The Financial Crimes Enforcement Network (FinCEN) issued, on May 20, 2014, an advisory to alert Financial Institutions (FIs) that certain foreign nationals are abusing the Citizenship-by-Investment program sponsored by the Federation of St. Kitts and Nevis (SKN) for illicit financial activity. FinCEN believes the program's lax controls make it attractive to bad financial actors who want to mask their identity and geographic background for the purposes of evading U.S. or international sanctions or to engage in other financial crime. 

FinCEN recommends FIs mitigate this risk through customer due diligence, including risk-based identity verification consistent with existing customer identification program requirements.