HOW ST. LUCIA VIOLATED AMERICAN SANCTIONS ON RUSSIA AND PLAYED THE U.S. STATE DEPARTMENT

While the attention of most compliance officers is focused on the allegations of money laundering and corruption in St. Kitts & St. Lucia, our investigation has uncovered an even more sinister development: how the country's Citizenship by Investment (CBI/CIP) passport sales program allowed some of its favorite vendors to apply for passports while the country had banned Russian applicants, to comply with Americans sanctions imposed due to the invasion of the Ukraine. The U.S. State Department had told all five of the East Caribbean states that have a CBI program that they could not pass Russian application fees (in USD$) through their New York banks' correspondent accounts, and all had formally agreed to cease and desist with all Russian applications, including St. Lucia, in March of 2022.

Unfortunately, in an internal maneuver designed to help certain select vendors, St. Lucia continued to process Russian applications after the early 2022 memorandum establishing the ban. This was done for the purposes of financial gain, and the U.S. State Department was not informed. We have a copy of a check showing payment for fees from a Russian applicant, drawn on St. Lucia's correspondent account at BNY Mellon, a clear violation of both the sanctions and the CIP's own ban. Attached please find an official memorandum confirming that the ban was still in place; it was never formally suspended, and no correspondence issued by the CIP in that period exists; Any claims to the contrary are bogus, spurious and without any basis in fact. The US eventually learned that violations were occurring.

Eventually, after an additional consultation with the US Government, a subsequent memorandum confirming the ban was issued in 2023, and some vendors are improperly claiming that it absolves those who illegally made applications for Russians, after March 2022. Therefore, a number of violations of America's Russian sanctions occurred, and as the U.S. State Department was never notified of any suspension of sanctions, which would have had serious consequences for St. Lucia, it was played by both CIP leadership, and the country's government. We trust that the Department of State and the Treasury Department is investigating the specific violations,and will take appropriate action. One of the individuals processing these illegal applications is a lawyer who is a close personal friend of the Deputy Prime Minister.

One final note; one of the post-sanctions Russian applicants reportedly made a USD$200,000 bribe payment, to insure that his illegal application would be processed. The recipients, who shared this cash payment, were a prominent individual in the CIP and a senior government official. The money was delivered by a Panamanian Courier (Testaferro), coming from Antigua.