Chetcuti Cauchi Advocates, an international law firm specialising in investment migration, recently published what seems to be the first index specifically measuring the rigor of the due diligence process of citizenship by investment programmes.
Despite all three CBI indices including due diligence as part of their ranking of programmes, the score for each CIP is rarely discussed at length.
Victor Zammit, Senior Manager for Research and Development at Chetcuti Cauchi explains that the CIP due diligence Index is based on measuring 38 criteria grouped into their five pillars which are Identification, Financial Due Diligence, Clearances, Enhanced Due Diligence and Reputation.
The index gives points to a program based on how many of the criteria in each pillar it meets. The data is then normalised to produce composite scores for each pillar which circumvents the arbitrary weighting of any one pillar.
In combination with the Index, the company also proposes an “industry-wide due diligence framework” which it hopes will become a guide to best practices and reduce concerns around vetting practices expressed in the European Parliament and the OECD.
Civiquo, an online, price-transparent market place for investment migration service providers, also proposed a “standardized, open-source, 8-step risk assessment framework to allow anyone to reliably identify the relative risk of taking on an applicant.”
Malta’s Individual Investor Program, whose due diligence procedures are commonly considered the industry benchmark, served as a basis for assessing other programs, giving it a score of 100 on each pillar and top place in the ranking.
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