Updated: June 2026

Case study · Italy · Residence permit

How We Navigated Strict Nulla Osta Compliance and Obtained ItalianResidence Permit for an Entrepreneur from Belarus

When an applicant faces heightened scrutiny, success goes not to those who contest the examination, but to those who respond to it thoroughly and calmly. Our client's application, an entrepreneur from Belarus, received a Request for Information (RFI) from the Committee and enhanced due diligence on source of funds. The case required patience and meticulous attention. We explain step-by-step how we responded to the request and secured Nulla Osta approval.

Sergey EvdokimovSergey EvdokimovManaging Partner, BRIDGESReading time9 min readVerificationReviewed by an expert

This case is based on a real matter. The name and certain identifying details have been changed to protect confidentiality.

BRIDGES client story - How We Navigated Strict Nulla Osta Compliance and Obtained Italian Residence Permit for an Entrepreneur from Belarus
Contents

Case at a glance

Situation, solution and outcome in seven lines

Client
Entrepreneur from Belarus
Objective
Investment-based Italian Residence Permit
Program
Italy, Investment Visa (Investor Visa for Italy)
Challenge
Committee Request (RFI) and Enhanced Compliance
Root Cause
Enhanced scrutiny of source of funds
Solution
Comprehensive, fully substantiated response to the request
Outcome
Nulla Osta obtained, Residence Permit issued

Client story

Client's Story

Where they started

The client conducted a successful business in Belarus and followed the clear investment-based Italian residence permit pathway—the "approval first, investment later" model suited him well. Capital was earned transparently, and he expected standard review procedures.

Why the standard route did not work

However, during the Committee's examination stage, an additional information request—known as RFI (Request for Information)—was issued, and the source of funds was scrutinized significantly more rigorously than usual. The reason lay not with the client himself, but in the broader context: applicants from certain jurisdictions, including Belarus, are subject to enhanced compliance procedures, and inquiries into capital origin go substantially deeper.

What BRIDGES had to solve

For the client, this was an anxious moment: many perceive a Committee request as a near-rejection and begin to panic or, worse, provide formal and incomplete responses. It is precisely incomplete RFI responses that derail such applications—the examination intensifies further.

Why a standard answer would not do

The client approached BRIDGES understanding that enhanced compliance is not a verdict but a task requiring meticulous execution. Our objective was to provide such a thorough and well-substantiated response to the Committee's request that all questions would be resolved and Nulla Osta would be granted.

When the Committee's request arrived, I was frankly frightened—I thought it was practically a rejection. Especially since I knew that we Belarusians face stricter examination. Sergey reassured me: a request is not a rejection but an opportunity to explain everything, and most importantly—to respond comprehensively, not dismissively. The team compiled an exhaustive response regarding the source of my funds, laying everything out clearly. The questions were resolved, and approval came through. I understood that enhanced examination is not a barrier if you respond to it properly.

Dmitry · Entrepreneur from BelarusThe name and certain identifying details have been changed to protect confidentiality.

What Was at Stake

What Was at Stake

The threat was real: under enhanced compliance, an incomplete or formal response to the Committee's request leads to further intensified examination and rejection. The danger lies not in the RFI itself—the request is a chance to explain—but in treating it carelessly. For an applicant from a jurisdiction under heightened scrutiny, the price of a negligent response is particularly high.

passing enhanced compliance procedures regarding source of funds;

  1. 01completeness of the response to the Committee's RFI request;
  2. 02substantiation of capital origin to documentary level;
  3. 03state approval itself—Nulla Osta;
  4. 04risk of rejection upon formal or incomplete response.

The logic of the solution

How the matter progressed: from checks to result

The chart is built from the facts of this matter and shows the logic of the work without decorative or unverified data.

  1. 01
    Stage 1

    We eliminated panic and assessed the request objectively. First, we explained to the client that RFI is not a denial, but an opportunity to resolve issues. This shifted the situation from "all is lost" to "we need to properly address the request" and set the correct mindset.

  2. 02
    Stage 2

    We identified what exactly the Committee was verifying. We carefully analyzed the request: what information and on which aspects of the source of funds was needed. Precise understanding of the question is the condition for a complete response, not shooting in the dark.

  3. 03
    Stage 3

    We compiled a comprehensive source of funds dossier. We gathered documents on the origin of the client's capital—from business activities in Belarus to fund movements—and structured them into a coherent, verified narrative. Under enhanced due diligence, the depth of disclosure must exceed standard requirements.

  4. 04
    Stage 4

    We provided a complete, substantiated response to the RFI. For each point of the request, we prepared a response with documentary support, leaving no open questions. We deliberately avoided a formal brush-off that would have failed the case.

  5. 05
    Stage 5

    We resolved enhanced verification issues. The completeness and substantiation of our response did the job: the Committee received a transparent picture of the source of funds, and enhanced due diligence questions were closed. No further intensification followed.

Takeaway. Conclusion: a Committee request is not a denial but an opportunity to resolve issues. Under enhanced due diligence, the outcome is determined by the completeness of the response on source of funds: a brush-off leads to denial; a comprehensive response leads to Nulla Osta.

How we solved the problem

How we solved the problem

The work was split into verifiable stages so that every conclusion rested on documents.

  1. 01

    Stage 1

    We eliminated panic and assessed the request objectively. First, we explained to the client that RFI is not a denial, but an opportunity to resolve issues. This shifted the situation from "all is lost" to "we need to properly address the request" and set the correct mindset.

