Due diligence is at the forefront of the Malta Citizenship by Investment Programme. Therefore, the government has devised an “internal risk matrix”, which ensures that the agency judges every application on a systematic and consistent basis.

Risk Assessment for Malta Citizenship by Investment Programme

The matrix has seven categories:

  1. Identification and Verification
  2. Business and Corporate Affiliations
  3. Politically Exposed Persons (PEPs)
  4. Wealth
  5. Reputation
  6. Legal and Regulatory Matters
  7. Relative Impact on the MA’s Immediate Network

Identification and Verification

Checking the applicant’s identity to ensure that their application is correct and truthful, as well as assessing the countries the applicants have resided in over the past ten years.

Business and Corporate Affiliations

Taking into consideration the applicants ties with offshore activity, jurisdictions and industries.

Politically Exposed Persons (PEPs)

This category assesses applicants who are politically exposed persons (PEPs) and are or have been on sanctions or watch lists.


A significant focus of the due diligence process looks at how the family have accumulated their wealth. Starting from where the funds for financing the application originated. The risk assessment looks into bank statements, articles of association, share registers and certificates of incorporation, certified copies of contracts, and transactions amongst others. Tax evasion risks are also taken into consideration.


Examining the applicant through Open Source Intelligence (OSINT), reports and on-the-ground intelligence.

Legal and Regulatory Matters

The focus on legal and regulatory matters checks the applicant for any charges or convictions for criminal or civil offences, including fines at an incremental period.

Relative Impact on the Main Applicant’s Immediate Network

Unique to the Citizenship by Investment industry, this search consists of an analysis of the applicant’s activities and the relative impact on the MA’s immediate network and society in general. Therefore, this ensures that all bases are covered is anything that was missed in the above categories.


There is no room for negotiation with these criteria as integrity is at the forefront of the Malta Individual Investor Programme. All applicants have their details submitted to the Financial Intelligence and Analysis Unit (FIAU) for full transparency. Decisions within Malta Individual Investor Programme Agency are documented and substantiated with the required rationale, and signed off by the Approved Agents, to ensure transparency and accountability. Therefore, this
risk assessment for Malta Citizenship by Investment Programme ensures that all applicants are assessed pragmatically and clearly to allow only the best and most qualified candidates to have a Malta Passport.

Papilio Services Limited – Approved Agents

Are you considering Malta Citizenship by Investment? Papilio Services can help as we are approved agents through Identity Malta we can assist you and your family with the residence application through to the issuance of your Malta Passport.

Contact our team today to arrange a consultation by emailing us on enquiries@papilioservices.com or call us directly on +356 2122 7553, and we will respond to you within 24 hours.

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