COMPLIANCE OFFICERS SHOULD CAREFULLY CHECK PASSPORTS FROM COUNTRIES WHO SELL ECONOMIC CITIZENSHIP

Notwithstanding the attention being paid to major problems, regarding unqualified foreign nationals receiving passports, and even diplomatic passports, through the Citizenship by Investment programs being operated in several Caribbean Jurisdictions, the offshore industry has scheduled a boatload of events in 2017, to showcase these programs for interested, and therefore affluent, purchasers.

The proliferation of CBI programs means that compliance officers should be alert for new clients, offering these documents, as proof of identity. Remember well these procedures:

(1) If the client, seeking to open an account, or commence a new relationship, offers you a passport from one of the countries listed below(all of whom are advertising some sort of program or other), check their place of birth. if it is NOT in the country where the passport is from, initiate enhanced due diligence immediately, for you may have one of the CBI passports.

(2) Is the passport brand new, and without the usual visas and entry/exit stamps affluent client are likely to have ? This is another red flag of a possible CBI passport.

(3) Does the passport holder fluently speak the official language of that country ?

(4) Does the passport holder appear to be of an ethnic or racial background other than those normally found in that country ? This is not profiling, but seeking to rule out any prospective client that is too high risk for you to accept at account opening.

While this list is probably not complete, all these countries are scheduled to make CBI presentations this year:
MALTA
PORTUGAL
CANADA
SPAIN
ST KITTS
GREECE
CYPRUS
TURKEY
ANTIGUA & BARBUDA
MONTENEGRO
SERBIA
DOMINICA
GRENADA
AUSTRALIA & NEW ZEALAND
GEORGIA
PANAMA
IRELAND/UK
SWITZERLAND
BULGARIA
USA

Whether you wish to examine, in detail, clients with US and UK passports, is optional, due to the
fact that strict vetting is conducted in this jurisdictions.

The days when compliance officers can accept a passport at face value are, sadly, gone forever, due to the expansion of CBI programs, and their uneven, and often, unacceptable levels of due diligence.