Saturday, March 14, 2020


Individuals attending a CBI seminar in the UAE.

Recent diplomatic moves in the Middle East by the Commonwealth of Dominica have greatly increased the chances that the holders of future Dominica Citizenship by Investment (CBI/CIP) passports acquired there are while collar criminals whose aliases were accepted by CBI unit due diligence. Dominica just opened an embassy in Abu Dhabi, and is scheduled to open a consulate in Dubai later in 2020.

Briefly, here's why these developments are troubling:

(1)  Dominica's CBI program does not require that the applicant be physically present, either during the application process, or when receiving the coveted CBI passport and citizenship documents. There is no face-to-face in Roseau; its all done from afar.

(2) There is no requirement that the applicant reside in Dominica, nor that he or she speaks English, has a certain level of education, or is familiar with the culture, history, or system of government there. This makes the preparation of a completely bogus identity feasible; it could be easily accomplished by a compliance consultant with access to corrupt government officials.

(3) The United Arab Emirates have a large population of expats, any of whom could present authentic, official identity documents that indicate they have names other than their true, legal identities. Given the state of official corruption in may countries, the lack of true due diligence inquiries in Dominica (look at who they have approved in the past) , the money talks, the identity presented is not questioned, and the next result is a genuine Dominica passport under an alias.

(4) Dominica does NOT yet employ facial recognition technology to verify identity. An artful white-collar criminal working out of the UAE will have no trouble pushing his bogus personal identity credentials through processing.

Whether compliance officers should raise Country Risk on Dominica, based upon this new information, is up to each individual's discretion, but these new developments should be taken into consideration, when calculating Country Risk.

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