Amicus International Consulting Examines the Legal Fallout as Brussels Targets Citizenship-by-Investment Schemes Used for Financial Obfuscation
VANCOUVER, Canada – May 30, 2025 — The European Union has launched a coordinated investigation into the use of Citizenship-by-Investment (CBI) programs for financial secrecy and illicit capital flows, citing rising misuse of “banking passports.” These passports—legally issued by small, investment-friendly nations—are now under intense scrutiny following evidence of their role in money laundering, tax evasion, and dual identity abuse. Amicus International Consulting, a global authority on lawful identity transition and privacy migration, is closely monitoring the EU’s comprehensive investigation, which could significantly impact how second passports are issued and regulated worldwide.
The investigation comes amid mounting concerns that individuals are using legal second citizenships to open foreign bank accounts, create alternative tax identities, and conceal the beneficial ownership of offshore assets. While second citizenship itself is not illegal, using it to obscure financial activity is drawing the ire of regulators, especially in a post-Panama Papers, post-1MDB landscape.
What Is a Banking Passport?
A “banking passport” refers to a second passport obtained, often legally, for the express purpose of accessing financial services under a different identity or in a different jurisdiction. These passports are frequently used to:
Open foreign bank accounts in secrecy-friendly nations
Register businesses with altered beneficial ownership
Obtain a new Tax Identification Number (TIN)
Avoid FATCA, CRS, or EU tax enforcement mechanisms
Establish a legal travel identity disconnected from one’s home country
While many clients seek such passports for privacy, mobility, or political security, authorities argue that the structure of CBI programs allows bad actors to exploit legal loopholes.
Brussels Targets CBI Programs
According to leaked EU documents reviewed by Amicus International Consulting, the European Commission is targeting several countries offering Citizenship-by-Investment programs, including:
Cyprus (now suspended but under retroactive audit)
Malta
Bulgaria
Montenegro
Vanuatu
Dominica
Antigua & Barbuda
St. Kitts & Nevis
These programs often lack public registries of new citizens and allow applicants to change their names or suppress their birth data, enabling them to construct a second legal identity without detection.
In February 2025, EU Justice Commissioner Aurelia van Kessel called such schemes “a systemic threat to the integrity of our financial systems.” She announced the formation of a task force to investigate links between banking passports and high-profile fraud and corruption cases.
Notable Case Studies
Case 1: “The Dual Identity Banker”
A Russian national facing sanctions acquired a St. Kitts passport under the name “Alex Gordon.” He used this identity to open a Swiss bank account and move over €25 million. EU investigators uncovered the scheme only after biometric inconsistencies flagged him at Schiphol Airport in Amsterdam.
Case 2: “Crypto in the Caribbean”
A Romanian entrepreneur acquired citizenship from Antigua in 2020 and used it to launch a decentralized crypto exchange. Regulators allege the exchange facilitated over $100 million in money laundering. His Antigua identity, paired with a new Tax Identification Number (TIN) and corporate nominee, prevented AML enforcement for years.
Case 3: “The Vanished Venture Capitalist”
An Italian businessman under SEC investigation obtained Maltese citizenship through a €1 million investment. He used his new identity to create shell companies in the UAE and Hong Kong and is now believed to reside in Georgia under yet another assumed name.
EU Recommendations and Proposed Sanctions
The Commission is considering multiple options to clamp down on CBI-related abuses:
Visa Suspensions for countries deemed to have weak due diligence or CBI transparency.
Blocklist Expansion: Adding Offending Nations to the EU’s Financial and Tax Haven Blacklists.
Interoperability Mandates, forcing biometric databases to cross-reference second citizenships.
Sanctions on Facilitators, including banks, real estate agents, and legal advisors who knowingly assist in obfuscation.
Mandatory Disclosure of all citizenships and tax IDs during financial onboarding processes within EU institutions.
If implemented, these measures would significantly restrict the ease with which high-net-worth individuals acquire and utilize banking passports across borders.
Financial Obfuscation in Action: A Breakdown
Amicus International outlines how banking passports fit into the classic 3-stage model of money laundering:
| Stage | Activity | How Banking Passports Help |
|---|---|---|
| Placement | Introduce illicit funds into the financial system | Use a second passport to open a foreign bank account |
| Layering | Move funds through multiple accounts and entities | Use different legal identities across shell companies |
| Integration | Reintroduce funds as legitimate income | Use a TIN and a passport of a second nationality to invest |
This method allows individuals to stay hidden in plain sight, even while interacting with licensed financial institutions.
The Legal Grey Area
A significant complication is that acquiring a second passport through investment is entirely legal in dozens of countries. So is opening a foreign bank account with that passport. It only becomes problematic when:
The individual fails to disclose other nationalities or identities.
The passport is used to mislead authorities or institutions.
The passport is paired with fraudulent documents (fake birth certificates, nominee contracts, etc.);
It is used to evade sanctions, taxes, or court orders.
This “grey zone” has led to widespread international inconsistency, where one nation’s legal identity can become another nation’s criminal liability.
Amicus International’s Position
Amicus International Consulting does not support or endorse any criminal use of second passports. The company works exclusively with legal clients, including:
Whistleblowers fleeing hostile regimes;
Journalists under threat in authoritarian countries.
Stateless individuals requiring legal recognition;
High-risk investors seeking geopolitical diversification.
“Our goal is lawful transparency with robust privacy,” said a spokesperson. “Banking passports, when used correctly, protect lives. But we must eliminate their misuse.”
How Amicus Ensures Compliance
Amicus uses a rigorous onboarding process, including:
Multi-Jurisdictional Background Checks
Biometric Consistency Audits
Disclosure of All Existing Identities
TIN Cross-Referencing
Exclusion of Sanctioned Clients
The firm also helps legitimate clients:
Correct name mismatches across passports;
Align all government records for tax and legal compliance.
Choose low-risk banking jurisdictions.
Navigate exit taxes or exit controls;
Avoid conflicts with international reporting frameworks, such as FATCA and CRS.
Calls for International Reform
In a white paper published this month, Amicus International recommends:
Global Registry of Economic Citizens: Similar to INTERPOL, countries could voluntarily contribute to a secure database of investment passport holders to prevent double identities.
TIN Harmonization Protocols: Passport-issuing countries should ensure that each new citizen receives a unique, traceable tax identification number.
Enhanced Due Diligence for CBI Programs: Including real-time biometric screening and mandatory name harmonization.
Transparency from Service Providers: Lawyers and brokers should be required to flag unusual identity structuring when applying for second citizenships.
What This Means for Passport Holders
If the EU’s proposals are enacted, current and future passport holders may face:
Scrutiny when opening accounts or crossing borders;
Mandatory disclosures of financial activity tied to any nationality;
Freezing or cancellation of bank accounts if identity obfuscation is suspected;
Retrospective audits for those who used CBI passports post-2015.
This could also damage the reputation of legitimate privacy-seekers and dual citizens, especially those from high-risk regions.
About Amicus International Consulting
Amicus International Consulting is a global leader in second citizenship, legal identity restructuring, financial mobility solutions, and privacy migration. The firm assists qualified clients with lawful identity diversification, travel planning, and second passport acquisition through regulated programs. Amicus does not support or condone criminal activity and applies strict Know Your Customer (KYC) and Anti-Money Laundering (AML) screening to all client applications.
Amicus specializes in providing discreet services to journalists, exiles, digital nomads, political dissidents, privacy advocates, and high-net-worth individuals in over 45 countries.
Contact Information
Phone: +1 (604) 200-5402
Email: [email protected]
Website: www.amicusint.ca
