In the aftermath of hurricane damage, and ostensibly to make needed repairs and reconstruction, the Government of St Kitts & Nevis has proposed, as a fundraising measure, to issue 4000 new Citizenship by Investment passports to new applicants. Has everyone in charge in Basseterre totally lost it ?
The estimate of 44 new due diligence investigations, per day, which will be required to be completed, to meet this governmental goal, simply cannot be attained, with any degree of effectiveness, given the size of current staff. Also, even if a boatload of new, qualified & experienced compliance officers arrived to handle that astounding workload, the pressure to complete files in record time, including overseas queries that generally take days to receive back, would crash the effort.
Remember, we are talking about enhanced due diligence, not the ordinary variety, and that type of inquiry of necessity is dependent upon multiple outside queries, not just reference to a database, and "check the box." Frankly, turning out reports at the 44-per-day rate would result in inferior, failed compliance products, meaning that criminal elements, individuals from high risk countries who require serious checks, and even terrorist financiers, wouls get those prized CBI passports.
I once served as a compliance officer, performing exclusively enhanced due diligence, at what was then the largest company of its kind in the world, offering insurance investment products, and I know how long it takes to properly vet one individual in that manner. I understand that St Kitts wants to raise $150m, in record time, but please, not at the expense of arming scores of criminals and terrorists with Kittitian passports.
Chronicles of Monte Friesner - Senior Financial Crime Analyst
Contributed by Kenneth Rijock - Financial Crime Consultant