Monday, November 20, 2023



Buried in the extensive recent coverage (by the OCCRP) of the fact that the five East Caribbean states have issued over 88,000 Citizenship by Investment (CBI/CIP) passports to applicants over the past several years, many of whom have not been publicly disclosed, is one extremely important detail: according to the EU Home Affairs Commissioner, Ylva Johansson, the holders of these valuable identity documents, which afford visa-free entry into the EU and UK, are allowed by the EC states to change their names and identities multiple times, at will.

Compliance officers, who rely upon their ability to identify prospective bank clients at account opening by checking their names against sanctions lists, and lists of high-risk individuals, are unable to properly identify transnational financial criminals, terrorist financiers, known sanctions evaders, and convicted felons if their names and biographical information have been altered, or otherwise changed into completely new identities, complete with bogus (but carefully constructed) social media postings that will fool even the most diligent inquiry.

 Even facial recognition methods, which often serve as an alternative methods of identification of clients at onboarding, can be defeated through techniques which we deem too sensitive to discuss openly, but which we have seen examples of, in certain CBI passports issued by the five CBI East Caribbean states and by the Republic of Malta, the sole remaining EU jurisdiction that sells passports to whomever has the cash to pay for them. 

It is impossible to overstate the probable impact that government-sanctioned alteration of identities has upon the ability of not only compliance officers at banks in EU Member states, but also customs and immigration agencies that screen arriving passengers for individuals from jurisdictions that are State Sponsors of Terrorism, sanctioned for violations of WMD and ballistic missile technology, human trafficking, and other crimes. We also must remember that members of hostile foreign intelligence agencies are also clients of such programs, and their ability to commit espionage is made infinitely easier by their ability to pose as low-risk nationals from visa-free jurisdictions.

 As a practical matter, individuals with "clean" aliases and identities, artfully facilitated by the CBI jurisdictions, have been successfully penetrating EU and UK financial institutions with impunity for some time, which may have been partially responsible for the recent action by the United Kingdom to remove the Commonwealth of Dominica from its list of former possessions (and Commonwealth of Nations Members) with visa-free privileges. Compliance officers must now decide whether to impose Enhanced Due Diligence procedures on the holders of all countries known to issued CIB passports, as a matter of course, irrespective of the delays such a policy will cause at client onboarding. Frankly, we trust that they make this decision, as otherwise, holders of these passports, who cannot be properly identified, will continue to abuse the financial institutions of the European Union and the United Kingdom.  


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