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An affidavit, prepared by a law enforcement investigator in the State of New York, and filed in the Federal criminal case against Iranian banker Ali Sadr Hashemi Nejad, the accused principal money launderer in the massive hundred million dollar Iran sanctions evasion case that drew international attention to Malta's Iranian-controlled Pilatus Bank details how St. Kitts & Nevis was employed in furtherance of the money laundering pipeline. It clearly shows that St. Kitts remains an active facilitator of international money laundering schemes, especially those used by Iran to evade US and international sanctions. Remember, Hashemi Nejad holds a St. Kitts CBI passport.
These facts illustrate why the US & Canadian governments consider St. Kitts to be an existing money laundering threat:
(1) Hashemi Nejad's primary money laundering vehicle, Stratus Global Investments, Ltd., was reportedly incorporated in St. Kitts. It was allegedly a"private equity firm domiciled in St. Kitts with a head office in Dubai". It is considered a non-transparent shell entity controlled by, and for the sole benefit of, the Government of Iran.
(2) The extensive recitation of transfers of funds, specifically designed to evade identification of, and interdiction by, US law enforcement, and global banks, included transfers through, into, and out of, St. Kitts & Nevis.
(3) The affidavit specifically states "St. Kitts & Nevis has been specifically identified by the US Department of Treasury's Financial Crimes Enforcement Network (hereinafter "FinCEN") as a high-risk jurisdiction, given its lax anti-money controls and DEARTH OF FINANCIAL AND CORPORATE OVERSIGHT." [emphasis supplied].
Compliance officers should continue to regard any sizable transaction involving a St. Kitts & Nevis origin or destination, or employing an SKN corporation or other types of entity, as a suspect, and initiate an Enhanced Due Diligence investigation forthwith, prior to approving it for any purpose. Until St. Kitts enacts true reforms, the risk levels are simply too high.
Chronicles of Monte Friesner - Financial Crime Analyst 
Contributed by Kenneth Rijock - Financial Crime Consultant
