Wednesday, February 25, 2026

WTF? FINCEN WRONGLY RESCINDS ITS LANDMARK ADVISORY ON MONEY LAUNDERING AND FINANCIAL CRIME CAUSED BY SAINT KITTS & NEVIS CITIZENSHIP BY INVESTMENT PASSPORTS; IF ANYTHING, THE SITUATION IS WORSE TODAY THAN IN 2014, DUE TO THE CARIBBEAN GALAXY SCANDAL


What on earth is going on over the Financial Crimes Enforcement Network (FinCEN)? Someone over there has now rescinded its groundbreaking Advisory FIN-2014-A004, entitled PASSPORTS OBTAINED THROUGH ST. KITTS AND NEVIS CITIZENSHIP-BY-INVESTMENT PROGRAM USED TO FACILITATE FINANCIAL CRIME, whose content remains painfully accurate today, and was the first real FinCEN countermove against the widespread use of CBI by financial criminals.

If anything, the unlawful sale of tens of thousands of SKN passports by the Chinese controlled company, CARIBBEAN GALAXY GROUP, to dodgy Asian financial criminals, intelligence agents, sanctions evaders, and people engaged in industrial espionage for China, has made the situation worse than a decade ago, and the Trump Administration has, if anything, ratcheted up its focus on that corrupt Eastern Caribbean state in 2026. So what happened here?

America's bankers expect more from their primary AML/CFT regulatory agency than this complete lapse of judgment, but given that most senior leadership there only use it as a stepladder to a subsequent lucrative career in the private sector, rather than stay on for a decade or more, I guess we should not be surprised. FinCEN, reinstate Advisory 2014-A004, forthwith, so that compliance officers will continue to correctly regard CBI passports as high risk.

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