PWM’s Financial Times Studio conducted an edition of a special episode focusing on “The mechanics of Due Diligence, World in Crisis: Securing Citizenship by Investment,” where representatives of three most dynamic due diligence agencies took part. Yuri Bender, Editor in Chief Financial Journalist at Financial Times PWM Magazine, hosted the special panel.

The expert panel included 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.


Kelly, who has over a decade of experience in due diligence, residency and citizenship programmes, said all host countries engage a third-party due diligence agency to ensure thorough checks upon applicants. She stated the scrutinization includes comprehensive document verification, criminal background checks, on-ground examinations etc.

Kelly also discussed the essence of carrying out extensive checks on applicants; she emphasized that the host country must take a very in-depth look at the investor to understand who they are and their backgrounds.

While highlighting the significance of the due diligence process in residency & citizenship by investment programmes, Karen Kelly of EXIGER also said that in-depth information checks help understand the source of funds an applicant is using for investment purposes.

While referring to the major Citizenship by Investment Programmes in the Caribbean, she said they meet the international standards and pay key attention to due-diligence procedures.


“The programmes in Caribbean countries are not only meeting the minimum standards but also carrying out different levels of due-diligence process in a very effective manner, for which they also engage with regional, national and international law enforcement,” Karen asserted.

Eddy Leviten, Chief Operating Officer of FACT Worldwide, explained how an application is scrutinized through different databases.

“We cross-check the credentials and documents via many different databases; the multilayered due diligence process is performed with accuracy and sharpness. We check up all the records of the person involving birth, marriage, and other educational qualification as well as employment of the family,” said Eddy Leviten.

Leviten said the main applicant and their dependents undergo similar background checks. The checks are carried out thoroughly across all the applicants.

While highlighting the necessity to conduct deep and enhanced due diligence on applicants, Eddy Leviten said, “We carry out the same level of investigation and checks for all the applicants and dependents based on the criteria that are given to us by the client country.”

Eddy Leviten, an expert in KYC, fraud, due Diligence, content protection, as well as business intelligence, also said that some countries use two different due diligence agencies for better security and cross-referencing.

Furthermore, he stated that once the background checks are done, a comprehensive report is prepared, which is similar to a person’s biography because it includes every little detail.

“We don’t make the final decision, we just return the report back to the client, and it’s ultimately upon them, whether they approve the citizenship or not,” Leviten explained.

CEO of SR-M Heyrick Bond Gunning, discussed the common challenges and red flags in due diligence. He said one of the major red flags is when the individual doesn’t 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 also focused on the importance of due diligence in the Citizenship by Investment Programme. He started 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. He shared some of his experiences during the panel discussion.

According to the CBI Index published by Financial Times’ PWM Magazine, Caribbean countries are ranked at the top position because of their stringent due diligence processes. The report further elaborates those frequent updates and amendments to the due diligence credits to the high regard of the programmes maintaining international standards.

As per the Index report, the Caribbean region has been very keen on putting efforts into polishing the integrity of their CBI Programmes and maintaining its safety and security.


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