CBI Under Pressure as Banks Tighten Source-of-Funds and Identity Reviews

New passports may change nationality, but financial institutions demand long continuity trails.

WASHINGTON, DC 

Private banks and mainstream retail institutions are converging on the same view of citizenship by investment in 2026: a new passport can change the nationality line on a form, but it rarely changes the risk questions that matter to compliance teams. In many onboarding rooms, it does the opposite. It triggers deeper review, longer document lists, and tougher internal debates about whether the relationship is worth the reputational and sanctions exposure.

That shift is not driven by a single scandal or a single regulator. It is driven by accumulated pressure: sanctions enforcement that moves faster than legacy screening models, political scrutiny of investment migration programs, and a post-pandemic compliance culture that increasingly treats “identity continuity” as a primary control, not a nice-to-have.

The result is a practical reality for globally mobile clients. The question banks ask first is no longer “What passport do you hold today?” It is “Can you explain, document, and verify how you became who you are across time, across borders, and across money flows?”

A new bank standard is taking hold: continuity is the product

Banks have always asked for proof of identity and proof of address. What is changing in 2026 is how those documents are interpreted.

A second passport, especially one obtained through an investment program with limited residency, can be seen as a mobility upgrade. It can also be seen as a fragmentation event. It introduces an alternate identity anchor that may not align neatly with older records: tax filings, company registries, property records, employment history, education history, litigation history, and prior banking relationships.

For low-risk customers, banks can absorb a bit of complexity. For higher-risk profiles, or for clients coming from jurisdictions perceived as higher risk, complexity becomes costly. Not because it is inherently wrong, but because it increases the work required to be confident that the client is who they say they are, and that the money story holds up under scrutiny.

This is where the phrase “source of funds” gets misunderstood by the public.

Source of funds is transactional. It asks: where did this deposit come from?

Source of wealth is historical. It asks: how did you become wealthy in the first place?

In 2026, institutions are leaning harder toward source of wealth. They want a long, documentary trail that can explain the client’s economic rise in a way that would still make sense if the relationship is reviewed years later.

A CBI passport does not answer that question. It can even sharpen it, because it forces the bank to reconcile two narratives: the client’s original life history and the client’s new nationality story.

Why CBI now triggers enhanced due diligence more often

The compliance logic is simple. CBI can increase risk in three ways.

First, it can reduce the predictive value of nationality as a risk signal. Many screening models still begin with nationality and residency, then adjust based on occupation, political exposure, and transaction patterns. When nationality can be acquired quickly without deep integration, some institutions treat it as a weaker indicator of long-term ties, enforcement cooperation, and documentary reliability.

Second, it can complicate sanctions controls. Sanctions regimes are increasingly enforced through networks of identifiers: names, dates of birth, known aliases, corporate associations, and travel patterns. A client with multiple citizenships and multiple identity documents may be entirely legitimate, but the bank must be more confident that it is not onboarding a proxy, a nominee, or a person whose identity has been strategically reframed to reduce visibility.

Third, it can elevate reputational risk. After years of headlines about “golden passports,” many institutions now worry about being the bank that onboarded the wrong person through a pathway that critics have already framed as vulnerable. Even when a program is lawful, the optics can be harsh. Compliance is not only about legal thresholds. It is also about explaining decisions to regulators, auditors, correspondents, and the media.

That reputational layer has become more important as de-risking accelerates. Some banks would rather exit a difficult relationship than spend months building a case file that might still draw questions later.

The continuity trail banks now expect to see

In practical terms, “continuity” means a client can produce a coherent timeline.

Where they lived, when, and under what legal status.

Where they worked, with documentation that matches tax and corporate records.

How key assets were acquired, including properties, companies, and major investments.

How liquidity events occurred, such as the sale of a business, a dividend stream, or an inheritance.

How money moved across borders, including the rationale for transfers that might otherwise look circular or unexplained.

Banks increasingly want this timeline backed by independent records, not only client statements.

Audited financials where relevant.

Tax filings or tax summaries where appropriate.

Corporate ownership documents and beneficial ownership declarations.

Contracts and closing statements for major transactions.

Bank statements that show inflows and outflows across time, not just a snapshot.

Third-party verification, including professional letters that are substantiated by underlying documentation.

This is why “new passport, new start” narratives tend to fail in modern onboarding. A bank is not only verifying the passport. It is verifying the life behind it.

The CBI applicant’s misconception: the passport is the end, not the beginning

Many clients approach CBI as a transactional purchase. Pay the contribution, pass the due diligence, receive the passport, and move on.

But banks increasingly treat CBI as the beginning of a new compliance story, not the end of an old one. A new nationality can create new reporting obligations, new tax residency questions, and new expectations about disclosure.

It also introduces a new problem for the client: they must now explain why they acquired the passport and what they plan to do with it.

This is not a moral interrogation. It is risk scoring. Motivation matters. If the client’s explanation sounds like avoidance, opacity, or “I want fewer questions,” the file becomes harder to approve, even if everything is lawful. If the explanation is about family planning, mobility resilience, business expansion, or long-term residence planning, and the documents support that, the file is easier to defend.

In 2026, banks are listening for one key phrase, even if they do not say it out loud: does this client want mobility, or do they want concealment?

Regulators are reinforcing the pressure, even indirectly

Banks do not operate in a vacuum. They are reacting to enforcement, guidance, and the growing expectation that high-risk relationships require a demonstrable rationale.

