Professionals within the citizenship by investment industry know too well that they carry a lot of responsibility on their shoulders. Agents have to make sure that they do their own due diligence on the applicants to guarantee that they only put forward reputable individuals, whilst countries have to put monetary interests aside and seek the best interests of their own jurisdiction and partner countries. A stringent due diligence framework is essential to impede security risks. Citizenship by Investment Units needs to have all the safeguards in place in order to detect any possible abuse of investment migration programmes for money laundering or criminal activity.
The application processing time and documentation required for each application are usually very good indicators of the rigorousness of the due diligence process for a particular investment migration programme. Malta conducts what has been termed as the ‘gold-standard’ of due diligence processes in the industry; a multi-tiered evidence-based risk matrix that goes into a serious level of detail. The current iteration of the Individual Investor Programme (IIP) risk matrix consists of multiple levels of risk, across seven categories. Through this risk matrix, the IIP has been able to undertake a more structured risk assessment, which facilitates a more objective and systematic review of applications. This ultimately resulted in case officers being able to conduct a more thorough risk assessment that facilitates new levels of standardisation, transparency and integrity, which will ultimately result in increased levels of trust in the industry.
This level of in-depth analysis is only possible because Malta has access to the required resources and support to be able to conduct such stringent due diligence, including, the required monetary budget, the human resource, the network of service providers, the techniques and the insight gained through four years of intense scrutiny from a number of bodies, including international media. Like all other operators, the Malta Individual Investor Programme Agency (MIIPA) needs to make sure that only reputable individuals are granted citizenship rights to Malta and the EU for the sake of the other citizens. Malta is not after big numbers but after quality applicants. In fact approximately 22% of the applications are rejected, showing that it takes due diligence very seriously. It will continue to lead and be a proponent of best practice and governance in the field. Malta’s aim has always been to carefully select, through the right checks and balances and a rigorous due diligence process, the right global citizens that will see Malta as their natural home and the place from where they choose to shape the world of tomorrow.
Jonathan Cardona is the Chief Executive Officer of the Malta Individual Investor Programme Agency (MIIPA). The Individual Investor Programme is designed to attract global high net worth individuals to obtain Maltese Citizenship and who can share their talent, expertise, and business connections. The IIP is highly regarded and considered to have the best due diligence procedures and in turn, has become the most exclusive and sought-after program in the world. Jonathan is also an advisor on EU Affairs to the Prime Minister of Malta
“ultimately result in increased levels of trust in the industry”