Predicting Application Outcomes With Big Data: The Malta IIP’s Risk Matrix

Jun 15, 2018 | Events

The current iteration of the IIP’s risk matrix consists of five levels of risk, across seven categories. Through this risk matrix, the IIP has been able to undertake a more structured risk assessment, which facilitates a more objective and systematic review of applications. This ultimately resulted in case officers being able to conduct a more thorough risk assessment, in less time when compared to the previous process.

Mr Jonathan Cardona, MIIPA’s CEO and Mr Yakof Agius, MIIPA’s Chief Officer for Risk & Compliance created the risk matrix with adaptability in mind. Using an evidence-based approach, the risk matrix was developed as a framework to facilitate a more structured and aligned risk assessment. Together with predictive capabilities, it lends itself well as a tool that facilitates and enables new levels of standardisation, transparency and integrity throughout the due diligence process, which will ultimately result in increased levels of trust in the RCBI industry. 

Further research includes the measurement of every application’s risk profile against the application’s outcome. With enough data, the risk matrix will be able to generally predict an application’s outcome based on the application’s risk profile.

Over the past 6 months, the Malta Individual Investor Programme Agency (MIIPA) has had a number of positive discussions about the details of its Due Diligence process, including the IIP Risk Matrix, with entities such as Transparency International, Global Witness, various representatives for the EU commission, the IMF and the OECD amongst others.

Yakof Agius, Chief Officer of Risk and Compliance at the Malta Individual Investor Programme Agency, explains how a systematic approach coupled with the collection of data points on large numbers of applicants can, over time, help predict the outcome of a citizenship by investment application before it is even lodged.

The Malta IIP, by many considered the benchmark among citizenship by investment programs in terms of due diligence, uses a so-called “risk matrix” to build a risk profile of applicants, an approach that grows more efficient over time as the amount of data needed to recognize patterns increases.


CIP-Countries Have “No Option” But to Invest in Solid DD Structures Says Malta IIP’s CEO“There is a structured way of looking at an application, of extracting a risk profile from that application […]. We are recording the risk profile for every application, and then we are recording the final outcome of that application – so, whether the application was accepted or rejected. Over time, what that means is that certain risk profiles will emerge that will be able to predict the outcome of an application,” said Agius about the approach, which will help the MIIP nip root out potentially problematic applications at an early stage and generally to improve due diligence by directing resources and focus in a more targeted manner toward high-risk applications.

Related: Malta Should Mentor Caribbean CIPs on Due Diligence, Says Thomson Reuters General Counsel

 Asked whether a similar approach could be adopted by the due diligence teams of other citizenship by investment programs, Agius pointed out that the IIP’s risk-matrix would lend itself easily to any CIU, but that accuracy would be slightly lower because of fewer data points.

“It can easily be adopted by other citizenship by investment units (CIUs) because having more data that feeds into the risk matrix helps it be more accurate, but if a CIU cannot invest the same resources that we invest and their data points are limited to 50% or 25% of what we have then, still, the risk matrix will give an indication based on that 25% of data.”

Source: Investment Migration Insider 投资移民知情者

Malta Individual Investor
Programme Agency (MIIPA)

Mediterranean Conference Centre
Old Hospital Street
Valletta, Malta VLT 1645

Phone: +356 21 225 232

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