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Due diligence helps understand source of funds applicant uses for investment purposes

WorldDue diligence helps understand source of funds applicant uses for investment purposes

PWM’s FT studio has held a special episode on “The Mechanics of Due Diligence, World in Crisis: Securing Citizenship by Investment,” where dignitaries from three dynamic due diligence agencies took participation in a panel discussion. The modulator of the discussion was Yuri Bender, Editor in Chief, Financial Journalist at FT’s PWM Magazine.

Chief Operating Officer of the FACT Worldwide- Eddy Leviten, Director of Strategy and Development at Exiiger- Karen Kelly, and Chief Executive Officer of S-RM Heyrick Bond Gunning were among the representatives. The panel discussion revolves around the importance of due diligence in the Citizenship by Investment programme.

Eddy Leviten, who has more than thirty years of experience in the creative industries, retail and enforcement, said that due diligence agencies carry out multi-layered checks on all applicants, including their dependents over the age of sixteen. He noted that the main applicant and its dependents have to go through the same level of investigation process even if they join later in the application.

Chief Operating Officer of FACT Worldwide further added, “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 a family.”

He noted that, “While carrying out the multi-layered process, the due diligence agencies do cross-checks on lots of different databases. We check the records, including the nation of birth, marriages, and death of any of the family members, educational qualifications, employment, if there is any red flag, we quickly notify it to the client.”

While emphasizing on the robust due diligence process, he said, “If you are a master criminal looking to avoid prosecution in a nation, then this is not a route for you; there would be better ways for fraudsters to hide out their assets and move themselves around the globe.

He stated that some nations offering Citizenship by Investment programmes use two or more due diligence agencies for cross-checking. Once the due-diligence report is ready, it is similar to reading a person’s life story as it contains entire details about the individual.

Leviten stated that every nation understands that due diligence has to have the highest possible standards. “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.

Director of Strategy and Development at EXIGER- Karen Kelly, who has over a decade of experience in due diligence and Citizenship and Residency by Investment, also highlights the importance of carrying out thorough checks on the applicants. She said a host nation must take a very in-depth look at the investor to understand who they are and their backgrounds.

While noting the importance of the due diligence process in residency and citizenship by investment programmes, Karen Kelly of EXIGER said that thorough due diligence also helps understand the source of funds an applicant is using for investment purposes.

Notably, referring to the major Citizenship by Investment Programmes in the Caribbean, she said they meet the international standards and pay key attention to due diligence procedures. She asserted that, “The programmes in the Caribbean nations are not only meeting the minimum standards but also carrying out different levels of due-diligence process in a very effective way, for which they also engage with regional, national and international law enforcement.”

She asserted while referring to the Caribbean nations, “It not only includes the third-party due diligence agencies but also engages with the regional and international law enforcement, intelligence agencies to collect information. They are also mandating immigration agents and marketing agents to carry out KYC- Know Your Customer, which is an important step.”

Kelly added that, “The due diligence provider is not there to decide whether a person should be approved or not be approved for citizenship.”

CEO of SR-M Heyrick Bond Gunning, highlighted the common challenges as well as red flags in due diligence. He stated that one of the major red flags is when the individual doesn’t work in the sector from which they derived the primary source of wealth. “There are various issues that we see that we flag to our clients (host countries),” he added.

In the panel discussion, Gunning also emphasized on the significance of due diligence in the CBI Programme. He begins his career in the British Army; not only that, but he also set up DHL’s operations in Iraq during the end of the Gulf War. He also shared his experience during the panel discussion.

Moreover, several reports have also appreciated the strict due diligence conducted by Caribbean nations. These nations ensure to keep the safety and security of their citizens as their topmost priority.

The due diligence undertaken by these nations is often thorough, extensive, solid and also meets all the international requirements of safety and security.


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