Investigate the Misuse of U.S. Passports and End Financial Discrimination Against Law-Abiding Iranians حسین عطار جاننثار نوبری
A U.S. Passport Must Not Become a Shield for Hidden Financial Control
I am HOSSEIN ATAR JANNESAR NOBARI, the initial petitioner of this campaign.
I am asking international financial regulators, law-enforcement authorities and governments to investigate a serious vulnerability in the international financial system: the potential misuse of the identity and passport of a U.S. citizen as a front for companies, bank accounts and international financial structures that are actually controlled by other people.
Why the U.S. passport matters
A United States passport provides its holder with extensive international mobility and a level of institutional and commercial credibility that is not equally available to citizens of many countries.
That credibility can become a vulnerability if a person’s identity is used by someone else.
We are particularly concerned about the alleged use of homeless, unemployed, financially vulnerable or economically inactive Americans who have little or no genuine commercial history as nominal owners, directors, shareholders or account holders.
A person may appear on corporate documents as the owner or director while the actual source of the money, the ultimate beneficial owner and the person exercising real control remain hidden.
The issue is not that an American citizen is inherently trustworthy or untrustworthy.
The issue is whether a U.S. passport can be deliberately used as a trusted identity to obtain banking and commercial access for someone who is not the real owner or controller.
If this occurs, the passport becomes more than a travel document. It becomes a potential instrument for creating an appearance of legitimacy.
The international financial network
This issue deserves investigation in major international financial and commercial centers, including:
the United States, London and the United Kingdom, Hong Kong, Singapore, Germany, Switzerland and the United Arab Emirates, as well as other jurisdictions that provide international corporate, banking and payment services.
A company incorporated in one jurisdiction may maintain accounts in another, conduct transactions through a third, and ultimately be controlled by a person located somewhere else.
This makes effective verification of the Ultimate Beneficial Owner (UBO) essential.
A company registration certificate, a bank account, a residential address or a valid American passport cannot by themselves establish who actually controls the money.
The criminal risks
Where beneficial ownership and source of funds are inadequately verified, international financial structures can potentially be exploited for serious crimes, including:
- money laundering;
- drug trafficking;
- human trafficking;
- illicit arms trafficking;
- organized fraud;
- sanctions evasion;
- financing of illegal armed networks;
- illicit trade in restricted military-related goods and technology;
- trafficking involving drones, missiles and controlled components; and
- other forms of transnational organized crime.
The purpose of this petition is not to accuse every American citizen, American company or financial institution of criminal conduct.
It is to demand that authorities investigate whether legitimate U.S. identities are being deliberately used as front identities to obtain financial access for people who are not the true beneficial owners or controllers.
The other side of the problem: law-abiding Iranians
I am Iranian.
Millions of Iranian citizens are ordinary people, entrepreneurs, professionals, workers and families who have never personally committed money laundering, terrorism financing, trafficking or any other financial crime.
Yet Iranian citizens can face severe obstacles to international banking, payments and legitimate commerce simply because of their nationality or connection to Iran.
This creates a profound question of fairness.
Why can a person who happens to be a homeless or financially vulnerable U.S. citizen benefit from the international credibility associated with a U.S. passport, while a law-abiding Iranian may face financial exclusion before any personal wrongdoing has been established?
The issue is not whether sanctions or financial controls may ever be legitimate.
The issue is whether nationality should become a substitute for individual evidence.
A person should be assessed according to:
- actual conduct;
- criminal and sanctions status;
- ultimate beneficial ownership;
- source of wealth;
- source of funds;
- commercial activity; and
- actual financial risk.
What we demand
We call upon the Financial Action Task Force (FATF), United Nations Office on Drugs and Crime (UNODC), INTERPOL, financial regulators and relevant law-enforcement authorities to:
- Investigate the alleged use of homeless, financially vulnerable or economically inactive U.S. citizens as nominal owners, directors, shareholders or account holders for businesses controlled by third parties.
- Investigate whether U.S. passports and identities are being deliberately used to obtain corporate, banking or financial access for undisclosed beneficial owners.
- Strengthen international Ultimate Beneficial Owner (UBO) verification.
- Require enhanced due diligence where a person’s financial circumstances and genuine commercial history are inconsistent with the scale of the companies or transactions associated with them.
- Examine corporate and banking structures operating through major financial centers, including the United States, London, Hong Kong, Singapore, Germany, Switzerland and the United Arab Emirates.
- Strengthen cooperation against financial structures used for money laundering, trafficking, illicit arms transfers, organized fraud, sanctions evasion and financing of illegal armed networks.
- Ensure that possession of a U.S. passport does not substitute for verification of the real owner, controller, source of wealth and source of funds.
- Establish transparent mechanisms through which law-abiding Iranian individuals and businesses can demonstrate their identity, lawful source of funds, beneficial ownership and legitimate economic purpose.
- Ensure that individuals who are not personally sanctioned and have not committed financial crimes are not automatically treated as criminals solely because of their Iranian nationality.
One standard for everyone
We are not asking for special treatment for Iranians.
We are not asking for restrictions against Americans.
We are asking for one evidence-based standard.
A U.S. passport should not be a substitute for financial due diligence.
An Iranian passport should not be a substitute for evidence of criminal conduct.
Criminal networks should not be able to hide behind legitimate identities, while legitimate people should not be treated as criminals merely because of theirs.
I, HOSSEIN ATAR JANNESAR NOBARI, call upon the international community to investigate this contradiction and build a financial system in which actual conduct, beneficial ownership and evidence—not nationality alone—determine financial risk.
HOSSEIN ATAR JANNESAR NOBARI
Initial Petitioner
حسین عطار جاننثار نوبری - بازرگانی نوبری
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