Kenneth Rijock

Kenneth Rijock

Tuesday, October 17, 2017


 Law enforcement mining of social media through platforms that can access information which might otherwise never be uncovered has moved from the primary role of understanding criminal networks to a broad range of applications involving ongoing investigations. Many are using their social media programs as a real time monitor of a wide variety of criminal activities, as well as the acquisition of information.

Some of social media monitoring uses reported by investigators at law enforcement agencies:
(1)  Using information obtained from social media as Probable Cause to obtain a search warrant.
(2)  Identifying associates affiliated with or linked to Persons of Interest.
(3)  Identifying the location(s) of criminal activity.
(4)  Identifying criminal activity.
(5)  Gathering photographs or statements to corroborate evidence.
(6)  Identifying Persons of Interest.
(7)  Identifying the location of Persons of Interest.
(8)  Anticipating or identifying crimes that may be in the early stages.

Innovative law enforcement agencies will continue to find new uses for their social media platforms in both violent as well as white collar crime investigations. Social media resources, whose initial application was solely on the civil side, when it was used to obtain data on "unbanked" individuals for money service businesses, has proven to be an extremely valuable tool in law enforcement investigations.


If you read yesterday's CNN  story, Hong Komg, Where North Korea Goes to Launder Money, you might have noticed that the authors made sure to point out that the Chinese national who allegedly is the principal front man for a sanctioned North Korean bank holds a Dominican passport. Whether it is a Citizenship By Investment (CBI) economic citizenship passport, or one of those diplomatic passports considered illegal under international law, the point is that Dominica documents are facilitating North Korea's evasion of international sanctions. While the extent of Dominica's relationship with North Korea is unknown, the continued  existence of the CBI program itself could be endangered, should major United Nations sanctions evasion activity be made public.

There's more: an examination of the North Korean Economy Watch, which publishes data from the annual Rason International Trade Fair, reveals that Dominica was one of the exhibitors. Considering that the country does not record that it exports anything to the DPRK , the obvious conclusion is that the government display is for the sole purpose of selling CBI citizenships. Dominican representatives have a history of hawking CBI products in the Peoples' Republic of China, and the Chinese reps are the likely people to be involved in North Korea. This matter is serious, and it requires further investigation.


Monday, October 16, 2017


This is Daphne Caruana Galizia, an investigative journalist in Malta. She was killed when a car bomb detonated, while she was driving her automobile. Mrs. Caruana Galizia, whose son was an ICIJ journalist involved in the release of the Panama Papers, exposed official corruption and money laundering,  at the cabinet level and above, when she extracted information implicating senior government officials for holding offshore corporations and hidden bank accounts abroad. That is what is left of her car, after the explosion.

The journalist, who also exposed rampant corruption among powerful figures in Malta, as well as activities of the country's organized crime syndicate, was killed while driving away from her home. If anyone still thinks that money laundering is a white collar crime, with no real victims, think again.


After our recent article, Dominica & St Lucia's CBI Programs have a CBI Consultancy in Iran, there was a denial issued, by the unofficial regime mouthpiece, Anthony "Tony" Astaphan, who has asserted that Swallow Immigration Consultancy, Inc., was not an agent for the Dominica CBI program, notwithstanding that the firm's website recites that it is. I therefore decided to settle the issue by contacting the consultancy's manager, Nousheen Pourjahani, via telephone at her office in Canada, and she was happy to confirm Swallow's status as Dominica CBI Agent & Promoter.
She admitted that she was in the business of selling CBI or CIP passports, from a number of East Caribbean countries, and that her targeted clients are Iranians, which raises multiple questions of whether international sanctions are being violated. She claims that she only sells to expatriate Iranians, who fund their passport purchases with funds held outside Iran. If that is the case, then why does Swallow maintain an office in Tehran ? One cannot sell to expat Iranians inside Iran; she lies about her clientele.

Enter the East Caribbean's dark CBI secret, that there are unlisted agents/promoters, in Dominica, and elsewhere in CBI jurisdictions, who funnel clients to the so-called "licensed" agents, and receive hefty commissions under the table for their trouble. You may recall our prior article about the unlisted Asian promoter who asked for an advance commission payment, to be sent to a Wells Fargo account in Singapore, when a person posing as an interested buyer contacted him. That individual was not named as an agent, but he was nevertheless acting as such. Do not expect anyone involved in the lucrative, and largely unregulated, international CBI industry to follow either local laws or the regulations.

Also, Ms. Pourjahani stated that she performed NO due diligence, upon neither her Iranian applicants, nor their funds, prior to taking possession of the money, in a third country, such as Dubai, as she expects that the CBI program will complete that task. What she is probably doing is engaging in money laundering for dodgy, or even criminal, clients, in a "don't-ask, don't-tell" scenario which the law refers to as willful willful blindness.

After she realized that she had given up far too much damaging information, she terminated the conversation, using an flimsy excuse of immediate travel for an extended period, but she did answer the telephone later that day, only to hang up when she realized who was on the line. Exactly how many Iranians now hold Dominica, St Lucia, Antigua, or St Kitt passports, thanks to Ms. Pourjahani's efforts during the past decade, we wonder ?


Sunday, October 15, 2017


A smart businessman knows to never express an opinion on any legal matter, if he is a non-lawyer, and a good attorney is aware of the risks when he talks to clients about legal issues in countries where he is not admitted to practice. Unfortunately, that is not the case when it comes to those CBI consultancies not actually located in the five countries of the East Caribbean that offer economic citizenship to affluent individuals from high-risk jurisdictions who are seeking a second passport. Those firms freely offer advice notwithstanding that they are no way qualified to do so, all to the potential damage of their clients.

