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.
