NEW PILOT ALTERNATIVE PAYMENT AND SETTLEMENT SYSTEM OF FOUR CARIBBEAN CENTRAL BANKS ANNOUNCED, AVOIDING THE ROUTING OF CBI MONEY THROUGH THE U.S. BANKING SYSTEM

TIMOTHY ANTOINE, the Governor of the EASTERN CARIBBEAN CENTRAL BANK, has announced the formation of a pilot program whereby the central banks of three Caribbean countries, and the ECCB, will form a cross-border payments and settlement system, based upon the model of the existing Pan-African Payments & Settlement system, to handle cross-border payments in local currencies. Antoine bluntly stated that the purpose of the new payments system is to avoid the use of U.S. correspondent banks and what he referred to as "foreign currencies," meaning the U.S. Dollar. The new system has been designated the CARICOM PAYMENT AND SETTLEMENT SYSTEM (CAPSS).

The proposed system, which was announced at the recent Africaribbean Trade and Investment Forum in Grenada, and which Antoine contemplates being eventually being linked to the African payments system, with central banks making settlements directly with each other, in USD, could result in payments for economic citizenships through Citizenship by Investment (CBI/CIP) programs, outside of the American financial structure. This means evading AML/CFT compliance at U.S. Correspondent banks, which adhere to Banking Best Practices policies and procedures; Payments would therefore not be traceable through the American banking system.

Given the long history of fraud, money laundering and corruption that has pervaded the CBI programs of the five EC states, St. Kitts & Nevis, Antigua, Dominica, St. Lucia and Grenada, whose compliance programs are known to be affected by local political actors, and other forces, rendering them intentionally ineffective, it is feared that this new political system will serve as an end run around the American financial structure for illicit funds being laundered through CBI investments.

We further fear multiple problems, coming from the region's primitive payments and payments processing sector, which is a complex ecosystem involving various players like banks, payment processors, fintech companies, and digital wallet providers, all required to be working together to enable seamless transactions. This industry is rapidly evolving with technological advancements, changing consumer expectations, and increasing regulatory scrutiny. The Caribbean's Payments industry, to properly discharge a cross-border function, will require major upgrades, professional advice, and extensive training of staff.

Whether it is the intent of Governor Antoine, and the other organizers, to evade American regulators, remember that serious financial crimes in the U.S. through CBI transactions have already occurred, and the offenders will have to account for those criminal violations, as this proposed plan won't immunize them, such a program will demand compliance at a seriously increased level to become successful.

AMERICAN CUSTOMS AUTHORITIES ARE ONCE AGAIN LOOKING CLOSELY AT CARIBBEAN SCOUNDRELS, SCALAWAGS AND SCRAPPERS

Back in the period some call the Golden Age of Money Laundering, when the owners of offshore tax haven financial institutions grew wealthy banking illicit cocaine profits earned in North America, and smuggled into the Caribbean, American Customs officers payed particular attention to citizens of the West Indies entering the United States. Many of those arriving "businessmen and tourists" were but a small cog in a huge international money laundering operation. that depended upon such fringe players to quietly bring financial instruments into American banks, make investments with cleaned drug capital, and facilitate what was a well-oiled machine, operated at the behest of traffickers for whom narcotics was simply a business featuring a high return on investment.

During that period, US Customs more than one photocopied my entire American passport upon my arrival in CONUS , outright interrogated me, and x-rayed my carry-on briefcase, looking for incriminating evidence. Now, thirty years later, we have reports that individuals arriving from the states of the West Indies are receiving a similar level of attention, which of course disturbs them, and which treatment they have been reporting to their government leaders, in such jurisdictions as Saint Kitts & Nevis, Saint Lucia and Dominica. Did those leaders not consider that the new American administration, which is slowly implementing a new policy regarding those CBI states, due to their systemic corruption, fraud and money laundering, would also detail its law enforcement agencies to increase surveillance of individuals who are potentially engaged in violations of American criminal law? Will those visits result in the arrest and prosecution of the Caribbean couriers?

We understand that, while publicly putting on an external facade, dismissing the possibility that major U.S. action will affect all their constituents, the leaders privately worry about whether the proverbial knock on the door of their palatial residences will come, sooner rather than later. It is fast approaching the point where all their CBI sins and transgressions will have serious international consequences; Let the Games begin.

