WHO ARE THE UHNW INDIVIDUALS WHO ACCEPTED CITIZENSHIP BY INVITATION OFFERED BY GRENADA?

If you read the press release from late January, the Government of Grenada advised that it had initiated a special Citizenship by Investment (CBI) program, known as "Citizenship by Invitation," available only to Ultra High Net Worth (UHNW) individuals, who will be invited to apply for an accelerated processing version of the CBI application process. UNHNW is defined as persons whose net worth is over $30million. The CBI passports so obtained will have lifetime renewals built into them, according to one consultancy article.

Given the stated 3-4 month processing time, the first invitations accepted by the recipients should already have received their passports, and we are wondering whether , given the serious privacy requirements of UNHNW individuals, whether their "personal information" (true identities) have been somehow modified, as some of them are most certainly considered to be Politically Exposed Persons, or PEPs, which necessitates additional account accessing by compliance officers tasked with Transaction Monitoring responsibilities, under the relevant anti-money laundering laws and regulations.

While we certainly respect privacy concerns, this new class of CBI passport does increase risk levels for compliance officers, and therefore, we are interested in the identification of those individuals who will be holding them, and using them for financial transactions.