WILL FINCEN AND OFAC TEAM UP TO STOP CHINA IN THE CARIBBEAN AND SAVE CORRESPONDENT BANKING IN THE REGION IN THE PROCESS?

While America Sleeps, China uses five countries' Citizenship by Investment passport programs to increase its influence in the Caribbean. Its tools; CARIBBEAN GALAXY REAL ESTATE LIMITED in Saint Kitts & Nevis and Saint Lucia; in Grenada, CHINA HENG SHENG (Singapore) DEVELOPMENT PTE., LIMITED; In the Commonwealth of Dominica, and Antigua & Barbuda, a number of entities, all designed to vastly strengthen the PRC's clout in a region where foreign interference has been strictly prohibited by the Monroe Doctrine since 1823. China apparently chooses to ignore this established foreign policy of the United States, while engaging in money laundering that affects American National Security interests, due to financial crime impacting our banks. 

As the direct result of Chinese actions that have resulted in the various CBI programs conducting illegal passports sales, the payments then deposited constitute money laundering for the US banks that maintain correspondent accounts for the Caribbean financial institutions that have CIU accounts. The situation now threatens the future of those accounts, the loss of which would surely plunge the East Caribbean into serious financial difficulty, given that the United States is the region's largest trading partner.

In order to insure that every East Caribbean state maintains the essential access to the American financial structure that is necessary for international trade, remittances from abroad, and the development of tourism, those correspondent accounts must continue to exist. Therefore, it is suggested that the Financial Crimes Enforcement Network, (FinCEN), and Treasury's Office of Foreign Assets Control (OFAC), issue such Advisories and Sanctions as are necessary and proper to block all the deposits of Chinese-owned and controlled entities of the payments for the illegal sale of discounted Economic Citizenships into any US bank accounts. 

One American financial institution with correspondent accounts for several Caribbean banks, Bank of America, has already started to block all CBI transactions, after discovering that such illegal payments were being deposited by Dominica. OFAC Sanctioning the companies known to be involved, and all payments being made by and through them, will assist US banks to meet their AML/CFT obligations, and with FinCEN publishing relevant Advisories, the response will preserve the correspondent relationships that are a lifeline for the Caribbean. We hope that FinCEN and OFAC staff will accept this timely advice, to assist in the solution of an emerging problem that can no longer be ignored by US regulatory agencies.