CYBER INTRUDERS MAY HAVE ACCESSED SEALED FEDERAL INDICTMENTS AND INFORMATION ABOUT CONFIDENTIAL INFORMANTS

There are multiple reports that foreign hackers have penetrated the Federal electronic case access system known to most legal professionals as PACER, for Public Access to Court Electronic Records, as well as the case management and filing system known as CM/ECF. this means that extremely sensitive court filings, which include sealed indictments of Federal fugitives, information that identifies Confidential Informants, and arrest and search warrants, could have been extracted by criminal elements.

Sealed Indictments of Federal fugitives, who are not in US custody, and many of whom are outside the United States, are non-public for a reason: to keep the targets from learning about pending charges, which information may cause them to flee to avoid apprehension. seeking to move to a non-extraditable jurisdiction. That information may also cause them to suspect Confidential Informants of being the source of incriminating information, and place them in grave physical danger. Other sealed filings could supply important clues to targets about the progress of pending investigations which they could act upon, to cheat justice. Foreign criminal organizations with access could modify their activities, assassinate witnesses, destroy evidence, and foil effective international investigations with this material.

The Federal filing system, which is said to be outdated and in sore need of replacement, has been the subject of repeated requests that it be replaced. Apparently, there have been multiple breaches, which have been disclosed to the Federal judiciary, but not acknowledged to the public. Individuals who have been Confidential Informants in Federal criminal cases should govern themselves accordingly.

MORE CRIME STATISTICS ( HOMICIDE) FROM THE EASTERN CARIBBEAN, TO ANSWER THE DOUBTERS WHO DON'T HAVE THE FACTS.

I have been receiving brutal pushback from my articles about the increasing violent crime in four of the Eastern Caribbean states that will be requiring that their CBI purchasers spend a stated amount of time in actual residence. While I am not saying that you are in imminent danger on the streets of Saint Lucia, Saint Kitts and Dominica every day you are shopping in the market, you should be aware of the increasing threats posed by narcotics trafficking gangs.

MOST CARIBBEAN CBI PASSPORT HOLDERS FROM ASIA AND THE MIDDLE EAST WILL NOT QUALIFY FOR A VISA TO ENTER THE UNITED STATES, UNDER TRADITIONAL ADMISSION POLICIES

You are a High Net Worth individual who has spent a hefty sum to acquire an economic citizenship from Antigua, Saint Kitts & Nevis, Dominica or Saint Lucia, and you apply for a visa at the US Embassy in Barbados, fully expecting that it be granted. Surprise, surprise; it is rejected.

A Consular Officer at the embassy, applying the legacy guidelines on visas, has ruled that you do not meet the traditional qualifications for visa approval. While you of course know that an applicant's lack of actual residency is a major factor, there are a number of other issues, which are guidelines the Department of State uses to specifically prevent overstays, and a CBI passport holder, although wealthy, will be disqualified because they will not be able to create satisfactory answers to most questions, as they involve long-term situations.

Besides "How Long have you resided in Your Country," questions about local (lengthy?) employment history, home ownership, family members whom you must support financially, and other ties to the nation you are now a citizen of, all show you have no close connections there. Consular officers, who fear you would therefore overstay, and remain in the US indefinitely, must apply these rules to CBI passport holders, as they would native-born citizens.

We trust that Investment Migration consultancies in the Middle East and Asia are not filling the heads of their CBI applicants with notions of visiting New York or Disney World anytime soon. Of source, enterprising attorneys will most likely be attempting to create positive answers to those questions for their CBI clients, but building such a long-term history may prove difficult. Thus, in addition to the new issues regarding Due Diligence, identity changing and national security threats, it is likely that most CBI passport holders will be unable to secure a visa to enter the United States.

SHOULD YOU PACK A BULLETPROOF VEST WHEN SERVING YOUR UPCOMING MANDATORY RESIDENCY PERIOD AT A CARIBBEAN CBI STATE?

Responding to American complaints that Citizenship by Investment (CBI/CIP) passport programs have no requirement that the purchaser of economic citizenships has a legal obligation to reside in his new adopted state (among other issues regarding integration into, and knowledge of, their new country), it appears that all five of the Eastern Caribbean CBI-issuing jurisdictions will be mandating uninterrupted actual residence for minimum periods. This may sound like an order to take a tropical holiday, but perhaps HNW. and UHNW individuals need to know that there are physical dangers in what they think are idyllic vacation spots.

