LEADERS OF CARIBBEAN STATES WITH CBI PROBLEMS RUSH TO REASSURE THEIR PANICKED CITIZENRY AFTER NEWS OF BLOCKING OF ENTRY TO U.S. LEAK IN THE PRESS

If you are reading the Caribbean press, you may have seen today that the leaders of SAINT KITTS & NEVIS, SAINT LUCIA and the COMMONWEALTH OF DOMINICA are hastening to tell their anxious citizens that they haven't received any official notice from the United States, about their country's upcoming ban on their citizens receiving visas to enter the United States, after new leakee that their countries are on the draft list. the three East Caribbean states, whose Citizenship by Investment economic passport programs are all accused of fraud, money laundering and corruption, all are quite busy declaring that their programs have effective due diligence, and that their citizens should not be affected for those reasons. In truth and in fact, their due diligence programs are abysmal, dysfunctional, corrupt, and intentionally flawed, resulting in the distribution of passports to criminals, sanctions evaders, terrorist financiers, and intelligence agents from countries hostile to the United States.

Anyone following the systemic problems the Caribbean CBI jurisdictions knew that this day would come; the people of the East Caribbean are about to pay the price for allowing rampant corruption by their greedy government officials, and it will be painful for them to lose the ability to obtain a visa to visit friends and family in the US, shop here, and conduct business. There have been more than enough warnings given during the past five years, which they have chosen to disregard. They are about to see what the consequences are of their inaction.

The US has deemed the problem a National Security threat, after seeing arrests of Chinese nationals with CBI passports in the United States, for white collar crimes, economic espionage, and spying for the PRC. The new American administration has decided to put a stop to it. The official Banned Countries List is expected to be released soon, as early as Thursday, and it may contain additional countries; both Grenada and Malta could be included.

MONEY LAUNDERERS; EXPERTS AT APPEARING TO BE SOMETHING WHICH THEY ARE NOT

I am enjoying the new Apple TV Plus dramatic series, "Dope Thief," in which two criminals who pose as DEA agents to rip off drug dealers in their place of business make the mistake of attempting to steal from an organized crime operation, and are fleeing for their lives as the result. It may sound contrived, but when I was a career money launderer in Miami, my narcotics clients had to be very careful to avoid criminals who specialized in armed robberies of their operations. Those individuals engaged in that sordid business knew their victims could not go to law enforcement. Those attacks forced traffickers to follow a Golden Rule: never keep the drugs and the money together in the same location, a drug dealer's necessary risk management policy. One of my clients actually specialized in negotiating with those ripoff specialists, because they often took hostages, and demanded still more drugs from their victims, and/or cash.

The relevance to today's AML compliance issues is that experienced money launderers are very good in creating, and operating, what look like legitimate businesses, but are, in truth and in fact, well-planned laundering operations. This is especially important when it comes to the payment and payments processing sectors, where a clever laundering operation can move millions in the proceeds of crime into legitimate commerce, completely unnoticed and undetected, if compliance is not aware of the methods employed. Unlike the fictional series now streaming, the real-life posers generally succeed, and are long gone by the time someone in compliance in Payments Processing wakes up to the possibility that money laundering is occurring on a massive scale.

WHY ISN'T GRANADA ON THE NEW U.S. STATE DEPARTMENT BANNED COUNTRIES LIST? OVERSIGHT, NEGLECT, OR SOMETHING MORE SINISTER?

As my friend RICHARD MOIR so aptly suggested, "Why not Grenada, too?" after reviewing the leaked draft of the Department of State Banned Countries List, and not finding it there. All the other four East Caribbean states that sell Citizenship by Investment (CBI/CIP) passports were named & shamed, and are the only Caribbean jurisdictions listed, obviously because of the CBI scandal. read the Executive Order if you doubt me.

So what happened? Was it a new State staffer, hired solely because of his politics, and not his academic and vocational qualifications, who never took a geography course at university? Did the author of the list forget about the US invasion of Grenada? Was the person somebody's nephew, with no background in political geography, and not culturally literate? Remember HENG SHENG GROUP, the Chinese-controlled company that infected Grenada's CBI, sent its PM to see China's leader, and sold thousands of illegal passports to Chinese criminals and intelligence agents? Can you say due diligence, mate?