In the UK, official notices about enhanced due diligence expectations for higher-risk jurisdictions reinforce that posture, especially where institutions must apply additional checks and document the basis for their decisions. One example is the UK government’s advisory framework around enhanced customer due diligence in relation to high-risk third countries, which speaks directly to the obligation for stronger controls when jurisdictional risk rises: Money laundering advisory notice: high-risk third countries.

Even when a CBI program is not in a “high-risk country” category, the logic carries over. If a passport is perceived as a risk amplifier, the institution will behave as if the onboarding requires the same level of documentation discipline, regardless of the marketing claims that come with the program.

What “due diligence failures” mean in bank language

Policymakers often describe CBI risk in terms of “due diligence failures.” Banks translate that into specific failure modes.

A program relies too heavily on criminal record checks and not enough on source of wealth verification.

A program screens at the front end, then does little after issuance, even as sanctions lists and risk profiles evolve.

A program allows intermediaries too much influence over the narrative and the documentation pack.

A program’s residency requirement is minimal, making it harder to argue that the client has meaningful ties that would support long-term record integrity.

When these concerns circulate in the market, banks do not wait for a formal rulebook. Many simply adjust internal risk scoring, flagging certain passports, agents, or program types for escalated review.

That is why some clients experience a confusing pattern: approval from a program’s due diligence provider, followed by hesitation from a bank that views the bank’s own obligations as stricter and longer-tailed.

The new reality: a “passport portfolio” can raise questions instead of solving them

CBI marketing often frames multiple citizenships as diversification, an insurance policy, a mobility hedge.

Banks are not allergic to diversification. They are allergic to discontinuity.

A client with two passports, three residencies, and a complex corporate structure can still be low risk if the documentation is consistent, the tax posture is clear, and the money story is coherent.

The same structure can be high risk if the documentation looks curated, the timeline has gaps, the corporate structure has unnecessary layers, or the client cannot explain decisions without leaning on vague language.

The key shift in 2026 is that banks are less willing to “fill in the gaps” with assumptions. If the client cannot provide evidence, the bank will often assume the worst-case compliance risk, because regulators and correspondents increasingly punish optimism.

What this means for lawful clients considering CBI

The practical advice is not “do not pursue CBI.” The advice is “treat banking as the real due diligence test.”

Before applying, a client should build a continuity file that is designed for financial institutions, not only for a citizenship unit.

A clean source-of-wealth narrative with supporting documents that match.

A clear explanation of tax residency and reporting posture.

A transparent corporate ownership map, showing beneficial owners and control.

A record of prior banking relationships and the reasons for changes.

A plan for how the new citizenship will be used, tied to lawful residence, business strategy, or family planning.

Clients who do this reduce the chance that a new passport becomes a compliance trigger rather than a mobility asset.

This is also where professional services can be the difference between “approved” and “stalled.” Advisory work that anticipates how banks underwrite risk can shape outcomes more than the passport itself. Amicus International Consulting’s work in lawful second citizenship planning emphasizes documentation integrity, identity continuity, and a compliance-forward narrative that is designed to hold up under modern onboarding standards, not merely to satisfy an application checklist: Second Passport services.

Why banks say “no” more quickly in 2026

A decade ago, some banks treated high-touch onboarding as a profit center. Today, many treat it as a risk center.

The reasons are structural.

Compliance costs have risen.

Correspondent banking relationships have become more sensitive.

Sanctions enforcement has become more aggressive.

Media scrutiny has intensified.

Regulators increasingly expect documented rationale for risk decisions.

In that environment, the marginal value of a complex client can be outweighed by the internal cost of sustaining the file. The path of least resistance is often to decline or exit.

This is why clients are experiencing a phenomenon that feels backwards. They acquire a new passport hoping for easier access, and they encounter more questions, not fewer.

How the pressure is playing out across jurisdictions

The tightening is not uniform. Some institutions remain open to CBI clients if documentation is strong. Others have effectively instituted quiet policies that treat certain passports, or certain program profiles, as a default high-risk marker.

There is also a split between private banks and fintech platforms. Some fintech platforms move fast but have rigid risk filters, meaning they can reject quickly with little explanation. Private banks may be willing to engage, but demand deeper documentation and longer onboarding.

Meanwhile, institutional memory is growing. Once a client has been declined by one institution, that outcome can influence future conversations, especially if the decline was tied to an adverse media profile, unexplained wealth, or inconsistent documentation.

This is why CBI clients increasingly need a strategy that is not just legal, but operational: how to present a clean, verifiable file to institutions that are under pressure to avoid surprises.

The news cycle is amplifying the trend

Public coverage has reinforced the idea that CBI is under scrutiny, not simply debated. That coverage shapes internal risk perception even when it does not change formal rules. A current Google News feed tracking reporting on CBI scrutiny, bank onboarding friction, and source-of-funds expectations can be followed here: CBI bank source of funds identity reviews 2026.

The bottom line

In 2026, the value of a second passport is increasingly determined by how it performs under institutional scrutiny, not how fast it can be obtained.

Banks are rebuilding trust by anchoring identity to continuity, and by demanding that wealth narratives be documented across years, not summarized in a few pages. For lawful clients, that is not a reason to panic. It is a reason to prepare.

A new passport can expand mobility. It can diversify geopolitical exposure. It can support family planning and long-term options. But it cannot substitute for a coherent, verifiable record. In the modern compliance environment, the passport is only the cover page. The story that matters is the one the documents can prove.