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https://amlcft.bnm.gov.my/circulars-technical-notes

We would like to share with you on emerging risks associated with Citizenship and Residency by Investment (CBI/RBI) programs, often referred to as 'Golden Passport'.

CBI/RBI programs enable individuals to obtain citizenship or residency status by making substantial investments in a country's economy. Originally designed to aid economic diversification in less privileged nations, these schemes are increasingly being exploited by illicit actors for financial crimes such as corruption, tax evasion, money laundering, and fraud. The threats posed by these schemes can be categorized into three main areas:

1. Criminal Actors: These individuals exploit various residency and citizenship programs to engage in extensive criminal activities while evading law enforcement.
2. Investment Migration Ecosystem Participants: Service providers, including immigration and migration agents, accountants, and wealth managers, may misuse funds to launder money.
3. Corrupt Public Officials: These individuals may exploit the programs for personal gain or illicit profit.

The Organisation for Economic Co-operation and Development (OECD) has identified 25 programs across 15 countries offering residence and citizenship by investment options, or so-called 'golden passport' schemes, used to conceal assets from reporting under the Common Reporting Standard (CRS).
These countries include:

1. Antigua and Barbuda
2. Bahamas
3. Bahrain
4. Barbados
5. Cyprus
6. Dominica
7. Grenada
8. Malta
9. Saint Kitts and Nevis
10. Saint Lucia
11. Seychelles
12. Turks and Caicos Islands
13. United Arab Emirates
14. Vanuatu
15. Panama.

Note: The list above reflects the current state of the OECD’s analysis of CBI/RBI schemes and will be updated on an ongoing basis. For more detailed information, please refer to the OECD website: OECD CBI/RBI.
 
Recommended Actions for Reporting Institutions (RIs):

1. Review customers claiming residence or citizenship in jurisdictions offering potentially high-risk CBI/RBI schemes.
2. If any suspicions are triggered, promptly file a Suspicious Transaction Report. Consider using keywords such as 'Golden Passport' or 'Dual Nationality' in the report's keyword field.

Additional Resources:

1. The Straits Times: Golden Passport - A Plan B for the Rich, a Rear Exit, and Safe Haven for Crooks
2. Forbes: CBI/RBI Schemes - Opportunities, Risks, and the Need for AML Compliance

We urge you to remain vigilant and proactive in addressing these emerging risks.