Or was it something more sinister; well-heeled foreign investors pairing their Grenada CBI with an American visa, who might just be manipulated into making a large (albeit illegal) campaign contribution? Whatever the reason, kindly add Grenada to the list, please. it is thoroughly deserved.

THERE ARE U.S.TRAVEL BANS FOR THE EAST CARIBBEAN CBI STATES ON THE STATE DEPARTMENT DRAFT LIST

The New York Times and several other major American news media are reporting that the draft list of countries, prepared by the Department of State, in response to President Trump's Executive Order entitled: 

PROTECTING THE UNITED STATES FROM FOREIGN TERRORISTS AND OTHER
NATIONAL SECURITY AND PUBLIC SAFETY THREATS

contains these East Caribbean States that have Citizenship by Investment (CBI/CIP) passport sales (Economic Citizenship) programs:

1. SAINT KITTS & NEVIS.

2. SAINT LUCIA.

3. THE COMMONWEALTH OF DOMINICA.

4. ANTIGUA & BARBUDA.

Complete mismanagement of the CBI programs of these countries appears to constitute the grounds for their inclusion by blocking the issuance of visas. We have been reporting on the fraud, money laundering and corruption that has infected them for a long time, and which was highlighted by MSR MEDIA in its public announcement, and subsequent litigation against present and former senior government figures, Chinese- controlled sales consultancies and their sub-agents, and affiliates.

The deadline for State to report its list of jurisdictions which it has included in the Travel Ban is this coming week, and the Draft List has been widely circulating, hence its availability. Readers who question whether the grounds for blocking all the nationals from these four EC States is CBI, look closely at the specific terms of the Executive Order; it is precisely the failure of the United States to properly vett CBI/CIP passport holders, whose true legal names and other identifiers may have been altered or changed which makes them a threat . You will notice that the non-CBI caribbean jurisdictions are NOT included on the Travel Ban list.

the bottom line is that the abject failure of the EC States with CBI to properly and legally operate their programs is the reason that all individuals who hold those passports because of their birthright citizenship, and about to pay the price for the misconduct of their corrupt national leaders, and their continued support of the illegal CBI programs.

Taken verbatim from the Times story:

Here is the relevant text of Trump's Executive Order dated 1/20/2025:

PROTECTING THE UNITED STATES FROM FOREIGN TERRORISTS AND OTHER NATIONAL SECURITY AND PUBLIC SAFETY THREATS

By the authority vested in me as President by the Constitution and the laws of the United States of America, including the Immigration and Nationality Act (INA), 8 U.S.C. 1101 et seq., and section 301 of title 3, United States Code, it is hereby ordered:

Section 1.  Policy and Purpose.  (a)  It is the policy of the United States to protect its citizens from aliens who intend to commit terrorist attacks, threaten our national security, espouse hateful ideology, or otherwise exploit the immigration laws for malevolent purposes.

(b)  To protect Americans, the United States must be vigilant during the visa-issuance process to ensure that those aliens approved for admission into the United States do not intend to harm Americans or our national interests.  More importantly, the United States must identify them before their admission or entry into the United States.  And the United States must ensure that admitted aliens and aliens otherwise already present in the United States do not bear hostile attitudes toward its citizens, culture, government, institutions, or founding principles, and do not advocate for, aid, or support designated foreign terrorists and other threats to our national security.

Sec. 2.  Enhanced Vetting and Screening Across Agencies.

(a)  The Secretary of State, in coordination with the Attorney General, the Secretary of Homeland Security, and the Director of National Intelligence, shall promptly:

(i)    identify all resources that may be used to ensure that all aliens seeking admission to the United States, or who are already in the United States, are vetted and screened to the maximum degree possible;

(ii)   determine the information needed from any country to adjudicate any visa, admission, or other benefit under the INA for one of its nationals, and to ascertain whether the individual seeking the benefit is who the individual claims to be and that the individual is not a security or public-safety threat;

(iii)  re-establish a uniform baseline for screening and vetting standards and procedures, consistent with the uniform baseline that existed on January 19, 2021, that will be used for any alien seeking a visa or immigration benefit of any kind; and

(iv)   vet and screen to the maximum degree possible all aliens who intend to be admitted, enter, or are already inside the United States, particularly those aliens coming from regions or nations with identified security risks.

