At the recently concluded 2015 Caribbean Anti-Money Laundering and Financial Crimes

Conference held in Miami, hosted by Compliance Aid for Board of Directors, CEOs and senior

management, Director of the Office of National Drug and Money Laundering Control Policy, Lt.

Col Edward Croft was a guest speaker and presented remarks on the Challenges Posed by

International Investment as Illustrated by Citizenship by Investment Programmes (CIPs). The

conference attracted over 131 leaders from 25 territories from the region.

 

In his presentation Lt. Col. Croft gave a background of the financial environment as it pertains to

AML/CFT regimes in the Caribbean and particularly in Antigua and Barbuda. He explained that

CIPs often act as catalysts for international investment which comes in different forms:

investment in real estate, in the hotel and tourist industry, in startups in various industries like

manufacturing, agriculture etc. He also mentioned the importance of identifying the relevant

novel and unfamiliar AML/CFT factors or issues that need to be taken into consideration with a

particular investment vehicle and then determine what is needed to address them. The

overarching question, he said, is what are their vulnerabilities to money laundering and terrorist

financing, and how does one apply adequate and effective safeguards to mitigate the risks.

 

Director Croft stressed the importance of sharing of information between competent authorities

of Citizenship by Investment Programmes. He highlighted the need to establish links with other

immigrant investor programs both regionally and internationally. In an effort to broadly protect

their reputation and integrity, countries of the region should collaborate to share data on rejected

CIP candidates. Likewise, international investment programs in general would be well advised

to arrange for the sharing of information with their counterparts in other countries to enable the

acquisition of pivotal information on applicants.

 

Director Croft posited several challenges being faced by the Citizenship by Investment

Programmes and suggested several solutions.

 

The Director concluded his remarks by recognizing that while International Investment

Programmes have the ability to attract significant foreign capital, it is the challenge to and

responsibility of investment administrators, board members and government regulators to control

and mitigate the risks involved through carefully implemented AML/CFT systems. Turning a

blind eye to fraud and corruption in the light of substantial inflow of funds by conducting

substandard due diligence may be the greatest risk, which would be a pathway to ultimately

bringing the sector, industry or country into disrepute. The safeguard is the integrity and

leadership of the Boards, Owners and Senior Management of investment organizations, capable

of foreseeing the excellent returns on a good reputation derived from sound practice. The

Director then admonished the participants to adapt a mindset that Success without Integrity is

Failure as they continue to make every effort to attract good, sound investments using proper

and adequate AML/CFT verification of the persons and entities with which they will partner.

Click the following link to read the complete presentation by Lt. Col Croft.

ONDCP – Presentation – Int’l Investment