ARE YOU BANKING ANY WEALTHY WEST INDIANS WHO WERE BORN IN TEHRAN ?

A reminder: the United States found that Iranian nationals evading global sanctions, through transactions conducted in the countries of Central Asia, found that these sanctions busters employed their St. Kitts & Nevis economic passports, when asked for identification, thus evading any questions about possible sanctions issues.

It is important to remember that these Caribbean nations offer  citizenship-for-cash programs:

(1) The Federation of St. Christopher & Nevis, more commonly known as St. Kitts.
(2) Antigua & Barbuda.
(3) Dominica.
(4) Grenada.

Compliance officers must ascertain, and verify, the place of birth of any potential client from these countries, to rule out economic passport holders. (Is the client not of African descent, and does he not have a Caribbean lilt to his English ? if so, you may have a problem.)  If the passport does not contain birthplace information, as do many from St. Kitts, require that data be shown by an official government document. Otherwise, you may later find yourself having approved an Iranian or Afghan national, who is a PEP, and is a person of interest in a financial crime investigation.