When looking at some marketing materials for Citizenship by Investment programs, it may seem that all you need to do is select an investment from the options offered, declare your desire to participate, and provide some basic information about yourself. In fact, since the industry’s inception in the 1980s in the Caribbean, absolutely all candidates have undergone a rigorous background check (including due diligence), regardless of what country they are from.
The CIP founders of the programs want to know who they are accepting, how this candidate earned his funds.
Now, when the programs are under close attention in the international media, as well as from European politicians, the quality of checks is especially important for preserving the reputation of the citizenship programs, and therefore their existence. For small countries, issuing passports to foreign investors via CIP is an opportunity to replenish the state budget without the intervention of international creditors.
It is important to understand that a poorly prepared application for the Citizenship by Investment program can seriously delay and complicate the review process.
If the officials who work with the papers think that the information is not accurate, a series of requests for various documents will begin, for example, bank statements, financial statements of companies that the candidate owns in whole or in part. In general, additional data requests are common practice. But not all investors are ultimately approved, and some may be rejected.
“Indeed, files are not always accepted and not always approved. Sometimes only because the client does not disclose information about himself, hoping that no inspection will be able to get acquainted with these facts. Do not underestimate Interpol,” clarifies the Head of the Legal Department of APEX Capital Partners.
Due diligence is a process of comprehensive examination and analysis of an investment object, company or transaction, conducted before concluding a transaction or making important business decisions. The purpose of due diligence is to identify risks, verify the reliability of information and assess the prospects of the investment object.
APEX experience in preparing candidates for Due diligence
APEX Captal Partners has been working as a licensed agent for Citizenship by Investment programs for over 30 years, handling files for submission and preparing them for Due diligence, so you can get a clear picture of the candidate’s capabilities even at the consultation stage.
Pre-check. It is better to choose a pre-check in advance, to undergo a consultation at Apex Capital Partners to identify the strengths and weaknesses of your dossier. Sometimes it is worth giving up some story simply because it is clear in advance that the documents will not be approved. Checking the applicant as a candidate for citizenship is the highest category of check.
What is really important for Due diligence?
- Curriculum Vitae (CV). A business resume where you describe your occupation, your career achievements and other details. There is no template, but we at Apex Capital Partners have seen many such documents and will tell you how to prepare a CV that “sells reputation”, similar to how a job resume sells a specialist to HR.
- Bank account history/cash flow.
- Debts and encumbrances.
- Payment of taxes.
- Have you had any experience in public service, especially importantly, have you had a career in politics (are you a PEP, a “politically exposed person”).
- Your social media history and other open data on the Internet.
In today’s world, social media has become an integral part of our lives, reflecting our views, interests and social connections.
It is not surprising that citizenship units are increasingly turning to monitoring applicants’ personal pages as an additional verification tool.
“On the one hand, such additional verification can help identify cases of providing false information or concealing facts that may affect the decision to grant citizenship. For example, identifying connections with extremist organizations, being in a certain location, having some citizenships or residence permits, property that were not declared in the submitted information. At the same time, the inspection bodies need to take into account that the information posted on social networks does not always reflect the real picture and can be interpreted incorrectly by them. In any case, I recommend that you pay close attention to what you publish. Content on social media carries serious reputational risks. Sometimes even a humorous photo or video can raise doubts from inspection authorities,” – comments Nuri Katz, President and Founder of APEX Capital Partners.
Of course, these processes raise many questions about the ethics, legality and effectiveness of using such information. Questions arise regarding the violation of the right to privacy and freedom of expression.
Who pays for Due diligence?
If participation in something is related to your desire and interest, but the cost of the check will be included in your expenses.
For example, an applicant for “Citizenship of Saint Kitts and Nevis by Investment” or any other similar program must pay a fee at the first stage, which includes Due diligence. Moreover, in Caribbean countries, the procedure of independent verification by a third party is practiced, that is, by a third-party organization that professionally conducts such verifications at the international level.
Each program has a list of current due diligence fees, and exact details can be requested from APEX Capital Partners.
