CONFIDENTIALITY OF CIP PASSPORT HOLDERS CANNOT BE MAINTAINED UNLESS ENHANCED DUE DILIGENCE IS APPLIED

An important feature of many of the Citizenship by Investment (CIP) programs being administered by the East Caribbean states is confidentiality; there is an understanding that their identities would remain a private matter, and that confidentiality prevented public disclosure of all CIP recipients.

We understand that the reasons the applicants requested and received, confidentiality is significant:

1. Some of the countries the applicants come from do not recognize any dual citizenship held by their nationals.

2. The public disclosure of their names might trigger tax audits, or charges of tax evasion, in their home countries, or even criminal investigation, for purely political reasons.

3. The listing of their names, from which one might infer affluent status, might draw the attention of criminal elements seeking to target wealthy individuals, especially by kidnapping a family member and holding them for ransom.

Since these appear to be valid grounds, it is incumbent upon the operators of CIP programs to ensure all applicants are subject to effective Enhanced Due Diligence investigation, so that no unsuitable applicants are accepted into the programs, if they want to continue confidentiality. EDD is a robust level of investigation that will delve deeply into an applicant's background, to determine whether his history or current status renders him objectionable, using risk-based parameters, which employ the information EDD obtains, and apply it to risk analysis.

If CBI jurisdictions wish to continue to offer confidentiality to all applicants, they must apply Enhanced Due Diligence in advance, on all applications, prior to any further processing.