Friday, June 21, 2024

WILL THE RECENT DISCLOSURES OF RAMPANT ABUSES OF CBI RESULT IN THE COMPLIANCE WORLD REGARDING THOSE PASSPORTS AS HIGH-RISK FOR BANKING PURPOSES, WITHOUT TRUE REFORM?


The documented use of counterfeit IDs to obtain Citizenship by Investment (CBI) passports, with the open cooperation of the CBI vendor, and the resulting multiple arrests of white collar criminals employing them in reported arrests and indictments has shaken up the banking compliance sector to the point where regarding all CBI passport as potential high-risk, has become a real possibility. While the CBI industry insists it is still Business as Usual with sales, the real issue is how the passports will be assessed, for risk management purposes, at account opening and during Customer Identification Procedures. All the slick PR spewed out by CBI vendors may result in increased CBI passport sales, but if wary compliance officers adjudge them to be High-Risk, then reform of the process may be the only way they survive pariah status in the banking world, which is where it truly counts.

Vendors can shout from the rooftops that number of visa-free jurisdictions that a passport enjoys, but if result in a stigma being attached to the holder, by the banks, then its utility not only sharply decreases, but the risk that such CBI passport owners will find themselves under continued AML scrutiny, ehren they trot out their prized (and expensive) passports, will increase. If this isn't a strong argument for the CBI jurisdictions to enact true reform of the process, free from corruption and illegality, I don't know what is. Clean up your industry, people, before your clients complain they cannot open a bank account with their shiny new passport.

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