  2. 02

    Stage 2

    We identified what exactly the Committee was verifying. We carefully analyzed the request: what information and on which aspects of the source of funds was needed. Precise understanding of the question is the condition for a complete response, not shooting in the dark.

  3. 03

    Stage 3

    We compiled a comprehensive source of funds dossier. We gathered documents on the origin of the client's capital—from business activities in Belarus to fund movements—and structured them into a coherent, verified narrative. Under enhanced due diligence, the depth of disclosure must exceed standard requirements.

  4. 04

    Stage 4

    We provided a complete, substantiated response to the RFI. For each point of the request, we prepared a response with documentary support, leaving no open questions. We deliberately avoided a formal brush-off that would have failed the case.

  5. 05

    Stage 5

    We resolved enhanced verification issues. The completeness and substantiation of our response did the job: the Committee received a transparent picture of the source of funds, and enhanced due diligence questions were closed. No further intensification followed.

  6. 06

    Stage 6

    We obtained Nulla Osta and arranged residence permit. After closing the request, state approval came—Nulla Osta. The client made the investment under the "approval-investment" model and obtained an Italian residence permit. Enhanced verification was completed.

Expert comment

Committee requests frighten clients considerably—almost everyone perceives it as a semi-rejection. But it is not a rejection; it is an opportunity. It is especially important to understand this for those subject to enhanced due diligence: for applicants from certain jurisdictions, including Belarus, source of funds verification is conducted more thoroughly, and requests are not rare but the norm. The problem lies in how they respond to them. Panic or a formal brush-off is a direct path to denial: the Committee reads an incomplete response as "something to hide" and tightens scrutiny further. We always act differently—we treat RFI as an opportunity to explain and respond comprehensively. For this client, we traced the entire history of his capital, mapped the source of funds through documents, and closed every question from the request. Enhanced verification passed; Nulla Osta arrived. Remember: a request is not a wall; it is a door, if answered properly.

Sergey Evdokimov, Managing Partner, BRIDGESSergey EvdokimovManaging Partner, BRIDGES

Outcome

What the client received

What was required
How we did it · Result
Do not panic
Assessment of RFI as an opportunity · Correct mindset
Understand the request
Analysis of Committee questions · Accurate response
Disclose source of funds
Comprehensive capital dossier · Transparency
Obtain approval
Complete response to RFI · Nulla Osta and residence permit
Obtain approval
Complete response to RFI · Nulla Osta and residence permit

What happened: an entrepreneur from Belarus's application for Italian residence permit received a Committee Request (RFI) and enhanced source of funds verification. What we did: eliminated panic and assessed the request objectively; identified what the Committee was verifying; compiled a comprehensive source of funds dossier; provided a complete substantiated response to the RFI; resolved enhanced verification issues; obtained Nulla Osta and arranged residence permit. What the client received: state approval and an Italian residence permit.

Practical takeaway

What matters in a similar situation

  • Conclusion: a Committee request is not a denial but an opportunity to resolve issues. Under enhanced due diligence, the outcome is determined by the completeness of the response on source of funds: a brush-off leads to denial; a comprehensive response leads to Nulla Osta.
  • The client passed enhanced verification and obtained status because we treated the Committee request as an opportunity and responded to it fully and documentarily, not formally.

FAQ

Questions people ask in a similar situation

01What is a Committee Request (RFI) for Italian residence permit?

It is a request for additional information during application review—an opportunity to resolve Committee issues, not a denial. The outcome depends on the completeness and substantiation of your response.

02Why is due diligence stricter for applicants from Belarus?

Applicants from certain jurisdictions are subject to enhanced source of funds verification: questions regarding capital origin are conducted more thoroughly. This is context, not an assessment of a specific individual.

03What should you do upon receiving an RFI?

Do not panic and do not respond formally. You must clearly understand the Committee's questions and provide a complete, document-supported answer to each one, fully disclosing the source of funds.

04Is it possible to undergo enhanced due diligence?

Yes. Enhanced compliance is a task, not a verdict. Full disclosure of the source of funds and a comprehensive response to the request resolve the issues and lead to Nulla Osta.

05What are the risks of a formal response to the request?

Further tightening of the review and risk of refusal. The Committee interprets an incomplete response as an attempt to conceal something, which is why perfunctory responses in such matters are unacceptable.

06Have you received a Committee request or are you anticipating enhanced due diligence?

Treat the request as an opportunity: compile a comprehensive dossier on the source of funds and provide a complete, document-supported answer to each point—to pass enhanced compliance and obtain Nulla Osta.

About the author

Sergey Evdokimov

Author: Sergey Evdokimov

Managing Partner, BRIDGES

As Founder and Managing Partner of BRIDGES, I am responsible for the firm's strategy and personally lead its most complex client matters, including cases in which citizenship or residence decisions require a strategic view and consideration of capital.

I begin by defining the objective: the outcome the client needs, the facts that affect the choice, and the matters that require further review. I then establish the available directions, the sequence of work, and the key decision points.

Once the strategy has been agreed, I oversee the BRIDGES team's key decisions and remain involved at the stages that shape the course of the matter. The purpose is to give the client a clear rationale for the chosen direction and a precise understanding of the next steps.

Prepared on the basis of BRIDGES practice and reviewed by a subject-matter expert.

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Dmitry NagyInternational Tax Consultant, BRIDGES
Dmitry Nagy, International Tax Consultant, BRIDGES

Names and certain details have been changed to protect client confidentiality. The result described reflects one specific situation and is neither a public offer nor a guarantee of a similar outcome. Programme terms are stated as of 2026 and may change - please confirm current parameters with a BRIDGES consultant.