THE IDENTIFICATION OF CITIZENSHIP BY INVESTMENT (CBI) PASSPORTS BY COMPLIANCE OFFICERS FOR AML/CFT PURPOSES

                                 

While the investment migration industry sells most of its economic citizenships to legitimate purchasers, most of whom are affluent or high net worth individuals, a number of financial criminals do end up with passports that afford them visa-free entry into Europe or other areas, where they often seek to engage in white collar crime. Therefore, compliance officers at financial institutions and NBFIs must develop the skills necessary to readily identify CBI passports when they are presented as account opening, at real estate closings, and in connection with other business transactions.

It is humbly suggested that you follow these guidelines:
(1) Be aware of which jurisdictions currently, or previously, sell or sold economic citizenships; it is also helpful to keep a watchful eye on the CBI industry, so that you learn, in advance, of any new nation that is opening a program which could result in the appearance of new CBI passports in circulation, before you are aware that they are being sold.
(2) Assume that the listed name on a CBI passport is either a modification of the holder's legal name, an alias, or a possible translation/transliteration from another language, alphabet or script. This will interfere with your ability to use commercially available off the shelf databases to rule him or her out for sanctions or identification as high risk or with a criminal background abroad. Have you attempted to employ facial recognition software?
(3) Unless an individual has actually lived in the jurisdiction where his passport was issued, he generally will not have both the relevant language fluency, and the slang and terms peculiar to residents of that country. Do you have someone on your staff from that loication, who could tell in a moment if he was a native speaker, with local phrases, grammar usage and accent? Have him engage the client in conversation about what city he is from there.
(4) If you have not yet established that you have a CBI passport in your hands, check the Place or Birth closely. While originally, CBI jurisdictions like Saint Kitts and Dominica inserted bogus birthplace information, in recent years, legal requirements or local practice have dictated that the holder's real birthplace be listed; this can be an additional confirmation of CBI status.
(5) the passport of most world travelers have several pages of entry and exit stamps, visas, work authorizations, and other notations. Is the passport you have in hand new, and with few such stamp? That is one of the indicia of possible CBI passport status.

With experience, compliance officers are usually able to spot a CBI passport early on, and then must decide, as gatekeeper, whether enhanced due diligence is the next step, or should they decline the business outright, report it up the chain of command, or file a SAR. It's your decision; Choose wisely.