Wednesday, August 15, 2018


When looking for ways to achieve an effective Enhanced Due Diligence solution, regarding Ctizenship by Investment (CBI/CIP) programs, we must be mindful of the profiles of the applicants:

(1) If you are aware of the public statistics, released by the five East Caribbean CBI states, you know that one-half of the CBI passports issued by Antigua & Barbuda have been to applicants from China, and allmost one hundred per cent of the CBI passports issued by Grenada have gone to individuals from China.

(2) Many of the other successful applicants for CBI passports, whether they choose European or Caribbean jurisdictions, are from countries using non-Latin alphabets, such as the Middle East (Arabic and Farsi), and East Asia (Korean, Malaysian and Thai, to name a few).

(3) When transliterating applicant's names, from the non-Latin characters, into the English language equivalent, there are universally accepted translation norms to guide us. Therefore, any number of correct variations on an English language name are deemed acceptable, which is a recipe for disaster.

CBI applicants, most of whom come from countries of elevated risk, often include financial criminals, assorted other bad actors, fugitives from justice, and international  sanctions evaders. Others are PEPs, Politically Exposed Persons, who are artfully concealing their PEP status, whether because they are corrupt bribe or kickback recipients, or tax evaders at home, or are closely associated with one who is such. He may have even come to you with an alias, all properly documented by his government, but accomplished through corrupt payments for a bogus passport.

So, you end up with an individual being arbitrarily assigned what you hope and trust is the genuine English equivalnt to his original name, which may mean that his high-risk status is never discovered through normal data inquiries. How do we identify him ?

The answer is to employ a facial recognition software platform, which will cull through news photographs, passports, social media images, newspaper and magazine articles, CCTV footage and other sources, and extract from them your target's image, verifying his stated identity, or show him to be a completely different person altogether. Without facial recognition confirmation, the chances that the CBI jurisdiction has issued a passport, under a clean alias, to a career criminal, foreign intelligence agent, or other unsuitable party, is unfortunately good. Due to the elevated level of risk with CBI applications, it has become a necessary, and yes, even mandatory, element of their Enhanced Due Diligence efforts. Let us hope that the agencies operating these programs get the message, as facial recognition software is the only effective solution.

No comments:

Post a Comment

Note: Only a member of this blog may post a comment.