Common reasons why a second citizenship can be denied

The ‘Citizenship by Investment’ programmes – where individuals invest in real estate or a government fund in order to qualify for second citizenship and a passport – have become more popular in recent years in the Middle East.

But applying for a second citizenship is not just about how much money you have but also the integrity of your profile.

The first step in investing in any of these programs involves a detailed security check, where a person’s background is thoroughly examined to make sure they are not involved in any criminal activity or have not acquired their wealth through illegal means such as money laundering.

How is this background check process carried out?

The government citizenship units deploy third-party due diligence providers such as Thomson Reuters World-Check service or IPSA International, who use a mix of publicly available information and a bit of on-ground detective work to confirm whether information provided in the citizenship application form is true.

This can include visiting a person’s office to ensure the business address provided is linked to an operational company, fact checking official documents like birth certificates and marriage certificates, reading local media reports or even checking out your LinkedIn profile to confirm your work history. If it’s in the public domain, you can be sure that the due diligence providers will find it.

In addition to the publicly available information, the due diligence providers also communicate with law enforcement records, global alert systems, sanctions and embargo lists, and Interpol blacklists to identify anyone who has ever had an encounter with the law or committed a criminal act.

How does one deal with the issue of identical names, especially in the Middle East?

The question of identical names is one that does come up – sometimes an ordinary individual happens to share a name with a criminal or blacklisted person.

It just means extra hours of thoroughly checking the individual’s identity for the due diligence officer handling the case. The main reference document for citizenship is the individual’s birth certificate and this is used as the base document. After that it is up to the due diligence provider to thoroughly check the facts in order to confirm the person’s correct identity. If any suspicious information turns up, the agent processing the application is notified and then the applicant is given the opportunity to explain the information and to produce sworn affidavits to clarify any details.

Most are common grounds for denial of an application

The government citizenship investment units check the following criteria before they grant citizenship to a foreign national – 

1. Is this person going to be a security risk to the country?

This can be due to previous criminal activity, association with terrorism activities etc. A criminal conviction will be a problem. A civil law suit may not lead to an automatic denial but will need to be explained in detail.

2. Is this person going to be a reputational risk to the country?

An individual may be involved in a business such as selling arms – which is technically not illegal when carried out with a licence – but it may still not be one that a government wants to be associated with. Politically Exposed Persons (PEPs) often carry similar reputational risks.

What happens when an applicant fails the due diligence check?

If an applicant is a security risk, it is usually an immediate denial with no chance of the decision being reconsidered.

If the applicant is seen to present a reputational risk, the processing agent is informed and the applicant may be asked to provide more information to make a case for a positive re-consideration. Most citizenship units have special committees appointed to evaluate a complicated case before taking a decision.

As a citizenship consultant, my advice is – always tell the truth. If you are a legitimate applicant with nothing to hide, the likelihood of your application being accepted is high.

Giselle Bru is the COO at PassPro Immigration Services, a government approved agent for processing second citizenship