Why Human Source Intel is Indispensable for CIU Due Diligence

Fabienne de Blois

As anyone who has prepared a European or US visa application can attest, documentation to corroborate the commonplace can be hard to come by.

In many parts of the world, even across the wealth divide between states, contractual arrangements that require no input from a court or ministry – such as those pertaining to tenancy and employment – are often not documented in written form.

Of course, in some instances, tax and social security bodies have an interest in verbal contracts being formalized on paper but, in many other contexts, particularly in much of the Arabian Gulf, where income tax obligations are minimal, verbal employment and commercial contracts are legally recognized when they can be attested to by witnesses.

When the required documents don’t exist, some applicants create them

This presents an issue for citizenship by investment units (CIUs) and other migration assessment bodies. While citizenship by investment programs (CIPs) require documents to attest to an applicant’s address or employment, in many cases, these documents do not exist. As such, they must be created specifically for the purpose of the application.

This raises further complexity: If a document attesting to an individual’s employment is obtained specifically for use outside of the jurisdiction in which it is issued, there are far fewer incentives for the issuing body to provide accurate information and no regulatory oversight over the content of the contract.

At this point, insight from human sources becomes invaluable in allowing CIUs to look beyond the paperwork. In many cases, the paperwork itself happens to be misleading. Not necessarily for nefarious reasons but because it seeks to explain information in a way that intermediaries believe will be readily understood by the CIU at the cost of the accuracy of that information.

An applicant who receives windfall cash payouts from his father’s firm but holds no formal contract of employment with the firm might provide a so-called employment letter signed by his father or one of his father’s employees. While on the face of it, the information conveyed in the employment letter is incorrect – and the applicant does not in fact receive a regular salary from the firm, we may find that the applicant really does receive the total annual sum the employment letter indicates but as a lump sum cash payout, rather than regular monthly salary payments.

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When translators think they’re helping by adding context

Likewise, we often find that translators intentionally mistranslate birth certificates – not always for nefarious reasons – but in an effort to portray the birth certificate in a format that they believe will be better understood by the body issuing the passport.

A good example here is in the name field: In many Middle Eastern jurisdictions, naming conventions mean there is no need to list a newborn’s middle names or surname on their birth certificate, as civil law stipulates their father’s legal name determines subsequent names. As such, while the Arabic original in a Saudi or Jordanian birth certificate will list only the subject’s given name, translators often add their middle and surname in the translation of this field.

The effect is that while the applicant’s original document is untampered with, the translation, which is often the only document with which the CIU is able to work, reflects slightly different information from the original.

Of course, beyond validating information provided by applicants and filling in the gaps we identify during the public record research process, human source inquiries also play an integral role in allowing the CIU to assess the source of funds or identify fraud concerns attached to an application.

The risks of relying solely on the media and online public record to build a nuanced picture of a person’s probity and wealth generation trajectory are well understood. Try Google searching someone you know well in a professional or commercial context, and the added value of insight from individuals with real experience interacting with them becomes clear.

While third-party information databases are critical to the early stages of the due diligence process, it is important to remember that the limitations of online research and of an overreliance on third-party data aggregators come to the fore as the due diligence process matures. Not only the availability but also the credibility and accessibility of documentation start to be questioned.

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Fabienne de Blois AuthorSubscriber
Associate Director , S-RM

Fabienne co-leads the S-RM dedicated investor due diligence practice. She has 12 years of experience researching and managing complex due diligence, business intelligence, and corporate investigations projects for multilateral institutions, global law firms, and leading corporates and is well-versed in the intersection between social, legal and economic dynamics and civil society and public record engagement with issues that present global AML and ABC concerns. Before joining S-RM in 2018, Fabienne worked for two leading corporate intelligence consultancies, and in a research capacity for leading academics researching statelessness and political economy dynamics in the MENA region. Fabienne holds a BA in Arabic and Politics from the School of Oriental and African Studies (SOAS), University of London.

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