What is due diligence in CBI applications?
Due diligence in CBI is the multi-stage screening process operative programmes apply to applicants. Frameworks include government-mandated background checks, third-party investigative firms, sanctions and PEP screening, source-of-funds review, and biometric capture. Malta operates the strictest framework (four-tier); Caribbean five operate a converged harmonised framework; Vanuatu operates the lightest. Diligence depth correlates with banking acceptance of the resulting passport.
Due diligence frameworks across operative CBI programmes share a common structure but diverge sharply in depth. Every programme runs: government-mandated background checks against criminal databases; third-party investigative firms (Exiger, World-Check, S-RM are dominant) for international screening; sanctions and politically-exposed-person (PEP) lists at OFAC, EU, UK, and UN levels; source-of-funds (SoF) chain review; and biometric capture. The depth of each layer varies by programme. Malta operates the strictest framework — the four-tier model introduced in 2024 layers government, third-party investigative, and intelligence-services review with the highest evidentiary threshold globally. The Caribbean five operate a harmonised MoA framework with shared regional CARICOM-level checks plus programme-specific national review. Turkey operates a real-estate-registry-driven framework with property due diligence overlaying applicant screening. Vanuatu operates the shallowest framework with a single-stage national review. Applicant disqualifiers across all programmes include sanctions or PEP overlap, prior visa rejections at top-tier jurisdictions (US, UK, Canada, Schengen), undocumented source-of-funds chains, prior tax-evasion findings, and serious criminal records. Diligence depth correlates directly with banking acceptance of the resulting passport — Maltese CBI passports face minimal additional KYC at Western banks; Vanuatu CBI passports face heavy additional KYC. Pre-application screening with a senior advisor identifies risk flags 3–6 months before filing.
5 programmes relevant to this answer
Malta
St. Kitts & Nevis
Dominica
Antigua & Barbuda
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Sanctions or PEP overlap, prior denied visa applications at top-tier jurisdictions, serious criminal record, undocumented capital chains, prior tax evasion findings. Pre-screening identifies these before formal filing.
Typically $7,500–$15K per applicant; included in the fees structure of most programmes. Higher for files with international complexity (multi-jurisdiction business interests, complex inheritance chains).
Concurrent with overall processing. For Caribbean programmes, ~60–90 days of the published 2–4 month window is diligence. For Malta, ~3–6 months of the 12–14 month timeline is diligence-driven.
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