THE USE OF SHELF COMPANIES IN TRADE-BASED MONEY LAUNDERING

Twenty years ago, I was a compliance officer in Fort Lauderdale, handling only enhanced due diligence inquiries for an investment company, and having the time of my life catching money launderers as their gatekeeper. I was also moonlighting for the British Compliance firm Complinet, writing financial crime articles; among the topics that I covered extensively was the exposure of the use of shelf companies. That's shelf, not shell.

I took particular pains to acquaint my readers on this important subject for a reason; during my misspent youth as a career money launderer, I artfully used shelf companies for my narcotics trafficking clients. I would quietly fly into the British Virgin Islands (BVI) in a private plane, in my preferred mode of operation, which was to conduct business in a tax haven that I was not comfortable in, as fast as humanly possible, and get the __ out before anyone, especially law enforcement, knew I was even there in person. Keeping the pilot in his seat, with instructions to be ready to depart as soon i returned, I zoomed into Road Town via taxi, and picked up a shelf company from my usual Irish accountant there, hurrying back to the airfield, to depart forthwith.

I used aged shelf companies, formed years earlier, because routine queries by unimaginative compliance officers, generally found a history that satisfied their due diligence queries. Today, laundrymen working TBML often are attracted to shelf companies, because cursory investigations rarely turn up any red flags. Compliance officers handling transaction monitoring should be especially sensitive to the possibility that your money launderers are employing them to deceive you. Don't let them; do a deeper dive into the suspected shelf company; read its annual corporate reports online, to determine whether the previous officers and directors were merely nominees, or frontmen. Look at the company's history with the client; is this the first time they have appeared in a payment? Is the name deceptively similar to that of a reputable company? And what is the jurisdiction where it was formed or incorporated or domiciled? Dig into that company to find out whether it is truly legitimate, and not a shelf company; good luck.

TODAY IS NATIONAL VIETNAM WAR VETERANS DAY 2024

REAL REASON FOR HOUTHI ATTACKS ON SHIPPING MEANS THEY ARE NOT STOPPING IF GAZA CEASEFIRE OCCURS

Experts examining the violent and fatal attacks that the Yemeni HOUTHI rebels are raining down on merchant shipping in the Red Sea/Gulf of Aden region have concluded that they are being conducted solely to distract attention from the failed economy in the Houthi-occupied area of Yemen, and definitely not to support the Hamas terrorists in their war with the State of Israel. The Houthi claim, that it is conducting attacks on shipping in solidarity with the Palestinians in the current Gaza war, is merely a pretext to divert the Yemeni people from the dire economic situation in the rebel-held portion of the country. The Houthis are levying extremely high taxes and fees on the civilian population, especially operating businesses, to finance their war on the legitimate government of Yemen, and these charges are seriously impacting the economy.

Given this fact-based conclusion, do not expect the missile and drone attacks to end if the Gaza war has a temporary, or even permanent, ceasefire. Therefore, compliance officers engaged in countering TBML should accept that they will continue to face uneven and uncertain aspects of trade payments, meaning that uncovering trade-based money laundering operations that take full advantage the chaotic situation will persist. They must adjust their investigative methods and ever-changing guidelines accordingly.

IMF STATS SHOW TRADE DISRUPTION MORE SERIOUS IN WESTERN HEMISPHERE THAN IN EUROPE

The International Monetary Fund (IMF), in a major study of global trade disruption, has found that it is the countries of the Western Hemisphere, not those in Europe, that have suffered the most from our issues with transportation problems at the world's chokepoints, Panama & Suez. We are publishing here its graphic representation of the amount of disruption, which is as high as fifty per cent in some nations, according to IMF statistics.

If you are a compliance officer handling transaction monitoring for trade based money laundering interdiction, take heed of this, because rest assured that TMBL laundrymen are fully exploiting the lack of uniform delivery costs, supply chain nightmares, and other dysfunctional aspects of international trade to Latin America, and to a lesser extent, even North America. read the graph carefully, and adjust your thinking about the possibility that you may be seeing TMBL disguised as outrageous and clearly excessive costs and fees.

