US BANKS MUST NOW DECLINE TO ACCEPT ANY FURTHER CITIZENSHIP BY INVESTMENT APPLICATION MONEY, UNLESS MEANINGFUL REFORM IS ENACTED BY ALL EAST CARIBBEAN CBI STATES FORTHWITH

Back in 1984, when the first Foreign Minister of St. Kitts & Nevis, William (Billy) Herbert, Jr., created the world's first Citizenship by Investment (CBI) citizenship and passport sales program, he chose to have all payments under the scheme to be in US Dollars ($). While he could not have foreseen the coming of the Money Laundering Control Act of 1986, and the fact that court decisions construing the Act have conferred Extraterritorial Jurisdiction upon all individual and entities, CBI programs wherever located, which all employ USD during any Predicate Act, gives rise to money laundering exposure, Neither St. Kitts nor any of the subsequent four EC states that enacted CBI/CIP have those changed currency requirements. The impact of this fact cannot be underestimated, as foreign individuals and entities whose sole nexus with the US is the Dollar, are now fully subject to American Federal criminal laws.

Fast forward to 2024, where a massive American RICO suit, against St. Kitts and St. Lucia bad actors, alleging fraud and systemic corruption, and claiming four hundred and fifty dollars in damages, has been filed, and among the party defendants is a major Caribbean financial institution, demonstrating the exposure that US banks have to plaintiffs alleging that their willing participation in the acceptance of CBI money, in greenbacks, which they process through the New York banking center, and the dangers that they face for that reason.

One of the principal causes of action in the RICO case is the fact that Chinese compliance companies central to the application process intentionally perform compromised Due Diligence, with the result that Chinese with counterfeit identification are allowed to obtain SKN passports, which is a National Security risk to the United States and other Western companies. US banks therefore cannot guarantee either the Source of Funds or Source of Wealth of the CBI applicants, are in danger by accepting CBI payments.

Unless and until the five EC states that sell CBI products, St. Kitts & Nevis, Antigua & Barbuda, the Commonwealth of Dominica, St. Lucia and Grenada, totally reform their programs now, US banks should:
(1) Hereafter decline to accept any and all Dollar wire transfers, and deposits which appear to be CBI application payments, and redline all senders known to have sent such funds in the past for Enhanced Due Diligence.
(2) Examine all existing correspondent accounts, especially those of all jurisdictions where CBI programs exist, to determine whether they should be terminated, as part of a new De-Risking strategy. These decisions should be made after consultation with outside bank legal counsel, for risk reduction purposes.

The days when CBI money freely flowed through New York are coming to an end, unless reform starts now.