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
Also shows an Iranian address:
Unit 36, Mahtab Building
Livarchi, Villa St,
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 ?
Chronicles of Monte Friesner - Senior Financial Crime Analyst
Contributed by Kenneth Rijock - Financial Crime Consultant