ARTICLE ABOUT MY UPCOMING NEORAMA PRESENTATION ( IN GREEK)

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Μέσα στα πλαίσια των συνεχών επιμορφωτικών διαδικτιακών σεμιναρίων, το διακεκριμένο εκπαιδευτικό κέντρο, Neorama Education θα φιλοξενήσει τον Νομικό κ. Kenn Rijock από το Miami-Florida ο οποίος για 10 χρόνια την δεκαετία του 1980 ήταν πρώην διακινητής εκαταμμυρίων δολλαρίων προιόν των καρτέλ ναρκωτικών της Ν.Αμερικής, ενώ τώρα εργάζεται ως Νομικός Σύμβουλος Κινδύνων Ξεπλύματος Παράνομου Χρήματος και εκπαιδευτής των Αρχών Ασφαλείας των Ηνωμένων Πολιτειών. Το συγκεκριμένο σεμινάριο θα διεξαχθεί στις 2-10 Απριλίου διαδικτιακά με θέματα Παρακολούθησης Πληρωμών (Transaction Monitoring), συμπεριλαμβανομένων Ναυτιλιακών Κυρώσεων (Maritime Sanctions) και τεχνικών Ξεπλύματος Παράνομου Χρήματος (Money Laundering) μέσω του διεθνές εμπορίου.(TBML)

Παρουσιαστής του Προγράμματος θα είναι ο κ. Αβραάμ Δημητρίου, πρώην τραπεζικό στέλεχος σε θέματα παρακολούθησης πληρωμών και Κανονιστικής Συμμόρφωσης με έμφαση το Ξέπλυμα Παράνομου Χρήματος και Διεθνής κυρώσεις. Διακεκριμένος φιλοξενούμενος θα είναι ο κ. Kenn Rijock από το Miami Florida ο οποίος θα αναπτύξει και θα επεξηγήσει τεχνικές τις οποίες ακολουθούν παράνομες οργανώσεις και συνδικάτα με την επιστροφή χρημάτων από την πώληση ναρκωτικών στα καρτέλ ναρκωτικών στην Ν.Αμερική μέσω των νόμιμων οδών, εξαπατώντας τις νόμιμες Αρχές των κρατών μελών της Ευρωπαικής Ένωσης.

Το συγκεκριμένο σεμινάριο είναι μοναδικό στο είδος του και αναμένεται μεγάλο ενδιαφέρον από οικονομικούς κύκλους. Το Εκπαιδευτικό Κέντρο Neorama Education Ltd, το οποίο εδρεύει στην Λακατάμια- Λευκωσία, είναι εγκεκριμένο από την ΑνΑΔ και το Υπουργείο Παιδείας και Πολιτισμού. Παρέχει κατάρτιση και Επικαιροποίηση γνώσεων σε πολλούς τομείς (www.neorama.eu). Με το παρόν σεμινάριο αλλά και με άλλα παρόμοιας θεματολογίας προγράμματα, αναμένεται να προσδώσει μια υπεραξία στις προσπάθειες των Κυπριακών Αρχών σε θέματα ουσιαστικής ενημέρωσης και εκπαίδευσης στις τάξεις των λειτουργών συμμόρφωσης όλων των οργανισμών. Το πρόγραμμα προσφέρεται μέσω της Αρχής Ανάπτυξης Ανθρώπινου Προσωπικού (ΑνΑΔ) με ουσιαστικά πολύ χαμηλό κόστος για τις επιχειρήσεις. Επικοινωνία συμμετοχής στο 77778818.

THERE IS AN EFFECTIVE WAY TO PERMANENTLY SHUT DOWN THE EAST CARIBBEAN STATES THAT SELL CITIZENSHIP BY INVESTMENT PASSPORTS, AND IN DOING SO LAUNDER THE PROCEEDS OF CRIME THROUGH AMERICAN FINANCIAL INSTITUTIONS

The United States appears to be afraid to rein in the five East Caribbean states that sell Citizenship by Investment (CBI/CIP) passports to financial criminals, corrupt Politically Exposed Persons (PEPs), terrorist financiers, and nationals from countries under international sanctions. I assume it is the Department of State that, wanting to keep good relations with, and maintain upon, these mini-states, that keeps US law enforcement away from America's corrupt Caribbean English-speaking neighbors.

