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How does Malta define ‘fit and proper’ for its CBI program?

I want to apply for Maltese citizenship. But the laws say I must be “fit and proper” to get approved. How does the government determine who is that way?

  • November 07, 2018

    To be eligible to apply for the Malta Individual Investor program, the applicant should provide evidence that he/she, as well as his dependents, are fit and proper persons to hold Maltese citizenship. Therefore, through due-diligence processes, it must be proven that the applicant and his dependents are individuals of good conduct and character and have a clean criminal record. In terms of the law regulating the program, the applicant and his dependents cannot have been found guilty (or have pending charges) of any crimes such as terrorism, money laundering, crimes against humanity or crimes that disturb the good order of the family (such as rape, defilement of minors, etc.). Furthermore, to be successful, there should be no reason to believe that the application is deemed to be against the public interest or may be a treat to the national security, public policy or public health or Malta. It is important to understand that the program is regarded as having one of the strictest standards, thus ensuring that only highly respectable applicants will be admitted.

  • Advocates Primei
    October 26, 2018

    An applicant for the Maltese Individual Investor Program (IIP) has to pass through a rigorous due-diligence process which would determine whether he is deemed to be "fit and proper" to hold Maltese citizenship. Hence, it is clear that the "fit and proper" criteria is directly tied to the said due-diligence process.

  • BIZ Consult Limited
    October 28, 2018

    All applicants will undergo a “fit and proper” test so as to show they are in good standing and repute. An extremely high standard of due diligence is carried out on the applicant and his/her dependents so as to ensure that only reputable applicants are allowed to proceed with the application of the Malta citizenship-by-investment program. A four-tier due diligence process is carried out directly by the government that will assess applicants and process applications subject to governmental approval at various stages. All applicants who go under Malta IIP eligibility must have a clean criminal record, with checks taking place with various authorities and sources (the International Criminal Court, Interpol and others).

  • Arthur and Partners
    October 29, 2018

    Kindly note the "fit and proper" test is carried out through the due-diligence process. The first tier is the standard KYC due diligence done by both the IIP Unit and the agent through databases such as World-Check. The second level is the clearance obtained from the police authorities following thorough checks through a number of databases, such as Interpol, Europol and others. Any issues encountered at this stage are reported back to the IIP Unit. It has to be pointed out as well that to be able to visit Malta, third-country nationals have to go through the standard Schengen screening procedures. The IIP team takes care of the third tier of due diligence. There are two stages at this level. The first is that of completeness and correctness of the application. This in itself would identify anomalies in the application form that highlight any potential risk. Every kind of accompanying documentation submitted to the IIP Unit is checked to ensure that it has been filled in correctly and that the documents are submitted in the proper format, correctly translated, and apostilled or notarized, as the case may require. Where documents are missing or not in the correct format or errors are identified, a request for submission is made to the agent representing the family applying for Maltese citizenshiup and the application process is paused until everything is in order. The second stage is that of a thorough and in-depth online due-diligence check and verification of documents submitted. These checks involve checking with international databases for sanctioned individuals and companies. Searches are conducted on all the members of the family applying for citizenship, their corporate affiliations, any significant one-time transactions, donations, or inheritance, and any significant business partners or very close associates. As soon all these checks are done, another member of the due-diligence team reviews all the information collected both internally and externally and puts all the pieces of the jigsaw puzzle together to prepare an internal memo. In cases where more clarity is required, the IIP Unit goes out with further questions to the applicant to ensure it has the right and proper picture of the family’s application. Where necessary, information is bounced back with the due-diligence companies to ensure coherence. 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.