AFTER THE EU SLAMS CBI PASSPORTS, CONSULTANCIES FLOOD THE INTERNET WITH PROPAGANDA

If you go on the Internet and search under "CBI" or "Citizenship by Investment," you will see dozens of new entries, what are what we call infomercials, pro-CBI propaganda masquerading as news articles. They all extol the virtues of Citizenship by Investment programs that exist in the five East Caribbean States, as well as Malta and Cyprus. This has occurred after the European Union, in a sharply critical analysis, recommended that any EU Member operating CBI programs terminate them, due to the dangers involved.

The new articles appear to focus upon making it look like compliance systems have all been upgraded, that applications are on the rise, and that the government agencies that run the programs have greatly improved their policies and procedures.

Don't you believe it; dodgy applicants, many with dark white-collar crime backgrounds, are drawn to CBI passports like flies to honey, and there is no evidence that they are now, finally, being barred from completing their applications. Additionally, many applicants from authoritarian dictatorships, where true compliance investigations are impossible to conduct, are also being approved. These articles are simply well-written propaganda tools, written by international CBI consultancies anxious to insure that the "Golden Goose." clearly excessive commission paid to them, remains intact.

Compliance officers, continue to regard CBI passports, and their holders, as high-risk, and subject to Enhanced Due Diligence at account opening, and that's if your risk-based compliance program doesn't bar them altogether.