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Misuse of Citizenship and Residency by Investment Programmes – listen and read.


Each year, tens of thousands of people worldwide become new citizens or permanent residents of countries where they were not born by investing in those countries.

Listen to a podcast with Tivon Sterin and Graham Peachey about the recent FATF-OECD REPORT ON the MISUSE OF CITIZENSHIP AND RESIDENCY BY INVESTMENT PROGRAMMES and learn more about how these programs can also be abused by criminals who seek to launder and conceal proceeds of crime or commit new offences, including financial crimes.



Citizenship and residency by investment (CBI/RBI) programmes are government-administered programmes that grant citizenship or residency to foreign investors by expediting or bypassing normal migration processes.

These programmes can help spur economic growth through foreign direct investment, but they are also attractive to criminals and corrupt officials seeking to evade justice and launder the proceeds of crime, amounting to billions of dollars.

In response to the FATF Ministers’ call in April 2022 for greater focus on corruption, the FATF completed a joint project with the Organisation for Economic Co-operation and Development (OECD) that explores the money laundering and financial crime risks associated with CBI/RBI programmes, including risks related to foreign bribery, fraud and corruption, and their impact on public integrity, tax and migration.

FATF President T. Raja Kumar said.

  • “Granting citizenship and residency to wealthy investors through 'golden' passport and visa programmes can potentially lead to economic growth. But they can and are being exploited by criminals and the corrupt, who want to launder their money, hide their identity and assets, or commit further crimes. This report calls on governments operating these programmes to implement various safeguards to ensure these programmes are administered risk-sensitively”

  • ”Criminal exploitation of citizenship and residency programmes is a multi-billion-dollar business to launder the proceeds of fraud and corruption, evade justice, or access third countries. Our joint FATF-OECD work identifies the risks and vulnerabilities around golden visa schemes and offers a series of mitigation measures to help policy makers and programme operators including appropriate due diligence, transparency, and integrity mechanisms,”

The report highlights

  • How can CBI programmes allow criminals more global mobility and help them hide their identity and criminal activities behind shell companies in other jurisdictions?
  • The vulnerabilities of these complex and international investment migration programmes include the frequent use of intermediaries, involvement of multiple government agencies, abuse by professional enablers, and lack of proper governance of the CBI/RBI programmes.

The report

  • Proposes measures and cites examples of good practices that can help policymakers and those responsible for managing the investment migration programmes to address these risks.
  • Provides an in-depth analysis and understanding of how criminals can exploit CBI or RBI programmes.
  • Advises on how Governments can incorporate risk mitigation measures, such as multi-layered due diligence, in the design of their investment migration programmes.
  • Highlights elevated risks of money laundering and financial crime in these investment migration programmes relates not only to the applicant, but also the professional enablers and intermediaries involved in the process.

It is therefore essential to ensure clarity around the respective roles and responsibilities of the various parties involved in RBI/CBI programmes to be able to detect fraudulent activity.


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