Due diligence firms do cross-reference on lots of different databases, says Eddy Leviten

PWM’s Financial Times studio broadcasted an exclusive episode on , “The Mechanics of Due Diligence, World in Crisis: Securing Citizenship by Investment”, in which the members of the three major due diligence firms participated in a panel to discuss due diligence in citizenship by investment programme with Editor in Chief, Financial Journalist, Yuri Bender at FT’s PWM Magazine.

Eddy Leviten Chief Operating Officer of FACT Worldwide, Karen Kelly Director of Strategy and Development at EXIGER, and Heyrick Bond Gunning Chief Executive Officer of S-RM, discussed the need for due diligence in the citizenship by investment programme.

Karen Kelly, EXIGER’s Director of Strategy and Development, who has over a decade of expertise in due diligence and Citizenship & Residency by Investment, also spoke on the need of doing strict checks on applicants. She also said a host country must take an in-depth look at the investor to comprehend who they are and their backgrounds.

Kelly also went on to say that the due diligence agencies assist the governments in verifying all applicants and scrutinizing their bio-data, including personal documents, financial documents, and criminal backgrounds, by using on-the-ground intelligence resources by asking questions to individuals who know the person.

In addition, while discussing the difference between jurisdictions, Karen Kelly stated that some nations are actively engaged in the due diligence multi-layered procedure and asking questions regarding the new developments. She added that citizenship by Investment programmes throughout the Caribbean include various phases of due diligence checks.

“It not only involves the third party due 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,” said Karen Kelly, while referring to Caribbean countries.

However, the due diligence provider is not there to decide whether an individual should be approved for citizenship or not, highlighted Kelly.

Eddy Leviten, who has over 30 years of experience in the creative industries, retail, and enforcement, said that due diligence agencies carry out multi-layered checks on applicants, including their dependents over the age of sixteen, before granting them secondary citizenship.

Moreover, he highlighted that the principal applicant and his/ her dependents are subjected to go through the same level of scrutinization even if they join later in the application.

“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,” added Chief Operating Officer of FACT Worldwide.

While explaining the process of due diligence, he added that agencies do cross-reference on lots of different databases.

“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 it the client.”

“If you’re a master criminal looking to avoid prosecution in a country, 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 world,” he added while referring to the robust due diligence procedure.

Furthermore, he stated that some nations which provide citizenship by investment programmes use two due diligence agencies for cross-referencing. Leviten added that once the due-diligence report is prepared, it is like reading an individual’s life story because it contains so much information about the person.

Every country, according to Leviten, 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.”

While discussing the common red flags, CEO of SR-M Heyrick Bond Gunning said one of the major red flags is when the person does not 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.

During the panel discussion, Gunning shared some of his life experiences. He said that he began 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.

Besides this, Gunning also said that the tightening of checks of CBI applications increased in the previous 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.

Despite the numerous challenges caused by the COVID-19 pandemic, Caribbean countries remain committed to the robust due-diligence procedure. He stated that the Caribbean countries’ Citizenship by Investment units have become even more focused since the daw of the pandemic on their operations and how they run themselves in order to become more efficient.

These countries’ due diligence is frequently comprehensive, robust, and meets all international safety and security standards. The procedure includes reviewing of all the supporting documents by the third-party due diligence agencies, both regional and international entities concerned with crime detection as part of the process. The transparency of these programmes contributes to the maintenance of high CBI standards.