
Blogs • December 12, 2025 • 16 Min
How to Pass Due Diligence for a Second Passport in 2026
If you are considering citizenship or residency through investment, one requirement appears in every program: due diligence. It is the stage where governments verify your identity, financial background, and personal history, and it is also where most delays occur. Even well-qualified applicants often feel uncertain about what is checked, how deeply governments review their information, and which details can trigger follow-up questions. Read the guide to understand the due-diligence process, so you know what authorities examine, why these checks are necessary, and how to prepare a file that moves through approval without interruptions. What Is Due Diligence and Why Is It Required for a Second Passport? Before a government grants citizenship or long-term residency through investment, it must confirm that every applicant is transparent, traceable, and financially compliant. Due diligence is the mechanism that verifies this. What Governments Verify During due diligence, authorities review your identity records, financial background, criminal history, and immigration history. They assess the legality of your funds, check for sanctions or adverse media, and confirm that your profile does not present reputational or security risks. The purpose is to ensure that every approved investor meets international standards used in banking, finance, and cross-border compliance. Why These Checks Exist Citizenship programs operate under strict global scrutiny, especially from Europe, the UK, the US, and FATF. To maintain visa agreements and program credibility, governments must demonstrate that every new citizen has been screened to a high standard. This is why even simple cases require full documentation and why incomplete files slow down the process. How Deep the Screening Can Go Depending on the program, due diligence may include: verification through international criminal databases cross-checks in corporate, litigation, and financial registries review of your public reputation and business activities analysis of your source of wealth and source of funds Programs with stricter frameworks may also use independent investigative firms to produce detailed reports. The result is a complete picture of who you are, how you earn your income, and whether your profile aligns with the program’s requirements. What Is Due Diligence and Why Do Governments Require It? When you apply for citizenship or residency through investment, due diligence becomes the central part of your approval. Governments use this stage to understand who you are, where your funds originate, and whether your personal and financial background aligns with program standards. For investors, a clear due-diligence record leads to a smoother and stronger approval. Programs that apply strict compliance create secure long-term citizenships. Authorities work with internal databases, independent screening firms, and global security systems. Every detail you share is verified through multiple channels, which is why preparation is essential. How Do Due Diligence Checks Work? Identity and Personal Background Verification Governments review your civil documents, past residencies, travel history, and any previous immigration interactions. They look for consistency across all documents: the same names, dates, addresses, and identity details. When everything aligns, the file moves through screening quickly. Financial and Source-of-Funds Review A complete financial picture is required. Authorities examine how you earned your funds, including; salary and business income dividends and investment returns real-estate sales inheritance or gifts long-term savings What they need is a clear and fully documented financial story. Criminal Record and Security Screening Your application is screened through international systems such as INTERPOL notices, sanctions lists, and global AML compliance databases. Governments assess risk, review past events, and evaluate each case through a factual lens. Applicants who provide full clarity from the start experience far fewer questions during this stage. Reputation and Public-Domain Assessment Authorities also examine your professional background, business relationships, litigation history, corporate involvement, and public records. This helps them form a complete profile and confirm that your track record aligns with their eligibility standards. Which Documents Should You Prepare Before Due Diligence Begins? Every citizenship and residency program relies on documented facts. When your paperwork is consistent, and complete, the due-diligence stage moves forward without unnecessary requests or pauses. Below is what governments typically expect and why each item matters. Identity and Civil Status Documents Governments verify your identity through official records. This usually includes: A valid passport Birth certificates and marriage certificates Any legal name-change documents Authorities compare these records with international databases. Clear, recent, and legible documents help your file progress efficiently. Financial Documentation and Bank Statements Your financial profile must show a stable history that aligns with the investment you plan to make. Most programs usually request: Bank statements covering several months Evidence of regular income or business activity Account summaries for personal and corporate banking These records allow authorities to understand your financial footprint and confirm that your current assets match your declared profile. Source of Wealth Evidence Source of wealth explains how you built your capital over time. Common forms include: Business ownership records Annual financial statements Salary contracts Proof of property sales Investment portfolios Inheritance documentation If you provide a clear explanation supported by paperwork, that gives governments full clarity regarding long-term