Sunday, March 15, 2026

IF YOU CANNOT ACCEPT THE UK FINDING THAT CBI IS "INHERENTLY HIGH RISK," THEN YOU ARE IN DENIAL, AND PART OF THE PROBLEM, NOT PART OF THE SOLUTION


If you read the comments closely, you have seen that my commentary regarding the risk factors that compliance officers at financial institutions face, when it comes to the money laundering and financial crime threat posed by the holders of Citizenship by Investment (CBI) economic passports, is getting a lot of pushback by individuals who deem my articles a threat to their livelihoods. Those people wish to distract potential purchasers of CBI passports from the UK Government's findings of fact, and its pronouncement that economic passports pose an "Inherently High Risk," by stating that my warnings constitute fear mongering, and that all major Western jurisdictions are also infected with financial crime.

This approach, which is a cleverly designed marketing tool, intended to distract consumers from the distinct possibility that their six figure CBI purchase may at some point become useless for visa-free travel into the countries which they purchased it for, by falsely endorsing what are passport sales programs already known to have rampant shortcomings regarding major money laundering, corruption and financial crime issues, should be ignored.

Economic passports, in the hands of career financial criminals, facilitate crime, pure and simple. Whilst the majority of those holding them use them merely to evade the expensive and time-consuming visa application process, those with ill intent are not to be disregarded as serious threats by the compliance community. The UK, and US and the EU are not wrong, when they advise about CBI being a systemic problem, and readers should disregard the slick marketing programs touting them as safely administered, because that is a misstatement of material fact.

Remember, we are required to maintain an effective risk-based compliance program; ignore the propaganda, people.

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