How We Conduct In-Country Checks in a COVID World
Trust and confidence matter more than ever in a world turned upside down by the pandemic. As the world struggles to find a way out of the current crisis, there is much that can be learned from what happened in the run-up to Covid-19 taking hold and in the subsequent reaction of governments businesses and individuals.
Investment migration provides opportunities for individuals and their families to change their lives for the better and for governments to benefit from investment to improve the lives of their citizens and future citizens. However, as we know, it is vital that those applying for citizenship through approved schemes are properly vetted and verified to ensure they pose no risk to the country to which they are applying for citizenship nor to the countries to which they might travel in the future using their newly acquired passports.
Independent third-party due diligence is the cornerstone of any citizenship programme and numerous checks are required to verify identity, location, property, financial interests and personal information. Whilst some of this can be verified through online checks, the only means of carrying out a complete verification is through in-country checks; visits to confirm addresses and businesses and visits to local record offices to check documents. This is particularly vital in countries where digital records are non-existent or where physical documents may be unreliable.
2020 has so far proved to be a challenging year; for CBI and RBI programmes, for applicants and for due diligence providers. Lockdowns and restrictions on movement, combined with the closure of government offices, have slowed down the ability to apply, process and verify. In the case of verification, this has meant having to review on a daily basis the situation in specific regions or countries to assess the ability to obtain information, to manage risks to agents and applicants and to ensure that verification can be completed satisfactorily. This may not always be easy but communication with clients is crucial, as is utilising a variety of methods to assess the veracity of documents whilst maintaining the highest standards of due diligence.
Online resources can certainly offer some solutions, but it is only through oversight by experienced researchers and analysts that a full picture of an applicant’s good standing can be obtained and communicated to the client. Whilst the overwhelming majority of applicants to programmes are acting in good faith and are not seeking to mislead or provide fraudulent information, it is well documented that there are some who may seek to use CBI and RBI programmes as a cover for criminally obtained wealth. A global pandemic may also have given some the mistaken belief that they can avoid detection during applications if they think that less checks can be made. In-country checks on residential and business locations, finances and assets, and criminal and civil records form the backbone of a complete due diligence process, and, by and large, these have all continued to be carried out during 2020, though with some delays.
Detailed local knowledge should ensure that, where there are intermittent interruptions to travel, these can be overcome by alternative means of verification or by referring back to an analyst who can add their skills to the mix. Identifying unusual behaviours or issues with documentation requires sometimes detailed understanding of cultural, political and hyperlocal influences that need to be reflected in the checks made in country and online and then reported back to the client in interim and final report stages. That may also require a delay to standard reporting timelines to ensure accuracy and that all checks have been carried out.
On top of the ongoing need to ensure that no shortcuts are taken in the due diligence process, recent negative media reports around some schemes mean that due diligence is in the spotlight more than ever. The Investment Migration Council’s recommendations for best practice are to be welcomed, yet it is vital that the investment migration sector as a whole takes on board and supports these measures. Pandemic or not, there can be no cutting of corners in any part of the verification process.
Author: Eddy Leviten, FACT’s Chief Operating Officer