Due Diligence Process
The due diligence process which has been developed and adopted by the Malta Individual Investor Programme Agency (MIIPA) has garnered several international positive reviews. This is the result of an open-minded approach and the continuous development of internal processes to ensure that only the rightful applicants make it through the programme. The programme 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
The Malta IIP has a four-tier due diligence process, which is considered the most stringent, and of the highest standard, in the industry.
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. If the team deems that more information or clarifications are required before a recommendation is made to the Minister, these are requested from the applicant. In some instances, another report is requested on specific areas of concern.
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.
Due diligence within MIIPA is taken very seriously. All employees working in the due diligence section go for an AML course to have a better understanding of what is expected of them. In addition, the employees within this section all have previous experience in either Risk and Compliance or Audit.
Identification and verification
Business and Corporate Affiliations
Politically Exposed Persons (PEPs)
Legal and Regulatory Matters
Relative Impact on the MA's Immediate Network
The six categories of risk mentioned so far are very commonly analysed within the financial sector. However, the seventh category is somewhat bespoke to the industry of CBI and consists of an analysis of the MA’s activities and the relative impact on the MA’s immediate network and society in general. This is to ensure that no stone is left unturned and to enable the team to cover any incidental area, which is deemed essential and was not covered by any of the other previous categories.
Decisions within MIIPA are documented and substantiated with the required rationale, and signed off by the responsible person, to ensure transparency and accountability.
As an oversight of the whole process, there is also a regulator who reviews all the applications to ensure that the procedures were followed correctly. The regulator is appointed by the government after consulting the opposition party. The regulator prepares a report, which is then presented to a monitoring committee composed of the Prime Minister, the Minister Responsible for Citizenship and the Leader of the Opposition.