Multiple Citizenship Identities

Criminals maintain more than one nationality or passport to obscure their true identities and reduce scrutiny when opening financial accounts or conducting cross-border transactions. Leveraging multiple citizenship statuses allows them to bypass or manipulate varied KYC requirements and beneficial ownership regulations across different jurisdictions, making it harder to trace illicit fund sources. While holding multiple citizenships is not inherently illegal, criminals exploit it to present alternative documents—thus creating fragmented account profiles and diminishing the likelihood of consistent, enhanced due diligence. In some cases, these individuals already have dual citizenship through birth or marriage, while others may obtain additional passports using formal or informal means. Criminals can also combine these alternate nationality documents with forged or borrowed identities to open or register bank accounts under different personas, further hampering investigators and reducing the effectiveness of AML controls. They sometimes use layered shell entities across multiple jurisdictions, compounding beneficial ownership obfuscation and making it extremely difficult for authorities to pinpoint the true identity behind illicit transactions. See subtechnique (ID #408) for cases involving citizenship-by-investment routes, where criminals actively purchase new passports or residency to strengthen their ability to evade standard verification checks. When seeking new travel documents from official Citizenship or Residency by Investment (CBI/RBI) programs, launderers mask their criminal background or misrepresent financial resources to meet investment thresholds. Once these programs grant them fresh legal status, they can open accounts or initiate cross-border transfers under new identities with minimal scrutiny. For high-risk applicants, weak vetting requirements in certain jurisdictions can accelerate approvals and undermine global AML efforts. Corruption in the application process can also speed document issuance and ensure anonymity. Additionally, there often are no sufficient procedures to revoke or retrieve passports if a recipient’s risk level changes, allowing criminals continued access to these identities. By strategically selecting passports from jurisdictions with weaker AML regimes or lax disclosure laws, adversaries expand their options for layering transactions, concealing beneficial ownership, and avoiding investigative triggers. Multiple citizenship identities can thus facilitate more seamless cross-border movement of illicit proceeds, exploiting regulatory blind spots and inconsistencies across financial institutions. This poses elevated jurisdictional risk when criminals rely on passports from states where AML enforcement is limited, as well as heightened customer risk due to the resulting complexity in beneficial ownership checks. Cryptocurrency exchange services are especially vulnerable when adversaries rotate between different passports or nationalities to bypass KYC thresholds, while credit and debit cards linked to parallel identities aid in moving value undetected. Operational indicators include a customer shifting passport or nationality details over time, opening accounts in multiple jurisdictions, or utilizing newly acquired citizenship from a recognized offshore center without clear personal or economic rationale. Criminals frequently select programs with minimal or weak vetting requirements, effectively “forum shopping” for jurisdictions whose due diligence standards are lower or inconsistently applied. The European Commission has noted these investment-based schemes as particularly vulnerable to money laundering, tax evasion, and corruption, given that prospective applicants can inject illicit proceeds to secure legitimate documentation. In some instances, corruption within the application process further facilitates quick access to new identity documents, heightening anonymity and mobility. Once approved, limited or nonexistent mechanisms to revoke or physically retrieve the passport can allow criminals to continue using these newly acquired identities undetected, even if their risk profile changes.

[
Code
T0024
]
[
Name
Multiple Citizenship Identities
]
[
Version
1.0
]
[
Parent Technique
]
[
Risk
Customer Risk, Jurisdictional Risk
]
[
Created
2025-02-10
]
[
Modified
2025-04-02
]

Multiple Citizenship

Second Citizenship

Multiple Nationalities

Citizenship by Investment (CBI)

Tactics

By leveraging multiple passports or nationalities, criminals can circumvent KYC and identity verification barriers under different personas, enabling easier access to financial services without triggering standard or enhanced due diligence measures.

Risks

RS0001
|
Customer Risk
|

Criminals exploit multiple passports or nationalities to obscure or fragment their identities, directly undermining KYC and beneficial ownership checks. This is the primary vulnerability, as the technique fundamentally relies on exploiting confusion stemming from customers' complex or deceptive identity claims.

RS0004
|
Jurisdictional Risk
|

Offenders deliberately select passports from, or acquire citizenship in, jurisdictions with weaker AML standards or lax disclosure requirements. This adds a secondary layer of risk by further thwarting cross-border investigative efforts and regulatory scrutiny.

Indicators

IND00141
|

Customer uses different passports or multiple national identification documents when opening bank accounts or registering business entities in separate jurisdictions.

