The Government of Spain is close to enacting legislation that will grant Spanish citizenship to individuals whose Jewish ancestors were expelled by the country's rulers in 1492. The program, which appears to be a modern, good faith effort to right a wrong that occurred in Spain's dark past, unfortunately will also be a target of opportunity for the world's financial criminals, as an EU passport is regarded by them as a valuable tool, affording them visa-free travel to many international financial centers.
It does not seem that proving one's Spanish Sephardic roots, to the satisfaction of the Spanish Government, will be difficult, meaning that bogus applicants should not find approval difficult:
(1) The flexible methods of proving that one's Hebrew forebears were forced to emigrate from Spain, rather than convert to the Catholic faith, due to the extreme length of time since the event occurred, add to the problem. Written accounts from foreign religious figures, to confirm family histories, can unfortunately be bought, and counterfeit confirmation can also be obtained.
(2) A Sephardic family name, or proof that one engages in Sephardic customs at home, are the alternative methods of proof. Again, this can be constructed.
(3) A working knowledge of Ladino, the unique language spoken by Sephardic Jews, which is an amalgam of traditional Spanish, and Hebrew, is another listed qualifier. This skill can be acquired by anyone with sufficient drive and patience, irrespective of their actual religious background.
Please note that applicants themselves do not now have to be practicing the Jewish religion, only that their ancestors were Sephardic, and were expelled by King Ferdinand and Queen Isabella at the end of the fifteen century. They need a basic knowledge of the Spanish language, and of Spain itself. All this can be easily learned, if they do not already have it in hand, from work experience.
Just as they did when taking advantage of Israel's Law of Return, organized crime figures will most certainly construct Jewish backgrounds, to make themselves eligible for these EU passports. Their places of birth, however, may give them away, when using these Spanish travel documents. That may be your only means to identifying individuals who hold these passports. Possession of a Spanish passport could vastly facilitate the global reach of any financial criminal.
These new passports will probably be issued late in 2015, so find a way to upgrade your compliance program to flag any incoming Spanish passport holder whose place of origin, or place of birth, is outside Latin America.