The individual who solicited and received $1,000,000 for a diplomatic passport, from a European businessman has been identified as the Managing Director of a company that sells passports through Citizenship by Investment, through a number of East Caribbean countries. He is Christopher Willis, then the MD of Henley & Partners Caribbean Ltd., believed to be a wholly-owned subsidiary of Henley & Partners, located in Jersey, in the Channel Islands. Willis is currently listed as such on Internet websites, and has been quoted in the press, as recently as May, 2017, representing himself as such, though the company new claims he does not hold that position, but another one in another location.
The victim, who was led to believe by Willis that he could obtain a diplomatic passport in Either Antigua or Grenada, due to the strength of his relationships there with government, was ordered to send via wire transfer the sum of one million dollars, to an account at Wells Fargo Bank in Singapore. He never received the passport, and initiated inquiries through government, at the highest level, after hearing, from another victim, similarly situated, who also made a very large payment, and did not receive a passport, on any kind or type, in return.
Correspondence received by this blog showed that Antiguan authorities have never had any file on the victim, CBI or otherwise, and advised him accordingly, which he acknowledged. We confirmed this information through other channels; Antigua was not involved. He then moved on to Grenada with his inquiries.
The victim's correspondence to Grenada resulted in an extensive exchange of emails, between him and the minister charged with CBI matters in that country. No mention appeared of any passport; it centered around the return of his fund, and how Grenada could assist him. Grenada did not deny that he was known to them, but offered to facilitate a complete refund.
Several months later, the victim reported that he had recovered his money, but whether any part of it was received by senior government officials in Grenada has not been confirmed. Possible violations of the Foreign Corrupt Practices Act (payment was in US Dollars), FinCEN or TARP regulations, are under investigation.
CHRISTOPHER WILLIS IN DOMINICA
It is important to note that none of the five CBI programs being administered in the nations of the East Caribbean provide for the purchase of diplomatic passports, which do NOT confer citizenship, and which are strictly regulated by the Vienna Convention, in which all the CBI-issuing nations are members. Any distribution of a diplomatic passport to non-nationals, of any country, is a violation of the Convention, are are generally regarded as void, as a matter of international law. Several Caribbean countries have been rocked by diplomatic passport scandals, involving international financial criminals, notably Dominica.
Finally, we should consider Wells Fargo Bank, whose acceptance of those funds flies in the face of generally-accepted compliance procedures, regarding both high-risk customers, as well as, high-risk jurisdictions. Wells Fargo is reportedly the correspondent bank for foreign financial institutions that bank a number of companies that sell CBI products. Its participation in the transaction which is the subject of this article call into question the effectiveness of its global compliance program, including but not limited to, Know Your Customer (KYC), and Know Your Customer's Customer (KYCC) regulations, as well as Banking Best Practices.
Chronicles of Monte Friesner - Financial Crime Analyst
Contributed by Kenneth Rijock - Financial Crime Consultant