ST. KITTS' ANNOUNCEMENT OF THE CREATION OF A "CONTINUING DUE DILIGENCE" UNIT IN EUROPE, TO MONITOR ITS CBI PASSPORT HOLDERS, UNDERESTIMATES THE SKILLS OF MONEY LAUNDERERS AND FINANCIAL CRIMINALS

Today's announcement, that St. Kitts and Nevis, as a component of its efforts to control its Citizenship by Investment (CBI/CIP) passport holders, will form what it has named a "Continuing International Due Diligence" (CIDD) Unit, to monitor financial crimes they may be committing in Europe. Reportedly to be led by a former St. Christopher & Nevis Police Force Commissioner, and based in Europe. the Unit is being touted as part of the Government's solution to the fact that many Kittitian CBI passport holders have been engaged in financial and other crimes, and used its visa-free advantages to enter the EU, the UK, and Commonwealth countries.

Having spent much of my younger days as a career money launderer, my immediate response is that this action, coming on the heels of the public exposure of St.Kitts' CBI passport program as allegedly corrupt and in violation of the program's laws, grossly underestimates the abilities of financial criminals,especially money launderers, to successfully operate without detection.

Let's look at just two of the reasons why:
(1) Professional white collar criminals, working in Europe, have been known to possess multiple genuine official as well as CBI passports, from a variety of the world's jurisdictions, under various aliases, making traditional identification impossible under most circumstances; in fact, the money launderers the hardest to identify.
(2) Their use of anonymous shell, shelf & front companies, from jurisdictions that stubbornly refuse to allow unrestricted access to beneficial ownership information, allows them effectively hide from even EDD investigation; layering the entities makes unmasking the players even more difficult.

If the best-equipped and funded bank compliance departments in Europe and the United States have an extremely poor record of uncovering the true identities, how can a unit, which will have to monitor activities in thirty countries in real-time, and investigate all its leads, have a chance against the professionals, who set up their operations specifically to confuse and misdirect anyone seeking them out. Identifying those arrested is far too late; the damage will already have been done.

The only solution with CBI is to raise the bar (via real EDD) so high that you rarely, if ever, sell citizenship & passports to anyone other than fully-vetted legitimate applicants.