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The Citizenship by Investment program in Malta has the world’s strictest due diligence standards and vetting of applicants, according to Henley and Partners, that helped design its original iteration. 

In the advisory firm’s latest report, “Investment Migration Programs 2021”, it details how each application is “thoroughly checked and assessed and undergoes a four-tier due diligence process including through background checks”. 

Only then (and after the fulfilling of the investment, donation, and property requirements), in the words of the firm, are applicants “invited to come to Malta to take the oath of allegiance, after which a Maltese certificate of naturalization is issued”. 

The report emphasises the strength of the vetting and due diligence implemented by Malta’s citizenship by investment programme, identifying it as one of the scheme’s four “key advantages”. 

12 citizenship-by-investment programs were compared by the firm, and Malta’s once again beat the competition to be ranked at the top of the index. 

The programmes were rated out of 10 in 10 categories, including application processing time, quality of life, reputation, transparency and investment requirements.

In three out of the categories (compliance, relocation flexibility, and passport strength), Malta scored a perfect 10, and the country’s program only dropped 20 points in the other areas, to score 80 – one higher than the 79 it scored in 2020. 

Another advantage of Malta’s scheme, as identified by Henley and Partners, is that the nation “enjoys an excellent reputation for its splendid climate, friendly people, low crime rate, and superb quality of life”.

Furthermore, from a business perspective, Malta might appeal as a “transparent, reputable financial center and a jurisdiction for international business”. 

Henley and Partners’ relationship with Malta’s Citizenship by Investment program has come under scrutiny in recent years.

In 2014, when Malta’s Individual Investor Programme (IIP) was unveiled as the first EU-approved citizenship by investment programme in Europe, London-based Henley and Partners had been contracted by the Government to design and implement the program, and to serve as the scheme’s sole concessionaire.

Under the agreement, the company would receive four per cent out of every contribution fee paid by successful citizenship applicants, for its 10-year duration.

However, the controversial scheme faced opposition from inside and outside Malta and in 2020, the Maltese Government issued a new set of regulations that it said would address the concerns of one of the scheme’s key detractors, the European Commission.

As reported by the Times of Malta in July, the new scheme does not include Henley and Partners as its concessionaire, although this move made the Government “liable” for the losses incurred by the firm as a result. 

Parliamentary Secretary for Citizenship and Communities, Alex Muscat announced in July that the IIP would be scrapped in favour of a residency scheme that could lead to the granting of citizenship.

Recent criticism and negative publicity about Malta’s scheme, including that from the European Commission, has focused on the programme’s “soft residency requirement” along with “concerns over risks associated with tax evasion and money laundering”, according to CBI Guide.

For its advocates, the programme’s benefits are, however, obvious and quantitive.

The initial IIP scheme is said to have generated €1.5 billion in six years. As of December 2019, 833 investors and 2,109 family members had obtained Maltese citizenship through the scheme, according to the BBC.

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