Kenneth Rijock

Kenneth Rijock

Monday, December 11, 2017


Remember when the journalist seeking information about the bearer share companies of the British Virgin Islands was denied entry into the BVI, by local immigration authorities ? It looks like the next time a journalist from the ICIJ tries to get some straight answers in Bermuda, he'd best stay away.

An ICIJ journalist has reported that his visit to Appleby's Bermuda headquarters, where staff had refused to answer questions submitted in advance, meet with him, or even identify themselves, was a total waste of time. When he returned to DC, some officer from the Bermuda Immigration Service, armed with his direct line, contacted him and asked him questions about the purpose of his trip. It was reportedly not a friendly call. Only Appleby had received a business card from the journalist; you do the math.

So, is there any difference between the treatment the BVI-bound journalist, who was run out of town, and the "Big Brother" telephone call the ICIJ journalist received ? No much.  Only time will tell whether the Paradise Papers will have the same effect upon Appleby as the Panama Papers had on Mossack & Fonseca only time will tell.

Friday, December 8, 2017


A US District Judge in Miami has set January 9, 2018 for oral argument, on former Panamanian President Ricardo Martinelli's Petition for a Writ of Habeus Corpus, challenging the Magistrate Judge's order for his extradition. Martinelli remains in Federal custody, amid rumors that his extreme efforts to obtain bond, pending the resolution of his extradition, were made because he intended to flee to the Dominican Republic, where rampant corruption could delay any legal action to remocve him for years.

Curiously, there is still no public access to any of the filings in the Habeus proceeding, giving rise to the suspicion that some of the facts alleged by Martinelli may reveal sensitive information about Martinelli, or Panama, that law enforcement does not want publicly released, including about ongoing criminal investigations. Court files are rarely sealed in this manner. We are still unable to analyze any of his arguments, to determine whether they are legally sufficient, or even valid arguments, to be made by his counsel.

The public, in the Republic of Panama, now fears that their former president, alleged to be the most corrupt in Panamanian history, will never see the inside of a Panamanian courtroom. The Miami proceedings have dragged on for months, and some are beginning to wonder whether some government agency, with a prior relationship to Martinelli, is involved.  


Thursday, December 7, 2017


I am still wondering why the Office of Foreign Asset Control, OFAC, never levied a Civil Penalty against Range Developers or Range Hospitality,* for offering or selling time-share investments in the US, to the Al-Randatain residences, located in Karbala, Iraq, due to the fact that the contractor, and later owner, of the project, was an OFAC-sanctioned entity named Tadbir Construction Development Group. Readers who did not see our prior article may access it here: Americans Sending Time-Share purchase deposits to sanctioned Iranian Company.

I have confirmed that OFAC received actual notice of the ongoing violation, but action was ever taken to levy a monetary fine, or name & shame the offending entity, or its officers or principals, and to compel the company to build an effective compliance program. Of course, the fact that Tadbir was an Iranian entity, and on the OFAC sanctions list, would have been apparent to anyone who Googled it.

How did the time-share deposits wind up in Tadbir accounts in Iran, I wonder ? Whether Range, which has a number of corporate identities, in different jurisdictions, ran afoul of international sanctions against Iran is yet another issue that OFAC seems to have overlooked. Who is watching the store, Mr. Director ?
* Range Hospitality WLL, incorporated in Bahrain.
   Range Hospitality, ltd., incorporated in the United Kingdom.
   Range Hospitality (Cayman).


In a much-publicized manner, the European Union this week named & shamed a number of jurisdictions, for their lack of international cooperation. Grenada immediately characterized its failure to comply as " inadvertent," and hastened to clear up the problem, hoping to reverse the blacklisting forthwith, though the government's failure to act was about as accidental as Antigua's "delays" in extraditing its former (and eminently guilty) banking regulator, to face American justice in the Stanford International Bank criminal prosecution. There are no accidents in the East Caribbean, when it comes to governance.

Grenada & St Lucia may have a bigger problem than they believe; Country Risk will certainly be raised upon both jurisdictions, as the direct consequence the EU action. Compliance officers, in North America as well as in Europe, are taking note of all countries named by the EU, and irrespective of what consultancy firms say, when they trumpet the CBI virtues of both countries, their programs becomes less desirable than those of, say Antigua or St Kitts-Nevis.

Therefore, the EU action appears to have served the purpose for which it was taken, to focus compliance attention where it is sorely needed, and to stimulate jurisdictions that choose to ignore international norms, in a way that they immediately recognize, in their pocketbooks.


Wednesday, December 6, 2017


The recent media coverage, detailing the role of reputed Russian Organized Crime members, who were purchasers of most of the condominium apartments at Panama's Trump Ocean Club, fails to explain precisely how the developer, Roger Khafif, the CEO of Newland International Properties Corp., was able to obtain $220m in construction bond financing for the project. No discussion of the Trump Ocean Club International Hotel & Tower is complete without that information, as it reveals the presence of seed money of yet an additional organized crime group.

