Rightly or wrongly, given the apparent ease with which you can buy a fake one these days, the passport is still viewed as the primary document for CDD. (I’ve occasionally considered buying one myself, in order to get rid of the Tenko-meets-Tellytubbies photo in my officially-issued one.) But until we find a way to barcode babies’ bottoms in the delivery room, I think we’re stuck with passports as the best of a bad lot. A recent research piece on the BBC website, however, should probably be required reading for MLROs, to help them decide precisely what shade of a jaundiced eye to turn on certain documents.
In a piece entitled “Where is the cheapest place to buy citizenship?”, it is revealed that the wealthy, as well as taking on the appearance of mahogany and paying £18 for a bowl of cornflakes (true story: I saw it on a menu in Portofino), are now “diversifying their passport portfolio”. How naïve I am: I had always thought that the purpose of a passport was to indicate where you belonged, taking into account where your parents belonged and where your mum happened to be when her waters broke. But no: it is apparently, like so many things for those with deep pockets, a matter of choice. You can read the details yourself, but among the countries offering their citizenship for sale are Dominica, Malta and Cyprus.
So where does that leave the prudent MLRO? If a client presents a Maltese passport, should you ask why? Are the client’s parents leading lights in the Valletta Bridge Club – or did he just pony up the necessary €650,000? And does it matter? I think I might be interested to know why someone has (or feels they need) a portfolio of passports rather than just the standard issue set of one. Maybe our client take-on forms should be more nit-picking, particularly when it comes to high-risk situations: rather than asking simply for the details of “your passport”, perhaps we should ask for details of “all passports”, and maybe even when and why acquired.