(b)  Within 60 days of the date of this order, the Secretary of State, the Attorney General, the Secretary of Homeland Security, and the Director of National Intelligence shall jointly submit to the President, through the Assistant to the President for Homeland Security, a report:

(i)   identifying countries throughout the world for which vetting and screening information is so deficient as to warrant a partial or full suspension on the admission of nationals from those countries pursuant to section 212(f) of the INA (8 U.S.C. 1182(f)); and

(ii)  identifying how many nationals from those countries have entered or have been admitted into the United States on or since January 20, 2021, and any other information the Secretaries and Attorney General deem relevant to the actions or activities of such nationals since their admission or entry to the United States.

(c)  Whenever information is identified that would support the exclusion or removal of any alien described in subsection 2(b), the Secretary of Homeland Security shall take immediate steps to exclude or remove that alien unless she determines that doing so would inhibit a significant pending investigation or prosecution of the alien for a serious criminal offense or would be contrary to the national security interests of the United States.

Sec. 3.  Additional Measures to Protect the Nation.  As soon as possible, but no later than 30 days from the date of this order, the Secretary of State, in coordination with the Attorney General, the Secretary of Homeland Security, and the Director of National Intelligence, shall also:

(a)  Evaluate and adjust all existing regulations, policies, procedures, and provisions of the Foreign Service Manual, or guidance of any kind pertaining to each of the grounds of inadmissibility listed in sections 212(a)(2)-(3) of the INA (8 U.S.C. 1182(a)(2)-(3)), to ensure the continued safety and security of the American people and our constitutional republic;

REMOVAL OF THE BEST LAWYERS AT THE DOJ'S NATIONAL SECURITY DIVISION, AND PLACEMENT OF A POLITICAL APPOINTEE AS PERMANENT DIRECTOR WHO HAS DISTURBING BAGGAGE, MEANS THE US IS ABANDONING PROSECUTION OF THE CHINA THREAT IN THE CARIBBEAN

If you are watching the news from Washington this week, you know that all the senior leadership in the Department's National Security Division, as well as the experienced career prosecutors who are the heart and soul of the Division, have been terminated. The unit has essentially been gutted of its best legal talent, and it gets worse.

The Acting Director, Devin Debacker, who is a career prosecutor, and who has been serving since the beginning of the Trump Administration, has been abruptly terminated, and JOHN EISENBERG has been nominated to serve as Permanent Director, in what must be regarded as a purely political appointment in a career position. You may remember Eisenberg from his alleged role in the leak of classified information to DEVIN NUNES, and his reported transfer, to a classified server, of an incriminating telephone call between Trump and the leader of the Ukraine, and his alleged efforts to contain the dissemination of the details of that call, by instructing LTC Vindman, who was on that call, not to tell anyone about it.

We are advised that the ongoing Federal investigation into billion-dollar fraud, money laundering and corruption, in the Citizenship by Investment (CBI/CIP) programs of the East Caribbean states, which has serious issues involving the national security of the United States, especially its financial sector, will be transferred to the National Security Division. Given that we must presume that a number of the major American banks that have a known long and sordid history of facilitating the money laundering of Chinese-controlled companies, and would logically be co-defendants together with the Senior Caribbean officials who cooperated with the Chinese companies, all the government actions since since Trump took office would indicate that there will not be any targeting of American entities, especially financial institutions, it is extremely doubtful that we will see any indictments arising out of the CBI investigation, notwithstanding the incriminating evidence which has publicly surfaced.

The illegal sales of discounted economic citizenships & passports, which has reportedly continued unabated through programs in Saint Kitts & Nevis, Saint Lucia, Grenada, and Dominica, and possibly elsewhere, continue unrestricted, in some locations even on an expedited basis, without a gatekeeper. It now appears that the US Department of Justice cannot be bothered to tackle it, and will ignore what is an increasingly more disturbing national security threat and clear and present danger, due to what can only be considered partisan politics. Hereafter, any banker that accepts a Caribbean CBI passport as proof of identity might want to check into whether he has adequate insurance coverage.

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ST. KITTS FOREIGN MINISTER DENZIL DOUGLAS, A CENTRAL FIGURE IN HIS COUNTRY'S CBI FRAUD, MONEY LAUNDERING AND CORRUPTION SCANDAL, REJECTS AMERICAN DEMAND FOR BREAKING TIES WITH CUBA, A DESIGNATED STATE SPONSOR OF TERRORISM

DENZIL DOUGLAS, the Minister of Foreign Affairs in Saint Kitts & Nevis, has publicly declared that his country will not terminate its close relationship with the Government of Cuba, after the United States reportedly notified the SKN Prime Minister, TERRANCE DREW, that it will revoke the American visas of all Kittitian officials if the country does not break off its cooperation with the Republic of Cuba, including the physical presence of Cuban nationals in the medical profession. Douglas, in making that official statement, has demonstrated Saint Kitts' loyalty to Cuba, a State Sponsor of Terrorism under US law.

