Passports of the Caribbean: An Iranian Shipping Magnate, a Hotel That Never Got Built, and 7,700 Dominican Passports

He owned £25 million of prime London real estate, three apartments at 199 The Knightsbridge, purchased in Dubai under an alias called Sami Hayek. Mohammad Hossein Shamkhani is the son of Iran's Minister of Defence and the target of a US OFAC sanctions filing — and the passport he used to move money and buy property wasn't Iranian. It was Dominican, bought through a Caribbean citizenship-by-investment scheme, alongside 7,700 others, 1,400 of them Iranian nationals. This briefing traces how that passport pipeline works, who's using it, and what it means for any firm checking a counterparty's nationality at face value.

What’s inside

• The Shamkhani network - how a sanctioned Iranian shipping magnate and his associate Hossein Ghorbani Zahed used Dominican passports to acquire £25 million of Knightsbridge property and $29 million of Dubai real estate under an alias, while his network's shipping operations were separately sanctioned for financing the IRGC's Quds Force
• Dominica's Golden Passport economy - how a $100,000 donation buys visa-free access to the Schengen area, the UK and Australia, why the scheme became a vital revenue lifeline for a 72,000-person island economy, and how it became the preferred route for Iranian nationals after other citizenship-by-investment countries closed their doors
• Cankash and the Tranquility Beach Hotel - how an Iranian citizenship-by-investment broker embedded itself in Dominican politics, meeting the Prime Minister and the head of the Citizenship by Investment Unit, while marketing a beachfront hotel investment that appears never to have been built
• Themis' own UK company data analysis - uncovering 706 Dominican nationals sitting as directors or persons of significant control of UK companies, 93 of them with Persian names, including sanctioned individuals tied to Douran Software's surveillance work and Opal Exchange's sanctions-evasion financing
• The Pirouzan network - how OFAC-designated sanctions evader Pedram Pirouzan and his associate Hossein Mohammad Rezaei ran UK front companies mimicking Chinese business names, CK Huichison and Sunning Commerce, from a shared letterbox address in Wales, and how Themis Search mapping caught UK entities that OFAC's own listing missed
• The 2026 enforcement response - Dominica's closure of its scheme to Iranian nationals since March 2026, the EU's July 2026 threat to end visa-free travel for Caribbean passport holders, and what it signals about the international squeeze on citizenship-laundering routes
• Practical guidance for firms - why a passport of origin can no longer be treated as a reliable proxy for nationality risk, what red flags to build into onboarding and periodic review, and how network mapping catches the front companies and alias identities that a clean passport check would miss