Due Diligence and the Durability of a Second Residency or Citizenship
Due diligence tends to get framed as a procedural hurdle — a further round of paperwork standing between an application and its outcome. That view understates its function. Properly conducted, due diligence is the mechanism that protects the value of the status a family is acquiring.
Due Diligence Deserves More Credit
An investment migration program confers a legal status: a passport, a residency card, or a tax position. Unlike a stock certificate or a deed, that status remains subject to review, and in certain jurisdictions to reassessment, particularly where the underlying investment or supporting documentation is later found to be irregular. For a family seeking long-term optionality abroad — a second home, a hedge against instability, greater mobility, or a plan for the next generation — a status subject to future challenge undermines the purpose for which it was acquired.
Rigorous due diligence is what converts a purchased status into a durable one. An independently verified property valuation, a properly traced source of funds, and a well-documented investment file serve as the record that the status was obtained correctly. Jurisdictions, including Turkey and Cyprus, have conducted reviews in recent years addressing cases in which investments were misrepresented or improperly valued. The appropriate response is not to avoid investment migration altogether, but to insist on diligence rigorous enough to keep a family’s file outside that category of risk from the outset.
What Weak Due Diligence Has Cost
In August 2026, Turkish authorities confirmed the revocation of citizenship for 6,134 individuals who had obtained it through the country’s Citizenship by Investment programme, following an investigation that identified inflated property valuations, fictitious transactions, and falsified documentation across a significant number of approved files. A minority of those affected were the original investors; the remainder were spouses and children whose status had followed the principal applicant’s, without independent involvement in the underlying transaction. The revocations followed an earlier, smaller enforcement action the previous year, indicating a programme under continued rather than isolated scrutiny.
By September 2025, Cyprus had revoked citizenship from 360 individuals who obtained it through its own Citizenship by Investment Programme, following findings that included sanctions exposure, undisclosed criminal matters, false declarations, and unmet investment conditions. Of those affected, 101 were original investors; the remainder were family members whose citizenship had derived from the principal applicant’s without independent involvement in the transaction. These revocations accumulated over time — beginning with seven cases in 2020 and continuing through additional cohorts in 2021, 2022, 2024, and 2025.
Both cases illustrate that status granted on a compromised file remains subject to challenge indefinitely; there is no limitation period that extinguishes the risk with time, and family members bear that exposure regardless of their own involvement in the original transaction.
Malta’s Alternative Framework
Malta’s position has evolved along a different trajectory. In April 2025, Malta discontinued its direct citizenship-by-investment route — the Citizenship for Exceptional Services by Direct Investment scheme — following sustained scrutiny at the EU level regarding the compatibility of a capital-for-passport exchange with the obligations of EU membership. Malta now administers a Citizenship by Merit framework under which citizenship is reserved for individuals who have rendered exceptional service or made an exceptional contribution to the nation — scientific, humanitarian, or otherwise — rather than for those who have made a fixed financial contribution on a set schedule.
The distinction is not cosmetic. Citizenship by merit is granted on the strength of an individualized determination as to the applicant’s actual contribution, rather than on a transaction — a property purchase, a government bond, a fixed donation — that a later audit could characterize as improperly valued or fabricated. There is no valuation to contest and no consideration to unwind, because the operative act is naturalization itself: a determination the state makes and stands behind, not a price it must later account for. On this basis, the framework sits on considerably firmer ground than the volume-driven citizenship-by-investment programs that led to the Turkish and Cypriot revocations.
The Malta Permanent Residence Programme (MPRP) remains a transactional programme — structured around a government contribution, a property purchase or lease, and an administrative fee, rather than a merit-based assessment. This does not place it on the same footing as Turkey or Cyprus in outcome, but it does mean the same diligence questions apply: how the contribution and property transaction are documented, whether the source-of-funds trail is independently verifiable, and whether the file would withstand review years after approval. The rigor of that underlying diligence is what determines the durability of the status obtained, since the structure of the programme itself does not remove that exposure in the way a merit-based framework does.
Structure Over Marketing
A programme’s exposure to future revocation depends on the substance of the file behind each individual grant, not on how the application process is presented. For applicants, the underlying due diligence — both their own and the programme’s — determines whether a status obtained today remains secure a decade from now. A clean, independently verified file is not administrative overhead; it is the evidence that keeps a family’s status outside the category of risk that the Turkish and Cypriot revocations have shown can be revisited at scale, years later, regardless of which family members participated in the original transaction.
Talk to a Licensed Advisor
As a licensed agent for the Malta Permanent Residence Programme, we also advises on citizenship-by-merit pathways for families considering a non-transactional route. Reach out to schedule a consultation and discuss which option fits your circumstances.