PWM’s Financial Times studio hosted a special discussion on “The Mechanics of Due Diligence, World in Crisis: Securing Citizenship by Investment” through an interactive session with the three major due diligence agencies, including Exiger, FACT, and S-RAM.
With the host-Yuri Bender, Editor in Chief Financial Journalist at Financial Times’s PWM Magazine, the panel discussion was joined by Chief Operating Officer of FACT Worldwide- Eddy Leviten, Director of Strategy and Development at EXIGER- Karen Kelly, and Chief Executive Officer of S-RM Heyrick Bond Gunning.
The prime focus of the discussion revolved around the process of due diligence and its significance in the Citizenship by Investment programme. The discussion has also featured the process of examination of the credentials of the families who applied for the CBI programme.
While highlighting several aspects of the vetting process for the host country, Karen Kelly, who has over ten years of experience in due diligence and Citizenship & Residency by Investment, said that it is important for the host country to conduct vigorous due diligence so that the backgrounds of the investors could be determined.
She further added that scrutinizing or verifying the profile of investors, which includes the manifestation of financial documents, personal documents and criminal backgrounds, could be done with the help of the due-diligence agencies as they used all on on-the-ground intelligence resources. Kelly also mentioned that it is not in the hands of the due-diligence agencies to accept or reject the application.
Applauding the CBI programme of the Caribbean, Kelly emphasized that some countries are actively engaging in the due-diligence process and always remain eager to know several changing trends of the programme. She said that the CBI programme in the Caribbean talks about the several levels of multi-layered checks.
Emphasizing the process of the Caribbean countries, Karen Kelly affirmed,” It not only involves the third party due to diligence agencies but also engages with the regional and international law enforcement, intelligence partners to gather information. They are also mandating immigration agents and marketing agents to carry out KYC- Know Your Customer, which is a significant step.
While emphasizing the process of thorough background checks, Eddy Leviten, who has worked for thirty years in the creative industries, retail and enforcement, said that every application is rigorously vetted by the due-diligence agencies. The multi-layered checks are applied to all the applicants who are over the age of sixteen and the same level of vetting has been conducted by the agencies for the dependents as well.
Leviten further mentioned that the agencies also cross-check the application from the data collected by the different databases.
He noted, “We apply the same level of background checks on dependents as well. We also look at the relationship chart of not just the applicant or dependents but also on their associates, whether they are in a business or within the family. We check the records in the country of birth, marriages, and deaths of a family member, educational qualifications, employment; if there is any red flag, we immediately notify our client.”
Chief Operating Officer also stated, “If you are a master criminal looking to avoid prosecution in a country, then this isn’t a route for you; there would be better ways for fraudsters to hide out their assets and move around the world,” he added while referring to the robust due diligence process.”
Outlining the procedure of due diligence, Leviten said that this depended upon the different jurisdictions as some countries prefer to use two due-diligence agencies for cross checkings. He added, “We provide a report back to our clients; what the client does with the report is what determines if the applicant will be granted citizenship.”
Discussing the common red flags, CEO of SR-M Heyrick Bond Gunning said one of the major red flags is when the individual doesn’t work in the sector from which they derived the major source of wealth, and there are a variety of issues that they while referring flag to the clients.
Gunning, who was in the British Army at the start of his career has, successfully set up DHL’s operations in Iraq during the end of the Gulf War.
Meanwhile, he also outlined the new changing trends in the vetting process of the countries and stated that the tightening of checks of CBI applications has witnessed increment over the past few years.
“Applicants also go through checks by the agents before being put through the unit, sometimes, there are double-checks by two companies, and then they are put through security services in the country and in a broader base as well. The ongoing monitoring is critical,” said CEO of SR-M Heyrick Bond Gunning.
Lauding Caribbean countries in response to COVID-19, he said that the region has always conducted rigours due-diligence processes and become even more focused while operating the Citizenship by Investment programme. Now, the countries are running the programme efficiently with enhanced background checks.
Despite being small island nations, the Caribbean countries have made extremely great efforts to ensure a robust due diligence process on every application. These countries guarantee to place the safety and security of their citizens as their utmost priority. The moral obligations towards the international community are also among the most precedence for countries offering citizenship through investment programmes in the Caribbean.
Caribbean countries are renowned for having a comprehensive, robust due- diligence process that meets all the international standards of safety and security. The process is carried out by third party due-diligence agencies and also meets the high CBI standards of transparency.