Dominica has revoked the citizenship of Abolfazl Shamkhani, the younger son of slain Iranian political adviser Ali Shamkhani, according to a letter obtained by OCCRP. The revocation, dated March 27, 2026 and signed by State Minister Daren Pinard, is part of a broader tightening of the country’s Citizenship by Investment (CBI) program. The government accused Shamkhani of obtaining citizenship through misrepresentation, specifically for concealing his father’s senior political role in Iran. He had obtained Dominican citizenship in 2020 under the alias “Sami Hayek.”

- Citizenship Obtained Under False Identity
Shamkhani reportedly acquired citizenship using an alias (“Sami Hayek”), while allegedly failing to disclose his family’s political connections. The government stated that this omission constituted a material misrepresentation, justifying the revocation. He has been granted 25 days to request a formal review of the decision.
- Family-Wide Action: Earlier Revocation of Brother’s Passport
This is not an isolated case. His older brother, Hossein Shamkhani, previously lost his Dominican citizenship in August 2025 under similar circumstances, also involving identity concealment (“Hugo Hayek”).
Hossein had already been sanctioned by:
- The United States (OFAC)
- The European Union
- The United Kingdom
Authorities accused him of operating a multi-billion-dollar oil-smuggling network linked to Iran and Russia, using foreign passports to obscure identity and financial flows.
- Financial and Corporate Network Allegations
Investigations by OCCRP and US authorities link the family to extensive international assets, including:
- At least $29 million in Dubai real estate, held under Dominican aliases
- Luxury properties in high-end developments such as Golf Place and Jumeirah Bay Island
- Participation in investment structures in Cyprus
- Corporate links to entities later sanctioned by OFAC
US prosecutors also filed civil forfeiture cases targeting $15.3 million, alleging funds connected to companies acting as fronts for the network.
- Dominica’s Policy Shift: Stronger CBI Enforcement
Dominica has significantly tightened its Citizenship by Investment program:
- All Iranian applications suspended as of March 2026
- Stricter eligibility rules (10-year non-residency requirement in Iran)
- Restrictions similar to those applied to North Korea and Sudan
- Up to $70,000 additional due diligence fees previously imposed on Iranian applicants
The country has also revoked 68 CBI passports since mid-2024, most due to fraud or misrepresentation.
- Broader Political and Security Context
The revocations come amid increasing international pressure on CBI programs. Western governments have expressed concerns that such programs can be used to:
- Obscure identity
- Evade sanctions
- Move capital discreetly across jurisdictions
The case is also linked to wider enforcement actions following sanctions on Iranian-linked networks and geopolitical tensions involving Iran and Russia.
- Regulatory Environment: Global Crackdown on CBI Programs
Dominica’s actions are part of a wider tightening trend affecting Caribbean CBI jurisdictions:
- The United States has imposed visa restrictions on Dominican nationals
- The EU has warned that CBI programs may lead to visa suspension risks
- Caribbean states face pressure to enhance due diligence and transparency
These developments reflect growing global scrutiny of investment migration frameworks.

Summary
The revocation of Abolfazl Shamkhani’s citizenship highlights a clear shift toward aggressive enforcement and compliance-driven CBI regulation.
Dominica is signaling that:
- Misrepresentation will lead to retroactive citizenship revocation
- Political exposure and sanctions risk are now critical screening factors
- The CBI model is under sustained international pressure and reform
At a broader level, the case underscores a global trend: Citizenship-by-Investment programs are moving from sales-driven systems toward security-regulated frameworks.