All five of the EC CBI states have, to one degree or another, serious gang and organized crime problems, all involving narcotics, and the rival groups generally are not adverse to shooting at their competitors when they find them in the streets of the towns and villages of the Caribbean. a newly-arrived CBI passport holder, trying to serve out his mandatory residency period, may find himself not a crime victim of an intentional act, but simply by being in the market or shoppe when assassination attempts by drug dealers send bullets flying his way. The local law enforcement agencies, unable to suppress violent crime, are often only present after the fact, leaving the new SKN or SLC citizen with a gunshot wound in a country with few competent emergency room doctors to save his life. If you doubt the truth of those statements, look at the statistics.

Therefore, if you are considering the acquisition of a CBI passport that affords you visa-free entry into the EU, you may want to first perform a risk analysis on the level of personal safety you are likely to have, when living, albeit temporarily in your new Caribbean paradise; it may not be quite what the peson sho sold you that passport indicated it would be. Caveat Emptor

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Source of Caribbean Crime Chart:  https://getgoldenvisa.com/is-st-lucia-safe

DO PUNITIVE DAMAGES LIE AGAINST CBI CONSULTANCIES WHO SELL CARIBBEAN CBI AND CIP PASSPORTS AND CONCEAL EMERGING RISKS?

Whether Punitive Damages can be recovered, in civil litigation against consultancies, and their owners and executives, who continue to sell Caribbean CBI passports to investors, given the risks that foreign enforcement action, due to the exposure of massive fraud, money laundering and corruption, could result in a diminution of the value of those passports, for failure to expose major risks in advance to the buyers?

If you weren't paying attention at university, Punitive Damages, also known as Exemplary Damages, are considered punishment and are typically awarded at the court's discretion when the defendant's behavior is found to be especially harmful. They are damages assessed in order to punish the defendant for outrageous conduct and/or to reform or deter the defendant and others from engaging in conduct similar to that which formed the basis of the lawsuit.

Does the conduct of those sales staff at Dubai-based CBI consultancies that sell Caribbean citizenships, which currently come with Visa-free access to the EU and other jurisdictions, rise to the level of willful, wanton and reckless, because they fail to inform their clients, who must be regarded as consumers, on the ongoing and newly emerging risks that buyers incur, when purchasing economic citizenships, with the expectation that they will be able to get ready access to the Member state of the European Union? That is an issue for a court of competent jurisdiction to determine, and it is expected that attorneys who zealously advocate for their clients will be seeking its judicial determination, when bringing claims for damages. We will be reporting on those cases when they come to our attention.

UNITED STATES $15,000 VISA BOND REQUIREMENT APPLIES TO ALL CITIZENSHIP BY INVESTMENT STATES, ACCORDING TO TEMPORARY FINAL RULE PUBLISHED TODAY, AUGUST 5, 2025

                    Source: DEPARTMENT OF STATE, 22 CFR Part 41, Public Notice 12783.

Inasmuch as we have been hearing reports that certain Eastern Caribbean government agencies and government-controlled media are asserting that the five Eastern Caribbean states (St Kitts & Nevis, Antigua, Dominica, Saint Lucia & Grenada) are to be exempt from the new American Visa bond requirement, because they were not specifically named at a U.S. press conference, please see the attached portion of the Temporary Final Rule, issued and published today, which puts to rest any questions regarding whether they are included.

"Second, in another portion of the Temporary Final Rule, entitled 'Parameters of the Pilot Program,' it lists the specific deficiencies that nationals of countries with CBI programs cause them to be included: Second, the Department finds that nationals of countries where vetting and screening are deficient are nationals for whom there are concerns about overstay risks because the Department has difficulty obtaining full background and criminal history information. Third, nationals of a country with CBI who obtained citizenship with no residency requirement may have insufficient personal history within or connections to their country of nationality for sufficient screening and vetting checks to be conducted." DEPARTMENT OF STATE, 22 CFR Part 41, Public Notice 12783.