This political malfeasance allows career money launderers, fraudsters and sundry other financial criminals to clean their criminal profits through CBI passport programs, and most of them even end up with Caribbean real estate in the process. These countries, whose programs give their passport purchasers visa-free access to the UK and EU, need to be convinced to terminate their CBI schemes, as they facilitate international crime. besides, all these programs demand US Dollars from purchasers, which results in cleaned dirty money transiting the New York banking structure.

So, how can the United States artfully stop this transnational, organized criminal conduct? Simple, just have our banks employ Derisking, the termination of correspondent accounts in the US for all Caribbean banks that accept CBI agencies' payments. Those payments end up being laundered through American banks, and this has to stop; therefore, cut what are actually money laundering banks off from the US financial structure forthwith. That will force the CBI programs to switch to another currency to save their national economies, because a denial of access to American banks will be fatal to nations that depend upon major imports to survive, as well as to service their customers who are exporters, or need raw materials.

Shut down the bloody money laundering facilitating (through CBI schemes) Caribbean banks, and watch these programs die a quick death. If you consider this a radical step, consider the billions of dollars of dirty money laundered in the Caribbean through CBI passports, and what those purchasers do once they own a low-risk identity document in Europe. Kill the ECs golden goose, please.

THIRTY YEARS AFTER HIS DISAPPEARANCE, THIS CARIBBEAN MONEY LAUNDERER AND POWER BROKER IS STILL SPOKEN OF IN HUSHED TONES WHERE HE FORMERLY REIGNED SUPREME

This Summer, we are coming up on the thirtieth anniversary of the June 1994 disappearance of Saint Kitts Foreign Minister, attorney William (Billy) Herbert Jr., BUT his larger-than-life power and influence remains in effect. A recent call to a Kittitian professional, inquiring about whether media should return to covering the unsolved mystery was met with what can only be described as abject fear about any new publicity about the subject. I worked with Billy Herbert in the Caribbean Tax Havens for several years in the nineteen eighties; he coordinated and facilitated my money laundering activities for clients who were engaged in narcotics trafficking. I also knew him as one of the original founders of the Peoples' Action Movement, more commonly known as PAM.

Doctor Herbert, as he was known in the East Caribbean, was a potent political figure, both in his native St. Kitts, and in the nearby British Overseas Territory of Anguilla, where he was the Constitutional Adviser to the UK Government. His politics were judged by many to be radical; he was acquitted in an earlier era of Conspiring to Overthrow the SKN Government by Force, but he held several Ambassadorships, and I always regarded him as the heir apparent to a future premiership there, had he lived, but there are no happy endings for laundrymen in most cases.

The opaque circumstances of his death, where he is believed to be buried, the clients of his money laundering activities for over a decade, and his targeting by American and British law enforcement are all topics that St. Kitts' leaders do not want to see the light of day again. especially since Billy Herbert's involvement in creating the country's controversial Citizenship by Investment (CBI) passport sales program will only further draw attention to its flaws.

In short, the last thing that Saint Kitts politicians want or need is to revisit the sordid career of one of its past dominant leaders. Perhaps for this very reason, the truth should now come out, notwithstanding their sensitivities, especially when many observers have the island nation under close scrutiny, due to the CBI scandal, and the exposure of serious political influence by the Peoples Republic of China.

WILL AMERICA'S NEW OBSESSION WITH MIAMI'S 1980s COCAINE CRIME STORIES OPEN A PANDORA'S BOX FROM AN ERA OF UNCONTROLLED MONEY LAUNDERING?

Popular American interest, generated after a number of recent films on the subject have appeared, and been well received, has focused the attention of viewers on the dark, drug-infested "Miami Vice" era of the 1980s. Previous audiences have, in the past, been fixated on programs covering such prior lawless periods, such as the gangsters of Prohibition in the 1920s, and the American Mafia. After a sufficient amount of time elapses after such eras, interest about such stories when they appear as films, on the part of people who did not personally experience such tumultuous periods, tends to increase; Call it curiosity, albeit sometimes of a morbid nature.