earnings. Police Clearance Certificates Each applicant, including eligible family members must provide a recent police certificate from their country of citizenship and long-term residence. Authorities review these certificates alongside their own security systems to create a full background picture. Professional References or Letters of Good Standing Some programs request letters from employers, legal advisors, or regulated professionals. These references help confirm your professional reputation, the stability of your background, and your standing within your industry or community. Tax Compliance Records Governments may request tax returns or tax-residence confirmations. These documents demonstrate financial transparency and help align your fiscal history with your declared source of funds. Which Red Flags Slow Down Due Diligence? Governments review every application through strict AML and security standards. Most files move forward without issues. The ones that slow down usually have something that creates doubt, even if the applicant is fully eligible. Here are the red flags governments pay closest attention to today. Criminal History or Past Legal Issues Governments check international databases, police records, and court archives. If you had past legal matters, they must be disclosed upfront. Hiding information causes more concern than the issue itself. Financial Activity That Doesn’t Match Your Profile Review teams compare your declared income with how your accounts behave. They pause the file when the numbers don’t line up. For example, large deposits with no explanation, transfers through high-risk jurisdictions, or investment funds that came from another person’s account will always trigger questions. Caribbean programs, for instance, now follow this closely because of updated FATF recommendations. Explore Caribbean Citizenship Programs in our full guide: Best Caribbean Passports: Costs, Requirements & Benefits Unclear Source of Wealth Governments want to see how your capital was accumulated. If the financial story is incomplete, with no business records, missing tax filings, or property sales without contracts, the application usually enters enhanced review. This is one of the most common reasons programs request extra documents. Past Visa or Immigration Issues A past refusal is not necessarily a problem but failing to mention it is. CBI units check your name across Schengen systems, INTERPOL, and border-control databases. An undisclosed refusal, an overstay, or inconsistent spellings across passports will slow the file immediately because the government must confirm that the issue has been resolved. Civil or Business Litigation Most applicants have been involved in some form of business dispute. What concerns governments is when the case hints at financial misconduct or unpaid liabilities. Malta, Portugal, St. Kitts and Nevis, and Grenada routinely check court databases in countries where the applicant lived or operated a business. Negative Media or Online Mentions Independent due-diligence firms run deep media scans in all languages. They flag allegations related to corruption, tax problems, or business disputes, even old or inaccurate ones. When something appears, the government usually asks for an explanation or supporting documents. Politically Exposed Person (PEP) Status If you hold or recently held a public position, your application automatically receives additional review. This applies to investors, their spouses, and close family members. Programs often ask for full financial statements and declarations of business interests to confirm that the source of wealth is independent and clean. Inconsistent Identity or Civil Documents Small inconsistencies, like different spellings, outdated translations, missing stamps, or incomplete addresses, can pause the process for weeks. Governments must verify every detail before approval, which is why accuracy matters more than volume. High-Risk Country Indicators Living, working, or banking in a country under FATF grey/blacklist monitoring does not block eligibility, but it increases the depth of review. Applicants from such jurisdictions are asked for more detailed financial records and background information. Dependent Documentation Gaps Most delays involving families come from missing custody papers, old birth certificates, or unclear dependency for adult children. Caribbean programs have tightened these checks in 2025, especially for stepchildren and elderly parents. Unexplained Gaps in Career or Income Due diligence teams map your professional and financial life over many years. If there is a period with no clear activity or income, they will ask how you supported yourself. A short explanation usually resolves it, but it must be provided upfront. Financial Due Diligence: How Do You Prove the Legitimacy of Your Funds? Every Citizenship by Investment program requires a full financial review. This is the part of due diligence where governments confirm how you earned your money, where it was held, and how it is being transferred for the investment. If your financial story is structured and well-documented, approval moves quickly. If anything is unclear, the file pauses until you provide clarification. Below is what governments actually look for, and how to prepare for it. What Counts as an Acceptable Source of Funds? Governments recognise many types of income, as long as each one is clearly documented. Common sources include: employment income business ownership or dividends long-term savings real estate sales investment returns inheritance or family gifts (with supporting documents) You only need to show a legal, traceable source that matches the amount you invest. How Do You Prove Business or Salary Income? If your wealth comes from a company or employment, you will usually provide: recent and historical bank statements company registration documents financial statements or dividend records proof of your role and