CBI PASSPORTS DECEIVE COMPLIANCE OFFICERS WHO WOULD OTHERWISE INSTITUTE ENHANCED DUE DILIGENCE IN A HEARTBEAT

 

If you closely read today's news about the Titanic submersible that is missing, and possibly stranded on the floor of the North Atlantic, in a potential personal tragedy that reminds us about the dangers of experience tourism, you know that there is a Pakistani billionaire on that craft. What is being cleverly kept out of the stories is the fact that Shahzada Dawood, alive or dead, holds a Citizenship by Investment (CBI) passport issued by the dodgy Republic of Malta. Not one of the world's mainstream media has disclosed that interesting fact.in what sounds suspiciously like new management.

 In truth and in fact, his entire extended family have purchased those passports. Who cares about such details you say? Well, Dawood is actually listed, on the Companies House website as a Maltese, therefore an EU national Such a listing means that any compliance officer performing a due diligence check on this individual would then typically assign low risk to his profile, and decline to ramp up to enhanced due diligence, where Source of Funds and Source of Wealth become facts of interest in assigning a level of risk, when operating a risk-based compliance program.

While I have no reason to be concerned about Mr. Dawood's background, as he is indeed a legitimate businessman, with a long and admirable history of charitable work, the fact that he is listed on a UK Government website under his low-risk Maltese nationality, which was reportedly purchased at great expense, shows that CBI passports favorably skew risk, and do deceive compliance officers responsible for assessing whether EDD is necessary to be applied. 

Readers following the PILATUS BANK scandal in Malta know that ALI SADR HASHEMI NEJAD, the Iranian owner of the money laundering bank shut down by EU regulators, reportedly used his St. Kitts & Nevis passport in Switzerland, when moving illicit capital diverted from Venezuela, as personal identification, to reduce his level of risk, and I have lost count of number of transnational criminals who proffered their East Caribbean CBI passports from Antigua, Dominica, St. Lucia and Grenada to bankers, immigration officers, customs agents and law enforcement officials, when seeking an advantage that low-risk nationality confers.

If this isn't a reason to call for the abolition of CBI passport programs worldwide, I don't know what is, and you are reminded that the the European Union wants all such programs terminated among its Members, especially the last surviving offender, Malta. Wake up, compliance officers; you are being hustled.