INCREASED LIABILITY OF MIDDLE EASTERN AND ASIAN CBI CONSULTANTS AND ADVISORS TO AMERICAN MONEY LAUNDERING AND OTHER CRIMINAL CHARGES AFTER US vs. MCKINSEY CASE RESULTS IN $650,000,000 DEFERRED PROSECUTION AGREEMENT PAYOUT

In what appears to be a case of first impression, a criminal Information was filed against a major American consulting firm, McKINSEY AND COMPANY, INC., in US District Court in Virginia, resulting in a global settlement that included the payment of $650,000,000, criminal charges being filed against a senior officer of the company, and an admission of the corporate defendant's liability for advice rendered to a client, a pharmaceutical firm. Readers are urged to review the Deferred Prosecution Agreement for more details; it requires the corporate defendant to commit to an extensive five year program to avoid a conviction on multiple counts. Inasmuch as a corporation is not a natural person, and cannot serve prison time, extremely close supervision, or the corporate death penalty, dissolution, which would then have followed a jury verdict of guilty.

What is unique to the case, and relevant to the situation faced by a number of prominent Dubai and East Asian Citizenship by Investment (CBI/CIP) consultancies that have engaged in the illegal discounted sale of Saint Kitts & Nevis citizenships & passports, is that one of the criminal charges filed against Mckinsey was Misbranding its clients product. The CBI consultants who sold SKN passports to consumers engaged in marketing campaigns that were deceptive, failed to disclose important facts to to prospective clients which rendered these investments high-risk for a number of reasons, and glossed over or ignored recent legal developments or actions which have now rendered their investments void, without the payment of additional funds which were never disclosed.

Given that Federal courts in the United States have consistently conferred Extraterritorial Jurisdiction upon the Money Laundering Control Act of 1986, and that CBI sales are all in US Dollars, it will be interesting to see what impact the McKinsey case has on the investigation, and ultimate criminal prosecution, of CBI consultants abroad.