In truth and in fact, none of the principal international consultancies have qualified attorneys present on premises, in Europe,  the Middle East, Asia or elsewhere, who are admitted to the practice of law in the East Caribbean. Why is is important, you ask ?

 If your European "legal consultant," who professes to have all the answers, regarding the jurisdiction he is directing you invest your money, to obtain a second passport from, does not know the local law, how can he correctly navigate you through a potential minefield, specific to that country, such as:

(1) The possible future revocation of your citizenship, as well as your prized passport. Antigua is presently discussing passing such a law, but does the country recommended to you have the right to do so, at this time ? Remember the case of the Iranian Alireza Monfared, and his two passports, obtained from Dominica.

(2) Will the country recommended to you "lower the tax boom" at a later date ? Are those permanent assurances of tax holiday in the country's laws, and have you received an opinion, from a local attorney duly qualified, about this issue ?

(3) What are the possible tax ramifications, to your present nationality, if you get that second passport, and move assets offshore ?

(4) Has the selected country ever been, or is it now, a Blacklisted jurisdiction,  from any regulatory agency, which could put you in the cross-hairs of US, or EU law enforcement agencies in the future ? You do not want to become  a Person of Interest, simply because of the misconduct of others.

(5) Is the country selected for you by the consultancy, only a nominal democracy, but actually a dictatorship, which could conceivably be overthrown, and your status simply terminated, with no legal recourse ?

(6) Does the local court system regularly follow the Rule of Law, or are decisions handed down, based upon political pressure of the ruling party ? In that case, you may not be able to have legitimate business grievances addressed to your satisfaction.

(7) What about the country's criminal justice system ? Is it fair and impartial, or could you end up in jail, without a trial, for years, if anything you do incurs the wrath of local leaders ?

The bottom line: if your mind is made up about obtaining a CBI passport, by all means, go to the jurisdiction, and engage a local attorney to answer those questions, in advance, prior to investing. To do otherwise is literally playing with fire.

Saturday, October 14, 2017


The Government has filed its Brief of Appellee, in the DC Appeal of the District Court summary judgment, entered against the Waked family, seeking to remove the OFAC designation entered against those Panamanian nationals known to be involved in money laundering operations.

The issues discussed are no surprise:

(1) OFAC's disclosures satisfied its notice obligations, under both the Due Process Clause, and the Administrative Procedure Act.
(2) OFAC is not required to disclose evidence that would reveal confidential investigative sources and methods.
(3) The District Court's decision does not produce absurd results.

The case law aptly cited shows that, only in the rarest of circumstances, and then only where there is real OFAC misconduct or error, do the courts take action, regarding OFAC sanctions. We note that the only Waked family member actually in custody, has recently indicated, through counsel, his intention to enter a plea to the money laundering charges fled against him, in District Court in Miami. he is not a party plaintiff in the DC case.

Friday, October 13, 2017


  A review of the list of companies eligible to direct Citizenship by Investment clients to St Lucia and Dominica includes the Canadian consultancy, Swallow Immigration Consultancy, Inc*.  Swallow lists a Tehran office in its information, a disturbing fact, buried at the bottom of the page, but which poses not only a clear and present danger to the CBI programs of both countries, due to international & US sanctions, but will definitely expose external due diligence firms to major OFAC sanctions.

Swallow is owned by an Iranian national that advertises herself as an "immigration consultant." her name is NOUSHEEN POURJAHANI.

Swallow, whose addresses are listed as:
28 Saunders Street
56 Aviones Court
Fredericton, New Brunswick, Canada

Swallow logo

Also shows an Iranian address:
Unit 36, Mahtab Building
Livarchi, Villa St,
Tehran, Iran

Don't the CBI units in Dominica & St Lucia realize that there is a high risk that they may be accepting individuals who are government officials, individuals working in the sanctioned WMD or ballistic missile programs, Islamic Revolutionary Guard Corps agents, or other Iranian nationals who are internationally sanctioned. Can't they foresee the inevitable public relations nightmare when one of the clients they accept is exposed ?

There's another problem: If the outside due diligence firm handling the vetting of any Iranian nationals is either American, or a foreign subsidiary of an American company, there is strict liability for OFAC violations. See OFAC fines American Firm that conducted CBI Due Diligence for Iran Sanctions Violations, on this blog, August 19, 2017, Note that the due diligence firm fined $259,200 is IPSA, listed as a due diligence contractor at St Lucia.

Both countries should now take a hard look at whom they "qualify" as CBI consultancies, lest they get burned. In their eagerness to attract CBI clients, they license (I use the term loosely) salesmen, not the legal professionals who should be advising prospects. The firms listed are located in Moscow, Dubai, Pakistan and other other high-risk jurisdictions.

How many more Iranian nationals must be arrested or indicted, complete with East Caribbean CBI or diplomatic passports, before another FinCEN Advisory is issued ? Canada would do well to close Swallow immediately, as it is suspected of being a facilitator for Iranians seeking second passports, without any significant due diligence being performed upon them.
* There is also another CBI firm, owned and operated by Pourjahani, known as Parastou Company, also offering East Caribbean passports, in this case from Dominica, Grenada and Antigua & Barbuda. Parastou's webpage also features the "Swallow" logo shown above.