If that is more then what is less?

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You would have seen the headline that read, “CIP agents warned to be wary of Chinese with baggage”.  It was in reference to the warning issued by a top executive of an international due diligence firm to agents of the Citizenship by Investment Programme (CIP).  On the surface, the warning is logical but when you look into the details, the warning is logical; more to the point, it is obvious.
To understand what we mean, let’s look deeper in to what the Vice Chairman and Global Head of Immigration Citizenship and Visa (ICV) Practice at Exiger Diligence, Mr. Kim Marsh, had to say.  As he reminded agents that the Government’s largest market for citizenship, China, is “cracking down on corruption” he said, “There’s a lot of PEP’s [Politically Exposed Persons] on the run coming out of China now … more thought has to be given as to how we are going to analyse these individuals.”
That is an interesting comment because when Mr. Marsh gave greater detail on what “more” represented, we were a bit shocked.  But before we inject bias into your evaluation, let’s hear about the “more” from him.  Mr. Marsh advised agents and due diligence providers to ask themselves, “How influential was that individual?”  He added, “How far up the pecking order were they and how did they acquire their wealth?  Did they have legitimate businesses or were they a government employee and got their wealth through envelopes stuffed with cash?”
Now, maybe it is us, but are these not standard questions?  Has our due diligence process been ignoring or omitting these basic questions when vetting individuals who are possible recipients of our citizenship and travel the world on our cherished passport?  We have always been concerned about the level of due diligence in our CIP but have been assured that we execute the most demanding due diligence process of any programme in the world.  Now we find out that what we considered basic questions for any applicant are now being thrust to the fore by the due diligence folks.
We get that there is no perfect system in place and that no matter how fool-proof a system claims to be, you may look like a fool one day, but we do not understand how the source of a person’s wealth is not questioned as part of the due diligence process?  A career politician, high in the political pecking order, with no significant outside businesses should not be declaring a multi-million dollar fortune.   As a matter of fact, we would consider an application by any career politician to be suspect simply because they should love their country above all others and should not be seeking to travel with the passport of another.
Patriotic naivety?  Yes!  Absolutely!  But that is the world in which we live (sometimes).   It would be the first alarm bell to sound in our head.  Next, of course, would be the size of the fortune.  After all, who gets rich being a career politician?  Wait, a minute?!?  Did we really just ask that question?  We know you probably just yelled “What are you talking about?!?!” at the paper or screen.  Sorry, it was just another naive moment on our part.
Really, though, isn’t Mr. Marsh’s warning regarding giving “more thought” towards analysing these individuals a bit obvious?  And we are not just talking the Chinese?  Or the Russians … or, or, or …? These should be basic areas of investigation and questioning that pretty much everyone should be subjected to.
Mr. Marsh made reference to the St. Kitts & Nevis situation where our neighbours to the west have been accused of harbouring a Chinese fugitive by the name of Ren Bia.  That gentleman is accused of swindling over US $100 million from a Chinese state firm.  Be that as it may, Mr. Marsh doesn’t believe that St. Kitts & Nevis can be criticized because other nations have had similar experiences.  According to him, St. Kitts & Nevis “can demonstrate they have a proper process in place and they did what was required.”   Oh really?  Somehow, we think that Mr. Marsh may have picked up on some of our naivety when he was being interviewed.
We doubt that our big brother to the north, the United States of America, will be willing to accept that excuse – neither will the Chinese.  It makes no difference that the United States operate a ‘fast-track-to-citizenship-visa-program’ that is mired in fraud, corruption and scandals; they will point their long hypocritical fingers in this direction and say “Bad St. Kitts & Nevis” and the repercussions from that alone will be enough.
We accept that the CIP is here to stay but we are asking, whoever needs to be asked, please put a due diligence process in place that does more than ask “will that be cash or charge?”  Yes, we are being simplistic and sarcastic, so put down that pitcher of Kool-Aid before you hurt someone.

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