CBI INDUSTRY COMMENTARY ON PURPORTED REFORMS FAILS TO DISCLOSE THE MONEY LAUNDERING DANGERS THESE PASSPORTS PRESENT

                    

We note the barrage of so-called "news articles" appearing of late, mainly appearing on the websites of the Citizenship by Investment (CBI/CIP) passport sales industry, extolling purported reforms now being implemented by the five East Caribbean states that sell economic citizenship. Claiming to be a response to UK and EU demands for meaningful reform of an industry that has a long and sordid history of selling its passports to career financial criminals, international sanctions evaders, and corrupt Politically Exposed Persons (PEPs), these jurisdictions have yet to show that they have enacted any significant changes, as news reports continue to note the global arrests of individuals literally caught in the act of criminality, holding these identity documents when captured by law enforcement. Their claims that the industry has cleaned up its act are not only untrue, but amount to little more than propaganda. Compliance officers should not be taken in by a clever PR campaign.

CBI passports continue to pose a clear and present danger to international banks, as they allow criminals, and others with dark intent, to conceal not only their true nationality, but their actual identity as well. They serve as a a visa-free tool to enter the UK and EU at will, to commit whatsoever criminal acts they wish, especially money laundering, with impunity. There;s good reason that the UK recently yanked Dominica's visa exemption for its passport holders. Compliance officers must ignore what is essentially industry propaganda, and to continue to regard the individuals who present with "economic passports" as potential criminals that are high risk, as many have proven to be since the early 1980s, when St. Kitts became the first Caribbean jurisdiction to sell passports to all who apply, no questions asked, so long as they had cash in US Dollars.

Furthermore, legitimate investors, who come from jurisdictions where their nationality forces them to apply for visas through lengthy application policies, and who simply want to enter Europe through a seamless process, are not being properly advised by an industry that neglects to inform them that the mere possession of CBI passports can increase their risk of being lumped in with the criminals who abuse those identity documents. Such dangers, including the risk of law enforcement targeting, is not communicated to those affluent individuals who que up to purchase them. Again, an industry that overcharges its clients, often concealing obscenely high commissions, fail to make them educated consumers of these documents.

Compliance officers, kindly note: the game remains the same in the East Caribbean. Sell as many of these CBI passports, to whomever applies, so you can fund your dysfunctional failed local economies, all swollen with a surplus of government positions that serve to employ your people, as there is little in the private sector to provide all of them with income. There is no meaningful reform, and a large percentage of these passports are in the hands of individuals that you do not ever want as bank clients. Govern yourself accordingly.