DIPLOMATIC PASSPORTS PURCHASED THROUGH ECONOMIC CITIZENSHIP PROGRAMS OF THE CARIBBEAN POSE A SERIOUS AML/CFT THREAT

If you are a compliance officer at a North American financial institution, you probably feel that it is a problem for your profession, that Caribbean countries, such as St Kitts & Nevis, have issued tens of thousands of economic passports, for you must then raise risk levels on all new accounts, being opened, from those 'citizenship through investment' nations. Is he or she really an Iranian, or a Russian, or a corrupt PEP from a developing nation, with dirty money ? Should you decline opening the account altogether ? These are tough questions.

It gets worse; there are economic passport holders, roaming the friendly skies, holding diplomatic passports, notwithstanding that they hold no position, in their adopted countries, as accredited representatives, with diplomatic authority, and credentials; they bought their special status.

These counterfeit diplomats may be entering your country, carrying inspection-proof diplomatic pouches, or baggage, which under international law are immune from Customs search, and transporting cash, or financial instruments, over national borders, for the purpose of money laundering, or financing the operation of terrorism. The may even enjoy VIP treatment, at the airport of arrival, and be catered to by unsuspecting protocol officers, who believe that they have arrived on official government business. What a godsend for financial criminals such diplomatic passports can be.

Compliance officers should maintain updated rosters, of all nations known to have issued economic passports, for any purpose, and should circulate their lists to all new accounts staff members. Diplomats are generally expected to be affluent members of society, and even independently wealthy individuals, from upper-class families, in their countries of origin. This means that new account staff often bend over backwards to accommodate them, and skip over critical due diligence components.

Just because the diplomatic passport holder has the same last name as a prominent family abroad (it's an alias) does not mean you ignore CIP, under any circumstances. Ignore the chauffeur and personal assistant, it could all be a clever money launderer, with his associates, snowing you with his purported pedigree.

In essence, cast a cold eye on all "diplomats" who come through your door, if they present a passport from a country known to you to sell citizenships to those who will pay for them.