In the early 1980s, I was contacted by the late William (Billy) Herbert, then the Ambassador Plenipotentiary in St. Kitts, which afforded him multiple diplomatic positions. Dr. Herbert, who later disappeared, due to allegedly incorrect assumptions made by a client about missing funds in a money laundering project he was handling,* formed shell offshore companies and registered narcotics smuggling vessels in the UK for some of my narcotrafficking clients for a number of years.
He brought news of a newly-created passport program that we now call Citizenship by Investment, or more commonly CBI, which allowed my criminal clients to assume St. Kitts & Nevis nationality, and obtain an SKN passport in the process. Since then, four other East Caribbean states have embarked upon such a program, of which Grenada, whose citizens have the potential to apply for American E-2 Investor visa status, to allow CBI passport holders to eventually be able to access the United States, has a distinct advantage.
Speaking solely from the viewpoint of money laundering tradecraft, CBI passports are a godsend. They allow the holders to assume an anonymous alias, complete with a bogus Place of Birth that matches the country of their passport. Altering one's Date of Birth is also possible, given the rampant corruption associated with the CBI programs being operated at this time. In short, a completely new identity is created for the benefit of the holder. Add to this the availability of a local driver's license, and an included residence purchased in conjunction with the program, giving one the usual required proof of payment of a utility bill, and the identification required in most countries to open a bank account is satisfied. Since affluent new clients are much to be desired in the developing world, if they have the identity documents, they are generally accepted.
Armed with a CBI passport, a money launderer is free to visit a financial institution in a country in the developing world, conceal his real passport, and present his new, clean identity, thereby artfully deceiving the local compliance officer, who is totally in the dark about his new identity, especially since effective facial recognition software is most likely not in use there. Since typical checks of commercially-available databases of high-risk and sanctioned individuals will not result in a positive finding, the laundryman after waiting a short period, to appear to be a legitimate routine bank customer, is free to employ advanced and complex money laundering schemes at will. he then closes the account and disappears from that jurisdiction, his goals accomplished, and anyone later attempting to follow his trail will find that it has gone cold. Terrorist financing and sanctions evasion is also facilitated.
Many financial criminals hold multiple CBI passports, with variations on the name, and in several countries, to throw off any routine checks. Some only use a specific CBI passport briefly, and then use it on the other side of the world, knowing that in the developing world, access to information about "clean" passports from obscure island nations is nearly impossible to find, even for local law enforcement agencies in Latin America, Africa and the Far East.
Until and unless the CBI passport become a thing of the past, laundrymen will be free to abuse them at will, and since they represent significant revenue for third world jurisdictions who need cash flow to cover their budgetary needs, due to an excess of government employees and departments, it is in their best interests to continue to operate CBI passport sales programs. These passports will continue to be sold, hence the problem will continue.
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* A Caribbean Money Launderer casts a Shadow Long After his Death (October 9, 2014).
We expect to see sparks fly this week, when Secretary of State Marco Rubio meets with six of the leaders of the Caribbean countries from the organization of Eastern Caribbean States (OECS). while not listed on the agenda, the knotty American problem of money laundering connected to correspondent accounts in the United States receiving Citizenship by investment (CBI/CIP) will most certainly be on the minds of the senior State Department officials conducting the talks. American banks which are servicing the Caribbean have major exposure to prosecution for violation of the Money Laundering Control Act by processing illegal CBI application funds, although they have thus far resisted calls to close accounts which are an economic lifeline for the Caribbean, as 90% of the region's international trade flows through the United States.
What are the specific money laundering issues? Let's quickly survey them.
(1) SAINT KITTS & NEVIS and SAINT LUCIA: the CBI & CIP programs of those countries have processed thousands of illegally-discounted applications, acting in cooperation with Chinese-based CARIBBEAN GALAXY GROUP. Those payments are by definition money laundering.
(2) GRENADA: Another CBI state allowing deeply and illegally, discounted applications, this one in conjunction with yet another dodgy Chinese-controlled consultancy, HENG SHENG GROUP, has also resulted in the Proceeds of Crime to infect the American monetary system.
(3) DOMINICA: A monopoly by a single stakeholder, and of course more illegally-discounted applications has tainted this state's program. Murders connected to a survivalist-oriented CBI stakeholder project have raised serious questions about a total lack of government control over its CBI.
(4) ANTIGUA AND BARBUDA: A groundbreaking §1782 proceeding in the US is about to expose decades of money laundering orchestrated by the country's Prime Minister, GASTON BROWNE, all processed through American financial institutions; Antigua has become ground central for a Chinese-controlled "Hong Kong-style" enclave completely autonomous, including its financial sector.
While there have not been any instances of De-Risking resulting in any East Caribbean state losing all its US correspondent banks, such an event could occur, with disastrous economic, social and political consequences for the region. Will these EC states continue to allow their CBI programs to endanger their correspondent banking, and risk catastrophic De-Risking, and what will Secretary Rubio do about it?