If you are a compliance officer at an international bank that encounters customers at account opening who are using economic passports of Citizenship by Investment (CBI/CIP) jurisdictions in the Caribbean or Europe, DO NOT use the information about those programs' due diligence that you read in the online industry media, for it is not only inaccurate and misleading, it deliberately misinforms investors, regarding the effectiveness and quality of such programs.
Industry publications, such as Immigration Migration Insider, or IMI, run by Christian Nesheim, (who is not a lawyer), portray CBI due diligence as being at the same level as those found in major financial institutions, but in truth and in fact, are often intentionally ineffective, and unevenly applied, resulting in career white-collar criminals, sanctions evaders, narcotics traffickers, and fraudsters obtaining CBI passports. Many of these criminals are subsequently arrested and prosecuted, a fact that IMI and its sister publications cleverly omits from its articles touting CBI due diligence programs.
Compliance officers should conduct their own de diligence investigation into the holders of CBI or CIP passports in specific jurisdictions, to include:
(1) Articles about arrests and convictions of passport holders.
(2) Information regarding what entity is actually processing due diligence and its track record.
(3) Litigation and news about claims by applicants, information regarding CIU misconduct or negligence, and news about correspondent accounts being restricted or closed, due to concerns that applicants are not being properly investigated.
The last place you should be looking for accurate and complete information is CBI industry media, which is rife with Conflict of Interest, and disinformation which is intended to lull investors into a false sense of security regarding supposedly effective and professional due diligence programs, professed to weed out unsuitable and dangerous applicants. CBI jurisdictions intentionally pass bad actors; their due diligence is a sick joke being played on investors. Ignore those glossy articles, please, when conducting your own inquiries.
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