MONEY LAUNDERING THROUGH CITIZENSHIP BY INVESTMENT (CBI) PROGRAMMES

 

If you are a transnational money launderer, especially if you are from Iran, Russia, Syria and North Korea,  you probably own one or more passports proving that you are a national of those offshore jurisdictions that sell Citizenship by Investment, or CBI, schemes. Known by a wide variety of terms, such as CIB or IIM, these programmes represent a quick and easy method of disguising your nationality abroad, having at the same time accepted your criminal proceeds to pay, not only for the passport itself, but for the real estate that you were required to purchase as part of the arrangement. You can then use your new passport to move dirty money, under a new, low-risk, bogus identity.

Contrary to popular belief, I am not opposed to CBI schemes themselves, but to the universally defective due diligence programmes that the CBI republics intentionally employ, which result in unacceptable applicants, meaning financial criminals and corrupt Politically Exposed Persons (PEPs), being awarded passports  and citizenships. Time and time again, we see career criminals, especially money launderers and fraudsters, in possession of such identity documents, having been cleared and accepted, notwithstanding their "colorful" criminal histories, which often include fugitive status, or pending civil suits alleging the loss of millions of dollars, or evidence of the evasion of international sanctions on a grand scale. 

Disregard the official statements issued by the CBI jurisdictions, about how effective their enhanced due diligence investigations of applicants are, or their promises to improve those that are obviously deficient, for bribes and kickbacks, often paid in cash in US dollars, often persuade corrupt government officials, as well as senior leaders in local government, to issue passport to individuals who deserve to be arrested, and not rewarded with a new national identity, often with altered information that makes identification through traditional databases impossible, even facial recognition software.

I could list all the successful money laundering operations, later exposed by law enforcement agencies, after the fact, but most compliance officers are well aware of the most notorious examples, from Malta, St Kitts & Nevis, Antigua & Barbuda, the Commonwealth of Dominica, St. Lucia and Grenada. Many of those stories have appeared on this blog. If you want specific details, feel free to ask me those questions at  miamicompliance@gmail.com .

Given that the CBI republics are not inclined to give up the lucrative passport trade by refusing to sell, at a premium, to money launderers and financial criminals, and national sovereignty issues preclude external remediation, it is humbly suggested that compliance officers at international banks redline ALL passports from there jurisdictions listed above, and institute enhanced due diligence to rule out CBI passports, which you should decline, as gatekeeper, lest those passports deceive you into allowing further money laundering where you work.

 

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