DE-RISKING MAY BE YOUR ONLY RELIABLE CHOICE IN A RISK-BASED COMPLIANCE PROGRAM

While government agencies in the United States, as well as American foreign policy in general, advocate American banks keeping their correspondent accounts of Caribbean banks, the lack of reform among those financial institutions has forced widespread de-risking, as a matter of sound risk management. In a perfect world, Caribbean businesses and individuals that must have direct access to the American financial structure, to buy goods and services, to invest here, and to conduct necessary transactions, should have access, but it is not well advised, given the many issues with banks abroad, especially those in the Caribbean, due to the high-risk reality that exists today.

Caribbean banks, focusing upon those that (1) have a long history of facilitating money laundering, (2) Sell Citizenship by Investment (CBI) passports to buyers from high-risk, sanctioned, and even jurisdictions designated as State supporters of Terrorism, and (3) centers of rampant, systemic official corruption, are simply far too high-risk to be business partners through correspondent banking.

To add to the problem, these five East Caribbean states selling CBI passports, all of whom are former British territories, and members of the Commonwealth, insist upon selling passports for US Dollars, rather than Sterling. This wrinkle not only gives the United States potential jurisdiction over any financial crime, as US courts have given extraterritorial territorial jurisdiction to money laundering crimes involving USD, but those funds will end up clearing through the American financial structure, exposing US banks and bankers.

Given the flat out refusal of Caribbean banks to clean up their anti-money laundering compliance, keep ut transnational financial criminals, accept the proceeds of corruption, and fail to reform their CBI programs, American financial institutions, acting within a risk-based environment that is becoming stricter each year, have no choice but to eliminate the threat; the correspondent accounts. While the United States Government asks the banks to keep those dangerous Caribbean banks, it will not force sufficient reforms there, due to national sovereignty concerns. Close those accounts, or suffer the consequences, ladies & gentlemen.