Buried in Saint Lucia media recently is an article extolling a recent audit of the country's CIU, the agency operating the Citizenship by Investment (CIP) programme, and giving it a passing grade. I am attaching the article for ready reference. There's just one glaring problem with the methodology used by the firm conducting the audit, Deloitte. By definition, an audit is a thorough verification of all the financial records, transactions and operations of an organization. it is typically conducted by accounting professionals holding the appropriate licensed or certified status.
According to our information, the Deloitte firm failed to audit the accounts in Hong Kong, Macau and China of CARIBBEAN GALAXY GROUP, which reportedly hold, or held, at least two billion dollars of CIP funds. That is where the audits needs to be conducted, not on the money of the government fees reaching Saint Lucia. All they audit is the Saint Lucia government fees account, but in truth and in fact, the lions' share of the CIP funds went directly to the Galaxy accounts in China.
Given that the facts of the illegal diversion of the CIP funding was public knowledge, the question remains, was it accounting malpractice for Deloitte to fail to demand to see those financial records, and failing that, to refuse to conduct the audit, let alone certify the results. We leave the issue of whether Deloitte is liable for damages to all the subsequent purchasers of Saint Lucia CIP citizenships and passports, when the program's failures to adhere to the statutory requirements of the enabling CIP legislation, and is terminated or cancelled, concerning all the passport buyers who relied upon the audit when making their purchasers, to lawyers competent to render opinions on professional negligence on this set of facts.


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