THE PROBLEMS OF IDENTIFYING A NEW BANK CLIENT WHO PRESENTS A CBI PASSPORT AS IDENTIFICATION

If you are a compliance officer at a bank with an international clientele, you will run into this conundrum regularly; you are presented by your New Accounts staff with an affluent new individual, who promises substantial new and lucrative business, but who is using a Citizenship by Investment (CBI) passport.

Most likely, it was issued by one of the five East Caribbean states, most of whom are present or former offshore financial centers (translation: tax havens that formerly accepted narcotics profits),or the last holdout in the EU, Malta, or a former CBI passport seller,such as Cyprus. Is he a friend or foe?

Irrespective of who the issuing country was, you have a problem: how to conclusively identify your target, who is obviously not from the nation that sold him that prized passport giving him visa-free entry into the UK & EU, at least for the present day. His accent, physical appearance, newness of passport, and even inability to speak the language of his adopted jurisdiction, with its local slang and patois, all belie that he is a local.

You must then rule him out as a possible transnational white-collar criminal, terrorist financier or even foreign intelligence agent, all of whom move dirty money. There are two operations that I suggest, because his true name is most likely not on that document:

(1) Run his passport photo through a good facial recognition software program that offers access it its own comprehensive image database. You must identify this person, and traditional ID methods will usually fail. Facial rec is your first move. There are a precious few programs out there that meet these requirements.

(2) Since the only thing real on that passport is most likely his place of birth (remember that St.Kitts was forced to be accurate with this item) use a platform that features Artificial Intelligence with machine learning abilities, to ferret out his real name and nationality. The reason I have not stopped at facial recognition is that some really sharp criminals already possess other identify documents under and aliases, and it is possible your photo identification will fail. Although this is rare, you need to be certain; also AI platforms will confirm your image search results.

You now know whether your new client is one of the 95% of affluent individual who bought a CBI passport to avoid visas, or one of the other 5%, who are dangerous criminals. Your risk-based compliance program thanks you.