The Antigua and Barbuda Citizenship by Investment unit performs a risk based assessment on applications, conducts multi layer due diligence checks work in close coordination with other security agencies and internationally renowned due diligence firms, before approving investors under the CIP program.
Below you will have some basic understanding on the scrutiny done by government and third party due diligence firms.
CIU Compliance Department
The Compliance Department of Antigua and Barbuda’s Citizenship by Investment Unit conducts a four-tier due diligence review of all its applicants and associated businesses.
KYC/Basic
Licensed Agents perform basic Know your customer and request initial background checks based on sanctions, PEP, blacklist, news and media, wanted persons list . Ascertaining the applicant’s general good character and absence of a criminal record, absence of visa refusals from partner countries under visa waiver program and determining the source of funds
Tier 1 Checks
Tier one of the review process involves using Thomson Reuters World Check, INTERPOL
Most Wanted list, FBI Most Wanted Terrorist List, and the United Nations Al-Qaeda
Sanctions List to scan the name of the main applicant and any businesses the applicant
may be associated with. Internet searches are also conducted using search engines
such as Google and KYC360.com and the social media network, LinkedIn. These
searches are conducted with a view to ascertaining additional credible information on
the principal applicant, associated family members and associated businesses.
Tier 2 Check
Tier two involves the use of third party due diligence service providers to conduct
background due diligence on the principal applicant and associated family members.
These services, provided by independent private sector companies, cover the
applicant’s entire known public footprint. Typically, the service provider has a physical
presence in all countries where the applicant has spent a significant period. The focus
is of course on the applicant’s stated place of residence.
Tier 3 Check
Tier three involves submitting the applicants’ names and other pertinent information
to regional and international governmental partners. Tier four involves summarising the
findings of the due diligence review and making a recommendation to senior management.
Tier 4 Check
Banks in Antigua do compliance checks verifying the source of funds to protect correspondent bank relationships with US partners.
Tier 5 Check
Authorities continue to monitor citizenship holders post granting citizenship. Any persons wanted by law enforcement, or engage in illegal activities will have their passport and citizenship rescinded without refund.
JRCC Center
The Joint Regional Communications Centre is a sub-agency of IMPACS whose principal
role is to act as the central clearing house for the Advance Passenger Information (API)
system and acts on behalf of individual CARICOM Member States for the purpose of
pre-screening passengers from air and sea carriers traversing the region. The JRCC acts as a conduit to ensure effective communication among law enforcement personnel, which is necessary to enhance border control-related activities. The JRCC assists regional law enforcement personnel in the detection of persons who are travelling with stolen, lost and fraudulent travel documents, along with the identification and monitoring of the movements of persons of interest, including those who may be a high security threat to the safety and security of the region.
The JRCC membership consists not only of Caribbean states but also includes the United States, the United Kingdom, Canada, and the European Union
PEP
That process therefore includes being on the lookout for Politically Exposed Persons (PEPs). Since there is no global definition of a PEP, Antigua and Barbuda uses the Financial Action Task Force on Money Laundering definition.
IMPACS
The Caribbean Community (CARICOM) Implementing Agency for Crime and Security
(IMPACS), is the nerve centre of the region’s multilateral crime and security
management architecture, specifically designed to administer a collective response to
the crime and security priorities of member states. I