compensation The goal is simple: the government must see a consistent pattern between your income and your current financial position. How Do You Verify Assets or Investments? If your funds come from selling property, shares, or other assets, you may need: sale contracts payment receipts valuation reports bank records showing the proceeds arriving in your account The document trail must clearly show where the money originated and how it reached you. What If Your Funds Come from Inheritance or Family Support? Inheritance is accepted in all major CBI jurisdictions, but it must be documented with a will, probate records and bank statements confirming the transfer. Family gifts are also accepted, but authorities typically ask for the donor’s financial proof as well. The Most Important Rule: Every Transfer Must Be Traceable Governments review transactions line by line. If they cannot see how the investment amount moved from its source into your account, they will request clarification or pause the file until the path is clear. Unexplained balances, cash deposits, and transfers through unrelated accounts are the biggest reasons financial reviews slow down. How Background Checks Are Conducted Once your documents are submitted, the government begins a full background review. This is where they verify your identity, confirm your history, and check that nothing in your past raises concerns. Who Performs the Checks? Governments do not rely on your documents alone. They work with several independent sources: International due-diligence firms Financial intelligence units in the country issuing citizenship Security databases such as INTERPOL and EU/US sanctions lists Local authorities in every country you have lived in This multi-layer structure ensures that the information they see is complete and cross-verified. What Do These Agencies Review? They look for consistency across three main areas: Identity They confirm your name, date of birth, travel history, and any previous immigration interactions. Reputation They check global media databases, legal registries, and corporate records to ensure there is no negative footprint linked to your name. Security Flags They review sanctions lists, watchlists, past visa decisions, and legal activity, to understand context. If there is a match with someone who shares your name, the government simply asks for clarification or additional proof. This happens often and is easy to resolve. How Deep Do These Checks Go? Deeper than most applicants expect. The review covers: every country you have lived in companies you have owned or managed financial behaviour across your accounts your role in any past legal disputes any political exposure (PEP status) The goal is to confirm you present no financial, legal, or reputational risk to the issuing country. What Triggers Additional Questions? CBI units request clarification when something in your file is unclear or incomplete. Typical triggers include: unexplained financial transfers inconsistencies between forms and bank records negative media from past business activities similar-name matches in security databases previous visa refusals complex company ownership structures These situations usually require additional documents or explanations. How Long Does Due Diligence Take? Every second-citizenship program has its own verification speed. Some governments complete background checks in a few weeks; others take several months because multiple agencies are involved. Caribbean Citizenship Programs (8–12 weeks) Antigua and Barbuda, Dominica, Grenada, St. Lucia, and St. Kitts and Nevis generally complete due-diligence checks within two to three months. Timelines stretch when: your financial profile spans several jurisdictions documents need clarification dependents require additional verification St. Kitts may offer an accelerated review option when available, but only for applicants who submit a fully prepared file. Vanuatu (2–4 weeks) Vanuatu’s Financial Intelligence Unit reviews applications quickly, often within one month. Fast timelines depend on clear bank records and a simple financial structure. Türkiye (2–3 months) Türkiye reviews background information as part of the wider investment application. The timeline depends on: property valuation checks fund transfers through Turkish banks police clearance verification across all countries of residence Malta — Citizenship for Exceptional Services (4–6 months) This is not a CBI program, but it is relevant because many investors compare its due-diligence depth with CBI standards. Malta’s review is one of the most detailed in the world and includes: multi-layer financial screening international database checks enhanced assessments for complex profiles Because Malta requires residence first, this review happens after the residence stage and governs eligibility for citizenship. Common Mistakes That Cause Due Diligence Failures Due diligence failures usually come from avoidable gaps in paperwork or unclear financial records. These are the issues that slow files or lead to refusals. Unclear or inconsistent information Small inconsistencies create big delays. Examples that trigger extra checks: names or dates that differ across documents missing pages in bank statements income that doesn’t match account activity Governments pause the file until every detail aligns. Expired or outdated documents Police certificates, civil documents, and translations must be valid at the time of review. If anything expires, the file waits for updated versions, sometimes adding weeks. Weak financial traceability Due diligence teams need a clean path for the funds used in the investment. Files slow down when there are: unexplained deposits third-party transfers business income with no supporting paperwork A clear financial trail is one of the biggest approval factors. Selective disclosure Screening systems reveal past visa refusals, legal issues, or political exposure. If something is left