Tuesday, June 8, 2021



We have  recently learned that over one-half of the approved applications for a Citizenship by Investment (CBI) passport in Cyprus were illegal and improper. Specifically, they were conducted "in a Due Diligence Vacuum," and with insufficient background checks. Given that many white-collar criminals use bogus identification to make applications under aliases, the use of a facial recognition platform, paired with an adequate image database has become mandatory for compliance officers conducting due diligence for CBI programmes. It has become a requirement for Banking Best Practises, the industry norm, which CBI units must adhere to.

In plain English, so there is no question about it, the failure of a compliance officer, to check an applicant for a CBI passport, using an effective facial recognition platform, constitutes malpractice. There is no substitute, to put it bluntly. Using commercial-off-the-shelf databases of high-risk individuals is not longer an acceptable technique. Compliance officers stick in the past, who still use the old check-the-box name search method, are just fooling themselves and their clients.

One final note; the use of facial recognition software MUST include access to an adequate image database, through which the software searches for your target. Do not use any programme that simply access Google Images, or the Internet, as that is clearly a waste of time. A good image database, which has been collected by the facial recognition platform developers, or which they have access to,  contains passport and visa images, official and unofficial database images, and other non-public resources. Do not accept anything less.

Unfortunately, most CBI programmes deliberately omit the use of facial recognition, as a component of their due diligence  investigation, for they do not want to know the hard truth; they only want to collect the high fees. No wonder we keep reading about white-collar criminals arrested with CBI passports. Until these countries bulletproof their due diligence with facial recognition, they will fail every time.

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