CBI or RBI-Based Identity Acquisition

Criminals obtain new passports or residency permits through official Citizenship or Residency by Investment (CBI/RBI) programs, often using falsified backgrounds or undisclosed criminal proceeds to satisfy investment requirements. With freshly granted nationality or legal status, they face diminished scrutiny when opening accounts or initiating cross-border transfers. This additional identity can also reduce triggers for enhanced due diligence, allowing launderers to move illicit funds more freely between jurisdictions. By obscuring their original citizenship, criminals exploit regulatory blind spots and undermine consistent monitoring attempts by financial institutions. 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
T0024.001
]
[
Name
CBI or RBI-Based Identity Acquisition
]
[
Version
1.0
]
[
Risk
Customer Risk, Jurisdictional Risk
]
[
Created
2025-02-27
]
[
Modified
2025-04-02
]

Citizenship-by-Investment (CBI)

Golden Visa

Residency-by-Investment (RBI)

Golden Passport

Citizenship and Residency Programme Exploitation

Tactics

By acquiring new passports or residencies through CBI/RBI programs, criminals can explicitly circumvent stricter KYC checks tied to their true backgrounds. Presenting ostensibly legitimate documentation lowers scrutiny when opening accounts or transacting across borders, thereby streamlining entry into financial systems under an alternate legal identity.

Risks

RS0001
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Customer Risk
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Criminals exploit newly acquired passports or residencies to present themselves as legitimate customers with apparently clean backgrounds, circumventing enhanced due diligence checks tied to their real identities. By using CBI/RBI documentation, they obscure past offenses, the illicit origins of funds, or PEP status, thereby reducing scrutiny and increasing the likelihood that financial institutions will onboard them as low-risk customers.

RS0004
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Jurisdictional Risk
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CBI/RBI schemes often operate in countries with limited oversight or weak AML enforcement, enabling criminals to "forum shop" for jurisdictions where scrutiny of applicants' backgrounds and sources of funds is minimal. By securing official documents from such jurisdictions, launderers further exploit cross-border anonymity and regulatory gaps to move illicit wealth undetected.

Indicators

IND00831
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Frequent applications for citizenship or residency in multiple countries with Citizenship-by-Investment programs.

IND00832
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Investments in Citizenship-by-Investment programs disproportionate to the individual's known legitimate income or wealth.

IND00833
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Lack of transparency or reluctance to provide information about the source of funds used for investment in Citizenship-by-Investment programs.

IND00834
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Frequent cross-border transfers to jurisdictions known for offering Citizenship-by-Investment programs.

IND01680
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Use of complex corporate structures or trusts to make investments in Citizenship-by-Investment programs.

IND01681
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Involvement of unlicensed or non-accredited third-party intermediaries or agents in the application process for Citizenship-by-Investment programs, with unclear fee structures or services.

IND01683
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Rapid movement of funds through accounts in jurisdictions offering Citizenship-by-Investment programs.

IND01684
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Sudden or unexplained accumulation of wealth shortly before applying for Citizenship-by-Investment programs.

IND01685
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Applications for citizenship or residency through investment from jurisdictions with high levels of financial secrecy or known money laundering risks.

IND01686
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Applicants with complex or opaque ownership structures in their investment portfolio.

IND01687
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Frequent changes in the applicant's declared source of wealth or source of funds during the application process.

IND01688
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Investments made in real estate or businesses that are inconsistent with the applicant's known profile or economic activity.

IND01689
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Applicants with a history of legal issues, sanctions, or being associated with politically exposed persons (PEPs).

IND01690
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Sudden and unexplained liquidation of assets or transfer of funds from one jurisdiction to another coinciding with the application for a golden passport.

IND01691
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Applicants who maintain multiple citizenships or residency statuses without a clear economic or personal rationale.

IND01692
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Unusually high fees or commissions paid to agents or intermediaries facilitating the citizenship or residency application.

IND01693
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Use of intermediaries or third parties to mask the true identity of the applicant or source of funds.

IND01694
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Discrepancies between the applicant's declared income and their lifestyle or investment behavior.

IND01695
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Indications of forged or altered documentation in the applicant’s background, identity, or financial records submitted for the CBI program.

IND01696
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Payments or transfers made directly to officials or government staff involved in the CBI process that exceed official program fees or have no clear explanation, suggesting potential bribery or corruption.

Data Sources

Provides directories of individuals occupying prominent public roles, their close associates, and known affiliations. Screening applicants against these lists:

  • Identifies high-risk or politically connected individuals seeking CBI/RBI.
  • Facilitates enhanced due diligence for potentially corrupt or sanctioned officials.

