EVEN FACIAL RECOGNITION SOFTWARE CANNOT IDENTIFY CHINA-BASED FRAUDSTERS AND MONEY LAUNDERERS WHO ARE CBI PASSPORT HOLDERS

The increasing number of arrests, in the United States, United Kingdom, Singapore and elsewhere, of Chinese career criminals using Citizenship by Investment (CBI/CIP) passports issued using aliases and fraudulent IDs, has exposed the dangers which these passports possess. We fear that there is currently no adequate AML program available to identify and interdict them, even with the best facial recognition software platforms.

If you have been following our recent articles, and the stories of the arrests which have widely appeared in the media, it has been alleged in the civil RICO suit filed in the United States, MSR MEDIA vs. KHAN, that a China-based CBI vendor/consultancy has sold St. Kitts CBI & St. Lucia CBI citizenships with passports to Chinese nationals, who have used counterfeit and fraudulent identification to successfully process their applications. This results in the issuance of passports under aliases and potentially also with intentionally vague photographs, making facial recognition impossible, and that's even assuming that any facial rec platform even has accurate images of these individuals.

Here's an example of how fraudsters and laundrymen operate; they get images posted to their passports with other than their photograph. The individual pictured is currently serving a 20-year sentence for diverting billions of dollars. You can expect these Chinese career criminals to excel at placing such non-conforming and intentionally inaccurate images on their passports.

The only viable solution to the problem for compliance officers is to treat any and all Caribbean CBI passports as extremely high risk, and initiate enhanced due diligence upon all of them, which is prohibitively time-consuming. Whether we will see compliance rejecting Caribbean passports, and their holders, en masse, which may be the only practical response, we cannot say.