RAISE COUNTRY RISK ON SAINT LUCIA DUE TO SERIOUSLY ELEVATED MONEY LAUNDERING CONCERNS CAUSED BY THE CITIZENSHIP BY INVESTMENT (CIP) SCANDAL

The risk that any significant transfer of funds originating from SAINT LUCIA are the proceeds of crime remain elevated to the extent that we must recommend that Country Risk for that East Caribbean state be elevated to High Risk status. The efforts of both local, as well as American, media, to get to the truth about the full extent of the sale of citizenships at illegally-discounted rates, the location of more than a billion (US) dollars converted and diverted by Chinese actors, and a total lack of cooperation, from both government, as well as the country's principal private financial institution, the BANK OF SAINT LUCIA, requires that compliance officers exercise extreme caution in any financial transaction where Saint Lucia is remitting funds to US banks.

We remind our readers that the country's Deputy Prime Minister, ERNEST HILAIRE, has stonewalled and ignored all public inquiries, regarding the CIP program, and we note that he, as the Minister for Investment, has a fiduciary duty to be totally transparent, making full disclosure, in response to both media and public queries regarding CIP; inasmuch as he has not, we are unable to assume that any CIP funds have been vetted for Source of Funds, and represent a clear and present danger to any US financial institution that accepts them. Compliance officers charged with calculating and assessing Country Risk should govern themselves accordingly.