MAJOR PROBLEMS HAVE ALREADY EMERGED WITH THE NEW CBI PROGRAM AT SAO TOME AND PRINCIPE

Compliance officers, if you were wondering why the concerted disinformation that has appeared of late, attempting to discredit the undersigned's warnings about corruption in Citizenship by Investment programs, it was to confuse you about emerging threats I am covering. My sources have confirmed that the new CBI program at West African country, SAO TOME' AND PRINCIPE, is accepting, and processing, applications for economic passports from nationals of RUSSIA and IRAN, two jurisdictions on international sanctions list, and which are blocked from applying at most CBI programs. These passports can then be employed for sanctions evasion and related money laundering by bad actors working for those two outlaw states.

Furthermore, we are advised there is a rush on Sao Tome' applications, the majority of which are originating in the investment migration consultancies located in the United Arab Emirates, principally in Dubai. These companies exist there free of any regulation, control and enforcement, and Dubai has been the site of the majority of the massive prior sales of illegally discounted Caribbean CBI & CIP, passports, through Chinese companies which diverted billions of dollars to Hong Kong, denying needed revenue to the people who were the intended beneficiaries.

Please note that Sao Tome' is of particular interest to the law enforcement agencies of the United States, as it was the aviation registration jurisdiction of choice for Russian organized crime , which used the S9 prefix to hide the beneficial ownership of dozens of turboprop aircraft, whilst ferrying them to COLOMBIA, and other drug-producing countries in South America, where they became the aircraft of choice to transport cocaine and bulk US Dollars. in the region. Considering that it is US law enforcement that is tipping us off to the Sao Tome CBI passport abuse, we must assume that Russians and Iranians now holding those passports have now drawn their close attention.

We are aware that compliance officers at international banks generally check Place of Birth on all passports proffered by new customers, to determine whether they are being presented with a CBI document, but unless the holder of a Sao Tome' passport is a Portuguese expat who grew up there, and has the language skills and general familiarity with what is an obscure jurisdiction, you are urged to discredit any recitation of local birth, and institute enhanced due diligence on the holder, prior to accepting any funds at account opening.

FOR FURTHER READING:

https://rijock.blogspot.com/2025/11/consumers-acquiring-cbi-passports-from.html

https://rijock.blogspot.com/2026/03/acquiring-cbi-passport-from-african.html

IF YOU CANNOT ACCEPT THE UK FINDING THAT CBI IS "INHERENTLY HIGH RISK," THEN YOU ARE IN DENIAL, AND PART OF THE PROBLEM, NOT PART OF THE SOLUTION

If you read the comments closely, you have seen that my commentary regarding the risk factors that compliance officers at financial institutions face, when it comes to the money laundering and financial crime threat posed by the holders of Citizenship by Investment (CBI) economic passports, is getting a lot of pushback by individuals who deem my articles a threat to their livelihoods. Those people wish to distract potential purchasers of CBI passports from the UK Government's findings of fact, and its pronouncement that economic passports pose an "Inherently High Risk," by stating that my warnings constitute fear mongering, and that all major Western jurisdictions are also infected with financial crime.

This approach, which is a cleverly designed marketing tool, intended to distract consumers from the distinct possibility that their six figure CBI purchase may at some point become useless for visa-free travel into the countries which they purchased it for, by falsely endorsing what are passport sales programs already known to have rampant shortcomings regarding major money laundering, corruption and financial crime issues, should be ignored.

Economic passports, in the hands of career financial criminals, facilitate crime, pure and simple. Whilst the majority of those holding them use them merely to evade the expensive and time-consuming visa application process, those with ill intent are not to be disregarded as serious threats by the compliance community. The UK, and US and the EU are not wrong, when they advise about CBI being a systemic problem, and readers should disregard the slick marketing programs touting them as safely administered, because that is a misstatement of material fact.

Remember, we are required to maintain an effective risk-based compliance program; ignore the propaganda, people.

ACQUIRING A CBI PASSPORT FROM AFRICAN STATES NOW OFFERING THEM INSTEAD OF FROM THE CARIBBEAN IS JUST TRADING CORRUPTION AND MONEY LAUNDERING FROM ONE REGION FOR ANOTHER

The explosion of new opportunities to secure a Citizenship by Investment (CBI) economic passport from countries in Africa which have recently begun to offer them to consumers, while it sounds like a solution, is merely moving from one problem area, the Caribbean, to another, with the same issues. The investment migration industry, correctly abandoning the high-risk Eastern Caribbean CBI & CIP states of St. Kitts, Antigua, Dominica, St. Lucia and Grenada, for what it deems to be safer waters, is respectfully only trading one area fatally infected with corruption and money laundering for another.

