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The Case for Regular Look Backs in the RCBI Compliance Framework

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This piece was originally featured in The Citizen

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, strengthening 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.

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