On July 13, 2021, the Justice Department announced the indictment of four Iranian nationals for kidnapping conspiracy and other charges stemming from an alleged plot to abduct a well-known journalist and human rights advocate living in New York. The “outlandish plot,” as described in the indictment, contains details such as the group’s consideration of transporting their intended victim from her home in Williamsburg, Brooklyn, to Venezuela via boat.
Interesting aspects of this story have been overlooked in the general media coverage, particularly the conspirators’ use of legitimate US-based companies and mobile payment services in their scheme:
- According to the indictment, the kidnapping ring retained the services of a Manhattan-based private investigator to surveil their intended target. The US investigator was falsely told in email correspondence that the purpose of the assignment was to locate a missing person who owed a debt to a private client based in Dubai.
- One member of the kidnapping ring, then residing in California, paid the US investigator thousands of dollars for services rendered using a popular, US mobile payment app. To avoid raising money laundering or illicit finance concerns, the group structured payments to avoid reaching certain disclosure thresholds.
Why it matters:
This incident highlights the potential risks companies or individuals can face when dealing with unknown third parties, including those that may be referred by a trusted associate or friend. This is particularly true for small or newly established firms that may face pressure to develop new business, or lack the time and expertise, to properly vet potential new clients or business partners.
Although the kidnapping ring attempted to obfuscate their intent with a cover story, even basic investigatory research into the request could have identified possible red flags, the most obvious of which being that the target of this ostensible debt recovery effort was a prominent and outspoken critic of the Iranian government.
Email correspondence between the conspirators and their unwitting US partner show signs that should have elicited heightened skepticism. For example, the target, first described as a “missing person,” later is called a “suspect.” Their stated motive also did not align with the requested scope of work. Why exactly does a debt recovery effort require any information whatsoever on who may be visiting the debtor’s house?
Regular due diligence practices are designed to identify and uncover undisclosed interests, as well as other reputational, legal, or regulatory risks. The implementation of investigatory due diligence may have helped these businesses avoid becoming unintended co-conspirators in the facilitation of an international kidnapping scheme. It may have even helped bring this to the attention of law enforcement.