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Malta CDI – Raising the Bar on Due Diligence – A Four Tier Approach


Malta’s recently announced regulations for the Granting of Citizenship for Exceptional Services by Direct Investment (CDI) (L.N. 437 of 2020), stipulates that due diligence checks will be carried out in at least four tiers.

The newly formed Community Malta Agency (CMA) is responsible for administering the due diligence and verification process of the eligibility of each applicant. Such verification processes may also involve the engagement of one or more internationally recognised due diligence service providers for each applicant.

Each applicant will be subject to the same due diligence checks. The CMA may also include security checks to be carried out by law enforcement authorities in line with Data Protection Regulations enabling the Processing of Personal Data by Competent Authorities for the Purposes of the Prevention, Investigation, Detection or Prosecution of Criminal Offences or the Execution of Criminal Penalties (S.L. 586. 08). Such checks will also ensure the source of funds of the applicant is legitimate with regards to anti money laundering and the financing of terrorism legislation.

Due Diligence - Four Tiers

Tiers Detail
Tier One The first round of due diligence is carried out by the approved agent of the prospective applicant in order to submit a Maltese Residency application. The CMA will also perform standard due diligence at this stage and obtain the 1st police clearance.
Tier Two The CMA will carry out a second round of due diligence to ensure the application is complete and correct and all the required supporting documentation is presented. Checks at this stage include databases such as Interpol & Europol.
Tier Three Following the application submission, the CMA will carry out further checks. A critical and in-depth review takes place on the submission and the supporting documentation. The third tier is carried out by the CMA’s assessors and includes reviewing each applicant’s source of funds.
Tier Four Further rigour and assessment is carried out for the fourth stage of due diligence. The assessors review all the information collected internally and externally. The findings of such assessment are presented to the Minister on the eligibility for citizenship.

Throughout the process and at each tier of due diligence, if any issues are encountered the CMA will seek further clarifications. The CMA continues monitoring of the successful applicant for five years.

The Granting of Citizenship for Exceptional Services Regulations, requires a period of residency of 36 months, or by exception 12 months, before an applicant can apply for Citizenship by Direct Investment. Such direct investment requires a capital transfer, investment or leasing of a residential real estate property and a donation to a local voluntary organisation.

For more information about Malta’s Granting of Citizenship for Exceptional Services by Direct Investment Regulations please contact us.



Whilst we endeavour to provide precise and timely information, there can be no assurance that such article is accurate as of the date it is received. The information provided herein is merely intended for general information purposes and cannot be construed as professional advice without seeking an appropriate consultation.


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