Due Diligence agencies do cross-checking on many different databases, says Leviten

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Jason Miller

A special episode hosted by the PWM’s FT studio to elaborate the views on “The Mechanics of Due Diligence, World in Crisis; Securing Citizenship by Investment”, where representatives from three major Due Diligence agencies met Yuri Bender, Editor-in-Chief, Financial Journalist at FT’s PWM Magazine.

FACT Worldwide Chief Operating Officer – Eddy Leviten, Director of Strategy and Development EXIGER – Karen Kelly, and Chief Executive Officer S-RM Heyrick Bond Gunning were among the representatives to discuss the importance of due diligence in the Citizenship by Investments program.


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 discussed the importance of conducting a comprehensive screening of applicants. To understand a host country, an investor must look deeply into who they are and what their background is.

She said that the Due Diligence agencies assists the countries to inspect and verify all the applicants and their profile such as their personal documents, financial documents, and criminal backgrounds, by asking the question to the people who knows the applicant, by using on-the-ground intelligence resources.

Additionally, elaborating the differences between the separate jurisdictions EXIGER’s Karen Kelly said that some nations are participating actively to know the new changes about the CBI Programme, she added that the Citizenship by Investment programs in Caribbean calls for due diligence checks at various levels.

Karen Kelly stated while referring to the Carribean countries, “This includes not only third party due diligence agencies but also regional and international law enforcement, intelligence partners to collect information. They are also mandating immigration agents and marketing agents to do KYC- Know your customer, which is an important step.”

Kelly emphasized that Due Diligence firms are not authoritized to decide whether an individual is entitled to acquire the citizenship or not; but the investigation of their personal and family profile will approve the applicants for citizenship of Carribean nations.

Eddy Leviten, who has experience of over thirty years in the retail, creative industries and enforcement, stated that Due Diligence conduct multi-layered investigations on all applicants, including their dependents over the age of sixteen. .

Further, he added that the main applicant and his dependents are screened at the same level, even if they are included in the application later.

While explaining the merits of the Due Diligence the chief operating officer of FACT Worldwide asserted, “We do a similar level of background checks on dependents as well. We not only look at the relationship chart of the applicant or dependents, but also on their associates, whether they are in business or within the family ,”

Explaining the multilayer process, he said due diligence agencies do cross-checking on many different databases.

“We check the birth, marriage and death certificate of family members, educational qualification, employment records in the country, if there we find any red flag, we notify the applicant  immediately.” Leviten emphasized.


Noting to the unqualified applicants, Leviten reiterated if the applicant is master criminal in some country and trying to avoid prosecution then he is not liable to invest in the Citizenship by the Investment Programme of Caribbean Nations; and there would be better ways for fraudsters to hide their assets and move themselves around the world.

He noted that some countries that grant citizenship through investment programs use two due diligence agencies for cross-referencing. Leviten said that once the due-diligence report is ready, it is similar to reading a person’s life story because it contains a lot about the person.

While referring to the robust process of the Due Diligence Leviten stated that the countries around the world, believes that the Due Diligence should have the highest possible standards. “We provide a report back to our clients; what the client does with the report determines whether the applicant will be granted citizenship.”

Noting about common red flags, SR-M CEO Heyrick Bond Gunning said that one of the serious problem arise when people does not provide their actual source of funding; and that particular person does not work in the field from which they have obtained their major source of funding.“There are a number of issues that we see that we flag to our customers (host countries),” he said.


Gunning began his career in the British Army; besides that during the end of the Gulf War he also set up DHL’s operation in Iraq; while delivering his view about the Due Diligence, he also shared some of his work experiences during the pannel discussion. Apart from that, he told that the CBI applications are strengthen in past few years .

“Applicants also go through checks by the firms 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.

Gunning said that despite the challenges caused by the COVID-19 pandemic, Caribbean countries remain committed to the vigorous due-diligence processes. He said the citizenship by investment units of the Caribbean countries became even more focused on their operations and how they run themselves to become more efficient.

Regardless of their small size, Caribbean island countries put all their efforts into ensuring that a robust due diligence process is carried out on all applicants. 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 by investment programmes in the Caribbean.

The due diligence undertaken by these countries is often comprehensive, strong and meets all the international standards of safety, and security. The process requires inspection of all the supporting documents by the third-party due diligence agencies, both regional and international entities concerned with crime detection. The transparency of these programmes helps maintain high CBI standards.

Jason Miller

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