The Sept/Nov 2019 edition of ACAMS Today features an article authored by DSA president, Alison Jimenez, titled “EB-5: Pathway to US Citizenship or Money Laundering Concern?”
The article provides an overview of the EB-5 immigrant investor program and financial institutions role in escrow accounts, offering securities, and bridge loans to developers.
AML and Fraud Risks are broken-down into:
- KYC issues
- Illicit or Unknown Source of Funds
- Transactions without a Purpose
- Funnel Accounts & Hawala
- Theft of Investor Funds and/or Ponzi Schemes
The article also discusses the disincentive for immigrant investors to report suspected fraud and cases of financial institutions being drawn into litigation.