Miami, during the period of the eighties, was a chaotic time punctuated by the Mariel Boatlift, rampant and systemic drug trafficking, corruption in local government, and a desperate effort by American law enforcement to rein in the flood of illicit drugs, especially cocaine. Traffickers depended upon a number of Miami professionals, including many lawyers, to launder their criminal proceeds, and protect them from the law. One only need look at the long list of lawyers whose criminal convictions resulted in the loss of their law licenses during that period to verify that; I was one of those individuals, which I have detailed in "The Laundry Man."

My point is that all this renewed interest in all things Miami 1980 may shed some sunlight upon Miami money laundering operations that were never exposed, and that certain people who have worked very hard to conceal their dodgy past, the significant wealth and assets they earned during those years, and the banks that facilitated such crimes, may now see the light of day. For any who believe that the Statute of Limitations bars their arrest, our conspiracy laws might just be able to reach out and touch them in the present. Retired drug traffickers, having served long sentences, and at the end of their lives, can be brutally honest about their experiences, as we have seen from some of the documentaries.

Whether Miami stories appearing in 2025 will see publicity, and perhaps even accountability, for misdeeds committed in 1985 remains to be seen, but be assured many who were there back in the day, and presently wish that their past remain buried, may experience otherwise.

ADAPTING TO THE NEW 2024 TBML REALITY MEANS DISCARDING YOUR LEGACY RED FLAGS AND GUIDELINES

Any compliance officer with Transaction Monitoring responsibilities at an international bank where customers and third parties send payments through have a difficult, but not impossible,mission: to cull out of rare trade-based money laundering transactions from a sea of normal, legitimate goods and services transfers in global trade. Difficult, yes, but not impossible if you adapt with these changing conditions.

Understand that your worthy opponents, the lawyers, accountants, bankers and career criminals who are taking full advantage of the chaos spawned by the Houthis, climate change, the laws of Supply and Demand, and other variables created by a number of factors, to build plausible scenarios, which mask dirty money hiding in plain sight. Don't let them succeed.

Adapt and innovate like the laundrymen do, to catch them. Throw out your legacy red flags and indivia of TMBL, and build new ones that change when conditions change, but return to them when conditions revert. For example, now that the Panama Canal is, thankfully, starting to return to normal capacity, don't let the laundrymen continue to fool you with excessive insurance and other costs in that area, such as surface transport across the US or the Isthmus of Panama.

On the other hand, when costs skyrocket, as they are doing in the Red Sea region, due to risk, don't let the laundrymen place clearly excessive amounts in payments. in other words, become as flexible as those who seek to move the Proceeds of Crime. Take each transaction on its own merits; throw out your preconceived rulebook; verify all the strange and nonconforming elements of payments, even though it may slow you down in completing tasks. Prove through investigation the falsity of costs and charges and catch them if you can; You can do this.

CARIBBEAN CITIZENSHIP PROGRAMS ARE A THREAT TO U.S. NATIONAL SECURITY

During the Cold War, The United States and Soviet Russia competed for the hearts and minds of the leaders of the Caribbean, each with mixed success. America's long-held foreign policy position, the Monroe Doctrine, held that European powers were to be discouraged from any efforts to impose their colonial influence on any nation south of the Rio Grande. Russia, having already gotten a foothold in the region after the Cuban Revolution, led by a committed Marxist, sought to expand it influence. America responded when it considered events to be a significant threat to its national security, such as the regime change in Grenada, and subsequent construction of an airfield suitable for Russian bombers.

Today the Soviet Union is no more, and Russian influence in the caribbean is limited, according to most observers, to Russian private investment in Grenada, through its Citizenship by Investment (CBI) program. The current threat to US National Security comes from the Peoples Republic of China, whose major economic and diplomatic efforts in the East Caribbean states includes a significant percentage of CBI passport purchases being made by Chinese nationals, in both Saint Kitts and Dominica. Some experts are warning that China is in de facto control of the governments in both those countries, due to its extraordinary financial influence, which includes the payment of bribes & kickbacks, on top of the publicly known fees and "administrative costs" that accompany all CBI passport applications.

