SAINT KITTS REMAINS A CLEAR AND PRESENT DANGER TO U.S. FINANCIAL INSTITUTIONS, AND FINCEN'S DIRECTOR SHOULD RESIGN FOR REVOKING THE AGENCY'S ADVISORY ON SKN CITIZENSHIP BY INVESTMENT PASSPORTS

                                   

FinCEN Director Andrea Gacki

Who is in command at the Financial Crimes Enforcement Network ? Obviously, they are not paying attention to what goes out the door, because FinCEN recently cancelled its critical, eleven year old Advisory on Saint Kitts & Nevis Citizenship by Investment (CBI) passports. The fact that all the old SKN passports that were in force in 2014 are no longer valid is NOT a good reason to retreat from one of the most valuable moves the agency ever published, and which made Enhanced Due Diligence the order of the day for Saint Kitts transactions. And now you have removed that warning? If anything, St. Kitts CBI passports, now held by many thousand Chinese white collar criminals, spies and fraudsters, are more dangerous today than they were in 2014.

If ANDREA GACKI, the agency's director since 2013, cannot see the fundamental error of this action, then perhaps it is time for new leadership at FinCEN, someone who is understands the unintended consequences of the removal of Advisories. She used to be the Director of OFAC, and most certainly is aware of the rampant fraud, money laundering and corruption that have fatally infected Saint Kitts & Nevis.

If I was a compliance director at a major American financial institution, I would advise my frontline staff to treat Saint Kitts & Nevis transactions as if the Advisory was still in force. FinCEN, if you are not part of the AML/CFT solution, you are part of the problem.