Regulatory Ramblings

The Money Laundering Dangers of Citizenship-By-Investment Schemes

February 22, 2023 Reg/Tech Lab - HKU FinTech - HKU-SCF FinTech Academy Episode 14
Regulatory Ramblings
The Money Laundering Dangers of Citizenship-By-Investment Schemes
Show Notes Chapter Markers

Ajay Shamdasani speaks to Ken Rijock, a former banking lawyer turned-career money launderer, turned-compliance officer specialising in enhanced due diligence and financial crime consulting.

In this episode, they discuss the anti-money laundering (AML), know-your-customer (KYC) and politically exposed person (PEP) risks associated with citizenship and residency by investment schemes in places such as Malta, Cyprus, Nevis and St. Kitts – with strong interest emanating from places such as mainland China, India, Russia and the Middle East.

In an age where citizenship is seen as a commodity, those of means accumulate multiple passports and residency permits – permanent or otherwise – as contingency plans for themselves, their families, and dependents. To keep their options open, the ideal, most sought-after jurisdictions are those in the developed world with stable societies, rule of law and in general, places that are safe for one’s health, wealth, and personal safety, with passports that are respected in the international community that afford one the greatest degree of visa-free travel.

Yet, citizenship-by-investment schemes could be used as portals for illicit financial flows. National governments are, therefore, finally starting to look into both those that facilitate and partake in such programmes - and the source of their funds.

Ken regularly posts to his financial crime blog ( His exploits are recounted in the book The Laundry Man, which he authored.

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Citizenship-By-Investment (CBI) schemes: Beginnings
CBI passports and organised crimes – Rijock’s experience
CBI schemes, compliance, and money laundering regulators
Geopolitical context of CBI schemes
The firms at the bedrock of CBI schemes
The Malta programme and other countries' CBI schemes
CBI, offshore tax havens, and risks
Globalization as a driver of CBI
“Benign neglect” - CBI in Monaco and UAE
Corruption and “dark money”
Should the EU cancel its CBI programme? The case of Vanuatu
Old methods of compliance going obsolete
CBIs, regulations and crypto
Advantages of being a lawyer in a compliance career