Either of these two entries in the Rule are sufficient to conclude that ALL the five Eastern Caribbean states are definitely included in the Visa Bond requirement. We take offense to the manipulation of the truth by government forces in the Caribbean that are determined to misinform their own constituents about the truth, when the corrupt CBI programs they mismanaged are the direct and proximate cause of the Bond program. See my prior article: RESPONDING TO CARIBBEAN CBI CORRUPTION, MONEY LAUNDERING AND FRAUD, UNITED STATES TO IMPOSE FEES OF UP TO $15,000 TO ENTER AMERICA https://rijock.blogspot.com/2025/08/responding-to-caribbean-cbi-corruption.html

THE LIABILITY OF INVESTMENT MIGRATION MEDIA AND INDUSTRY GROUPS TO PURCHASERS OF CARIBBEAN CBI/CIP PASSPORTS DUE TO FRAUD AND MISREPRESENTATION

As more purchasers of Citizenship by Investment from the Eastern Caribbean states which offer such programs become aware of unfolding developments that will negatively affect the ability of the passports they acquired to achieve the purposes for which they were offered for sale, issues of fraud and misrepresentation of material fact have been alleged by them, and their legal counsel. While litigation against the consultancies that sell the economic passports will most certainly follow, the legal issue of whether a number of third parties in the so-called investment migration industry could also be found liable to the investor/consumers, for damages, has become a central element in the victims' legal strategy.

Both investment migration media and industry organizations and associations are alleged to have presented glowing and extremely favourable representations of the economic, social and personal benefits of CBI,without disclosing any of the adverse or negative consequences that purchasers may encounter after acquisition. Additionally, legal, tax, and even international law enforcement, and immigration issues are rarely objectively discussed, these media and associations purport to impart 'insider" expert advice, although they are generally not qualified professionals; Think sin of omission.

If investors, who are to be regarded as consumers for the purposes of major fraud issues, take action in detrimental reliance upon these third party representations, which do not disclose risks, there are certainly issues of strict liability for courts of competent jurisdiction to determine. Given the increasing number of complaints that have publicly surfaced, we are certain that the liability of such third parties will eventually be adjudicated.

RESPONDING TO CARIBBEAN CBI CORRUPTION, MONEY LAUNDERING AND FRAUD, UNITED STATES TO IMPOSE FEES OF UP TO $15,000 TO ENTER AMERICA

As the next round of American response to the serious threats the U.S. deems are posed by visits from foreign nationals from the five Caribbean states, where rampant CBI fraud and corruption threaten its National Security, corrective measures have been taken.

ROOSEVELT SKERRIT

The U.S. Department of State has published a Temporary Final Rule, where those Caribbean nationals will be required to post a bond of up to $15,000. The bond, which must be in an approved format that allows it to be readily redeemed in the event of violations, is said to also serve as a diplomatic tool to ensure appropriate vetting by the authorities in the country of origin of the visitors. 

TERRANCE DREW

State has published a detailed 33 page Public Notice, covering all aspects of the Pilot Program, which initially will run for a period of twelve months . Any reader that requires the complete text may email me at miamicompliance@gmail.com to receive a copy.

PHILIP PIERRE

The announcement of the Pilot Program, which advises that the bonds are intended to be applied to visitors or who overstay, or who cause "Security Concerns," resulting in a breach of the conditions of the bond, has caused what can only be described as panic in the Eastern Caribbean CBI states, whose citizens will now be required to make a substantial payment as a precondition to travel to the United States. Given the income and assets of most West Indians, it is doubtful that the majority will be able to afford this new cost of travel to America. Here is whom they have to blame.

ERNEST HILAIRE

We wish to congratulate Saint Kitts & Nevis Prime Minister TERRANCE DREW, Dominica PM ROOSEVELT SKERRIT, Saint Lucia PM PHILIP J. PIERRE and DPM ERNEST HILAIRE, and  SKN Foreign Minister and former PM DENZIL DOUGLAS, all of whom contributed to the CBI corruption, fraud and money laundering in their respective passport sales programs, for what they have now done to the citizens of their Caribbean states. This is only the beginning of more corrective measures to come from the United States.

DENZIL DOUGLAS

 I warned the voters of the Caribbean for many years about the dangers of electing governments that were using CBI to enrich themselves personally, as well as their political allies and supporters, including companies controlled by the Peoples' Republic of China, and who ignored the constituents who placed them repeatedly into office. They have enriched themselves, and brought China into the Caribbean, where it dominates the politics of these countries, and poses a National Security threat to the United States.

