Kenneth Rijock

Kenneth Rijock

Monday, August 21, 2017


Counsel for Mehmet Atilla, the Turkish bank deputy CEO charged with facilitating the multi-billion dollar international oil sanctions syndicate lead by Reza Zarrab, Babak Zanjani & Alireza Monfared, filed their Reply Brief today. The brief, in support of Atilla's pending Motions to Dismiss, Motion to Sever, and Motion to Examine Grand Jury Minutes, basically did not cover any new issues, and served to do little more than quote from the original brief. The defendant's motions do not appear to have a strong chance of success.

A sealed document was filed with the Court, which could indicate a possible change of plea from one of the defendants, or a sealed indictment of a new defendant, but it could also merely be classified evidence being deposited. Should there be any significant developments in this case, we shall promptly post them to this blog, as we are monitoring the court file.  

Sunday, August 20, 2017


President-Elect Trump, his wife,and Paolo Zampoli
 By far the strangest story to emerge from the Caribbean's "play for-pay" diplomatic passport sales programs, where foreign nationals acquire a diplomatic passport, is the tale of an Italian businessman from New York, Paolo Zampoli. According to reliance sources in the Commonwealth of Dominica, in 2011 Zampoli approached Vince Henderson, the UN Ambassador, and offered to pay $250,000, in cash, for a diplomatic appointment, and passport.

At the same time, Zamboli also approached the UN Ambassador from Grenada, with a similar request, which was reportedly declined, but reports show his subsequent appointment, ion August, 2012, as Grenada's Minister of Tourism, and his wife, Amanda also appointed to a diplomatic post in Grenada.

Over the reported objections of his advisors, Dominica PM Roosevelt Skerrit, who traveled to New York in March 2011, met Zampoli, who introduced him at that time to his close friend, President Donald Trump. Zampoli, who had owned a New York modeling agency, claims that he made the initial introduction between Trump and his current wife, the First Lady, Milania.  Zampoli has continued his close ties to the Trumps, appearing at the Mar-A-Lago resort with the Trump family, since his election.

PM Skerrit appointed Zampoli  to the diplomatic rank of Minister Counsellor for Dominica, and named him as Ambassador Henderson's deputy, in the UN Mission of Dominica, as of November, 2011. In October, 2013, Zampoli was additionally appointed Ambassador for Oceans and Seas, which appears to be basically a symbolic position, with little, if any, actual duties and responsibilities. Dominicans say that Zampoli has never visited the country he purportedly represents as a diplomat.

Zampoli, since his ambassadorial appointment, has been a fixture at the United Nations; the Internet is full of photographs of him with some of the world's most influential diplomats and statesmen. What he actually does at the UN is another story, other than mix and mingle. Some observers believe his primary goal is to cultivate relationships with powerful international leaders, but on whose behalf is not known, as Dominica's role at the United Nations is small, though its current government is closely aligned with China, Venezuela and Cuba. His end game remains a mystery; Why is he trying to win friends and influence people ?
Paolo Zampoli
What we are seeing is most likely a celebrity-obsessed businessman, who bought his way into the private halls of the United Nations, with a diplomatic passport from Dominica,  which allowed him to participate in the deliberations of that august body. As long as individuals can purchase diplomatic status, through programs that violate the Vienna Convention on Diplomatic Relations, these abuses will continue. We do wonder, who got the $250,000 ? It certainly did not end up in the National Treasury of the Commonwealth of Dominica.

Saturday, August 19, 2017


In responding to complaints that their economic citizenship programs allow high-risk individuals to obtain passports from a low-risk jurisdictions, proponents often point to the quality of due diligence that outside companies conduct on the applicants, especially in the five countries of the East Caribbean known for their CIP programs. A Civil Penalty recently levied by the Office of Foreign Assets Control (OFAC) could be a sign that these firms, and their actions, may not be as effective as we believe.

IPSA International Services Inc., a US-based "global business investigative and regulatory risk mitigation firm," has agreed to pay $259,200, to settle what OFAC describes as apparent violations of Iran sanctions regulations. The transactions cited totalled $290,784.

IPSA, which conducted due diligence investigations for an unnamed country's (St Kitts?) Citizenship by Investment program, when faced with vetting Iranian nationals, engaged its Dubai subsidiary to perform the tasks. That subsidiary in turn hired local background investigation contractors, working inside Iran, to obtain the information, and forward it to the US parent company, which used it in its due diligence investigations. The Iran-based contractors were thereafter paid by the Dubai subsidiary.

OFAC found that IPSAs compliance program was ineffective, with respect to the risks of the company doing business with Iran-origin background investigation services. If we cannot trust due diligence providers to obey US laws, how can we trust that they are delivering accurate and complete information to the operators of CBI programs ? The Civil Penalty also confirms that a large number of Iranian nationals are seeking to acquire citizenship, and passports, from low-risk countries located far from conflict zones. Since the Iran-based background investigators are in a jurisdiction where they cannot be disciplined, for negligence, or even intentional misinformation, how can we be sure that their data is truthful, current, and accurate ?

Furthermore, the consensus of opinion among North American compliance officers is that Caribbean CBI country operators are often disregarding the accurate due diligence investigation reports they request, and approving dodgy applicants purely for corrupt monetary reasons,  in Dominica and elsewhere, leading us to question the compliance comfort level of all East Caribbean CIP passports, from a risk-based perspective. The IPSA case should be a wake-up call to treat all passports from these jurisdictions, where the passport shows the holder was born in another country. with special attention.

