Kenneth Rijock

Kenneth Rijock

Saturday, August 24, 2013


Some of your bank clients are deemed national security risks, but the US Government agency USCIS does not feel that it has to share that information with you. Information about citizenship applicants whose cases are placed into a little-known American immigration track, designed to identify possible terrorists, and to deny them US citizenship, through indefinite delays, is not available to the public, with the result that bankers do not know which of their clients are considered "National Security Concerns," and are thus unable to adjust their own internal customer risk levels accordingly.

The disturbing aspect to this program, known as the Controlled Application Review and Resolution Program, is that individuals denied US Citizenship are still allowed to reside in America, as lawful permanent residents. This onerous label, National Security Concern, is not disclosed outside the US law enforcement community, meaning that private companies, who have no access to confidential, or law enforcement sensitive, information, never can learn from USCIS that a bank client:

(1) Has a record of residing in, or traveling through, jurisdictions of known terrorist activity, or usual travel patterns; or large-scale transfers or receipt of funds.
(2) Is a close associate of another subject or National Security Concern.
(3)  Is a member, or participant, in any organization that engages in suspected terrorist activities.

The fact that a potential bank client is linked, even indirectly, to groups or individuals who are suspected of planning terrorism, should be available to compliance officers conducting due diligence. Unfortunately, the United States will not disclose this information to its own citizens. Let me share with you a possible way to rule out a new client as an individual whose citizenship application may be facing an indefinite delay, due to his or her diversion into the Controlled Application Review Program:

(A) Does the client have legal permanent residency (green-card holder) ?
(B) has he applied for US citizenship ?
(C) has his application been in process for several years, with no end in sight ?

If so, his application may have been sidelined, indefinitely, as a person of concern. This method is not always foolproof, but is just one of many practical suggestions put forth here to aid compliance officers. Always look at where the client is from; both the Middle East and Latin America qualify under (1) above, and examine all other factors, before making an informed decision.

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