Investors who obtain citizenship or residence through a Caribbean or Pacific “citizenship‑by‑investment” (CBI) or “residence‑by‑investment” (RBI) program often wonder whether banks will accept their new passport. The main factor is not the passport itself but the tax‑residence and source‑of‑wealth checks that banks perform under the Common Reporting Standard (CRS) and anti‑money‑laundering (AML) rules, many of which reference the OECD’s list of potentially high‑risk CBI/RBI programmes.
How major banks treat CBI/RBI passports
| Bank | Document | Key requirement |
|---|---|---|
| UBS | Tax‑due‑diligence table (July 2026) | Lists CBI/RBI schemes from the OECD list plus three Panama residence permits. No clause refusing customers because of a CBI passport. |
| Standard Chartered | 2026 self‑certification form (individual) | Asks “Did the Individual obtain residence rights under a CBI/RBI scheme?” with a yes/no box. No outright refusal language. |
| Citi (Singapore private bank) | CRS self‑certification form (August 2022) | Triggers additional due‑diligence when the sole tax residence is a jurisdiction on the OECD list. Malta is listed; earlier OECD versions also listed two Maltese programmes. No refusal clause. |
All three documents tie extra checks to the OECD’s list of potentially high‑risk CBI/RBI programmes. The list is based on programmes that offer a personal income‑tax rate below 10 % on offshore assets and do not require a minimum 90‑day physical presence.
OECD list and the CRS
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The OECD’s model CRS form defines a “reportable person” as anyone tax‑resident in a “Reportable Jurisdiction.”
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Reporting is based on tax residence, not citizenship.
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When a client claims tax residence in a jurisdiction on the OECD list, banks may ask:
- Whether residence rights were obtained through a CBI/RBI scheme.
- How many days the client spent in other jurisdictions in the previous year.
- Where personal income‑tax returns were filed.
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The current OECD list (as of 2026) includes citizenship programmes of Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, Saint Lucia, and Vanuatu; a phased‑out Cyprus citizenship programme; and residence programmes in the Bahamas, Bahrain, Barbados, Cyprus, Seychelles, Turks and Caicos Islands, United Arab Emirates, and Vanuatu.
Additional questions identified by advisers
Immigrant Invest co‑founder Elena Ruda notes that banks typically verify:
- Tax residence.
- Source of wealth and business activity.
- Expected transaction types.
She recommends keeping the due‑diligence file prepared during the CBI application (including source‑of‑funds reports and asset‑structure explanations) to answer bank queries quickly.
FATF‑OECD joint report (Nov 2023)
The report advises financial institutions to:
- Require disclosure of all nationalities and passports at onboarding.
- Request original birth certificates and any earlier passports when a CBI passport is used as identity proof.
- Tag accounts opened with a CBI passport for ongoing monitoring.
It also mentions possible bans on name changes in CBI documents to prevent identity manipulation. Several Caribbean programmes (Antigua and Barbuda, Dominica, Saint Lucia) have introduced such restrictions.
AML regulatory references
| Jurisdiction | Relevant AML rule | Treatment of CBI/RBI |
|---|---|---|
| EU (Anti‑Money‑Laundering Directive 2018, amended) | Higher‑risk factor for third‑country nationals obtaining residence or citizenship “in the Member State” for investment. | Does not cover Caribbean or Vanuatu citizenship programmes. |
| EU (Regulation 2024/1624, effective July 2027) | Removes citizenship from the risk factor; focuses on investor residence. | |
| UK (Money Laundering Regulations 2017, amended 2020) | Higher‑risk factor for third‑country nationals applying for residence or citizenship in exchange for investment. | Covers any state, including CBI programmes. |
| US (FinCEN) | 2014 advisory warned about Saint Kitts‑Nevis CBI misuse; rescinded Feb 24 2026 with no explanation. | |
| Singapore (MAS AML notice) | No explicit mention of CBI passports; focus on source‑of‑wealth assessment. | |
| Singapore (2025 MAS enforcement) | Fined nine institutions S$27.45 million for AML breaches unrelated to passport nationality. | |
| Vanuatu | No AML guidance referencing CBI passports; banking relationships affected by correspondent‑bank decisions. |
Recent enforcement and market reactions
- Singapore (2023‑2025) – After a money‑laundering raid involving several CBI passport holders, some banks tightened scrutiny of Chinese clients with CBI passports. DBS stated that Singapore law does not permit discrimination solely on nationality. MAS fined nine institutions in July 2025 for AML shortcomings, though passports were not cited.
- Vanuatu (2025) – Commonwealth Bank of Australia announced it would stop Australian‑dollar transfers for agents of Vanuatu’s citizenship programme (effective Sep 2025). The National Bank of Vanuatu redirected payments through other correspondent banks. A similar cessation occurred in 2021 when National Australia Bank ended its correspondent relationship with the National Bank of Vanuatu.
Documentation banks expect from CBI/RBI clients
Saint Kitts and Nevis’s Inland Revenue Department (2026 bulletin) requires banks to apply enhanced due diligence for CBI/RBI customers, including:
- Proof of local ties such as a lease agreement, utility bill, or tax assessment.
- Full disclosure of all nationalities, including birth‑country citizenship.
- Original birth certificate and any earlier passports if the CBI passport is the primary ID.
Banks will also verify how each jurisdiction defines tax residence before the client signs the CRS self‑certification form. Claiming tax residence in a listed jurisdiction can trigger the OECD‑based questions on days spent abroad and tax‑return filings.
Practical steps for prospective account holders
- Gather the full due‑diligence file prepared during the CBI application (source‑of‑funds reports, asset‑structure explanations).
- List every passport and nationality you hold, and bring original birth documents.
- Prepare local‑address evidence (lease, utility bill, tax assessment) to satisfy enhanced‑due‑diligence requirements.
- Check each country’s tax‑residence rules before completing the CRS self‑certification; be ready to explain days spent abroad and where you filed tax returns.
- Anticipate additional questioning if your tax residence is in a jurisdiction on the OECD high‑risk list.
By meeting these requirements, clients with CBI or RBI passports can reduce the risk of account refusals or later closures.
Source article: www.imidaily.com
