MONEY LAUNDERING INTO U.S. BANKS THROUGH CARIBBEAN CITIZENSHIP BY INVESTMENT PROGRAMS CONTINUES UNABATED AND IGNORED

For decades, six figure application fees have been paid by dodgy foreign nationals, many from high-risk jurisdictions, into the Citizenship by Investment (CBI/CIP) passport sales programs of the five East Caribbean states, all going into correspondent accounts at America's biggest financial institutions, without any adequate prior AML/CFT compliance being conducted abroad. While we fully understand that those accounts are a lifeline to the developing countries from the Caribbean region, which must import 90% of finished consumer goods for local consumption, and American foreign policy has always been to support those countries in their economic development, the time has come to interdict large amounts of criminal proceeds that are effectively being laundered in our New York and Miami financial centers, because a substantial portion of it goes on to be invested in the United States for  transnational career criminals, corrupt PEPs, foreign tax cheats, and a host of the other Usual Suspects who would never pass a due diligence check should they dare to seek to open an account in an American bank.

Remember, it was the late William (Billy) Herbert, then the Foreign Minister of Saint Kitts & Nevis who, when he invented CBI forty years ago, chose to require that applicants remit their funds in US Dollars, rather than any European or Caribbean currency, which is what started what has become one long continuing money laundering nightmare for those US banks that choose to service the Caribbean through correspondent accounts. That, ladies & gentlemen, is how we have ended up in such a dark place, where AML is consistently ignored by the CBI states, and both Federal law enforcement agencies and our esteemed regulatory agencies sit on the sidelines and let all this dirty money enter our financial structure unmolested and untouched. 

If there is a bright side anywhere for the United States, it is that court decisions construing the Money Laundering Control Act of 1986 have conferred personal jurisdiction of foreign nationals that use our Dollars to commit money laundering, even though they have never entered the United States. The problems is that our law enforcement has utterly failed to use this valuable tool against those who would clean their proceeds of crime through CBI, into our banks. I challenge the incoming administration to step up, and shut down these financial barbarians literally at our gates, block and seize unchecked CBI funds from the Caribbean are entering with zero compliance, start bringing indictments of the bad actors, and if necessary, take whatsoever steps it deems necessary and proper to either reform the CBI programs, or failing that, deny them the ability to deposit what has become a financial obscenity into American banks.