Please take notice of persistent rumors, involving the actions, by both local and international banks located in the Commonwealth of Dominica, that are reportedly notifying customers, who have funds on deposit that were profits from the tainted Diplomatic passport program, that those funds will no longer be welcome, means that substantial amounts of dollars will probably soon be in transit, looking for a safe haven elsewhere. Your risk-based compliance program requires that you decline such deposits.
Should your bank, or non-bank financial institution, accept these funds, which may be later designated as the proceeds of crime, you run the risk of involvement in a money laundering prosecution, for willful blindness, given the recent disclosures about the likely criminal source of funds of a number of individuals who obtained diplomatic passports, outside the Citizenship by Investment (CBI) Program operated by Dominica, and who allegedly paid clearly excessive fees to obtain them.
This also goes for any large amount of US Dollars, in cash or cashier's check, drawn on a bank located in Dominica, presented for deposit, by any Dominican nationals, or their attorneys, at any financial institution located in the Western Hemisphere, or the United Kingdom. Be especially wary if their passport indicates their place of birth outside Dominica, which raises the presumption that they were participants in the CBI Program. They are also nationals of another country, which may be high risk.
The use of a diplomatic passport, to evade customs and immigration controls, could allow the holder to successfully smuggle greenbacks into your country, and then attempt to place them in a local bank or banks.
Considering that diplomatic passport sales, throughout the East Caribbean are under attack by opponents, Dominica's program may soon be terminated, creating fear among those who enjoyed lucrative profits from its operation, and stimulating them to move their funds out of the country forthwith. Be alert for any such large dollar transactions, even if they originate from a corporate client, so long as their journey started in Dominica, or are sent by a Dominican national.
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