America may be focused on electronic surveillance being conducted against its commercial and military structure from Cuba, by its adversaries, but understand that similar activities by the Chinese government is most certainly being performed from China's large embassies in the East Caribbean,as well as the Chinese "tourists" and "businessmen" hold CBI passports from the five East Caribbean states that maintain those sales programs. Is this yet another reason to seek the termination of such programs, either directly or indirectly ? Otherwise, we may see a further expansion of China's footprint in the Caribbean, which should be under the control of its people, and not become a base for further activities. One only needs to look at the recent history in the South China Sea, to understand the gravity of the potential problem.

US MARITIME ADVISORY ON RED SEA, GULF OF ADEN AND INDIAN OCEAN

2024-004-Southern Red Sea, Bab el Mandeb Strait, Gulf of Aden, Indian Ocean, Somali Basin, Arabian Sea, Gulf of Oman, Strait of Hormuz, and Persian Gulf -Threats to Commercial Vessels

Description

This advisory supersedes and cancels U.S. Maritime Advisory 2024-001, incorporates new advice to U.S.-flagged vessels to turn off their AIS transponders when transiting the Southern Red Sea, Bab el Mandeb Strait, and Gulf of Aden, highlights Houthi deceptive communications, provides information on the new Joint Maritime Information Center, and updates other threat info.

1. References: None.

2. Issue: Regional conflict, military activity, terrorist attacks, and piracy pose significant threats to commercial vessels operating in the above listed geographic areas as evidenced by recent Houthi terror attacks and Somali piracy activity. The U.S. government is continually assessing the maritime security situation in the region to safeguard freedom of navigation, ensure the free flow of commerce, and protect U.S. vessels, personnel, and interests. The recent standup of Operation Prosperity Guardian and EUNAVFOR Operation Aspides are examples of U.S. and international cooperative maritime security operations within this region. The following are currently deemed to be the most pressing threats to U.S.-flagged and U.S.-affiliated commercial vessels throughout this region.

a) Houthi Hostile Actions: Commercial vessels transiting the Southern Red Sea, Bab el Mandeb Strait, and Gulf of Aden continue to be at an elevated risk of terrorism and other hostile actions from the Houthis. Hostile actions include one-way Unmanned Aerial Vehicle (UAV) attacks; Unmanned Surface Vehicle (USV) attacks; ballistic and cruise missile attacks; small arms fire from small boats; explosive boat attacks; and illegal boardings, detentions, and/or seizures. There have been at least 47 separate Houthi attacks on commercial vessels and one Houthi seizure of a commercial vessel in these areas, affecting over 55 nations since November 19, 2023. Entities claiming to be Yemeni authorities have also attempted to divert commercial vessels operating in these regions from their course. These threats pose both direct and collateral risks to commercial vessels transiting in international shipping lanes, or otherwise operating in these areas.

- In the last month, one vessel was sunk by the Houthis in the Bab el Mandeb Strait and one vessel was struck by the Houthis in the Gulf of Aden, resulting in loss of life and forcing the crew to abandon the vessel. Both incidents resulted in the issuance of navigation warnings. Commercial vessels operating in these areas should be vigilant for hazards to navigation caused by vessels being struck by the Houthis and should be aware of all current navigation warnings.

- U.S.-flagged commercial vessels transiting the Southern Red Sea, Bab el Mandeb Strait, and Gulf of Aden with AIS transponders on are at increased risk of targeting by adversarial actors. U.S.-flagged commercial vessels operating in these areas are strongly advised to turn off their AIS transponders, unless vessel Masters believe that doing so would compromise the safety of the vessel. The International Convention for the Safety of Life at Sea (SOLAS), Chapter V, regulation 19.2.4 and IMO Resolution A.1106(29) permit vessel Masters to turn AIS off if they "believe that the continual operation of AIS might compromise the safety or security of their ship, or where security incidents are imminent." See also 33 CFR § 164.46(d)(2)(v). While vessels have been attacked by the Houthis while AIS transponders were on and while off, turning AIS off makes it more difficult to track and accurately target a vessel. Adherence to all flag state and international requirements and guidance regarding operation of AIS, and the safe navigation of the vessel, remains the responsibility of individual companies and vessel Masters.