Ensures financial institutions can detect and properly manage higher-risk applications that may exploit citizenship/residency programs for illicit gain.

  • Aggregates negative news, publicly reported legal actions, lawsuits, and criminal proceedings involving individuals or entities.
  • Directly aids in detecting applicants with histories of sanctions, fraud, or corruption seeking CBI/RBI to evade scrutiny.
  • Enables AML professionals to assess reputational and legal risks tied to individuals who may exploit citizenship or residency programs to launder illicit proceeds.
  • Consolidated information on AML/CFT regulations, enforcement practices, and risk ratings by country or jurisdiction.
  • Directly helps flag applications for citizenship/residency originating from or targeting high-risk or secrecy-prone jurisdictions.
  • Supports AML detection efforts by correlating the applicant’s geographical background or investment targets with known risk factors in CBI/RBI programs.
  • Collects publicly accessible data from websites, social media, and news reports to verify the legitimacy of individuals and agents.
  • Uncovers unlicensed intermediaries or suspicious practices in CBI/RBI applications, including inflated fees or questionable accreditation.
  • Supports AML detection by revealing the presence of fraudulent or non-compliant advisors and identifying red flags in applicant backgrounds.
  • Contains official compilations of sanctioned individuals, entities, and jurisdictions subject to financial restrictions.
  • In CBI/RBI contexts, screening applicants and their associated entities against these lists helps detect potentially sanctioned parties attempting to gain new legal status under false pretenses.
  • Facilitates AML detection by preventing criminals on sanctions lists from bypassing controls through alternate citizenship or residency.
  • Captures all financial activity within accounts, including timestamps, amounts, counterparties, and transaction channels.
  • In the context of CBI/RBI, these logs reveal sudden inflows or rapid movement of funds coinciding with golden passport applications, unusually high commissions to agents, or direct payments to officials.
  • Enables AML analysts to detect and investigate suspicious payment flows, asset liquidations, and potential bribery or corruption tied to citizenship or residency programs.
  • Validates passports, residency permits, and other official documents to check for forgeries, alterations, or tampering.
  • Directly supports investigations into false identities or misrepresented personal histories submitted for CBI/RBI applications.
  • Ensures institutions can authenticate documents and detect potential fraudulent background information used to obtain a second citizenship or residency status.
  • Provides verified identity details, beneficial ownership information, transaction summaries, risk ratings, and financial background data for each customer.
  • In the context of CBI/RBI applications, this information helps detect discrepancies in declared wealth, identify multiple or conflicting identity documents, and flag sudden changes in financial profiles.
  • Directly supports AML detection by revealing whether investments for citizenship/residency are sourced from illicit funds or inconsistent with the applicant’s stated profile.
  • Tracks ownership and transfers of real property and other high-value assets, including purchase dates, prices, and involved parties.
  • For CBI/RBI applicants, helps identify significant asset acquisitions used to meet minimum investment thresholds, potentially funded by illicit proceeds.
  • Supports AML detection by comparing declared financial profiles against large-scale property or luxury asset purchases indicative of money laundering attempts.
  • Contains records of international wire transfers, including sending/receiving banks, jurisdictions, amounts, and timestamps.
  • Directly helps identify patterns of cross-border funds movement into jurisdictions offering CBI/RBI.
  • Supports investigations by revealing high-risk corridors or unusually large inbound transfers that may indicate illicit funds being deployed to secure new residency or citizenship status.
  • Provides official records of corporate registration, shareholders, directors, and ownership structures.
  • Directly aids in identifying shell companies, opaque corporate vehicles, or trusts used to conceal the true source of investment funds for CBI/RBI programs.
  • Supports AML detection by verifying whether complex entities are being used to mask beneficial owners or bypass scrutiny in the citizenship or residency application process.

Mitigations

Incorporate Citizenship-by-Investment (CBI) or Residency-by-Investment (RBI) jurisdictions into the institution’s country risk framework by assigning higher risk ratings to those with weak vetting processes or documented corruption in their investment-based citizenship schemes. This approach ensures more rigorous review and verification measures for applicants from, or claiming, these jurisdictions.

Verify passports or residency permits from investment-based programs by cross-checking with official government sources or accredited third-party databases. Examine the authenticity of the documents, the applicant’s background, and the source of invested funds for any undisclosed criminal origins. Compile results in a comprehensive risk profile to ensure heightened transparency and scrutiny for CBI/RBI customers.

