Criminals channel illicit funds into real estate or business projects to meet the minimum thresholds and other conditions set by citizenship or residency by investment (CBI/RBI) programs, often misrepresenting these capital injections as legitimate commercial endeavors. By integrating illicit capital into officially sanctioned schemes, they obscure the origin of funds and benefit from an enhanced veneer of legality. In some cases, the real estate or business worth is deliberately inflated, then partially refunded to the investor after the formal requirement is met, disguising the true amount invested. Research indicates that many such CBI/RBI offerings pose elevated risks for international tax evasion and the circumvention of cross-border reporting, a concern underscored by analyses identifying multiple high-risk programs globally. Furthermore, individuals under sanctions have been documented leveraging “golden passport” opportunities to secure second citizenship and cloak illicit proceeds, thereby gaining broader global mobility while bypassing scrutiny.
Investment Through CBI/RBI
Investment Scheme Fraud
Tactics
CBI/RBI investment programs serve as a final laundering stage by embedding criminal proceeds into legitimate overseas ventures, such as real estate or business projects, under officially sanctioned frameworks. This confers an appearance of legality, enabling criminals to formally incorporate illicit assets into the legitimate economy.
Risks
Real estate and business investments are integral to the official CBI/RBI program pathway, enabling criminals to inflate property values or misrepresent investment amounts. Once thresholds are met, partial refunds conceal the true sum of illicit funds introduced. This inherent vulnerability in real estate and business transactions allows for disguising criminal proceeds under legitimate investment vehicles.
Criminals deliberately target CBI/RBI programs in jurisdictions with less robust AML enforcement or lighter oversight. By exploiting these cross-border residency or citizenship frameworks, they obscure illicit fund origins under the pretense of meeting official investment criteria, reducing scrutiny around the source of funds and beneficial ownership.
Indicators
Investment amounts consistently match or slightly exceed the minimum threshold for a particular CBI/RBI program, without accompanying documentation explaining the source of funds.
Sudden large cross-border transfers into real estate or venture funding accounts specifically tied to CBI/RBI projects, with no evident commercial justification.
Customer exhibits limited knowledge about a newly formed business, yet uses it solely to fulfill CBI/RBI minimum investment criteria.
Applicant declines to provide detailed financial records beyond basic investment paperwork required by CBI/RBI authorities, impeding standard due diligence requests.
Investments flow into jurisdictions known for minimal oversight of CBI/RBI programs, with high-value capital transfers from high-risk or non-cooperative countries.
Multiple applicants share the same intermediary or beneficial owner when investing in CBI/RBI-eligible projects, despite having no apparent connection otherwise.
Investment valuations for real estate or business projects appear significantly inflated compared to market rates, followed by partial refunds once CBI/RBI requirements are satisfied.
CBI/RBI applicant or beneficial owner appears on sanctions or PEP lists, indicating a possible attempt to circumvent restrictions via alternate citizenship or residency.
Data Sources
- Catalogs individuals holding high-profile public or political roles, along with their known affiliations and designations.
- Helps identify CBI/RBI investors who are PEPs seeking to potentially bypass enhanced scrutiny or exploit alternate citizenship pathways.
- Aggregates negative news stories, legal proceedings, and official court documents indicating allegations of wrongdoing or illicit activities.
- Reveals past or ongoing legal challenges faced by CBI/RBI applicants, assisting in identifying higher-risk individuals or entities seeking alternate residency or citizenship.
- Consolidates information on AML/CFT regulatory environments, legal frameworks, and enforcement practices across various jurisdictions.
- Supports the identification of high-risk CBI/RBI programs in jurisdictions with minimal oversight and suspicion regarding large cross-border capital transfers from high-risk regions.
- Covers official financial statements, tax returns, and corporate filings that outline an entity’s financial performance and obligations.
- Assists investigators in verifying actual financial capacity and legitimate sources of capital purportedly used to meet CBI/RBI thresholds.
- Official compilations of individuals and entities subject to economic, trade, or financial restrictions issued by governments and international bodies.
- Ensures that applicants or beneficial owners under sanctions are flagged, preventing them from using CBI/RBI programs to circumvent restrictions and launder illicit proceeds.
- Provides comprehensive records of financial transactions, including timestamps, amounts, counterparties, and relevant identifiers.
- Enables detection of suspicious transactions that match or slightly exceed CBI/RBI thresholds, monitoring of partial refunds after thresholds are met, and identification of patterns indicative of layering or concealment of funds.
- Provides data about a business's core operations, revenue streams, and expenses, indicating genuine economic activity or the lack thereof.
- Helps detect shell or newly formed entities set up purely to fulfill minimum CBI/RBI investment criteria without genuine commercial operations.
- Contains verified customer identities, addresses, beneficial ownership details, risk assessments, and evidence of the source of funds.
- Supports identification of incomplete or inconsistent documentation regarding capital injections for CBI/RBI and highlights reluctance to provide comprehensive financial records.
- Contains recorded data on property or high-value asset purchases, transaction values, beneficial owners, and historical sales.