A quick look at TRANSPARENCY INTERNATIONAL's take on those new African states now offering CBI passports shows that they all exhibit a high level of corruption, and a quick look at their poor levels of anti-money laundering and countering of terrorist financing activity also reveals that these jurisdictions fail to meet banking best practices benchmarks on those subjects. Not only that, but some African jurisdictions have additional problems which some risk managers might judge even more serious than those of the high-risk Eastern Caribbean. See CONSUMERS ACQUIRING CBI PASSPORTS FROM SIERRA LEONE AND SAO TOME & PRINCIPE MAY BE IN FOR A ROUGH RIDE: THOSE JURISDICTIONS HAVE MAJOR CORRUPTION ISSUES; IS IT SAINT KITTS ALL OVER AGAIN? https://lnkd.in/eeuTzMvz

While we understand the industry's move away from the rampant issues facing the Eastern Caribbean CBI states, perhaps it is better move to switch their clients to new jurisdictions without such existing corruption and money laundering baggage, such as the emerging program being constructed by ARGENTINA, with the assistance of well-known investment migration companies. Advising consumers to buy CBI passports from the African states who now have jumped head-first into the economic passport sector does not better serve their needs, and if there are issues with improper termination of citizenship rights by those countries in the future, I seriously doubt that their corrupt court systems with mete out justice fairly to foreign plaintiffs with claims adverse to their governme

SAINT LUCIA'S INVESTMENT MINISTER, ERNEST HILAIRE, LIES, DENIES AND OBFUSCATES ABOUT WHY THE UK JUST TERMINATED HIS COUNTRY'S VISA-FREE ADMISSION PROGRAM: IT'S CBI, YOU CONMAN

minutes ago • Edited • Visible to anyone on or off LinkedIn

Ernest Hilaire

Saint Lucia's Investment Minister and Deputy Prime Minister ERNEST HILAIRE, who has presided over the biggest theft in his country's history, through the sale of economic passports, has flat out lied to his constituents, regarding the reason the United Kingdom has imposed visa restrictions on them. He has tarnished his country's international reputation for years to come, due to his own personal greed, whilst assisting the Chinese-controlled CARIBBEAN GALAXY GROUP to illegally divert billions of US Dollars of CIP revenue abroad.

To add insult to injury, in Saint Lucia, Hilaire , notwithstanding a clear statement in a letter to his Prime Minister by the UK Government, a statement on its website, and a statement by the Home Secretary, Hilaire has the hubris to stand up in the Saint Lucian Parliament, and try to convince his listeners that they didn't hear what the UK Government told them, and the reason was native-born St. Lucians claiming UK asylum.

What do you think the UK Government will do, when it learns that there have been an additional 36,000 SLC passports sold over the last two years, and that this information has been withheld from public disclosure?

When the pendulum of justice swings back on the side of the Rule of Law, and Hilaire is held to account for his Crimes Against the State, it is suggested that he be sentenced to be placed upon the uninhabited Antiguan island of REDONDA, where he can contemplate the damage he has wrought to Saint Lucia, and his dark legacy.

AGENT WORKING FOR NEW RULER OF IRAN USED NEVIS SHELL COMPANY, SAINT KITTS CBI PASSPORT TO EVADE INTERNATIONAL SANCTIONS, ACQUIRE BRITISH REAL ESTATE WORTH OVER THREE BILLION POUNDS

As more detailed information, regarding the artful efforts of ALI ANSARI, the loyal agent of Iran's new Supreme Ruler, MOJTABA KHAMENEI, to accumulate pricey British real estate, one thing has caught out attention: his use of SAINT KITTS AND NEVIS to accomplish his covert goals. According to multiple reports, Ansari repeatedly employed a NEVIS shell company, ZIBA LEISURE LTD., later known as SMART GLOBAL, to hold those properties. Ansari also reportedly purchased a Saint Kitts & Nevis CITIZENSHIP BY INVESTMENT passport, to facilitate his transactions.

It has come to the point now, that the use of ANY Saint Kitts & Nevis corporation or business entity should set off alarms inside the head of any compliance officer, monitoring account opening, real estate transactions, business acquisition, purchase of aircraft or vessels, that the risks involved of dealing with sanctioned or criminal parties exceed the risk appetite of any legitimate enterprise. In short, if you don't redline the use of SKN companies for any and all purposes, you are probably guilty of compliance malpractice, if not Willful Blindness. Do not accept Saint Kitts entities under any circumstances, if you want to protect your employer, and yourself.

