POLARIS AND OTHER AGENTS SUBMITTED 11,372 APPLICATIONS TO THE SAINT LUCIA CITIZENSHIP BY INVESTMENT PROGRAM

POLARIS CITIZENSHIP & INVESTMENT SERVICES LIMITED, a company in the Caribbean island of Saint Lucia, owned and controlled by the law firm of local attorneys GEOFFREY DUBOULAY, DIANA THOMAS and BRENDA FLOISSAC-FLEMING, engaged in the processing of illegally-discounted Citizenship by Investment passports, together with other agencies, submitted 11,372 applications during hurried processing by their offices, as the scandal surrounding the illicit sales unfolded in the media, with Polaris and the others earning inflated processing fees for each, all for a lower price than legally permitted. Given that each file could generate passports for four family members, there may be as many as 45,000 passports involved.

The clearly excessive amount of money Polaris received for the simple processing of application forms is part of a broad conspiracy that returned obscene profits to all the participants in an illicit enterprise designed to extract maximum amounts of fees, while delivering economic citizenship passports that were not properly and fully paid for, putting them at a real risk of cancellation. Furthermore, the fact that the payments were part of an illegal activity means that transfer of the funds into, and through, bank accounts in America constitutes money laundering under US law, which we have previously detailed in several articles appearing here. Correspondent accounts in the US, being recipients, are thus in danger of imminent closure, another serious problem that we have discussed. 

Polaris sold citizenships for Saint Lucia's Infrastructure Program, through the Chinese company CARIBBEAN GALAXY REAL ESTATE LIMITED, which is a named defendant in the one hundred and fifty million dollar RICO case presently pending in the United States, and which alleges that Galaxy ran an operation that allowed its partners, such as Polaris, to sell thousands of citizenships as reduced, and thereby illegal, rates, and to divert the payments received to China, instead of to Saint Lucia government accounts. Several individuals who have received passports through Galaxy have been arrested around the world for financial crime activities.

Passports sold at an illegally-discounted rate, through the five East Caribbean states that offer them, stand to be cancelled by the issuing countries for failure to make proper payment; One country, Dominica, has already begin officially cancelling such passports, and another, Saint Kitts & Nevis, has announced that it will begin such cancellations as well.

We have taken the liberty of attaching a small portion of the Polaris records, identifying the names of the applicants, all of whom apparently were obtained through sub-agents located in the Middle East. You can see the names of the sub-agent companies throughout the Polaris lists that appear in this article, which were taken directly from the companies' correspondence to the Saint Lucia Citizenship by Investment Unit (CIU).

As a former bank attorney and compliance officer, I note that 99% of the purchasers appear to be from high-risk countries in the Middle East. The purchasers' names, which were transliterated from their native Arabic language and script into the universally used Latin (Roman) alphabet, pose a serious danger for the purposes of Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT), as there are dozens of academically accepted equivalents from the original Arabic. This means that the results may not precisely correspond with the original, increasing risk of an alteration. Individuals on global sanctions lists, financial criminals and terrorist financiers may therefore not be identified. Banks, immigration officials, and law enforcement agencies will most likely not be able to determine if any of these individuals are among such criminal elements, which multiplies the risk that they will remain unidentified when presenting their new passports, showing them to be Saint Lucia citizens. We cannot underestimate the threat that these passports represent.

Therefore, not only has Polaris facilitated the issuance of passports obtained without properly paying for them, but it has allowed individuals who may be unsuitable and unqualified to receive them, while increasing the risk that it created aliases for criminal elements in the process, securing new clean identities that will not show up on government lists. It has been reported that Polaris, as well as its three senior partners, will be added as an additional defendant in the RICO case, and that there is reportedly a major criminal investigation pending in the United States.