As ye sow, so shall ye reap.

MEET THE NEW BREED OF INTERNATIONAL MONEY LAUNDERER AND SANCTIONS EVADER OPERATING IN EUROPE: GEN X RUSSIANS RAISED AND EDUCATED ABROAD, ARMED WITH MULTIPLE CBI PASSPORTS

They may be ethnic Russians, but they have grown up abroad, and are well educated, generally in Europe, where they operate with impunity. Multi-lingual, and sophisticated in the discreet movement of money and assets, they are the next generation from their organized crime or oligarch parents, and they are very, very good at what they do. very few of them have been identified, let alone arrested in the act of money laundering or international sanctions evasion.

What is of interest to this Old School Caribbean Tax Haven money launderer is the fact that they employ multiple Citizenship by Investment (CBI/CIP) passports in their craft, all with different identities. This means one laundryman holds passports from at least two of the Eastern Caribbean states, say Saint Kitts & Nevis and the Commonwealth of Dominica, as well as from say Malta and perhaps an old one from Cyprus. They evade the restrictions on Russian nationals acquiring CBI by have been born in Western Europe, or being outside Russia in their youth long enough to effectively change their nationality or residence. Their familiarity with advanced technology is also known to exist.

While a small number of them have been caught in Europe or North America, most of them are not initially identified as Russian, some pose as Eastern Europeans from EU Member states, and their fluent linguistic skills go far towards creating alternate non-Russian profiles. Remember, they are also alternating their CBI passports, which feature multiple different aliases, foiling most traditional law enforcement or compliance investigative techniques, and requiring that effective facial recognition be the primary identification tool.

We must hope that as their organizations are identified by European law enforcement, or the intelligence services, their identities will become known to compliance officers at international banks, but at the moment, these 'talented" individuals hold all the cards.

WILL BELGIUM DENY THE EXTRADITION OF THE BILLIONAIRE FUGITIVE MEHUL CHOKSI TO INDIA?

We must now wait until September to learn whether the man we once called India's Most Wanted Fugitive, MEHUL CHOKSI, will be extradited to his native India to face the music, don't assume that the court in Belgium, which must decide his fate, will order he be transferred to Indian authorities, so that he may be transported home. Extradition requests can be denied, and Choksi's Belgian attorneys have interposed procedural objections, which could result in the court declining to approve his return to India. Lawyers who don't have the law on their side often seek relief through purely procedural actions.

Additionally, there are a number of other considerations, any one of which the court might seize upon as grounds to refuse extradition; although Choksi had a form of Belgian residency that allows extradition, reports state that he was either considering, or had already manifested the intent to step up to the local version of residency where one cannot be extradited abroad. His wife reportedly hold the non-extraditable form of residency.

Then of course, we have his health issue. Due to his poor health, he was reportedly scheduled to travel to Switzerland for medical treatment there. Whether that will be a factor in the court's decision we cannot say, but his counsel seems to have thrown out a number of issues, any one of which could result in a decision to deny extradition.

Considering how Choksi was able to defer extradition from Antigua, where he adroitly used his Citizenship by Investment (CIP) passport to delay the proceedings for many years, I would not count out his chances to escape justice once more. Whatever the ultimate outcome, we will be reporting on it here.

TRADITIONAL MONEY LAUNDERING VS. MONEY LAUNDERING THROUGH PAYMENTS AND PAYMENTS PROCESSORS

Readers who were wondering why I will be focusing a lot of my attention on Money Laundering through Payments and Payments Processors in the coming months, it is an emerging problem where compliance officers are often lagging far behind their laundrymen adversaries, and for good reason. Traditional money laundering generally involves the movement of the Proceeds of Crime through the financial system, from an external position. Laundering through Payments is a horse of different color: laundrymen often have confederates or co-conspirators within the system, or even are inside the Payments industry itself. It is much more difficult for compliance officers without the specific training necessary to ferret out Payments laundering for that reason.

I hope that you will join me in learning how to interdict Payments laundrymen in real-time, to be presented through the SOLTESZ INSTITUTE, in the coming months. Details will appear here.