Saturday, March 22, 2025

WHY IS THERE SO MUCH CONCERN IN THE UNITED STATES ABOUT THOSE CITIZENSHIP BY INVESTMENT PROGRAMS IN THE CARIBBEAN?


I am hearing from readers wanting to know why the American financial sector, as well as the United States government itself, have been raising issues about the Citizenship by Investment (CBI or CIP) passport sales programmes operated by five East Caribbean states. It is a valid question, which deserves an answer, especially since the impending U.S. visa ban on those countries has drawn so much controversy, including anti-American statements from EC leaders, incensed that their constituents may not be able to visit America in the near future.

West Indians, if you want to blame someone, don't vent your anger at the Trump Administration, which is only trying to keep Chinese spies and white collar criminals out of the United States. Instead, the person who is entirely responsible for your situation is the late Saint Kitts Ambassador William Valentine (Billy) Herbert, former radical bad boy and sometime narcotics and terrorist financing money launderer, who was a central figure in the creation of the SKN CBI program. Dr. Herbert chose to require that applicants for Saint Kitts & Nevis citizenships pay for them with the United States Dollar, rather than the regional currency, the EC Dollar, which was the appropriate choice for a number of fiscal, as well as practical, reasons. Alternatively, the Pound Sterling might have been a better choice at the time, but Herbert wanted the US Dollar, which was the currency of Latin American drug traffickers holding illicit narcotics profits. Now perhaps you understand his motives.

All USD payments for passports would then of course be processed through the American banking structure, which provides a basis for jurisdiction over criminal activity, notably the Money Laundering Control Act of 1986. Furthermore US courts have held that extraterritorial jurisdiction exists to enforce the Act, which is an additional tool Federal prosecutors have to charge foreign violators.

Now you understand that the deposit, in American correspondent bank accounts of CBI program fees, of the proceeds of crime earned by
applicants implicates the US banks in criminal activity. Therefore there is valid worry and concern about that exposure, resulting in American focus on Caribbean passport programs that some may believe to be excessive, or even obsessive, but it is well taken, given the potential problems facing American financial institutions. So, if you want to find someone to blame for 2025's issues, place it on Billy Herbert back in 1983; I rest my case.

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