The Citizen: The Case for Regular Look-Backs in the RCBI Compliance Framework

Tuesday, September 22, 2020

Article published in Antigua & Barbados | The Citizen in September 2020.

Residency and Citizenship by Investment (RCBI) programmes are actively seeking to strengthen their compliance regimes to meet the challenge of increased industry scrutiny. Efforts in this regard have included, depending on the country, enhancing due diligence processes, strenthening legislation around approval requirements and revocation processes, and performing periodic, scheduled reviews of previous applications and decisions. An applicant's risk profile may change over time due to new countries; their marital status may change; they may become involved in litigation, start new businesses or enter new industries; their political associations and affiliations may strengthen or diminish. Likewise, geo-political issues and an everchanging global landscape can have a significant impact on the risk profile of an applicant without any action or changes on their behalf.

An RCBI programme's risk framework can also change, as new due diligence standards are adopted, or when new regulations are introduced. Periodic reviews or "look-backs" on previously approved applicants present an opportunity to proactively view such changes accross the entire approved applicant population, identify individuals requiring renewed due diligence, and reassess overall and individual levels of risk against the current framework.

Reviewing previous applicants is a powerful tool to identify and flag instances where their profiles no longer align with an RCBI country's standards. The potential of a look-back is fully realised, however, when incorporated as a regular and periodic event within a robust and structured compliance programme. In performing reviews of an applicant population, information is updated, profile changes are identified, a risk-based approach is employed, and the internal risk assessment framework is optimised based on review findings.

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Karen Kelly , Director, Strategy & Development, Exiger Diligence

Karen is Director of Strategy & Development based in Exiger’s Vancouver office. Karen joined Exiger Diligence from IPSA International, Inc., where she assists on special projects and strategy related to the Immigration, Citizenship & Visa (ICV) Practice.

Russell Scarcella, Director

Russell Scarcella is a Director based in Exiger’s New York City office. Russell brings more than 20 years of legal and risk management consulting and advisory experience assisting clients in developing and implementing due diligence and operational risk programs. He has provided domestic and cross-border investigative due diligence consulting services across the alternative asset community as well as to multiple foreign governments with respect to immigration and citizenship programs.