Tuesday, May 29, 2018


It appears that the Commonwealth of Dominica has recently sold far more Citizenship by Investment (CBI) passports than any of the other four East Caribbean States; some insiders are saying that it may be as much as several hundred during the last few months. Here's why this is extremely disturbing, not only to bank compliance officers, who fear money launderers and terrorists with CBI passports, but to law enforcement agencies, who are tasked with crime suppression and counter-terrorist financing inside North America, the European Union, and the countries of the Commonwealth of Nations.

If you take a close look at the names of the companies that are CBI consultancies approved by the Government of Dominica, you find that there are firms targeting only Chinese nationals, and who also have offices inside China, or inside offshore tax havens frequented by Chinese. Other firms are specifically marketing to Russians, and/or are located in Russia.

Both countries use non-Latin alphabets, in their official languages; making accurate transliteration into English problematic, and making the intentional disguise of true identities, by unregulated CBI consultants intent upon earning those sky-high commissions, by seeing that all their applicants pass due diligence, the rule, rather than the exception.

Add to this the abysmal (some experts say dysfunctional) level of due diligence performed on applicants for Dominica CBI passports, and you have a perfect storm, whereby career criminals, terrorist financiers, sanctions evaders, and other dodgy types claim that valuable passport, only to use them for the purposes the drafters of Dominica's CBI laws never intended.

Inasmuch as Dominica will not elevate its vetting process to true Enhanced Due Diligence, it has become time to treat ALL Dominica passports, where the holder was not born in the country, as suspect, high-risk, and a potential danger, wherever they are produced abroad, for any purpose.

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