NEWLY EMERGING AFRICAN CITIZENSHIP BY INVESTMENT PASSPORT SALES PROGRAMS; MONEY LAUNDERERS' NEWEST TARGET OF OPPORTUNITY?

We are, in 2025, witnessing the birth of new CBI programs on the African Continent. Leaving said the traditional yardsticks through which we measure the quality of a country's economic citizenship program, such as the number of jurisdictions the passport gives visa-free entry to, tax considerations, lack of actual residency requirements and local language proficiency, the eight hundred pound elephant in the room (no pun intended) would be elevated risk that these specific programs could be used for money laundering, and even terrorist financing, operations.

Speaking as a compliance officer who formerly served in what was then an African-domiciled fintech, and as one with more than thirty years' experience in that occupation, anti-money laundering compliance in the financial sector, as well as counter-terrorist financing, is in most African nations far below the Western banking best practices level, for a large number of economic, historic legal, social and cultural reasons which have no solution in the foreseeable future. AML compliance is by and large ineffective, driven by budgetary deficiencies, processional and continuing education shortcomings, corruption and other factors too extensive to cover here.

I fear that professional money launderers for career criminals, and those who work for global terrorist organizations, are closely watching the emergence of these new African CBI programs, and will be most surely be testing the limits of their compliance capability, the usefulness of this new form of identification, at account opening in banks arounds the globe, and how they can clean dirty money through applications. Given the levels of corruption pervasive in many African nations, you can also expect to see efforts by non-state actors to avail themselves of the privileges of holding passports from low-risk developing countries. I plan to keep a close eye on these African programs, especially the use to which those passports will be put, and whether they become a destination for money launderers; stay tuned.