Saturday, April 18, 2015


If you read my recent article, Are you employing Enhanced Due Diligence on Special Interest Aliens from Latin America ? and you wanted to know from which Latin American countries do Special Purpose Aliens hold passports, here is what I know. The ones that my sources are aware of  possess valid passports from Panama, Argentina and Venezuela. Corrupt officials in those countries, for the right sum, in cash of course, are happy to document newly-arriving "applicants," from the Middle East, as local nationals.

Panama is by far the most popular jurisdiction for one reason: it is far easier to obtain a US visa in Panama than the other two choices. American Embassy services in Panama City are quite efficient, and one can expect a successful outcome in a far shorter time than in most other Latin American countries. This is one instance where American effectiveness results in increased potential danger to the US homeland.

Thus, does one now raise risk levels on individuals arriving from the above countries, ensuring that any such new clients are subject to a sufficient amount of enhanced due diligence that will serve to rule them out as Special Purpose Aliens ? I believe, in my humble opinion, that such action must be considered mandatory*. Otherwise, you may end up banking a member of a SDGT.

* This caution is specifically directed to compliance officers at US banks who typically serve affluent clients from Latin America, as the prospect of a new and potentially lucrative client can blind a banker to the need for additional Customer Identification Procedures.


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