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The East Caribbean's top five CBI money-laundering states

Ken Rijock, AML consultant, Miami, 3 May 2021


Donald Trump may not know where the Caribbean is, but the new Biden Administration most certainly does. Money laundering reporting officers are now paying attention to the five East Caribbean States that sell citizenship-by-investment passports, all of which are infested with money laundering, corruption and other financial crimes.

If you weren't paying attention in your geography class, never mind! Here is an up-to-date summary of these jurisdictions.

(1) Antigua and Barbuda. Neither the Stanford International Bank Ponzi scheme nor the decade it took to extradite Antigua's banking regulator, LEROY KING, have been forgotten. Mehul Choksi, India's most-wanted white-collar criminal, has been given sanctuary there. Corruption in local government is rampant and the offenders are rarely punished, although some lose their government jobs. The Colombian charged by the US with money laundering, ALEX NAIN SAAB MORAN, used its offshore and one local bank to move Venezuelan money in transit.

(2) The Federation of Saint Christopher (Kitts) & Nevis. ALI SADR HASHEMI NEJAD and his family hold SKN passports. In March 2020 the former Pilatus Bank owner was convicted in the US of illicitly moving US$115 million to Iran, although this was subsequently reversed in favour of a new trial because of prosecutorial failures to disclose documents. The Southern District of New York then decided not to prosecute further. Nevertheless, the country's CBI passport programme has been of use to many of the world's most notorious transnational white-collar criminals and many Asian mega-criminals.

(3) The Commonwealth of Dominica. PM ROOSEVELT SKERRIT's dodgy diplomatic passport sales have given super-criminals, such as Iran's ALI REZA MONFARED, the ability to bypass Customs at international airports of entry and smuggle the proceeds of crime wherever they want. Skerrit has remained in office for nearly two decades. China uses its huge embassy for regional intelligence-gathering, so espionage is a problem. A dictatorship claiming to be a democracy.

(4) Saint Lucia. Sales of CBI passports to criminals and highly risky individuals continue. The recent exposure of extensive land fraud has elevated the island's negative profile among compliance officers.

(5) Grenada. Massive Russian investment, of dubious origin, has dominated the island's CBI-centric economy. CBI-related frauds are never punished by local law enforcers.

If you are a compliance officer at a British, North American or European bank, you should immediately raise your country risk assessments of these jurisdictions and avoid any exposure to money laundering by conducting enhanced due diligence or EDD investigations on all clients and wire transfers to or from there. I expect an increase in the attention that US law enforcers pay to all five of these East Caribbean states with CBI products in 2021.

* Ken Rijock can be reached at miamicompliance@gmail.com

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