NEW EUROPEAN RULE THAT CBI PASSPORT SALES AGENTS ARE SUBJECT TO AML/CFT REGULATIONS AND POLICIES WILL BE A GAME-CHANGER IN AN INDUSTRY INFECTED WITH COMMISSION-DRIVEN SALESMEN WITH WILLFUL BLINDNESS

In what will surely be a sea change in the Citizenship by Investment passport sales industry, more commonly known as CBI, the European Union's latest anti-money laundering rules include what it classifies as "Immigration Migration Operators (CBI passport vendors and agents)" in the category of businesses subject to AML/CFT regulations.

If you want to know the precise scope of the term, we must go with the EU definition: "private companies, bodies or persons acting or interacting directly with the competent authorities of the Member States in behalf of third-country nationals, or providing intermediary services to third-country nationals, seeking to obtain residence rights in a Member State, in exchange of any kind of investments, including capital transfers, purchase or renting of property,investment in government bonds, investment in corporate entities, donation or endowment of an activity contributing to the public good, and contributions to the state budget."

This means that CBI sales vendors will be required to create, and operate, an AML/CFT compliance program that meets EU standards. It is the 'Don't ask, Don't Tell" method through which these companies have done business in the past that has been, in large part, responsible for the sale of CBI passports to international white collar criminals, fraudsters,sanctions evaders, corrupt PEPs, and many other categories of individuals totally unsuitable as applicants due to their extremely high-risk status. This will now change, for the typical CBI passport salesman will now be personally liable for failure to conduct customary due diligence on potential clients, through both Customer Identification Procedure and confirmation of legitimate Source of Funds and Source of Wealth.

Will Immigration Migration Operators who shirk their AML/CFT duties end up indicted, convicted and have a sentence imposed upon them for money laundering? It's far too soon to see what the future may hold with CBI salesmen, but this EU action represents a giant step forward in reforming and cleaning up the CBI passport sales industry. How it will be enforced, however, remains to be seen.