It was the perfect pitch for 1,076 young foreigners who had just graduated from a US university but didn’t want to return home.

They could continue their studies at the University of Northern New Jersey without bothering to attend class, take tests, or butt heads with professors. And they could stay in the US, at least temporarily. They could even work at companies such as Google, Facebook, and Morgan Stanley while they pursued their “education.”

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Unfortunately for them, the UNNJ didn’t really exist. It was a fake institution set up by the Department of Homeland Security. DHS created the bogus school as a sting operation to entrap immigration brokers who promised students that they could stay in the US longer than their visas would otherwise allow. In return, the brokers received fees, sometimes as much as $12,000, from each of the students. The students also paid the brokers sham “tuition fees.”

But in April, the government revealed it had all been a hoax. A total of 22 brokers now face fines and possible imprisonment. All 1,076 students face deportation. They won’t be allowed to return to the US for at least 10 years. Some even face lifetime bans.

This isn’t the place to discuss the “fairness” of having the DHS set up a fake university or of deporting the students who enrolled in it. The important point is that in matters relating to visas and second citizenships, it’s extremely important to “do it right.” That means not taking shortcuts and if possible, dealing directly with the agency responsible for approving your application. If you need to use an intermediary, hire a licensed immigration attorney or agent.

In the case of the 1,000-plus deported students, for instance, there were several important tip-offs. At the top of the list of course is that none of them ever had to attend class. In addition, many of them received fake documents from the undercover university. These included fraudulent transcripts, diplomas, student ID cards, and even phony parking passes.

Similarly, if you’re in the market for a second residence or second passport, you need to be alert for “red flags” indicating things might not be as they seem at first glance. For instance, in conducting due diligence on citizenship-by-investment programs, I look for the following warning signals.

Too cheap.

The total cost of the least expensive legally mandated citizenship-by-investment program comes to about $135,000 for a single applicant or $220,000 for a married couple. Any passport issued for much less than that amount should be presumed to be issued illegally, unless the company offering it can point to a specific law authorizing its issuance.

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Too easy.

No country issues a certificate of nationality and passport without a detailed application process, including completion of official application forms, a background check, and in many cases, an interview.

Too fast.

No government can approve an application for citizenship in only a few days. The fastest authorities can conduct a reasonably complete investigation and move the application through layers of bureaucracy is three or four months, and often much longer.

Too undocumented.

Some promoters claim they have the ability to acquire citizenship and a passport for you based on a secret law or regulation known only to select insiders. That’s a load of BS and usually means the promoter is dealing with a corrupt insider with connections to the passport office. In all legitimate programs, promoters will be able to point you to a specific provision in the country’s nationality law authorizing the citizenship-by-investment route. For instance, in Dominica, the citizenship by investment program is authorized in regulations published pursuant to Section 101 of the Constitution and Sections 8 and 20 (1) of the Citizenship Act.

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Too anonymous.

Any promoter who promises to issue you a passport in any name you choose falls into this category. In this age of hyper-compliance and enhanced due diligence, it’s ludicrous to think that a promoter can get a passport issued in a fake name without breaking the law.

Too limited.

Passports that come without a certificate of nationality fit into this category. A few years ago, a promoter was trying to sell me a passport from Bulgaria. I asked if the price included a Bulgarian certificate of naturalization, which is needed to renew the passport. It didn’t. Indeed, the promoter warned me the passport he wanted to sell me couldn’t even be used to enter or leave Bulgaria!

I’ve lost count of the bogus citizenship and passport programs I’ve encountered in my career. But one thing is for sure: Acquiring a second residence or second passport isn’t as easy as falling off a log. You can’t simply give someone a check and expect that a week later you’ll receive a shiny new visa or passport in an assumed name. As we all know, if something seems too good to be true… it probably is.

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Visa and Passport Fraud “Red Flags”

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