Updated
GL-D-03
Glossary · Due Diligence and compliance
Due Diligence - Trustworthiness check
The main check when obtaining citizenship or residence and opening an account. It reviews criminal history, sanctions lists, the origin of funds, court cases, PEP links and mentions in the media. Cost ranges from $50 for a basic screening to $20,000+ for a deep citizenship check; the standard check for residence and citizenship is $1,000-5,000 per applicant.
01 / In 30 seconds
The short answer
- What it is
- An in-depth background check on the applicant before a passport or residence permit is issued or an account is opened
- Where it applies
- Citizenship and residence by investment, bank accounts, large transactions
- Cost
- From ~$50 for basic screening to $20,000+ for citizenship; a standard residence or citizenship check costs $1,000-5,000 per applicant
- Duration
- 2-8 weeks, longer in complex cases
- Can you prepare
- Yes, and it decides the outcome: the source-of-funds file is assembled in advance
02 / In plain words
What Due Diligence means
Due diligence is an in-depth check on an applicant carried out by a state or a bank before it issues a passport or residence permit or opens an account. Put simply, the country wants to be sure it is taking on a reliable person with no hidden problems.
The check is broad: criminal history and convictions, sanctions lists, the origin of money and wealth, court and tax disputes, political connections (PEP status), and mentions in the media and open databases. In essence, a specialised licensed firm compiles a file on you and stakes its reputation on the conclusion — “clear” or “risk”.
This is the key stage: it is at the check that refusals most often happen. The good news is that you can and should prepare for it in advance — gather documents on the origin of your money, explain contentious points before they are found, and file the application so that the reviewer is left with no questions.
In Vanuatu the state due diligence is run by the FIU financial intelligence unit before the Commission filing, with a $5,000 or $8,000 fee per application. Before it we run our own pre-check in 1-2 working days.
A case from practice
An applicant for Grenadian citizenship sold a business five years ago and has lived on the proceeds since. During due diligence an old lawsuit from a former partner surfaces. If the court decision and an explanation are attached in advance, it is a passable episode. If the reviewer finds the lawsuit on their own, with no explanation, the application may be rejected — and the check fee will not be refunded.
When you will encounter due diligence
- Obtaining a second citizenship
- Opening a bank account abroad
- Company registration
- Property purchase
- Entering an investment fund
- Family offices and wealth management
03 / What it covers
What due diligence covers
Identity
- Convictions and police records
- PEP status (politically exposed person)
- Political connections and associates
Finance
- Source of funds
- Source of wealth
- Large transactions and transfers
Reputation
- Sanctions and wanted lists
- Media mentions
- Court proceedings and lawsuits
Business
- Corporate history
- Beneficial ownership
- Related companies
04 / How it works
How the check works
Preparing documents
Internal check
Filing
State check
Result
05 / Key facts
What is usually checked
01
International databases and watch lists
02
Sanctions lists (OFAC, EU, UN)
03
Court judgments and lawsuits
04
Media and open sources
05
Corporate and beneficial ownership registers
Common mistakes
- Hiding a conviction or a lawsuit — the reviewer will find it anyway, and trust in the application collapses
- Not preparing documents on the origin of the money in advance
- Stating one thing on the form while the databases show another — a mismatch reads as a lie
- Filing without a preliminary internal check and learning of the problem from the refusal
- Underestimating PEP status for yourself or close relatives
06 / Expert advice
Can you prepare in advance
Yes, and it decides the outcome. Before filing, assemble a file on the origin of your wealth (source of wealth) and of the funds for the investment (source of funds), explain contentious episodes in advance with documents — old lawsuits, the sale of a business, large transfers — and check yourself against the same open databases the state uses. Then by the time of the check the reviewer has no questions left, and you do not pay for the check in vain.
What we do for you. We go through due diligence with you: we run an internal check in advance against the same databases the state uses, find the weak points and close them with documents before filing. That way you learn about the risks from us in advance — before filing and before the check fee is paid.
Klara RihterBanking compliance and source of funds specialist
07 / Questions
Frequently asked questions
It depends on the depth of the check. Basic screening (sanctions, PEP, media): $50-300. An enhanced check for a bank account: $300-1,500. Professional due diligence for residence and citizenship: $1,000-5,000 per applicant. An in-depth investigation for citizenship and complex cases (Kroll, Control Risks and others): $5,000-20,000+. This is a non-refundable fee: it pays for the check itself, regardless of the outcome.
An unclear origin of money, concealed convictions or lawsuits, links to sanctioned persons, and lies on the form. Another common ground is a mismatch between what the applicant wrote and what the reviewer found.
Yes, and that is the main thing. We assemble a file on the origin of your funds (source of wealth and source of funds) in advance, check you against open databases and prepare explanations of contentious episodes — so that no questions remain by the time of filing.
Usually 2-8 weeks. Simple cases close faster, while for citizenship and with a complex capital structure the check may take several months — especially if additional documents are requested.
The check is commissioned by the state or a licensed agent and carried out by a specialised due diligence firm — often an international agency (Kroll, S-RM, Control Risks and others). Several independent firms sometimes work on a single applicant.
Identity and documents, criminal history and court cases, sanctions and wanted lists, PEP status, the origin of wealth and of the funds for the investment, business reputation, business interests and beneficial owners, and mentions in the media and open registers.
No. The due diligence fee is non-refundable: it pays for the work of checking, not for the result. That is why it matters to close the weak points with documents before filing — so as not to pay for the check in vain.
As a rule, all applicants included in the application above a certain age (usually 16-18): the principal investor, the spouse, adult children and sometimes parents. The fee is paid separately for each adult applicant.
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