Tuesday, May 15, 2018


The five East Caribbean States, St Kitts. Antigua, Dominica, St Lucia & Grenada, are all suspect in the eyes of the global compliance community, due to the uneven, and sometimes even absent, amount of due diligence that they performed in the past, upon their CBI applicants. The result was a nightmare, when the programs readily accepted Russian organized crime members, international fraudsters, corrupt Politically Exposed Persons (PEPs), global sanctions evaders, terrorist financiers, and various and sundry other dangerous individuals who should never have been awarded CBI passports.

To restore confidence, the CBI states must now conduct historic lookbacks, which are reexaminations of all individuals who hold, or were issued, CBI passports, this time applying Enhanced Due Diligence measures during the new investigations, as all must be considered high risk, and treated accordingly. Those individuals who fail must have not only their passports cancelled, but their names and original nationalities published, so that banks, as well as the legitimate business community, are not exploited, or become victims, by the continued illegal use of revoked passports by bad actors.

This may sound like a difficult task, but modern Second Generation AML/CFT resources, which employ facial recognition software, social media resoures, and global inquiry capability, will quickly and efficiently separate the legitimate individuals from the criminals and corrupt PEPs. Unless the CBI states proceed, now, to clean up their past mistakes, the global banking community will continue to look upon their CBI programs as suspect and high risk, and may eventually target all of their native-born nationals who seek to open acounts as presenting unacceptable threats, as potential CBI passport holders, or their criminal associates, and treat them accordingly.

Also, customs and immigration officers at international airports, who have already be subjecting some Caribbean arrivals to further search and inquiry, could further extend this secondary processing to all individuals from CBI states. Unless credibility is restored m through lookbacks, you can expect these difficulties to increase, to the damage and detriment of all Caribbean nationals from the five CBI states.  

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