SAINT LUCIA PARTNERS UP WITH CONTROVERSIAL OFFSHORE BANK; BIG MISTAKE?

The announcement, that the Government of Saint Lucia has accepted a sponsorship from Nevis-based HAMILTON RESERVE BANK, which has become embroiled in nasty litigation with an American bank client, and which has a number of serious consumer complaints** against it on the Internet, will not endear this economic passport-issuing Eastern Caribbean state to the American banking community, given its risk-adverse nature.

Hamilton, which reportedly requires a large minimum initial deposit to open an account, has allegedly failed to disburse deposits of clients upon demand, and was the subject of major litigation*, filed on behalf of an US-based company that claims it did not receive a request to disburse twenty seven million US Dollars from its account. Whether Hamilton is insolvent, as the case meets the traditional test of being unable to meet its obligations as they come due, remains an open question. Similar complaints by other bank clients can be viewed on whst appear to be consumer websites. Under the circumstances, compliance officers at international banks may have concerns regarding whether a relationship now exists, between Hamilton Reserve Bank, and Saint Lucia's rogue Citizenship by Investment (CIP) program, which has been accused of involvement in fraud, corruption and money laundering, and the diversion of an estimated USD$1.3bn, by Chinese-controlled CARIBBEAN GALAXY REAL ESTATE LIMITED. Saint Lucia's CIU, the agency that operates the CIP program, has correspondent banking relationships with American financial institutions, which could now be accessed by Hamilton. Alternatively, economic citizenship deposits for Saint Lucia could be routed though Hamilton. Considering that American banks are required to maintain a risk-based AML/CFT compliance program, issues with Country Risk could be the subject of concern. We shall be watching for any indication that these concerns are well taken.

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WILL NEPAL MEET ITS AML CHALLENGES, AND SUCCEED IN BEING REMOVED FROM THE FATF GREY LIST IN 2027?

If you have been following recent political developments in the Federal Democratic Republic of Nepal, you know that the country has gone through rioting, and an election of late, while its remittance-assisted economy continues to labor under the consequences of its second placement on the Financial Action Task Force Grey List. Unsolved problems with widespread money laundering in its casino, real estate, gold trade, and non-Governmental Organisations (NGO) sectors, where industries require comprehensive AML training to convince the FATF that effective compliance is in place, have not yet been conducted, primarily due to severe budgetary constraints.

Nepal needs to focus on AML/CFT programs that will demonstrate to the regulator it has upgraded both compliance in the private sector, to the level of Banking Best Practices, and adequate oversight from governmental agencies which have heretofore been underfunded and ineffective, in order to persuade the FATF that there has been significant reform, across the board. We hope and trust this will occur, now that there is a sufficient degree of political stability. 2027 will be here sooner than you think, and whether Nepal can show sufficient progress at this time, so as to justify FATF action, depends upon the government's resolve and action.

LOOK AT THE FACTS: NEARLY EVERY MAJOR CHINESE WHITE COLLAR CRIMINAL ARRESTED IN THE UNITED STATES DURING THE PAST TWO YEARS ENTERED WITH A SAINT KITTS & NEVIS CBI PASSPORT

Sentenced to 20 years' imprisonment; fled to China.

If you have been reading my articles diligently, you know that, by and large, most of the Chinese nationals arrested for major white collar crime in the United States since 2023 were found to own a Citizenship by Investment (CBI) economic passport issued by SAINT KITTS AND NEVIS. This is an established fact, and if you are a compliance officer, you correctly act accordingly, by classifying SKN passports as high-risk, requiring that an enhanced due diligence investigation be conducted, before you accept individuals holding those identity documents as bank clients, full stop, because you may have a career criminal before you, not a legitimate customer.

I know very well that I am going to receive a lot of pushback for this statement from all the passport sales consultancies in Dubai, who will point out what they claim is Saint Kitts' effective due diligence program, which in truth and in fact is a joke being played upon the financial community. One only needs to read the articles about about how CARIBBEAN GALAXY REAL ESTATE LIMITED, which is Chinese-owned and controlled, sold tens of thousands of passports to Chinese nationals, with ZERO due diligence, because they has their own captive compliance company, owned by one of their senior officers. You will still be hearing the so-called professional opinions from the investment migration sector, especially those at Holborn. (which our UK readers know very well has had it's own share of complaints from consumers; read the articles) Compliance officers should regard those lengthy diatribes, supposedly attesting to the legitimacy of CBI programs, as little less than pure propaganda and spin from individuals who have a conflict of interest by passing judgment on the products that they sell to consumers. My intended audience, as always, are American and European compliance officers, who I trust will take my advice seriously, given their demonstrated interest in reading all those horror stories about Chinese fraudsters, money launderers and those engaged in industrial espionage for the Peoples' Republic of China.

In essence, I advise you to redline ALL Saint Kitts & Nevis passports presented to you, unless you can confirm that the holder is a native-born Kittitian, engaged in legitimate commerce. Reject all the SKN CBI out of hand, in my humble opinion, based upon decades of watching those passports being abused by financial criminals.