CONVICTED RUSSIAN MONEY LAUNDERER, USING A CBI PASSPORT IN THE UK, RAN A MULTI-MILLION DOLLAR OPERATION THAT PROVIDED A SPECIAL SERVICE FOR HIS CRIMINAL CLIENTS NOT GENERALLY KNOWN TO COMPLIANCE OFFICERS

The use of Citizenship by Investment (CBI/CIP) passports issued by former British territories, which afford the user visa-free entry to the UK, as well as the other Commonwealth countries, has been a favorite tactic of Russian criminals for decades. At one point, more than 50% of the economic citizenships sold in the Republic of Malta were to Russian nationals, most of whom are suspected of being involved in organized crime. Malta's CBI program, known as IIM, freely sold its country's identity documents, which also featured EU access, to hundreds of Russian career criminals. Those passports continue to facilitate European money laundering on a grand scale. No wonder the European Commission is seeking in court to have the program cancelled.

SEMEN KUKSOV, the son of a Russian oil executive, ran a clever operation, which I am familiar with, because back in the "Miami Vice" days (1980-1990) I supplied the same service to my narcotics trafficking clients. Call it Hawala for Criminals; clients would deliver criminal proceeds, and be able to subsequently pick up the cash equivalent abroad, often in local currencies. No international bulk cash smuggling, which often carried serious risks of interdiction, occurred. I used funds already located in overseas tax havens to pay off the clients' representatives. This afforded clients virtually risk-free movement of their criminal profits abroad. As a bonus, it also allowed me to pay off other clients within the Continental United States, who had previously moved their funds abroad, but for some reason, needed cash here locally.

Mr. Kuksov, employed what we call the Token method, to identify the cash courier who was picking up money abroad; the holder of a specific low denomination note (bill) would be identified by the serial number, and pass that note to the banker abroad. BTW, he received a five year sentence in the UK for his crimes; whether that punishment fits the crime, I leave for others to argue and dispute. I note that there actually was a dialogue in Malta as to whether to cancel his CBI passport; it appears that Maltese authorities feared that to do so might injure their Golden Goose, the cash cow that CBI represents, irrespective of the fact that the holders are often criminals.