Interviews with financial executives reveal insights on money laundering risks in CBI schemes, highlighting practical risk assessment strategies.
Caribbean Citizenship by Investment (CBI) programmes present considerable money laundering risks that Middle Eastern financial institutions must navigate under intense international scrutiny. Through semi-structured interviews with 47 senior financial executives across six Gulf and Levant states, we examine how professionals assess CBI-related transactions in their daily compliance work. Participants described attending to red flags including unusually rapid passport acquisition, mismatches between stated business activities and transaction patterns, and layered fund transfers designed to obscure origins. Executives described balancing legitimate client migration needs against regulatory pressures from Western correspondent banks that increasingly flag Caribbean passports as high-risk indicators. The findings suggest that front-line compliance professionals developed practical heuristics for risk assessment despite regulatory ambiguity, often relying on relationship banking knowledge and network intelligence rather than formal due diligence protocols alone. These insights illuminate the operational realities of anti-money laundering compliance in contexts where geopolitical tensions, economic instability and global mobility intersect.
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Kyriakou et al. (2026) studied this question.
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