inclination to check anything, or where a small bribe facilitates everything.

Therefore, with all the posturing from St. Kitts and Dominica about solving the problem, they can only tackle it superficially; those passports will still be used effectively to commit financial crime, and for espionage, among other things.

One final note: how can we be sure that the Asian company that allegedly sold all those CBI passports at a steep discount, won't cheat in the future, and continue such illegal conduct? How can this new regulatory entity that will be created enforce the no-discount rule abroad?

And where is St. Lucia in this mess? Still hiding its head in the sand, I see.


Buried in a new civil lawsuit, filed against the United Nations, by some of the victims of the Hamas October 7 attack upon Israel, is a very disturbing allegation: that the UN actually knowingly engaged in terrorist financing, in the method through which it paid its aid employees inside Gaza. After you read this, you are going to wonder who is really running the UNRWA, the organization's Palestinian refugee agency, and their wilful blindness in the face of obvious terrorist financing.

It is has been alleged, in the lawsuit which was filed in the United States, that United Nations Relief and Works Agency, over strenuous objections from many quarters, including the United States, insisted on paying its aid workers in US Dollars (USD$), rather than Shekels, which is the currency of the realm in Israel and the Territories. The aid workers then, to be able ro locally use the funds represented by the greenbacks, would each time have to use Hamas-controlled money changing houses, to exchange their salaries. Those terrorist-owned firms then turned over that hard currency to their organization, which then had the right cash to purchase arms, ammunition, explosives on the world market. Thus the United Nations was, in effect, and allegedly intentionally, funding a Specially Designated Global Terrorist Organization.

It gets worse; these greedy money changing houses had the temerity to charge 10-25% in "fees" to the aid workers, knowing that they held a monopoly on currency exchange inside Gaza. That's even more funding for Hamas.

Was all this an intentional act to provide financial support for a terrorist organization? BTW, the present and former leaders of UNRWA have been individually named as defendants in the lawsuit, which should provide you with the answer. No wonder Israel has stated that it will not accept any role for the UNRWA in a post-war Gaza, or even in the West Bank a/k/a Judea and Samaria.