金融行动特别工作组-投资方案滥用公民身份和居留权（英）-2023.11-62页_2mb

Summary of "Misuse of Citizenship and Residency by Investment Programmes" (FATF/OECD Joint Report)

Introduction and Overview

• Citizenship and Residency by Investment (CBI/RBI) programs allow individuals to obtain citizenship or residency by making specified investments in host countries.
• These programs benefit both governments (via economic growth) and wealthy individuals (via faster migration processes).
• However, they are vulnerable to abuse for money laundering, fraud, corruption, and tax evasion, posing significant risks.

Money Laundering Threats and Vulnerabilities

• Threat Actors: Criminals, service providers (e.g., agents, financial advisors), and corrupt public officials can exploit CBI/RBI programs.
• Program Vulnerabilities:
  • Enhanced global mobility, ability to open shell companies, and disguising identity.
  • Lack of stringent vetting, weak monitoring, and inadequate due diligence during application processes.
• Challenges: Illicit actors can hide assets, evade law enforcement, and use programs for identity laundering and multiple citizenship purchases.

Other Financial Crime Risks

• Illicit Funds: CBI/RBI abuse is linked to massive fraud and money laundering schemes involving billions.
• Unregulated Money Transmission: Cross-border transfers via informal networks hide criminal proceeds.
• Virtual Assets: CBI/RBI programs are exploited for circumventing regulations in virtual asset services.

Corruption, Integrity, and Tax Risks

• Corruption: Poorly designed/implemented programs (e.g., opaque governance) facilitate bribery and fraud.
• Tax Transparency: CBI/RBI programs risk enabling tax evasion, posing challenges for automatic information exchange via CRS.

Potential Mitigation Measures

• Robust Governance: Clear objectives, integrity measures, designated agencies with authority.
• Multi-layered Vetting: Multi-tier customer due diligence involving licensed agents, government, and financial institutions.
• Continued Monitoring: Periodic checks post-grant, linking CDD with financial intelligence.
• Corrective Actions: Procedures for deactivation/revocation of documents if fraud or abuse is detected.
• Transparency: Public reporting on applications, investments, grants/refusals.
• Strengthened Public-Private Cooperation: Clarity on roles, auditing, and anti-corruption frameworks.

Conclusion

• CBI/RBI programs, if not properly managed, present substantial money laundering, fraud, and corruption risks, particularly in jurisdictions lacking comprehensive mitigation measures.
• Effective risk mitigation relies on whole-of-government approaches, transparent procedures, international cooperation, and adequate resource allocation.

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