Minister Douglas, who is also a former prime minister, is one of the major players implicated in the massive billion dollar fraud, money laundering and corruption scheme in Saint Kitts, in which a Chinese-controlled company, CARIBBEAN GALAXY GROUP, sold thousands of illegally-discounted economic passports to dodgy Chinese and other foreign nationals, many of whom have now been arrested in a number of countries for financial crime, espionage, and other illicit activities. He is no stranger to controversy; he holds a diplomatic passport issued by the Commonwealth of Dominica, which states that he is a native-born Dominican citizen which he has admittedly used to conceal his Saint Kitts nationality in international travel. He is reportedly at the top of a target list for indictment for money laundering in the United States.

SOUTH AFRICAN AUTHORITIES INVESTIGATING FIFTY NON PROFIT ORGANIZATIONS FOR TERRORIST FINANCING AND MONEY LAUNDERING

Reports from South Africa confirm that regulatory and law enforcement agencies have approximately fifty non profit organizations under investigation for terrorist financing and money laundering, responding to a deficiency listed by the Financial Action Task Force in AML/CFT. While countering the financing of terrorism is states to be a major concern, money laundering and tax evasion are also listed as part of the ongoing investigation.

Given the large number of targeted NGOs, none of which have been publicly identified, compliance officers at SA banks and non-bank financial institutions should reduce risk levels by conducting new due diligence procedures on clients that declare themselves to be non-profits, to rule out the possibility that any which were approved at account opening are now engaging in illegal activities.

Questions to answer: Are there any new signatories on NGO accounts since account opening? They should themselves be subject to due diligence; have any NGO clients added additional addresses, new missions, international operations, funds transfers abroad, payments to high-risk jurisdictions, or any other new activities which might indicate illicit activity? Follow up on any positive indicators, to rule out AML/CFT issues, and thoroughly document all the findings, reporting them up your chain of command.

TRUMP ADMINISTRATION FIRES THE DIRECTOR OF OCDETF, WHICH WILL HURT PROSECUTIONS OF MONEY LAUNDERERS IN THE UNITED STATES

The number two official at the Department of Justice, Todd Blanche, a Trump political appointee, abruptly fired ADAM COHEN, who is the Director of the ORGANIZED CRIME DRUG ENFORCEMENT TASK FORCE, more commonly known as OCDETF, a move which will definitely affect the DOJ efforts to convict money launderers for narcotics traffickers. OCDETF targets drug trafficking organizations, including the laundrymen that clean the millions of dollars these groups each each month within the Continental United States, and their prosecution is key to suppressing their sophisticated money laundering operations.

I know this because, many decades ago, my own narcotics trafficking money laundering operation was targeted, and taken down by, OCDETF. It is a totally apolitical branch of the DOJ, with a superior crime suppression capability, and to summarily remove its Director, a key component, only to replace him with a less qualified political appointee, which is what will obviously now happen. Effective prosecutions of experienced money launderers, who are adept at concealing their operations inside legitimate industries, and using methods who often defy identification and exposure, require the type of investigatory skills that OCDETF possesses. I am not optimistic that the future appointee, who will get the job in large part because of his political views and statements, not his competency, will be able to do the job the position demands.

THE CAMPAIGN TO EXPOSE FRAUD AND CORRUPTION IN THE CITIZENSHIP BY INVESTMENT INDUSTRY SHIFTS TO DOMINICA

If you have been following the news, regarding the unfolding scandal of fraud, money laundering and corruption that pervades the economic passport (CBI/CIP) industry in the East Caribbean, you must know that first, Saint Kitts & Nevis, and then Saint Lucia were exposed to the billion dollar fraud, perpetrated by the Chinese-owned consultancy, CARIBBEAN GALAXY GROUP, in those two island states.

Then, we learned of the operation of a massive illegally-discounted passport sale fraud in Grenada, by the new Dubai-based HENGSHENG GROUP, also under Chinese ownership. This second phase of the scandal is about to further stain an industry that prefers to label itself "Investment Migration," although its primary focus is selling passports facilitating visa-free access to the UK & EU, for individuals from countries of elevated or high risk.