HOW SPONSOR BANKS CAN REDUCE THEIR LIABILITY FOR MONEY LAUNDERING AT THEIR FINTECH PARTNERS

When a friend sought to retain the services of an effective divorce lawyer, whilst contemplating the filing of a petition for dissolution of marriage here in Florida, I directed her to one of Miami's premier attorneys who specialize in that type of litigation, because that lawyer's initial consultation with clients always included the client taking away form that meeting a summary of both rights and responsibilities in contested divorce cases. The object of that briefing package, which the client was required to sign at the subsequent consultation, was to insure that he or she fully understood what was expected of them.

As regulators regularly assign liability for fintech deficiencies in anti-money laundering compliance to the sponsor bank partner, It is humbly suggested that this technique be applied for AML/CFT risk reduction in this manner: that newly onboarded fintechs must execute an extensive briefing package, which includes the minimum compliance requirements for operating with the sponsor bank partner. Furthermore, not only is the fintech required to employ banking best practices in its compliance program, but that the typical methods and
techniques that money launderers employ at fintechs be specifically listed, and that fintech management, as well as compliance, agrees that it understands them and will make a major effort to find and interdict them. If Sponsor banks are unaware of what methods should be included in the briefing, this old reformed money launderer will be happy to assist them.

Since regulators love to point the finger at sponsor banks, for the compliance mistakes of their fintechs, look that the signed briefing book as an appropriate response to them, demonstrating that the sponsor bank has defined that obligations of fintech compliance, and that this responsibility has been acknowledged and assumed.

DOES MALTA'S CURRENT PRIME MINISTER HAVE TOO MANY SKELETONS IN HIS OWN CLOSET TO SEIZE HIS CORRUPT PREDECESSOR'S MILLIONS, SITTING IN FOREIGN BANK ACCOUNTS

                                

Robert Abela, by COSIMO

Our recent article, WILL MALTA'S MOST CORRUPT PRIME MINISTER NOW BE UNABLE TO GET HIS MILLIONS IN BRIBES & KICKBACKS OUT OF DUBAI? https://lnkd.in/d-QJRY4 exposed allegations that JOSEPH MUSCAT, the former Prime Minister of the Republic of Malta (2013-2020), has reportedly cached many millions of Euros and Dollars in a prominent UAE financial institution. These funds, alleged to be bribes and kickbacks paid to Muscat, by American businessmen and others, should be properly seized and forfeited to the people of Malta.

Joseph Muscat and Robert Abela

Unfortunately, Joseph Muscat's successor, ROBERT ABELA (2020-present), has refrained from seeking justice for his constituents. In truth and in fact, before replacing the disgraced Muscat, Abela was his most trusted advisor when in private legal practice. In addition, although he presented himself as an employment attorney, he represented a number of Maltese allegedly known to be connected to organized crime, individuals who appear to have repeatedly evaded accountability in the country's arcane criminal justice system, which allows cases to be delayed indefinitely, where prominent lawyers are involved.

In truth and in fact, PM Abela appears to have a Conflict of Interest in taking Muscat's alleged criminal profits away from him, as well as sufficient skeletons in his own closet that to preclude any move against Muscat, who could expose his successor's dark background if charged with corruption. Will Muscat escape justice due to Abela's sins?

ARGENTINA ATTRACTS CBI GIANTS, AS CARIBBEAN PROGRAMS FACE INTERNATIONAL PRESSURE

The global citizenship-by-investment (CBI) industry appears to be entering a period of profound transformation. For decades, the Caribbean dominated this lucrative market, But mounting scrutiny from the United States, the United Kingdom, and the European Union—combined with tightening visa policies—may now be accelerating a strategic shift away from the region.The latest signal came from London; The United Kingdom recently cancelled visa-free access for Saint Lucia, citing concerns about the integrity and oversight of Caribbean citizenship-by-investment programs. The decision sent shockwaves through the investment migration industry and reinforced warnings already issued by both Washington and Brussels regarding security risks associated with poorly vetted economic citizenship schemes. At the same time, a significant development is unfolding thousands of miles away in South America. Argentina is positioning itself as a new frontier for the global investment migration market.

