THE IDENTITIES OF MANY CITIZENSHIP BY INVESTMENT PASSPORT HOLDERS WHO ARE HIGH-RISK INDIVIDUALS HAVE BEEN CHANGED, TO INTENTIONALLY DEFEAT COMPLIANCE EFFORTS

 The welcome news that the last of the five East Caribbean States* to allow its holders of Citizenship by Investment passports to change their names after their identity documents are issued focuses compliance attention upon the fact that many, indeed possibly thousands, of CBI/CIP passports previously issued, contain aliases of their holders, which were approved and implemented after the original passports were issued. Given that most compliance due diligence inquiries rely extensively upon name checks, and not facial recognition software platforms, to rule out prospective bank customers as potential high-risk or sanctioned individuals, the previous use of EC government-approved aliases on CBI passports was a standard practice, specifically designed to defeat compliance due diligence.**

Additionally, it is important to point out that the new prohibition on issuing a subsequent CBI passport with a name change is only for a period of five (5) years, meaning that the huge number of already-issued CBI passports from the East Caribbean region are exempt from this new regulation. Enterprising money launderers representing high-risk individuals can also obtain backdated passports in many EC jurisdictions, given the fact that details of new passports are generally concealed from the public for extended periods of time. This new rule is obviously not foolproof, and the widespread use of aliases on CBI passports will continue to be a major obstacle to the identification of holders of those documents by traditional, and banking best practices, compliance methods.  

______________________________________                                                                                           *St. Kitts & Nevis, Antigua and Barbuda, Commonwealth of Dominica, St. Lucia and Grenada.

** As an aside, if this isn't a reason to cause compliance officers to adopt facial recognition programs as an integral part of their due diligence, I don't know what else they need to do to move into the 21st century.