Operationalising a CBI AI System and Legal Framework

Abstract

Chapter 6 explains how Citizenship by Investment (CBI) programmes can operationalise an AI-driven due diligence (DD) system while remaining compliant with data protection, cybersecurity and emerging AI governance standards. It begins by outlining the structural weaknesses of current CBI know your customer (KYC) and DD practices—high cost, duplication across jurisdictions, repetitive documentation burdens and legacy data-security risks—and argues for a minimum DD standard that improves efficiency without weakening oversight or privacy protections. The chapter thereafter proposes a hybrid technical architecture combining AI with blockchain-enabled tools. It cautions against storing personal data on-chain due to General Data Protection Regulation constraints (especially the right to erasure) and instead supports an off-chain storage model anchored by on-chain hashes for verification, auditability and traceability. Smart contracts are presented as a mechanism to automate requests, validations and multilateral reuse of verified KYC outputs across Citizenship by Investment Units, reducing redundant screening while strengthening integrity through immutable audit trails. The chapter also addresses blockchain sustainability concerns by contrasting Proof of Work with Proof of Stake. Finally, the chapter operationalises AI governance through impact assessment and conformity assessment models aligned with the EU Artificial Intelligence Act. It proposes an Organisation of Eastern Caribbean States-oriented institutional framework involving a regional AI board, national supervisory authorities and independent conformity assessment bodies to ensure accountability, human oversight, monitoring and reporting across the AI lifecycle.