Evaluate and monitor agents, legal advisors, or brokers who facilitate CBI/RBI applications for potential complicity in money laundering. Confirm their licensing or accreditation status, assess fee structures, and review any history of unethical behavior or red flags in prior citizenship transactions.

Establish specialized risk segments for individuals with newly acquired citizenship or residency through investment-based programs. Adjust ongoing transaction monitoring and alert thresholds to detect deviations from the expected profile, addressing the increased risk of concealed criminal backgrounds or laundered funds.

Leverage open-source intelligence and external databases to verify the applicant’s history, identify negative reporting about specific CBI/RBI programs, and detect discrepancies in personal details. Investigate publicly reported allegations of corruption or fraudulent identity acquisition connected to these programs before onboarding or extending services.

Continuously re-verify the legitimacy of the customer's CBI/RBI status, monitoring for new information that could indicate undisclosed criminal proceeds or corruption. Escalate accounts for enhanced scrutiny if subsequent background checks reveal changing risk factors or attempts to obscure true identity or source of funds.

Instruments

  • Criminals open new bank accounts using newly acquired CBI/RBI identities, depositing illicit funds while representing them as legitimate personal or business assets to meet investment requirements.
  • Once a new passport or residency status is granted, these accounts bypass the heightened scrutiny associated with the launderer's actual background, enabling cross-border transfers with reduced due diligence.
IN0013
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  • CBI/RBI programs often require or encourage real estate investments; criminals inject illicit funds into property purchases to qualify.
  • By claiming legitimate investment activity, they disguise the funds’ illegal origin, securing citizenship or residency. Once approved, the property can be sold or further used under the new identity, raising fewer red flags.
IN0019
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  • Some CBI/RBI schemes permit investment in government or corporate bonds; criminals purchase these with illicit capital portrayed as legitimate wealth.
  • Obtaining a new passport or residency status minimizes subsequent scrutiny regarding sources of funds, making future transactions appear legitimate under a newly established identity.
  • Criminals place illicit funds into local business equity to satisfy CBI/RBI investment criteria, misrepresenting themselves as lawful investors.
  • This enables them to acquire official documentation and conduct future business or financial activities under the new identity, circumventing red flags associated with their original background.

Service & Products

  • Criminals inject illicit proceeds into qualifying investments (e.g., real estate or government funds), obtaining legitimate passports or residency permits that reduce AML scrutiny.
  • They often hide or falsify their background and the origin of funds, exploiting weak due diligence standards to secure official documentation under a new identity.
  • Once the new identity is established, criminals avoid enhanced due diligence triggers associated with their real profiles, facilitating cross-border fund movement.

Actors

Illicit operators apply for CBI or RBI programs using concealed or criminally sourced funds to meet investment requirements. By acquiring a new legal identity, they evade enhanced due diligence linked to their actual backgrounds and move illicit capital under largely unexamined credentials, complicating financial institutions' efforts to identify or monitor suspicious activity.

Document forgers provide falsified or altered personal, financial, or background records to support CBI or RBI applications. This deception allows criminals to conceal illicit sources of wealth and prior offenses, undermining financial institutions' KYC and due diligence processes that depend on authentic identification documents.

AT0072
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Tax evaders exploit CBI (Citizenship by Investment) or RBI (Residency by Investment) programs by injecting undeclared or illicit funds into qualifying investments, thereby acquiring new legal status that obscures their original tax residency. This tactic hinders financial institutions from linking financial activities to existing tax obligations, facilitating cross-border tax evasion and laundering.

Corrupt public officials overseeing CBI or RBI applications may accept bribes, expedite approvals, or ignore discrepancies in an applicant’s background. Their involvement reduces the efficacy of government vetting, allowing launderers to obtain citizenship or residency with minimal scrutiny and compromising financial institutions' reliance on official documentation.

References

  1. Financial Action Task Force (FATF) & Organisation for Economic Co-operation and Development (OECD). (2023). Misuse of citizenship and residency by investment programmes - A joint FATF/OECD report. FATF/OECD. https://doi.org/10.1787/ae7ce5fb-en

  2. Financial Crimes Enforcement Network (FinCEN). (2014). Passports obtained through St. Kitts and Nevis Citizenship-by-Investment Program used to facilitate financial crime. FinCEN. https://www.fincen.gov/sites/default/files/advisory/FIN-2014-A004.pdf

  3. Isolauri, E. A., Ameer, I. (2023). Money laundering as a transnational business phenomenon: A systematic review and future agenda. Critical Perspectives on International Business, Vol. 19 No. 3, pp. 426-468. https://doi.org/10.1108/cpoib-10-2021-0088