Argentina’s Strategic Move; According to a recent report published by IMI Daily, the Argentine government has recommended awarding the master agent contract for its new citizenship-by-investment program to a consortium composed of Apex Capital Partners, AIM Global, Passport Legacy, and Arton Capital—four firms with deep experience in the global investment migration industry. These companies are not minor players. They have been central pillars of the Caribbean CBI ecosystem for years, marketing and distributing citizenship programs from jurisdictions such as Saint Kitts and Nevis, Dominica, Antigua and Barbuda, Grenada, and Saint Lucia.

Argentina’s evaluation process placed this consortium ahead of other bidders, including the well-known migration advisory firm Henley & Partners. The selected consortium will now help design, launch, promote, and operate Argentina’s new citizenship-by-investment framework, potentially processing up to 5,000 citizenship approvals under a multi-year contract. In essence, Argentina is preparing to enter a market long dominated by small Caribbean island states.

There has been a Shift in the Investment Migration Industry; The timing of this move is particularly striking. Caribbean CBI programs—once marketed as the gold standard of economic citizenship—have come under increasing pressure in recent years. The industry is seeking new jurisdictions, and with good reason, for the Eastern Caribbean programs have become infected with money laundering, fraud and corruption. Look for this focus away from the Caribbean, replacing it as the region of choice for economic passports, with clean programs, free of crime and corruption. 

WILL MALTA'S MOST CORRUPT PRIME MINISTER NOW BE UNABLE TO GET HIS MILLIONS IN BRIBES & KICKBACKS OUT OF DUBAI?

Mugshot by COSIMO

If you are following the fast-moving developments in wartime UAE, you know that the government, shocked at being on the receiving end of Iranian missiles, is in the process of considering how to block the expected massive capital flight out of Dubai, as high net worth individuals take assets from what they thought was a safe haven elsewhere. It will not just be Iranian capital that is blocked from exiting Dubai financial institutions, according to our sources in the Emirates.

Enter the former Prime Minister of the Republic of Malta , JOSEPH MUSCAT, once named as the European Union's most corrupt leader. Muscat alegedly has many millions of US Dollars and Euros, all received in bribes & kickbacks as well as stolen public funds , from his tenure as Maltese PM, in a major UAE bank, with Emirati royal connections. He is now said to be unable to withdraw any of them at this time.

As we understand that he only has a very small portion of his alleged criminal proceeds in Swiss bank accounts, he now has a major problem; will the UAE notify the government of Malta about his frozen illicit assets, and facilitate their seizure and forfeiture to the Maltese Treasury? We cannot say, but we will be watching.

WHAT IS IT ABOUT CBI AS "INHERENTLY HIGH RISK" THAT NOBODY WANTS TO ADMIT IN SAINT LUCIA?

After the United Kingdom changed its Immigration Rules this year (HC 1691, 5 March, 2026) to require Saint Lucia passport holders to obtain a visa to enter the UK, terminating the existing visa-free entry policy, it squarely placed the blame for this action upon the country's Citizenship by Investment (CIP) economic passport program, identifying it as "INHERENTLY HIGH RISK." That term is an existential threat to CBI all over the Eastern Caribbean.

As the plain meaning of that term is not open to honest debate, the Labour government of Saint Lucia is desperately attempting to spin the news into some sort of ficticious new cooperation, between it and the UK, hinting that its amazing diplomatic skills will, sooner or later, result in a reversal. If one looks at the two years since the UK slammed the visa-free door on the Commonwealth of Dominica, you know that, due to the corrupt CBI program, Saint Lucia will not see relief on visas so long as ERNEST HILAIRE, the most corrupt minister in PHILIP J PEIRRE's Cabinet, and in bed with China's CARIBBEAN GALAXY, remains in command of the CIU.

Minister for Investment Ernest Hilaire

Therefore, Saint Lucians, who gleefully reelected Labour recently, have made their bed, and now they must reap the consequences; no entry into the USA, *(a $15,000 bond if you can even get a visa),tight controls on entry into the UK, and the visa-free roof is about to fall in over in the staunchly anti-CBI European Union.

Add this to the Saint Lucia government's political alignment with the Peoples' Republic of China, autocratic Cuba, and what's left of Venezuela, all of which is strongly disapproved by the present United States administration, and Saint Lucians are facing a dark future, where their Citizenship by Investment piggy bank could be forced to close shop.

I understand that the presence of American warships off Saint Lucia's beaches, as well as a US attack on some of its "fishermen" allegedly smuggling cocaine, is making Saint Lucians nervous, as they should be, as storm clouds look to be on the horizon, and the US still has a number of nasty cards to play in its deck of surprises. Philip J Pierre has chosen Ernest Hilaire and Caribbean Galaxy over Saint Lucia.