Malta’s Individual Investor Program (IIP) and the Due Diligence Process
Malta’s Golden Visa Program (IIP) is, in general, a well-received program. To be precise, the program adopted by the Malta Individual Investor Programme Agency (MIIPA) has garnered several international positive reviews. Maltese government maintains high quality in its golden visa program by continually developing the processes and adopting an open-minded approach. This way, The Agency ensures the accession of only the rightful applicants through the program. The program is not about numbers, but more about quality and attracting talent who can prove to add value to the country.
The Different Stages of MIIPA’s Due Diligence Process
Malta’s renowned due diligence process involves four levels. The program which is considered the most stringent, and of the highest standard, in the industry owes its success to these four tiers.
The first tier is the standard KYC (Know Your Customer) due diligence done by both the IIP Unit and the Agent through databases such as World-Check.
The second level is the clearance obtained from the Police Authorities following thorough checks through a number of databases, such as Interpol, Europol and others. Any issues encountered at this stage are reported back to the IIP Unit. It has to be pointed out as well that to be able to visit Malta, Third Country Nationals (TCNs) have to go through the standard Schengen screening procedures.
The IIP team takes care of the third tier of due diligence. There are two stages at this level. The first is that of completeness and correctness of the application. This in itself would identify anomalies in the application form that highlight any potential risk. Every kind of accompanying documentation submitted to the IIP Unit is checked to ensure that it has been filled in correctly and that the documents are submitted in the proper format, correctly translated, and apostilled or notarised as the case may require.
The second stage is that of a thorough and in-depth online due diligence check and verification of documents submitted. These checks involve checking with international databases for sanctioned individuals and companies. Searches are conducted on all the members of the family applying for citizenship, their corporate affiliations, any significant one-time transactions, donations, or inheritance, and any significant business partners or very close associates.
The fourth level is conducting outsourced due diligence. Two reports are commissioned from international companies on every family to ensure that as much ground as possible is covered and no stone remains unturned. These checks would include verification of all the information submitted, checks with databases, both international and local, in each of the family’s country of residence, and even discreet on the ground interviews with individuals who know the family.
As soon all these checks are done, another member of the due diligence team reviews all the information collected both internally and externally and puts all the pieces together. In cases where more clarity is required, the IIP Unit goes out with further questions to the applicant to ensure it has the right and proper picture of the family’s application.
Once all questions are answered, every application is first discussed internally within the IIP Due Diligence team. The team is composed of eight individuals from a banking and audit background, and who are trained in anti-money laundering regulations. Together, they share the information internally and corroborate the information gathered, which is then discussed again with the senior management team within the IIP Unit.
Finally, the senior management of the IIP takes a collective decision where a recommendation is prepared and submitted to the Minister responsible for Citizenship, with all supporting documentation of due diligence reports and findings. The Minister, together with the team, reviews the findings again upon which a final decision.