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The Money Laundering Dangers of Citizenship-By-Investment Schemes
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Ajay Shamdasani speaks to Ken Rijock, a former banking lawyer turned-career money launderer, turned-compliance officer specialising in enhanced due diligence and financial crime consulting.
In this episode, they discuss the anti-money laundering (AML), know-your-customer (KYC) and politically exposed person (PEP) risks associated with citizenship and residency by investment schemes in places such as Malta, Cyprus, Nevis and St. Kitts – with strong interest emanating from places such as mainland China, India, Russia and the Middle East.
(See chapter markers below)
We live in an age where citizenship is seen as a commodity and those of means accumulate multiple passports and residency permits – permanent or otherwise – as contingency plans for themselves, their families, and dependents. To keep their options open, the ideal, most sought-after jurisdictions are those in the developed world with stable societies, rule of law and in general, places that are safe for one’s health, wealth, and personal safety, with passports that are respected in the international community that afford one the greatest degree of visa-free travel.
Yet, citizenship-by-investment schemes could be used as portals for illicit financial flows. National governments are, therefore, finally starting to look into both those that facilitate and partake in such programmes - and the source of their funds.
Shownotes:
00:00 Start
02:16 Citizenship-By-Investment Passports (CBI): Beginnings
05:50 CBI passports and organised crimes – Rijock’s experience
08:36 CBI, compliance, and money laundering regulators
09:30 Geopolitical context of CBI schemes
13:01 The firms at the bedrock of CBI schemes
19:24 The Malta programme and other countries' CBI schemes
22:55 CBI, offshore tax havens, and risks
27:19 Globalization as a driver of CBI
28:02 “Benign neglect” - CBI in Monaco and UAE
28:58 Corruption and “dark money”
34:55 Should the EU cancel its CBI program? The case of Vanuatu
42:40 Old methods of compliance going obsolete
49:21 CBIs, regulations and crypto
57:54 Advantages of being a lawyer in a compliance career
In this episode, they discuss the anti-money laundering (AML), know-your-customer (KYC) and politically exposed person (PEP) risks associated with citizenship and residency by investment schemes in places such as Malta, Cyprus, Nevis and St. Kitts – with strong interest emanating from places such as mainland China, India, Russia and the Middle East.
(See chapter markers below)
We live in an age where citizenship is seen as a commodity and those of means accumulate multiple passports and residency permits – permanent or otherwise – as contingency plans for themselves, their families, and dependents. To keep their options open, the ideal, most sought-after jurisdictions are those in the developed world with stable societies, rule of law and in general, places that are safe for one’s health, wealth, and personal safety, with passports that are respected in the international community that afford one the greatest degree of visa-free travel.
Yet, citizenship-by-investment schemes could be used as portals for illicit financial flows. National governments are, therefore, finally starting to look into both those that facilitate and partake in such programmes - and the source of their funds.
Shownotes:
00:00 Start
02:16 Citizenship-By-Investment Passports (CBI): Beginnings
05:50 CBI passports and organised crimes – Rijock’s experience
08:36 CBI, compliance, and money laundering regulators
09:30 Geopolitical context of CBI schemes
13:01 The firms at the bedrock of CBI schemes
19:24 The Malta programme and other countries' CBI schemes
22:55 CBI, offshore tax havens, and risks
27:19 Globalization as a driver of CBI
28:02 “Benign neglect” - CBI in Monaco and UAE
28:58 Corruption and “dark money”
34:55 Should the EU cancel its CBI program? The case of Vanuatu
42:40 Old methods of compliance going obsolete
49:21 CBIs, regulations and crypto
57:54 Advantages of being a lawyer in a compliance career
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