Now, given that we know that a large number of incriminating documents, have been produced in an unrelated legal proceeding, constituting evidence that passport agents licensed by the Commonwealth of Dominica have sold a very large number of illegal citizenships to that country, you can expect that the scandal will expand to that state. In fact, the most popular article on the subject happens to be:

DOMINICA CONTINUES TO SELL CBI PASSPORTS AT AN ILLEGAL DISCOUNTED RATE, IN VIOLATION OF THE MEMORANDUM OF AGREEMENT IT SIGNED LAST YEAR

Therefore, we can fully expect civil litigation over Dominica's illicit program during 2025; the big question is, of course, whether those deposits of CBI payments by the country's banks, into correspondent accounts in the United States, which by definition constitute money laundering under The Money Laundering Control Act of 1986, will result in indictments of the Dominican players this year. Caribbean insiders are watching for it, and the impact it will have on the future of the economic passport industry in general; Stay tuned.

TRUMP PLAYS DIPLOMATIC HARDBALL; HE TELLS CARIBBEAN LEADERS: IT'S THE UNITED STATES OR CHINA, AND YOU MUST NOW CHOOSE. HE ALSO THREATENS LOSS OF VISAS FOR ITS LEADERS TO VISIT AMERICA, IF THEY DON'T CEASE MEDICAL COOPERATION WITH CUBA

American President Donald Trump, in what has been reported in local media as a direct challenge to Caribbean leaders, is forcing them to choose the United States over the Peoples' Republic of China, in what is fast becoming a new Cold War between the world's greatest economic & military powers. The Caribbean states are being told to disengage with China, and to render unqualified allegiance to the U.S. upon pain of diplomatic and economic sanctions, if they decline.

And in an even more direct statement, Trump has advised the most senior Caribbean leaders to either cancel all medical cooperation with Cuba, or face the loss of visas for politicians and government leaders to visit the United States. The Caribbean states are now faced with a hard choice, for China has freely extended credit for vital infrastructure, but the U.S. wants the region to be free from becoming part of China's sphere of influence, and is demanding that the Caribbean unmoor itself from China, and firmly support America, or face painful economic and political consequences. 

We will be watching to see which choice the EC states now make. Will the region's left-leaning Caribbean leaders defy President Trump, and risk crippling sanctions from their largest trading partner and source of remittances from Expats, by retaining their financial ties with China and Cuba? These are hard choices; will these leaders make the correct one?

SOUTH AFRICA'S RECOGNITION OF HAMAS POSES A CLEAR AND PRESENT DANGER OF TERRORIST FINANCING RISK TO THE COUNTRY'S FINANCIAL INSTITUTIONS

The love affair between the African National Congress (ANC) and HAMAS, which is a designated (and sanctioned) global terrorist organization in several Western countries, notably the United States, raises risk levels in South Africa's financial sector and requires increased sensitivity to possible unwitting exposure to terrorist financing, when matters of international banking are concerned.

There are multiple issues that compliance officers at the country's major banks must be constantly aware of:
(1) Are exports to the Middle East really a supporter of Hamas or the ANC providing material support to a sanctioned terrorist organization?
(2) Is the movement of funds abroad by a Politically Exposed Person (PEP) the transfer of bribes payments made by Hamas to a government official or politician, now finding their way into a Western bank?
(3) Is that obscure small company, opening an account at your bank, in truth and in fact really a front for a terrorist operation?
(4) Could compliance malpractice in interdicting funds connected to Hamas result in an OFAC sanction to your bank, blocking all access to the American financial structure, with the resulting loss of competitiveness threatening its long-term existence?

Compliance officers at banks in Johannesburg, Cape Town, Pretoria and Durban, whose clients are engaged in substantial international trade and commerce, must defend daly against these threats, the failure of which to do so could prove fatal when exposed by Western regulatory bodies or law enforcement agencies. They require special practical training on advanced money laundering techniques to be able to identify and interdict those methods in real-time, and to coordinate with law enforcement so that the laundrymen are arrested and convicted, reducing the banks' risk to terrorist financing charges abroad to acceptable levels. Presently, such education and training is not being conducted, but if such steps are not taken, there will be, sooner or later, consequences imposed from abroad.