IND00405
|

Customer refuses or fails to disclose known dual nationality status during onboarding or subsequent due diligence.

IND00406
|

A customer recently acquired citizenship in a known offshore financial center or CBI jurisdiction without a clear economic or legitimate personal rationale.

IND00407
|

Customer simultaneously holds multiple passports from countries offering citizenship-by-investment or recognized for corruption, lacking legitimate economic ties to those jurisdictions.

IND00408
|

Frequent cross-border transfers to or from high-risk or secrecy-haven countries using alternate nationality documents or newly acquired passports.

IND01676
|

Frequent updates or alterations in passport or nationality information during periodic reviews or subsequent account activity.

IND01677
|

High-value cross-border transactions initiated under differing identity details—where the document used deviates from the customer’s primary registered identity.

IND01678
|

Establishing accounts or corporate entities in jurisdictions known for lenient KYC/AML standards using alternative citizenship documentation.

IND01679
|

Discrepancies between the nationality declared at onboarding and the identification details provided in later transactions or entity registrations.

IND01682
|

A single individual provides multiple distinct residential addresses correlating with different claimed nationalities, without clear personal or economic basis.

Data Sources

Provides official records of individuals' cross-border movements, enabling the detection of multiple or inconsistent travel documents linked to the same person. Such data helps confirm whether a customer is using varying passports or nationalities for travel, which can signal higher money laundering risk in multi-citizenship identity schemes.

Provides risk insights on specific countries and regions, including their AML/CFT frameworks, corruption indices, and known vulnerabilities in citizenship-by-investment programs. Linking these risk ratings to account openings or transactional activity tied to high-risk jurisdictions helps detect layering schemes involving alternate passports from secrecy havens or jurisdictions with weaker AML enforcement.

Aggregates information from official registries and public sources, including identity details, legal statuses, and historical citizenship data. By cross-referencing these records, financial institutions can validate claimed nationalities, detect newly granted passports, and highlight inconsistencies where a single individual appears under multiple citizenships without legitimate rationale.

Offers specialized checks and authentication for identity documents, detecting inconsistencies or forgeries. This is particularly relevant for identifying individuals who present multiple passports or citizenship documents, verifying if those documents correspond to the same person, and flagging potentially fraudulent multi-citizenship claims.

Includes verified identity documents, personal and business details, addresses, beneficial ownership information, and ongoing risk assessments. By reviewing these records for each customer account, institutions can detect inconsistent nationality declarations, track newly introduced passports or ID documents, and identify undisclosed dual or multiple citizenship usage. This directly helps uncover attempts to evade scrutiny by leveraging different passports or nationalities.

Comprises records of cross-border payments, including transaction details, currencies, involved countries, and counterparties. Reviewing this data alongside identity documents can highlight instances where an individual alternates between different nationalities or passports when directing funds internationally, signaling potential evasion of consistent due diligence controls.

Mitigations

For individuals with multiple passports or known participation in citizenship-by-investment programs, verify passport authenticity directly with issuing authorities. Conduct deeper background checks to confirm the individual's identity, the source of funds used to obtain additional nationality, and any potential criminal or corruption flags unique to their multiple passports.

Require full disclosure of all existing or newly acquired nationalities during onboarding. Verify each passport or ID document for inconsistencies, assessing the customer’s rationale for holding multiple citizenships, especially from high-risk or CBI jurisdictions, to detect misuse of parallel identities or obfuscated beneficial ownership.

Individually screen each declared (or discovered) passport and nationality against relevant sanctions and watchlists. Investigate inconsistent or contradictory identity details, such as mismatched birthdates or unexplained passport origins, to detect possible misuse of multiple citizenships for evasion of scrutiny.

Regularly update and re-verify customers' declared citizenship statuses, flagging any newly presented passports or unexplained changes in nationality. Investigate deviations identified during periodic account reviews or subsequent transactions to ensure that customers do not exploit parallel identities to evade detection over time.

