The vetting of applicants for Citizenship by Investment (CBI) passports, in the five East Caribbean, states that operate such programs, Antigua & Barbuda, Dominica, St Kitts & Nevis, St Lucia and Grenada, has suffered from uneven effectiveness, due in large part to the fact that only investigations at the limited level of Due Diligence are being conducted, for the most part. This is inadequate for CBI purposes, as many applicants are from high-risk jurisdictions, and jurisdictions with unique issues, all of which demand that Enhanced Due Diligence (EDD) investigations are absolutely necessary to properly evaluate such applicants.
Why Enhanced Due Diligence, you ask. Here are some of the major challenges that EDD alone can meet:
(1) The majority of CBI applicants are from Asian and Middle Eastern countries, where the official languages are in non-Latin alphabets. This means that legal names of applicants must not only be expressed in English, they must be transliterated into the Western alphabet. This is a recipe for illegal alteration of the identity of the applicant, into an alias that will not come back to his history.
(2) Several of the jurisdictions that are attracting many applicants to the CBI program contain internationally-sanctioned individuals and entities, terrorist organizations, sanctions evaders, organized crime syndicates, terrorist financiers, and countries that are state sponsors of terrorism. All applicants from these high-risk nations demand an extremely high level of inquiry, which can only be adequately addressed by the broad scope of Enhanced Due Diligence.
(3) Organized crime members from the high-risk countries, as well as intelligence agents, may employ counterfeit or altered forms of personal identification, and Due Diligence-level inquiries do not examine, with attention to detail, such documents, to determine their validity. Only Enhanced Due Diligence procedures, which are sensitive to the probability of forged and counterfeit documents, will actually discern the bogus identity documents, whereas simple Due Diligence procedures will not spot them.
Only through Enhanced Due Diligence procedures can the East Caribbean CBI states separate the dangerous and unsuitable criminal elements from the legitimate CBI applicants. Anything less than EDD will result in continued compliance failures in the CBI republics, and the embarrassing public exposure of more CBI passport-equipped criminals and sanctions evaders in global media. Use EDDI to cull them out in the application process!
Chronicles of Monte Friesner - Financial Crime Analyst
Contributed by Kenneth Rijock - Financial Crime Consultant