The CBI industry is made up of private and professional stakeholders assisting applicants apply for a CBI programme: marketing agents, immigration agents, concierge firms, law enforcement agencies and financial institutions or wealth managers.
1. Marketing Agents
Marketing agents recruit prospective investors to a programme and usually target
jurisdictions that are likely to have a large source of applicants. many marketing agents may be officially authorised by a host jurisdiction for one or several programmes, but then also advertise for programmes from other jurisdictions with which they hold no formal association.
2.Immigration Agents
Immigration agents are usually regulated law firms or immigration assistance companies that assist applicants in organising the documentation needed to apply to CBI or RBI programmes. In some jurisdictions, particularly where immigration agents are required to be regulated members of the legal profession,
3. Financial Institutions and Accountants
Applicants may engage with financial institutions and accountants at the pre-application stage for advice on investment choices and the financial elements of the programme. They may also be involved in the provision of mandatory evidence, such as proof of applicant’s funds.
4. Concierge Firms
Concierge firms act as an intermediary between an applicant and the wider service provider ecosystem. Their role is to arrange packages of services from a network of providers and to provide wider associated services, such as finding clients private schooling for their children, purchasing property, registering businesses, and generally acting as a “fixer” for prospective applicants
5. Due Diligence Firms
Due diligence firms have become a common feature within the application processing
function, particularly within the CBI ecosystem. Due diligence firms often serve as the primary means through which CBI programmes verify the identity background of applicants. This is accomplished through an extensive investigation of private and public sector records. Some CBI and RBI programmes contract with due diligence firms to produce a report on each applicant and their families to gather information in addition to what is provided by the applicant. Due diligence firms are more commonly encountered working under contract to CBI programmes during the assessment stage. due diligence firms do not have access to information held by law enforcement agencies (LEAs), the FIU or other closed information sets that may hold derogatory information on the applicant. it is important to note that due diligence firms provide
information to help countries mitigate risk, but the issuing jurisdiction takes the final decision on whether to grant or refuse a case as this is an inherently governmental function that can only be granted by a competent authority operating a CBI/RBI program.
6. CBI Investment Units
Investment units associated with CBI/RBI programmes are dedicated government units that exist either as a distinct function within their immigration system, or in some cases, as quasi commercial bodies headed by a government appointed Chief Executive Officer. Investment units may be chiefly responsible for carrying out governance functions for a jurisdiction’s investment migration programmes. These include the oversight of authorised agents, marketing of the programme, appointing due diligence providers and the associated validation of required investment activity.
7. Immigration authority
Immigration authorities may operate under an investment unit or conduct conventional
casework. The CIU undertake checks in the context of an investment migration application, including verifying:
• Identity and supporting documents and mandatory evidence documents for applications,
• Individual immigration history,
• Minimum requirements for required investment funds,
• Source of funds,11 and
• Criminal records and/or law enforcement database checks
8. National Law Enforcement, FIUs and Intelligence Agencies
National law enforcement, FIUs and intelligence agencies play a critical role in identifying ML and other financial crime risk. Given the money laundering and illicit finance risk associated with investment migration programmes, some countries have relied on their law enforcement and intelligence communities and their FIU within the application screening process. In these cases, the FIU’s role is to carry out verification and screening of applicants utilizing investigation and intelligence databases held by a jurisdiction’s wider law enforcement and national security community and include checks against available international information sharing databases, in particular Interpol.
9. Multilateral Law Enforcement Co-operation
Multilateral law enforcement co-operation can be a key element of most countries CBI or RBI programmes. The role of units dealing with such cooperation is to screen names across international databases, such as those held by Interpol. Some countries also participate in wider regional initiatives particularly where free trade and movement agreements are in effect. In the Caribbean for example, the Caribbean Community (CARICOM) group of nations Joint Regional Communications Centre (JRCC) run by CARICOM’s Implementing Agency for Crime and Security has played a role in the vetting process for CBI programme applications. The JRCC demonstrates how small countries can pool resources to share information particularly where issuing countries have a common interest. Similarly, EU member states running investment migration programmes within the European Union normally run checks that would draw on shared intelligence resources and cooperation entities such as the Schengen Information System (SIS) and Europol.
10. Banks / Financial Institutions
FIs play is as a gatekeeper to the initial receiving of funds into a jurisdiction and as facilitator and investigator of any further qualifying investment transactions. Requirements for applicants to open accounts with a regulated financial institution in the issuing country engages an additional set of independent onboarding due diligence and financial crime obligations beyond the checks carried out by the country operating the programme
11. Councils & Associations
Membership organisation and lobbying group bringing together the leading stakeholders, governments, lawyers, agents, non-profit firms, due diligence firms, developers, in the CBI/RBI business. The association sets global standards, provides qualifications and publishes in-demand research, organises annual events in the field of investment migration bringing together governments, policy makers, international organisations, and the public.