- U.S.-flagged commercial vessels operating in these areas are advised to remain as far as possible from Yemen’s coastline without compromising navigational safety. Crewmembers should be especially vigilant when at anchor, operating in restricted maneuvering conditions, loitering, or proceeding at slow speeds.

- U.S.-flagged commercial vessels should coordinate voyage planning with U.S. Naval Forces Central Command (NAVCENT) Naval Cooperation and Guidance for Shipping (NCAGS) and consider their recommendations and guidance whenever possible. NAVCENT NCAGS stands a 24-hour watch and has the latest information on the current maritime security threats and the operational environment in this region.

• The route taken through these areas and the timing of the transit remain at the discretion of individual companies and vessel Masters. Planned routes, waypoints, and speeds should not be duplicated from prior voyages, when possible. Transiting these areas during hours of darkness may frustrate efforts to target vessels.
   
• U.S.-flagged commercial vessels are advised to provide hourly positional email updates to the NAVCENT NCAGS detachment when transiting these areas.
   
• Maritime operators are advised to alert their crews to the fact that all electronics signals from their vessels pose a risk to maritime operations and are strongly advised to secure WiFi routers while underway in these areas when feasible.

- A missile strike on a Marshall Islands-flagged commercial tanker in the Gulf of Aden on January 26, 2024 resulted in a significant onboard fire. U.S.-flagged commercial vessels carrying flammable, explosive, or otherwise hazardous cargoes are strongly advised to reconsider transit through these areas. However, if planning voyages through these areas, vessels should take all prudent safety precautions, including thoroughly preparing for emergency responses, and consider carriage of additional safety and damage control preparedness supplies and equipment.

- If hailed on VHF by the Houthis, or entities claiming to be Yemeni authorities, and instructed to divert from their course, U.S.-flagged commercial vessels should ignore the VHF call and continue their passage if safe to do so. U.S.-flagged commercial vessels that encounter this tactic are advised not to follow Houthi direction to divert course, as doing so may enhance the ability of the Houthis to accurately target vessels. U.S.-flagged commercial vessels are advised to update the NAVCENT NCAGS detachment when this occurs.

- If the Houthis seek to board a U.S.-flagged commercial vessel in these areas, the vessel’s Master should, if the safety of the ship and crew would not be compromised, decline permission to board, noting that the vessel is proceeding in accordance with international law, as reflected in the Law of the Sea Convention.

- When combined with evasive maneuvering, vessels transiting these areas with armed security details onboard have successfully deterred boarding by individuals in approaching small craft. The decision whether to embark a contracted armed security detail and assessment of associated risks is the responsibility of individual companies and vessel Masters, who are responsible for establishing use of force guidance and pre-planned responses for vessels carrying contracted armed security details.

- If Houthis board a U.S.-flagged commercial vessel without a contracted armed security detail onboard, the crew should not forcibly resist the boarding party. Refraining from forcible resistance does not imply consent or agreement to that boarding.

- When operating in these waters, U.S.-flagged commercial vessels should always maintain a proper, vigilant lookout by employing all suitable means in the prevailing circumstances and conditions. This includes incorporating additional lookouts to ensure a comprehensive assessment of the situation. See 1972 COLREGS, Rule 5. If U.S.-flagged commercial vessels observe or hear a suspected UAV or missile or observe a small boat approaching with apparent hostile intent, crewmembers not needed for the safe navigation and operation of the vessel should be relocated to a safe space until the threat has passed. Additional precautions should be taken to ensure small boats are kept at a safe distance whenever possible.

- In addition to U.S. Maritime Alerts and this Advisory, interim industry transit advice for the Southern Red Sea and Gulf of Aden is being distributed by Combined Maritime Forces (CMF). CMF guidance messages are available on the Maritime Global website.

DON'T LOOK TO THE UNITED STATES TO SOLVE EUROPE'S BLOODY CITIZENSHIP BY INVESTMENT PASSPORT MONEY LAUNDERING NIGHTMARE: EU, TAKE ACTION FORTHWITH

I happen to know more than a little about both money laundering and the employment of of Citizenship by Investment (CBI) passports to facilitate it. I was a career money launderer in the "Tax Havens" (read: the money laundering republics) of the East Caribbean states, five of which sell CBI passports, for a decade, and I worked closely with the man many call the father of St. Kitts' groundbreaking passport program, the late William Herbert, Jr., former Foreign Minister of St. Kitts & Nevis, until his untimely demise, reportedly over the alleged loss of funds belonging to the IRA.

