Regulatory Alerts2014-05-20 | FinCEN Advisory – FIN-2014-A004Added
Advisory on Abuse of the Citizenship-by-Investment Program Sponsored by the Federation of St. Kitts and Nevis (FinCEN Advisory – FIN-2014-A004)
Financial institutions are advised to conduct risk-based customer due diligence to mitigate the risk that customers are using passports from the St. Kitts and Nevis Citizenship-by-Investment program to disguise their identity and evade sanctions. The program allows citizenship for investments of at least $400,000 USD in designated real estate or a $250,000 USD contribution to the St. Kitts and Nevis Sugar Industry Diversification Foundation. If a financial institution suspects a transaction involves illegal activity or sanctions evasion, it may be required to file a Suspicious Activity Report, which must include the term “SKN Passport” in the narrative and applicable fields.