FACT Due Diligence

Whilst FACT has been in existence since 1983, carrying out investigations and developing sophistication in intelligence gathering, we are more recent entrants into the investment migration sector and we see an industry that is addressing challenges and embracing change.

At the recent Global Citizenship Conference in London, FACT spoke about the importance of maintaining high standards in due diligence to ensure that applicants, agents and governments are able to trust in the security of information and that risk is minimised. In carrying out our work, we have to verify identity, background and location, as well as checking against a number of other records and databases. This includes in-country checks, sometimes in regions or countries where information is not always easy to obtain or where there can be risks to our agents and/or the applicant due to state or political interference. Naturally, we mitigate against those risks whilst also ensuring that the client has the fullest picture to make an informed decision on an application.

Our experience in intelligence gathering and investigations has seen us overcome many challenges but we have always adopted the highest possible standards, which has allowed us to present intelligence and evidential packages that have ultimately led to criminal convictions and other disruptive or preventative outcomes. Intelligence, of course, needs to be handled sensitively and confidentially and there are clear guidelines in most countries as to how this should happen. In the UK the National Intelligence Model is the framework for policing that drives strategic direction, decision making, resource allocation and risk management. FACT uses this as part of its daily workflow and it allows us to share intelligence with trusted partners and with government agencies, police and law enforcement bodies globally, as they can all be assured that there is consistency and management of intelligence at all levels of the organisation.

Due diligence work that we undertake for citizenship by investment programmes is treated in the same way and we are keen to work with the IMC and its members to develop best practice and support training for all those working in this field.

Author: Kieron Sharp, Chief Executive, FACT, UK

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