IM Yearbook 2018/19
Created out of the need for a global, credible, “go-to” industry publication, the IM Yearbook offers valuable access to a prime target audience of your partners, your peers, and the foremost referral network leading to the world’s most influential RCbI programmes: senior level representatives of the global migration industry, academics, migration agents, migration law firms, wealth managers, UHNWI’s, government representatives, and international organisations involved in migration and citizenship-by-investment.
Created out of the need for a global, credible, “go-to” industry publication, the IM Yearbook offers valuable access to a prime target audience of your partners, your peers, and the foremost referral network leading to the world’s most influential RCbI programmes: senior level representatives of the global migration industry, academics, migration agents, migration law firms, wealth managers, UHNWI’s, government representatives, and international organisations involved in migration and citizenship-by-investment.
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<strong>IM</strong> INVESTMENT MIGRATION YEARBOOK <strong>2018</strong>/20<strong>19</strong><br />
Jonathan Cardona, CEO of the Malta Individual Investor Programme AGENCY<br />
The Importance of Due Diligence:<br />
Lessons from Malta<br />
Malta’s Individual Investor Programme is the first CBI programme in the<br />
EU to be endorsed by the European Commission. It is considered to have<br />
the best due diligence procedures in the industry. Jonathan Cardona shares<br />
his thoughts on best practice in the investment migration industry.<br />
Can you give us an overview of<br />
Malta’s Individual Investor Programme<br />
(IIP) and its economic impact?<br />
The programme was not designed to address<br />
any form of economic distress, and our economy<br />
does not depend on income from the programme.<br />
Malta is experiencing growth rates of<br />
6% plus in recent years, and the revenue from<br />
the IIP is certainly welcome and is giving our<br />
economy an extra boost, but it is not required to<br />
keep our economy afloat. When the programme<br />
was launched in 2014, the rationale was to attract<br />
international talent to the country and to create<br />
a sovereign wealth fund. The programme is currently<br />
capped at 1,800 successful applicants, and<br />
to date, we have approved 900 applications.<br />
Malta is often cited as being the reference<br />
point and gold standard in terms of<br />
due diligence. Can you run us through<br />
the process that Malta follows?<br />
We have developed a multi-tier due diligence<br />
system where we ensure that the applicant does<br />
not have a criminal record or pose a threat to<br />
national security. First of all, applicants do not<br />
approach the agency directly, but all applications<br />
have to go through an approved agent.<br />
These agents conduct tier 1 due diligence, including<br />
KYC checks in line with established industry<br />
standards. If these checks yield positive<br />
results, the applicant can move on to the next<br />
stage, which is the application for a residence<br />
card. As part of this process, the Maltese police<br />
perform background checks and searches in the<br />
Europol and Interpol databases. Once the agent<br />
receives clearance from the police, the applicant<br />
can start preparing the actual application for the<br />
programme. It usually takes between two to six<br />
months to complete the application and gather<br />
all the supporting documentation.<br />
Can you tell us what checks you perform<br />
when screening applicants, and how exactly<br />
you develop an applicant’s risk profile?<br />
Once we receive the IIP application, we ensure<br />
that all the documents that we require have actually<br />
been submitted, such as birth certificates,<br />
marriage certificates, inheritance certificates and<br />
Bio : Jonathan<br />
Cardona is the<br />
Chief Executive Officer of<br />
the Malta Individual Investor<br />
Programme Agency (MIIPA).<br />
The Programme is designed<br />
to attract global highnet-worth<br />
individuals to<br />
obtain Maltese Citizenship.<br />
Jonathan is also an advisor<br />
on EU Affairs to the Prime<br />
Minister of Malta.<br />
company information. We then pass on the information<br />
to specialist due diligence companies.<br />
We always contract two companies to investigate<br />
each applicant. Connecting the dots between<br />
people, businesses and financial records has<br />
become a complex task, and we take no chances.<br />
Once we receive the reports prepared by the<br />
third-party due diligence firms, our internal<br />
due diligence team goes through the file again,<br />
adding our own findings from sanction lists and<br />
other online databases. They create an internal<br />
executive summary about the applicant, applying<br />
a risk matrix with seven categories that we<br />
have developed.<br />
The risk matrix starts with the identification<br />
of the family and the question whether they are<br />
politically exposed persons (PEPs). We also place<br />
a strong emphasis on the source of their funds<br />
and the source of their wealth. We are further<br />
looking into their business affiliations, their<br />
general reputation and any legal as well as regulatory<br />
issues that might affect the application.<br />
Last but not least, we define their ‘impact radius’.<br />
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