Friday, August 18, 2017


The Palestinian Authority has handed down a decree, reportedly weitten by PA leader Mahmoud Abbas, which implements what is described as a cyber crime law, but in reality targets social media postings that are critical of the local government.The penalties are indeed Draconian.

 The new law provides for a maximum penalty of fifteen years for posting any social media content deemed offensive by the PA. The punishment call for imprisonment at hard labor, with sentences ranging from three to fifteen years*. The grounds, which are definitely overly broad, are listed as "harming national unity or social harmony." This means that social media posters who come down hard on the PA on any grounds, could be summarily convicted, and imprisoned.
* Palestinian journalists can be sentenced to as much as life in prison, for publishing articles the government considers objectionable, including those stories that expose corrupt officials.


 In the opaque world of diplomatic passport sales, it is definitely Caveat Emptor, let the buyer beware. Last year, a Ukrainian businessman*, who is linked to Dubai, and who wanted to buy a diplomatic passport from a cooperating Caribbean country, contacted Henley and Partners. A Henley officer named "Chris" represented that his firm was a duly licensed provider in several Caribbean jurisdictions, and showed him emails from Prime Ministers to prove the company's bona fides.

Chris instructed the applicant to wire $1,000,000, as and for the fee, to the firm's account at Wells Fargo in Singapore. You may view the wire transfer document below. it confirms the amount and the identity of the recipient.

 When Henley and Partners failed to deliver diplomatic passports from either Antigua, or Grenada, and ignored the businessman's repeated call, he contacted Antiguan authorities, who denied there was any application pending. Grenada, through one of its ministers, arranged, after a lengthy delay, for a refund. What's wrong with this picture ?  It appear that whatever constitutes the diplomatic passport program in Grenada is completely out of control.

The issues, all of which require investigation:

(1) Why didn't the applicant's fee go directly into an escrow, or trust account, of the Government of Grenada ? Does Grenada approve of this policy ?  Does it control its licensees at all ?
(2) Why is Henley and Partners holding a US Dollar account at a US Bank, in Singapore, for a Grenada Government client ?
(3) How did a US bank, Wells Fargo NA, accept one million dollars, for deposit into the account of a company known to service purchases of diplomatic passports, in foreign countries, a high risk client ?
(4) Did the Wells Fargo Bank compliance department perform due diligence on the sender, before accepting the wire transfer ? If not, why not ?
(5) Did any of the money end up in the hands of the Government of Grenada, or any of its officials ?
(6) Did Minister Alexandra Otway-Noel resign, because of the exploding diplomatic passport scandal in Grenada, and is Prime Minister Keith Mitchell the primary reason why she resigned ?

Whoever is in command of Global Compliance at Wells Fargo Bank should be required explain to FinCEN why it is banking foreign companies that deal in the sordid world of economic and diplomatic passports, in countries considered high risk.        

I will have more about Grenada's dysfunctional diplomatic passport program in the next article. 
* For the purposes of privacy, I have not named the applicant, but I will provide his name to any law enforcement agency that opens a criminal investigation into the matter.

Thursday, August 17, 2017


Let's assume the following: that I am one of thirty partners in a New York City law firm involved in representing Fortune 500 corporate clients in mergers and acquisitions. All of us are privy to confidential information that will affect the market prices of our clients' stocks. The SEC and FINRA have seen serious profits taken multiple times, all in advance of major events. If one of us supplying inside information to a conspirator, who is illegally trading and profiting from it,who are they, and who am I ? 

Criminal investigators seeking to determine if investors engaged in illegal insider trading of publicly traded securities often have difficulties linking individuals who possess non-public information, with confederates who have traded upon that information. Even armed with the identities of investors who made extraordinary profits based upon the subsequent release of positive business news, investigators often cannot uncover the necessary connections. The result is that many "Tippees" who have profited from their crimes are never charged. It was impossible to track them back to the source who divulged the inside information.

Enter into the equation a research tool* that enables the investigator to diagram and inspect not only indirect relationships, but relationships separated by more than one degree. These are connections that are so remote that conventional inquiries will never link them up. This result is accomplished through the use of artificial intelligence software algorithms which scan available social media sources, a feat that would literally take years to accomplish manually.

Therefore, returning to our initial fact pattern, user generated graphs and charts now created by those ai/deep learning algorithms, uncover and display two of my personal indirect connections, which appeared totally disconnected to effectively deny investigators access to conspirators. Using this software program myself, the culprits were identified as a former co-worker from my first job as an assistant district attorney, and that conspirator's onetime university roommate, from twenty years ago.These individuals who would most likely never be found through conventional means, would be identified, and linked to me, due solely to an asset that represents the application of technology to big data social media information.
* Note to readers: if you are not familiar with this social media resource, kindly email me privately at  and I will furnish that information to you.


Google News, which has recently undergone a major facelift, has cut back on so many of its valuable features that I deem it unsuitable for anyone looking for negative news in a due diligence investigation. It now reportedly limits, to 30 days, any articles it returns for a search query. Many researchers valued the Google news feature that went back several years, but regretfully that is now totally in the past.

In its current form, Google News (1) limits the  number of returns you receive from a search query, (2) has zero hyperlinks, a departure from its prior format, and (3) appears to value quality over quantity, meaning that you won't see the results that do not have high confidence. Now, when you perform a search, you often get no results at all; this is not acceptable to me.

Do any of your existing data services include CheckForRisk, by Nomino Data ? That's the only resource for negative news that I recommend you use (no, I am not affiliated with them in any way) , if you want total coverage; Check it out.