There has been a lot in the news recently about passports, and I realised that although I of course understand the basics of the document, there are certain key things that I do not know – and knowing them would help be more efficient in my fight against money laundering. And the most important of these is the concept of dual (or even multiple) nationality.
In the UK, we permit our citizens to have dual nationality – to hold a British passport alongside another one. But it has to be agreed by both countries, and keeping track of who they are is quite the job of work. Exactly half of the 28 EU member states restrict or forbid dual nationality; it’s an imperfect check, but the best quick source I have found is this Wikipedia page. Issues of nationality are rarely simple, of course: nationality can be conferred by parental nationality or place of birth or marriage or religion, and that’s just for starters. Multiply it up, and you get all sorts of interesting variants. In Australia and Egypt, for instance, dual citizens are permitted, but then cannot be elected to parliament. (I guess they figure that if you’re hedging your bets passport-wise, you might not be quite committed enough to serve full-heartedly.) Spain has dual citizenship treaties with several South American countries, but when it comes to taking on dual citizenship with other countries, you automatically lose your Spanish citizenship after three years unless you say that you want to keep it. South Korea permits dual citizenship to a limited number of people. All very complicated, but much more common than I had realised – I feel quite left out with my one measly passport.
For the MLRO and his staff, I think it is useful to know when they are dealing with someone who might be offering only one of a pair (or even suite) of passports when asked for identification verification. After all, the non-presented passport(s) might reveal much more pertinent information when it comes to risk assessment. So when dealing with someone who could have more than one passport (including, we now know, all British citizens), it might be worth asking (especially in high risk situations) whether they have any others.
I hate money laundering 
I can relate myself to your post. I’m currently doing an EDD on a application I’ve received recently. The lady’s (the prospect) husband’s name matches with a designated individual of Indian nationality having connections with a terrorist organization. The report available on the screening software is dated 1998. The lady’s Australian – so when I inquired about her husband’s nationality – I was told that he’s Indian born – BUT an Australian.
Fortunately the Indian law does not permit dual citizenship – so our friend probably surrendered his Indian passport. But if I need to establish whether he’s the same individual listed on the screening solution, I’ll have to find out whether he got his Australian citizenship before or after 1998. If it turns out to be the latter, I wont be able to investigate any further because (1) I wont be able to source out a copy of his Indian passport and (2) the screening report does not have any other information.
Welcome to the blog, The MLRO, and thank you for your comment. No-one ever said that doing due diligence (especially EDD) was easy, and your current example illustrates perfectly how dual citizenship and passports add an extra wrinkle to it all.
Best wishes from Susan
The non-presented passport(s) might also reveal much more pertinent information when it comes to US and UK FATCA reporting …
Indeed, Lorraine – an excellent point. I hadn’t even thought of that, so thank you.
Best wishes from Susan
Ooh – I’ve got both British and Irish 🙂 Well on my way to becoming a globetrotting fugitive travelling under the radar.
Ah, Roy, now you see what you’ve done: you’ve blown your cover. Or is Roy the real person, and we haven’t yet spotted the cover. Dastardly! Either way, you’re now on my watch list.
Best wishes from Susan
A Guernsey reader has emailed me about a situation he remembers, when an American cruise passenger came ashore and went to a high street bank in St Peter Port to open an account. When asked for ID, the American offered a commercially obtained non-US passport, which he explained was his “hijack passport”, should he ever become involved in a situation involving terrorists and not want to produce his normal US passport. Apparently this is common practice for US travellers. Our reader had a chance to look at a copy of the “hijack passport” provided, and reports that it was a very convincing ID document, which in this particular case had genuinely been obtained for a commercial fee from a certain Caribbean jurisdiction. Effectively you pay a fee and thereafter become a passported national of that country – but who knows what level of due diligence (if any) is done on the applicants.