Mr. Khafif, who was obsessed with creating a Trump building in Panama City, swapped a property he owned for the tract that became the hotel site. He then needed to convince Bear Stearns & Co. to underwrite the bond issue, and for that he had to have purchase contracts, or options to purchase, in hand, with deposits, to demonstrate that he had buyers ready to close.

Though he we do not know how he accomplished this feat, he soon had a sufficient number of signed agreements to obtain the needed financing. The trouble is, most of the purchasers have been identified as members of Panama's powerful Syrian organized crime syndicate, which hides in the shadows, but influences much of what goes on, behind the scenes, in Panama.

This organization, whose members are descended from immigrants who came to Panama from a specific area in the Middle East, consists of seven major families, whose intermarried reach extends into every major bank, and every government agency. Roger Khafif's family is reportedly from Aleppo; connect the dots.

These individuals later sold their contracts at a huge profit, after Alex Ventura suggested that prices at the Trump be doubled. Without their seed money, and support, the Trump Ocean Club would have never been built.   

This is the first of a series of articles exposing details of the Trump Ocean Club International Hotel & Tower project that have not been covered by conventional media.



It is being reported that customs & immigration officers in the United States and Canada are detaining holders of CBI and Diplomatic passports from the East Caribbean countries participating in Citizenship by Investment programs. Passports are being photocopied, mobile telephones inspected, and questions asked about business activities of the holders. Some reports state that the delays were extensive.

Readers who wonder how immigration officers can identify CBI passport holders, the answer is simple. If the holder's listed place of birth is found to be NOT in the country from which he or she has a passport, in most cases the passport is CBI. Commentators in the Caribbean have long warned that CBI & diplomatic passports issued to career criminals, individuals from sanctioned nations, and those from high-risk countries, will result in increased scrutiny, by North American law enforcement agents. When they photocopy your entire passport, and cross-examine you in depth, you have become a Person of Interest to law enforcement.  Their question: Are you using the CBI passport to evade detection of your true identity and nationality ?

Whether all nationals, entering the US & Canada from CBI jurisdictions will ultimately face extended questioning, and temporary detention, while their possessions are searched, is the question being asked. That lucrative CBI income may come with a price that is to be paid by every national from those countries, when he engages in international travel. We have repeatedly advised that this might occur, but to date our warnings have fallen on deaf ears. Perhaps now they will be taken seriously. 

Tuesday, December 5, 2017


Al-Randatain residences, Karbala, Iraq.
Most of us know where Karbala is in Iraq; in 2003, the 101st Airborne Division shed a lot of  American blood when taking the city from the Republican Guard. Karbala is an important destination for Shi'ite Muslim pilgrims, and several years ago, the Dubai-based project developer, Range Developments/Range Hospitality broke ground there for a timeshare project, a $100m hotel, called Al-Randatain Residences.

Range, which is familiar to those of us who focus upon the Caribbean, as the developer of several 5-star hotel and resort projects, in jurisdictions where Citizenship by Investment laws require investments of some kind, such as in St Kitts and Dominica, chose as its principal contractor in Al-Randatain the Tadbir Construction Development Group, which is an Iranian company. What's wrong with this picture ?

Tadbir is not only owned by the senior leadership of the Islamic Republic of Iran, it is part of an elaborate Iranian plan where profits are kept from the Iranian government treasury, and distributed to those groups at the top of Iran's power structure, and yes, it is also OFAC-sanctioned.

How does a non-US corporation, with a project outside the United Stated, run afoul of American sanctions ? it's simple:

(1) First,  Range offered investments, in Al-Randatain, to American Muslims, from two of its US-based offices, and through at least seven sales promotions, all conducted inside the United States. Purchasers were sending pre-construction deposits, some of which were obviously turned over to Tadbir, for constriction costs. Was American money going into the accounts of an OFAC-sanctioned entity from Iran ? Tadbir was to receive units in the project, as part of its compensation.

(2) Then, Range ran into serious cash flow problems, at the Al-Randatain site. Some reports allege that the financial difficulties were due to corruption, and the illegal diversion of funds, but Range ultimately sold its entire interest to Tadbir. Were the deposits of American purchasers not now flowing into Tadbir's accounts, with Tadbir an OFAC-sanctioned entity ? Of source they were.

(3) Other analysts fear that, when cash flow became a real problem at Al-Randatain, some of the deposits, made by Americans, for the Park Hyatt (St Kitts) might have found their way into the Karbala project, and its Iranian contractor. We cannot confirm whether this occurred, but a routine audit would certainly put to rest this nagging question.

So, the question remains, where was OFAC in all this ? They were alerted, I can tell you from personal knowledge. Americans sending funds to Iraq would certainly ring bells in my shop, I assure you. Were Suspicious Activity Reports (SARs) filed in some of these transactions ? Were the US sales promotions, of an Iraqi project publicly known to be under construction by an Iranian contractor, red flagged by anyone in US law enforcement ? Obviously not, because there have been no OFAC Civil Penalties levied in this matter, against Range, or any other entity.

We wonder whether there were political considerations involved; Iraq is stated to be an ally of the United States, though realistically, it is now within the Iranian sphere of influence. We hope this was not some well-intentioned State Department decision that resulted in Americans funding Iran.

Tadbir group in Iranian network