- Enables detection of inflated real estate valuations or suspicious partial refunds once CBI/RBI conditions are satisfied, revealing potential laundering schemes.
- Details transactions routed through correspondent banks or cross-border channels, identifying sending institutions, recipient accounts, and countries of origin/destination.
- Reveals large incoming transfers from high-risk or non-cooperative jurisdictions specifically directed into CBI/RBI-related accounts, supporting scrutiny of unexplained inflows.
- Maintains official or aggregated details on corporate entities, including shareholders, directors, incorporation data, and ownership structures.
- Assists in detecting instances where multiple CBI/RBI applicants share the same intermediary or beneficial owner, indicating potential collusion or hidden relationships.
Mitigations
Categorize jurisdictions known for lax oversight or elevated corruption indices where CBI/RBI programs may enable illicit fund integration. Apply enhanced scrutiny to applicants involved in these high-risk locales, ensuring heightened verification and monitoring to detect money laundering disguised as legitimate investment.
Implement specialized due diligence measures for high-risk CBI/RBI applicants by:
- Verifying the declared source of funds with independent documentation.
- Analyzing real estate or business investments for inflated valuations.
- Confirming that capital transfers align with legitimate personal or corporate wealth.
These measures help unmask hidden beneficial owners, detect partial refunds, and ensure investments are not disguised channels for illicit proceeds.
Establish targeted alerts for inbound cross-border transfers that meet or slightly exceed CBI/RBI thresholds. Monitor for partial refunds following official program requirements and investigate high-risk jurisdictions or unexplained surges in account inflows. Escalate anomalies that indicate deliberate misuse of CBI/RBI schemes for money laundering.
Screen all prospective CBI/RBI applicants and associated beneficial owners against relevant sanctions and watchlists to identify individuals attempting to evade restrictions through second citizenship or residency. Investigate any matches thoroughly before proceeding to ensure compliance with international sanctions requirements.
Use escrow accounts to hold inbound CBI/RBI investment capital until thorough verification of the source of funds, accurate property or business valuation, and compliance with program requirements is complete. Release funds only when no evidence of inflated valuations, partial refunds, or other suspicious activity is found.
Conduct external source checks on CBI/RBI investment claims, including market comparisons of real estate prices, verification of business structures, and review of media or other public records. Identify discrepancies in quoted valuations or beneficial ownership data to detect inflated investments or concealed ownership typically exploited under CBI/RBI programs.
Instruments
- Criminals meet CBI/RBI thresholds by purchasing property, falsely presenting illicit funds as legitimate investment capital.
- Property values are deliberately inflated; after qualifying for residency or citizenship, the excess amount is secretly returned to the perpetrator, concealing the true sum of illicit funds introduced.
- This official "real estate investment" masks suspicious capital behind a lawful home purchase or development project, reducing scrutiny of the transaction source.
- Criminals set up or invest in businesses solely to fulfill CBI/RBI program requirements, labeling illicit funds as share capital or corporate injections.
- Once thresholds are satisfied, a portion of the nominal “investment” can be funneled back to the criminal, hiding the illicit origin of the capital.
- Because CBI/RBI authorities officially validate the business investment, it confers a veneer of legitimacy on otherwise tainted funds.
Service & Products
- Enables introduction of illicit funds into officially sanctioned investment pathways, allowing criminals to present suspect capital as legally sourced.
- Some applicants seek new citizenship or residency to evade sanctions or heighten anonymity, bypassing AML scrutiny by obscuring their true identities and fund origins.
- Criminals can channel illicit funds into real estate purchases that formally qualify for CBI/RBI thresholds, making the funds appear legitimate.
- Property values may be artificially inflated and partially refunded after meeting required investment criteria, concealing the true amount of illicit capital introduced.
Actors
They facilitate property transactions that meet CBI/RBI requirements by:
- Handling sales that may involve artificially inflated property values.
- Coordinating closings or paperwork that can disguise true investment amounts, potentially overlooking red flags related to the origins of funds.
These entities receive illicit capital presented as foreign investment by:
- Allowing criminals to set up or invest in commercial projects that fulfill CBI/RBI thresholds.
- Offering a veneer of legitimate business operations, masking true ownership and source of funds.
They inject illicit funds into real estate or business ventures under CBI/RBI programs by:
- Misrepresenting capital as legitimate to fulfill minimum investment thresholds.
- Exploiting official pathways to gain legitimacy for suspicious funds, hindering financial institutions' ability to trace the real source.
They leverage CBI/RBI programs to evade restrictions by:
- Securing alternate passports or residencies to bypass sanctions screening.
- Obscuring their identity and financial footprint, enabling further movement of illicit proceeds across borders.
They exploit CBI/RBI opportunities to:
- Conceal funds offshore and evade cross-border tax reporting.
- Legitimize undisclosed income through official investment pathways, complicating financial institutions' efforts to identify true tax liabilities.
References
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
Gudzowska, J., Lockhart, E., Keatinge, T. (2024). Disabling the enablers of sanctions circumvention. RUSI's Centre for Finance and Security. https://www.rusi.org/explore-our-research/publications/policy-briefs/disabling-enablers-sanctions-circumvention