When I interact with my peers, as well as clients, they often raise questions about the nature of the due diligence system for the Caribbean investment naturalization program. Below, I would like to answer this question by introducing the context of the due diligence process and the role played by various investigative and intelligence agencies in this process.
Some industry insiders may claim that Caribbean banks play a big role in most investment and naturalization programs: "After all, the government has the only responsibility to formulate and manage laws and discretion".
In this case, why does the bank’s list of “unqualified countries” affect the government’s decision on which countries’ citizens are not eligible (the list of “unqualified countries” consists mainly of sanctioned countries) to apply for naturalization through their investment naturalization program? Perhaps a brief explanation of the operating environment of the Lower Caribbean Bank can provide some ideas.
Bank closure of accounts seen as high risk has become a global trend, which usually belong to NGOs , foreign embassies, agency banks and remittance companies.
, a practice called "risk removal", may be an inevitable reaction in the financial services industry, because in recent years, the prevalence of "anti-money laundering/anti-terrorism financing ", coupled with the financial crisis in 2008, the industry began to rethink its way of defining and managing risks. However, the standards for risk elimination actions remain unclear and agencies lack consistency in their implementation.
However, Caribbean banks, especially East Caribbean countries, were seriously adversely affected, with five of the eight members operating investment naturalization programs. In most cases, there is only one US bank that provides agency banking services in every country. Fears about losing this agency banking relationship and facing an intensified “anti-money laundering/anti-terrorist financing” approach, local banks have become more extreme conservative in accepting and maintaining their clients.
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