Due diligence process is comprehensive, robust, and meets all international safety and security standards
Due diligence process is comprehensive, robust, and meets all international safety and security standards.

PWM’s Finacial Times Studio commenced an interactive discussion through a special episode on “The Mechanics of Due Diligence, World in Crisis: Securing Citizenship by Investment” with the three major due diligence agencies. The representative of these agencies, such as Exiger, FACT, and S-RAM, with host Youri Bender, held a panel discussion on several aspects of due diligence.

The guest of the panel discussion was 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 delegations touched on the process of due diligence and its significance in the Citizenship by Investment programme in the session.


In addition to that, the session has also centred on the process of the examination of the credentials of the families who applied for the CBI programme.

Firstly, outlining the process of the rigours vetting process, Edy Leviten, who has thirty years of experience while working in the creative industries, retail and enforcement, said that due diligence agencies conduct thorough background checks. The multi-layered checks have been conducted on all the applications, who are over the age of sixteen, and the dependents are also not out of it.

He further highlighted that cross verification is done through the information and data collected by the different databases.

Leviten noted, “We apply the same level of vetting process on dependents as well. We also take a look at the relationship chart of not just the applicant or dependents but also their associates, whether they are in a business or within the family. We also keep an on 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.”

He also emphasized, “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.”

Further, he also provided a framework of the procedure of due diligence; Leviten asserted that it depended upon the different jurisdictions as there are also many countries which are preferred to use two due-diligence agencies for cross-verification.

While highlighting the procedure, he emphasized, “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.”


In addition to that, Karen Kelly, who has worked for around ten years in due diligence and Citizenship & Residency by Investment, also bring out some key factors of the due-diligence in the panel discussion. She said that it is necessary and significant for the host country to conduct a thorough vetting process so that they can determine the true background information of the applicant.

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.

She 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.


Meanwhile, 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 referred to while referring to flag to the clients.

Gunning, who was in the British Army at the start of his career, successfully set up DHL’s operations in Iraq during the end of the Gulf War.

He also outlined the new changing trends in the vetting process of the countries and stated that the tightening of checks of CBI applications had 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 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.