Banks no longer required by FinCEN to ‘give us some SKN’ on suspicious activity reports

Banks will no longer have to file suspicious activity reports (SARs) with the term “SKN Passport” in the narrative for transactions involving investors in the Caribbean nation of St. Kitts and Nevis, the Treasury’s financial crimes arm said Tuesday.

The Financial Crimes Enforcement Network (FinCEN) said that, since passports issued by the U.S. State Department have now expired for individuals in the Federation of St. Kitts and Nevis’ (SKN) Citizenship by Investment (CBI) program, it is now rescinding its advisory on the program.

In 2014, FinCEN issued the advisory aimed at ending abuse of the CBI program. FinCEN alleged then that certain foreign individuals were abusing the program to obtain SKN passports “for the purpose of engaging in illicit financial activity.”

However, the agency said, it urged banks to be vigilant. “FinCEN reminds financial institutions to apply appropriate risk-based procedures for conducting ongoing customer due diligence,” the agency said.

FinCEN Rescinds Advisory on the Abuse of the Citizenship-by-Investment Program Sponsored by the Federation of St. Kitts and Nevis