out, the risk level rises immediately. Incorrect translations or authentication Low-quality scans, missing stamps, or unofficial translations often cause fast rejections of the document set and force resubmissions. How Savory & Partners Supports Applicants Savory & Partners is officially authorised by multiple CBI governments, which allows us to prepare and submit applications that align with their exact due-diligence standards. Our support covers: Pre-screening to identify risks early Document preparation with correct formats, certifications, and translations Financial review to ensure the source of funds is clear, consistent, and traceable Application assembly according to government requirements Follow-up with CBI units until approval This structure minimises delays and increases approval confidence for eligible applicants. What Happens If You Fail Due Diligence? A refusal usually means the government could not verify part of your background, finances, or documentation. If the issue is administrative, including a translation error, a name match, or missing paperwork, you can request a review and submit corrected evidence. If the concern is more serious, such as unclear funds or undisclosed legal issues, reapplying is only possible once the underlying problem is fully documented and resolved. Some applicants may still qualify for alternative programs with different risk criteria, but only after a careful reassessment. How Do You Prepare for a Smooth Due-Diligence Review? Preparing correctly is what determines whether your application moves through screening in weeks or gets held for clarification. These are the areas governments examine most closely and the steps that help your file pass without interruptions. Start Collecting Documents Early Government-issued documents have strict validity periods. Police certificates, civil documents, bank letters, and employment or business records often take longer to obtain than expected, especially when they must be reissued, apostilled, or certified. Preparing these early prevents repeated requests and ensures your file is ready for immediate submission. Keep a Clear and Traceable Financial History Your financial records must show a clean, continuous path of funds. Governments expect to see where your income originates, how it moves between accounts, and how it reaches the investment amount. You avoid delays when: all transfers are supported with statements or contracts income sources match business activity or employment history no third-party accounts appear unexplained A simple, documented money flow speeds up approval significantly. Disclose All Relevant Background Details Anything tied to your identity, travel history, or legal history must be shared from the start. This includes past visa refusals, previous applications in other countries, old name variations, or legal disputes, even if resolved. When explained early, these items are normally manageable. When discovered during screening, they become red flags that slow the file. Follow the Required Document Format Exactly Governments assess documents based on strict technical standards. You reduce the chance of rejections by ensuring: certified translations follow official rules notarisation and apostille stamps are correct dates and spellings match across all documents scans are clear and unaltered Most resubmissions happen because of formatting mistakes, not eligibility issues. FAQs on Due Diligence for Second Citizenship How deep do due-diligence checks go? Governments run multi-layer checks using international criminal databases, sanctions lists, financial-intelligence systems, and open-source media screening. They review your identity history, financial activity, business ownership, past visa applications, and any legal issues associated with your name. The depth depends on the program, but all reputable schemes follow international AML and KYC standards. Can a past visa refusal affect my second-citizenship application? Yes, but it depends on the reason. Administrative refusals (missing documents, unclear travel purpose) rarely cause problems when explained. Refusals linked to security, fraud, overstays, or misrepresentation must be disclosed and supported with clarification, otherwise they become a red flag. What financial documents do governments check most carefully? Bank statements, tax filings, business registration records, audited accounts, property sale agreements, loan documents, and dividend or salary records. Governments need to see that the investment funds come from legal, traceable sources with a documented history. What if someone with my name appears in negative records? This is common and manageable. Your file must include additional documents proving your identity timeline, such as entry/exit records, business registrations, or employment history, to differentiate you from the unrelated individual. Licensed advisors prepare these clarifications before submission. How long does due diligence usually take? Most programs take 8–20 weeks, depending on the country, season, and whether enhanced screening is triggered. Any inconsistencies in your financial or personal documents extend the process, while a complete and well-prepared file typically moves faster. References Government of St. Kitts & Nevis — Citizenship by Investment Unit. Due Diligence Framework & Application Regulations. Referred from: https://www.ciu.gov.kn/ Government of Grenada — Citizenship by Investment Committee. Applicant Screening Requirements & Source-of-Funds Guidelines. Referred from: https://www.cbi.gov.gd/ Government of Antigua & Barbuda — Citizenship by Investment Unit. Application Processing Standards & Background Verification Rules. Referred from: https://cip.gov.ag/ Government of Dominica — Citizenship by Investment Unit. Due Diligence Procedures, Family Inclusion Rules, and Regulatory Updates. Referred from: https://cbiu.gov.dm/













PORTUGAL | RESIDENCY BY INVESTMENT
