The Cable

BASSETERRE, ST. KITTS (PRESS SEC) – At his monthly press conference on Wednesday, May 10th, 2017, Prime Minister Dr. the Honourable Timothy Harris spoke of the multiple layers of due diligence that go into ensuring the credibility of applicants – as well as the source and legitimacy of their funds – received through the Citizenship by Investment (CBI) Program.

"We have always said and we continue to reiterate that our CBI under the Team Unity Government is only open to legitimate persons to participate.  For us, it is an honour and a privilege for anyone to be able to become a citizen of St. Kitts and Nevis and we want the most worthy of personalities from around the world to come and help us build a greater St. Kitts and Nevis than we now have," Prime Minister Harris said.

"Clearly, those who are tainted in any way, as a result of criminal activities, cannot be part of that forward thrust of making our program the platinum standard," the Prime Minister of St. Kitts and Nevis added.

The Honourable Prime Minister noted that IPSA International, a regulatory risk mitigation company, has completed a comprehensive overhaul of the Citizenship by Investment Program, transforming the modus operandi that prevailed under the previous Douglas administration.

"That mode of operation created a FinCEN advisory in May 2014, about which we are still dealing," Prime Minister Harris said, adding: "The FinCEN [the U.S. Treasury Department's Financial Crimes Enforcement Network] did say in their report that 'illicit actors' were participating in the program under the Denzil Douglas administration, and so that evidence was with them.  We [the Team Unity Government] said that we were determined to bring a new order."

The Prime Minister of St. Kitts and Nevis said this new order has resulted in:

- improvement in the controls of the program.

- a "look back" of applicants who were approved for citizenship over the last eight years, as well as in subsequent remedial action where "some of them have turned out to be bad," Prime Minister Harris said, noting that in those instances steps were taken "to ensure that they no longer could use our passport."

- new management, to include a new head of the Citizenship by Investment Unit (CIU) in the person of Mr. Les Khan.  Mr. Khan, the CEO of the CIU, was IPSA International's Project Team Leader for St. Kitts and Nevis who led the restructuring of the unit during the consultancy.

- additional members of staff at the CIU who have high-level expertise in administration, anti-money laundering/counter-terrorist financing (AML/CFT) preventive measures, immigration, international banking and marketing. 

- the introduction of a 24/7 case management system that allows for round-the-clock, real-time monitoring of the status of CBI applications.

- the employment of additional due diligence providers with specialist knowledge of particular countries and regions.                

- increased international partnerships with friendly governments, such as the United States of America, and agencies, such as the International Monetary Fund (IMF).  Coming out of the Article IV Mission to St. Kitts and Nevis held between April 18th and May 3rd, 2017, the IMF observed that, "They [the St. Kitts-Nevis authorities] have strengthened the due diligence process with dedicated resources and global collaboration..." 

- increased collaboration with CARICOM's Implementing Agency for Crime and Security (IMPACS) and one of its sub-agencies called the Joint Regional Communications Centre (JRCC). 

"We are ensuring [collaboration with] the JRCC and other regional bodies that relate with INTERPOL, that relate with the CIA [and] that relate with all the law enforcement bodies, so that we bring to bear a body of information in the analysis beyond what would normally be available to the commercial providers of due diligence support," Prime Minister Harris said at Wednesday's press conference.

"We have then a multi-layered program of due diligence that makes it one of the most robust within the region, and we hope by so doing to be able to contain – if not avoid – instances of the past from reoccurring," Dr. Harris also said.

The Prime Minister of St. Kitts and Nevis further stated that this multi-layered program of due diligence looks at a number of variables, including whether an applicant is from a high-risk country, for example, a country that has been described as a state sponsor of terrorism.

"We do a broad check of media and of criminal databases, sanctions lists and so on and so on, and make a determination whether there are serious or pending legal, regulatory or political matters that would require consideration," Prime Minister Harris said.

The Prime Minister of St. Kitts and Nevis also said: "It is a broad list...and then, depending on where persons fit, another set of questions may have to be answered for that person to move on in the process.  So it is a very involved process, and basically the risk matrix would help to determine what one does in relation to this matter." 

Dr. Harris continued: "To be sure, we have been very satisfied about the extent of our due diligence process...It is an ongoing exercise of review.  It is an ongoing exercise of collaboration.  It is an ongoing exercise of ensuring that we are aware of best practices." 

 

 

 

 

 

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