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| Chismosa by ALEX CEPPI |
The Nationality Law of the Peoples' Republic of China (https://lnkd.in/en7tr_MJ ) clearly states, at Article 3: The People's Republic of China does not recognize dual nationality for any Chinese national." Given that the Citizenship by Investment (CBI & CIP) programs of SAINT KITTS & NEVIS, SAINT LUCIA and GRENADA have issued tens of thousands of economic passports to Chinese nationals, the matter of the validity of those identity documents, for compliance purposes at account opening, or for any other transactional purpose, continues to be of concern. Is this a disqualifying factor?
We bring this up, because it is a known fact that the due diligence firm used by the firm CARIBBEAN GALAXY REAL ESTATE LIMITED to approve Chinese applicants for Caribbean CBI passports was owned by a senior officer employed by Galaxy, and is suspected for failing to conduct any effective inquiry whatsoever, in addition to being a clear conflict of interest. Does the fact that the Chinese holder of a CBI economic passport violated the laws of China, by using it as identification, and failing to properly renounce his Chinese nationality, make these individuals an unacceptable high risk, as part of a risk-based AML compliance program, when taking these two issues together?
Furthermore, what is the legal status of these CBI passports, held by Chinese nationals, for law enforcement purposes? Should they be declined when presented for visa applications, for visa-free use at international ports of entry, for work or study applications, or for any other purpose? They have been used to gain entry into the United States, and the holders then went on to commit financial crimes. Should they no longer be considered valid?
Until and unless these issue are resolved, compliance officers charged with administering their AML/CFT programs are well advised to consider rejecting, as identification, any and all CBI passports presented abroad by Chinese nationals, lest a court of competent jurisdiction subsequently decree that such passports are voidable, or invalid, as a prudent risk management decision.

