Instruments

  • Criminals use different passports to open separate bank accounts in the same or multiple jurisdictions.
  • Presenting alternate national identities circumvents routine KYC checks that rely on matching personally identifiable information.
  • Illicit proceeds are then distributed across these accounts, masking the ultimate beneficial owner and complicating investigations into consolidated financial activity.
  • By rotating among multiple passports during account creation on exchanges, criminals minimize effective KYC checks.
  • They funnel illicit funds into different exchange accounts under distinct national identities, reducing the risk of flagged consolidated activity.
  • Rapid conversions between fiat and crypto across these separately verified accounts hide transactional origins and beneficiaries.
  • Criminals present alternative citizenship documents to open multiple credit or debit card accounts under different identities.
  • Each card is tied to a separate legal "persona," fragmenting account ownership and bypassing consistent due diligence.
  • This allows layering and swift movement of illicit funds, with transactions on one card seemingly unconnected to another, hindering a consolidated money trail.

Service & Products

  • Criminals misrepresent their background and asset sources to obtain alternate passports or residency, circumventing stricter KYC in other jurisdictions.
  • Once issued new travel documents, they open accounts and move funds internationally under different identities, reducing scrutiny.
  • Weak vetting or corruption in certain programs enables fast-track approvals, ensuring anonymity and undermining AML controls.
  • Criminals use alternate passports to apply for credit cards under multiple identities.
  • Parallel credit lines facilitate swift movement and layering of illicit funds.
  • Discrepancies in identities linked to these cards make transaction monitoring difficult.
  • Criminals rotate between different passports to bypass KYC measures when creating accounts.
  • Allows rapid conversion of illicit funds into cryptocurrencies, further masking source and ownership.
  • The pseudonymous nature of crypto transactions, combined with multiple national identity documents, accelerates layering and hampers AML compliance.
  • Criminals acquire debit cards by presenting alternate nationality documents, enabling funds access under different names.
  • Frequent withdrawals and transfers add complexity to financial tracing efforts.
  • Institutions face difficulty linking transactions to a single true identity.
  • Criminals rely on passports from low-regulation jurisdictions to open offshore accounts with minimal scrutiny.
  • Shifting funds across international boundaries hinders law enforcement’s ability to track beneficial owners.
  • Multiple citizenship identities facilitate account creation and continuous layering of illicit proceeds offshore.
  • Criminals employ multiple citizenship documents to lessen oversight on international fund transfers.
  • Differences in KYC standards among jurisdictions allow them to obscure discrepancies in their documentation.
  • Rapid cross-border movements of value complicate regulatory attempts to trace transactions back to a single individual.
  • Criminals leverage multiple passports to register shell entities in jurisdictions with lax AML oversight.
  • These layered corporate structures obscure true beneficial ownership, complicating investigative efforts.
  • Incorporating entities under different national identities fragments due diligence oversight across jurisdictions.

Actors

Illicit operators exploit multiple citizenships by:

  • Presenting alternative passports or nationalities when opening accounts or transferring funds, which reduces the likelihood of consistent due diligence.
  • Fragmenting their financial footprint across different identities, hindering investigators’ attempts to consolidate beneficial ownership information.
  • Bypassing stricter KYC controls in certain jurisdictions by strategically selecting which passport or identity to present.

Document forgers facilitate this technique by:

  • Producing or altering passports and other ID documents to align with falsely acquired or claimed nationalities.
  • Enabling criminals to create cohesive yet fraudulent identity portfolios that bypass financial institutions' KYC measures.
  • Supplying forged credentials that combine with legitimate passports, further complicating customer identification.

Shell or front companies compound multiple citizenship identity misuse by:

  • Allowing criminals to register corporate entities under alternate nationalities, obscuring the true beneficial owner.
  • Layering these entities across various jurisdictions, making it extraordinarily difficult for investigators to trace ownership.
  • Combining multiple passports with corporate records to further fragment due diligence efforts and benefit from weakened AML controls.

Financial institutions are unwittingly exploited when:

  • Criminals open accounts under different national identities, circumventing consistent KYC checks.
  • Multiple passport details mask the link between separate accounts, undermining beneficial ownership tracing.
  • Varying identity documents reduce the efficacy of transaction monitoring and red flag detection.

References

  1. Wardhana, I. M. W. (2023). The analysis of non-profit organisations in terrorism financing in Indonesia (Doctoral dissertation). Charles Sturt University. https://researchoutput.csu.edu.au/en/publications/the-analysis-of-non-profit-organisations-in-terrorism-financing-i

  2. Pacini, C., Hopwood, W., Young, G., Crain, J. (2018). The role of shell entities in fraud and other financial crimes. Managerial Auditing Journal, Emerald Group Publishing Limited, vol. 34(3), pages 247-267. https://doi.org/10.1108/MAJ-01-2018-1768