Every nation providing economic citizenship must have highest possible standards under due diligence: Leviten

A special episode on "The Mechanics of Due Diligence, World in Crisis: Securing Citizenship by Investment" was held by PWM's Financial Times studio, where three leading agencies of Due Diligence participated in a group discussion with Editor in Chief of Financial Journalist at Financial Times's PWM Magazine, Yuri Bender.

A special episode on “The Mechanics of Due Diligence, World in Crisis: Securing Citizenship by Investment” was held by PWM’s Financial Times studio, where three leading agencies of Due Diligence participated in a group discussion with Editor in Chief of Financial Journalist at Financial Times’s PWM Magazine, Yuri Bender.

The significance of due diligence under the Citizenship by Investment programme was discussed by the Director of Strategy and Development at EXIGER- Karen Kelly, Chief Operating Officer of FACT Worldwide- Eddy Leviten, and Chief Executive Officer of S-RM Heyrick Bond Gunning.

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Karan Kelly, who is the Director of Strategy and Development at EXIGER, has experience in due diligence and Citizenship and Residency by Investment of over ten years also discussed the importance of carrying out strict due diligence on applicants. She said that the host country must take a very deep look at the applicant to know their background and from where they belong.

 

Kelly also said that the due diligence firms help the countries to verify their investors and examine their profiles, including their financial and personal documents and criminal backgrounds. This can be done by using on-the-ground intelligence resources by questioning from the ones who closely know the applicants.

Furthermore, while discussing the difference between different jurisdictions, Kelly said that some countries are highly involved in the process of due diligence and ask frequent questions regarding the new changes. She said that Citizenship by Investment Programmes in the Caribbean talks about carrying out different levels of due diligence checks to ensure that the individual investing in the Citizenship by Investment Programme must be legal.

“It involves the third party due diligence agencies and engages with the regional and international law enforcement and 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,” said Karen Kelly, talking about the due diligence process of Caribbean countries.

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She drew attention towards that the due diligence provider is not present at the moment to decide whether or not a person should be approved for second citizenship.

 

Eddy Leviten, who has experience of over thirty years in the retail, creative industries and enforcement, stated that a multi-layered due diligence is carried out on all applicants and their dependents who are aged 16 and more.

He also highlighted that the main applicant and its dependents experience the same level of inspection irrespective of whether they join along with the main applicant or later on.

Levitan further added, “We also apply the same background checks on dependents. 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.”

 

He also explained the whole multi-layered process and said that the agencies of due diligence go through cross-referencing on various databases to confirm the claims made by the applicant.

“We check the records in the country of birth, marriages, and deaths of family members, educational qualifications, employment. If there is any red flag, we quickly notify the client.”

He also said that there are some countries offering Citizenship by Investment programme cross-refers by using two due diligence agencies.

Eddy Levitan further mentioned that once the report of due diligence is prepared, it is as similar to reading the life story of a person because it contains so much thorough details about the applicant.

He stated that every country providing Citizenship by Investment Programme understands that there must be the highest possible standards under the due diligence process.

“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.”

 

Heyrick Bond Gunning, CEO of SR-M, talked about the common red flags and said that one of the utmost red flags is when the applicant does not work in the field from which he has got his major source of wealth. “There are various issues that we see that we flag to our clients (host countries),” he added.

CEO Gunning was in British Army when he first started his career. Not only that, he was the one to set up DHL’s operations in Iraq at the end of the Gulf War. He shared many of his experiences during the panel discussion.

Other than this, he said that the due diligence of CBI applicants has become strict in 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 Heyrick Bond Gunning.

CEO of SR-M, Gunning, said that despite many challenges which were caused by the COVID-19 pandemic, Caribbean nations still remain committed to the strict processes of due diligence. He further highlighted that the Citizenship by Investment units of the Caribbean countries has become even more focused on their work and how they run their administration after this pandemic to become even more successful.

Despite of the small sizes of the countries of the Caribbean island, they put all their efforts into ensuring that a strong due diligence process must be carried out on each and every applicant. These countries give a guarantee to their citizens that their security and safety are their top priority. The moral responsibility toward the international community is also the top priority of the nations providing CBI Programmes in the Caribbean.

The due diligence that is undertaken by these nations is often robust, comprehensive as well as meets all the international standards of security and safety. The process requires investigation of all the supporting documents by the third-party due diligence firms, both global and regional entities, related to the detection of crime. The transparency of these CBI Programmes helps nations to maintain high standards of Citizenship by Investment Programmes.

Tariq Saeed

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