The news that the Members of the European Union, having had more than enough with the use and abuse of CBI passports, to engage in money laundering, terrorist financing, and financial crime, is contemplating terminating all visa-free access by the holders of those prized identity documents, is music to me ears. The reason this pleases me is that, since the United States has deliberately, as a matter of national policy, ignored the severe money laundering threats posed by CBI passports for decades, someone has finally stepped up to deal with this tool of crime.

For decades, yours truly has loudly blown the whistle in the US, to both its law enforcement agencies, as well as its secretive intelligence community, about the clear & present danger of CBI passposts, but due to what is certainly a State Department policy of not appearing to be an overbearing superpower, America has kept its hands off what are basically Caribbean jurisdictions whose corrupt and greedy leadership has thrived on dirty money spent on CBI passports, both in the purchase thereof, and their subsequent use to facilitate global money laundering. The US has even gone so far as to decline to pursue the systemic CBI-enabled money laundering operation, by American citizens, in the Republic of Malta, Europe's sole holdout in the dirty business of CBI sales to criminals.

We welcome Europe's belated, but necessary,, efforts to shut down this important loophole, through which money launderers drive a truck full of the proceeds of crime in, and through, that region's financial institutions, and hope that the EU's actions will result in delivering a fatal blow to East Caribbean state (and Maltese) CBI-facilitated financial crime for once and for all. Frankly, I am tired of watching the laundrymen use those passports to clean the proceeds of crime in the European financial structure.

IS IT NOW TIME TO FINALLY END VISA-FREE TRAVEL TO THE EU FOR HOLDERS OF CITIZENSHIP BY INVESTMENT PASSPORTS, DUE TO SYSTEMIC AND INTENTIONAL DUE DILIGENCE FAILURES TO SCREEN APPLICANTS?

                                 

When I told St. Kitts then-Foreign Minister, WILLIAM HERBERT, JR.,* that my Medellin Cartel-linked cocaine trafficking clients could no longer qualify for his newly-independent nation's groundbreaking Citizenship by Investment (CBI) passport program, due to their indictment in the United States. Dr. Herbert advised me to simply find a cooperating law enforcement agency somewhere, and obtain Certificates of Good Standing for the required SKN due diligence. His actual knowledge that my clients were completely unacceptable as applicants, but that he still wanted to sell them passports, was only my first encounter with what was to be an industry that regards the lucrative cash flow it brings into a developing country, and its vendors, as more important than being a proper gatekeeper to bar career criminals, corrupt PEPs, terrorist financiers, and the Usual Suspects, all of who are seeking entry into the EU, and elsewhere, without visa scrutiny of their background, hidden agenda, and dark goals.

Due diligence, at Customer Identification, for applicants at the five East Caribbean states that have CBI passport programs, and at the Republic of Malta, the last EU Member to still sell such passports, is an utter failure, and a continuing insult perpetrated upon the European Union, which accept them for entry visa-free. Whether they be Russian organized crime members, citizens of countries designated as State Sponsors of Terrorism, corrupt foreign officials from states that are known kleptocracies, or just garden-variety international fraudsters, the wrong people seem to get approved, time after time, by the dysfunctional CIP programs the CBI vendor nations operate.

Unless and until the CBI states move to external, onshore due diligence, by reputable compliance organizations, that will be completely free of corrupt influence, it is high time to revoke the visa-free EU entry status that these passports freely come with. All the other nonsense, about the virtues that these passports convey to their holders, will fall by the wayside, as unfettered EU access is the single most important that CBI passports possess, and without it, their attractiveness to purchasers will disappear, like the cool breeze early on a Caribbean morning.
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*Dr. Herbert would later meet a reported violent end, allegedly at the orders of a terrorist client who wrongly suspected him of stealing money earmarked for weapons purchases, but actually confiscated by an agency of His Majesty's Government.