Earlier this month, the investment migration industry gathered in Paris for the 8th Investment Migration Forum, one the sector’s most significant annual events. The Forum brought together government officials, legal practitioners, wealth managers, and due diligence professionals from across the globe. FACT was proud to be represented at the event, with Natalie Smith, Due Diligence Manager, joining a high-profile panel on 10 June to launch a landmark white paper co-authored by the IM Due Diligence Community of Practice (CoP).

Established in 2025 under the auspices of the Investment Migration Council, the IM Due Diligence CoP comprises a group of practitioners who represent leading due diligence firms active in the investment migration arena. This working group meets regularly to collaborate on sharing best practice, tracking emerging risks, aligning with international requirements and ensuring that due diligence firms are at the forefront of safeguarding and protecting programmes.. FACT has been an active contributor to this process from the outset.

The White Paper: A Framework for Intelligent Due Diligence

The white paper – “Elevating Due Diligence in Investment Migration: Addressing Identity, Source of Funds & Intelligence-Led Risk Assessment” – sets out a comprehensive methodology for applicant onboarding built around four pillars: document review and assessment, discursive human source work, live online interviews, and contextual analysis. Its core argument is that information must be not only collected, but also tested, corroborated, and interpreted in its proper jurisdictional context. On document verification alone, the paper draws an important distinction: a notarised document confirms the identity of a signatory, it does not confirm the accuracy of its contents. Transparency about what has and has not been verified is essential to decision-making.

In Focus: The Interview as an Integral Due Diligence Step

The white paper discusses the live online interview stage which is a methodology described as indispensable to robust applicant assessment and one that FACT has long championed. With 20 years of investigative experience and a team well-versed in due diligence boasting multilingual capabilities, FACT brought practical depth to this section of the paper, reflecting the firm’s a comprehensive human-centred approach to interviews.

The paper clarifies that while technology can and does support verification, it cannot match the judgement, adaptability, and observational skill of a trained interviewer. FACT’s interview approach reflects this: careful preparation, strong elicitation skills, and real-time intelligence gathering producing insights beyond the reach of automated processes.

The interview is not about creating an atmosphere of interrogation, it is about creating the conditions in which honesty is most likely to emerge.

A key dimension addressed in the paper is one that FACT has consistently emphasised in practice; the role of ‘soft intelligence’. This is evident when information emerges not from direct questioning but from tone, hesitation, behavioural shifts, and environmental cues. A skilled interviewer observes whether an applicant appears to rely on prepared notes for basic questions, whether their manner changes when particular topics arise, or whether a third party appears to be coaching them off-screen. The paper highlights the interview’s value in assessing source of wealth and funds narratives, allowing interviewers to probe complex financial structures in real time and distinguish between genuine red flags and legitimate but unfamiliar arrangements that might otherwise be misread as suspicious.

The paper also explores identity, arguing that document authenticity alone is insufficient. The live interview, combined with discreet human source enquiries about an applicant’s real appearance and background, helps confirm that the person presenting documents is who they claim to be.

Raising the Bar for the Sector

The Investment Migration Forum 2026 demonstrated that rigorous, intelligence-led due diligence is not just a compliance requirement, it is the foundation of programme credibility. As CBI programmes come under increasing scrutiny and the sector continues to confront questions of transparency and integrity, the CoP’s work and the standards articulated in this white paper will become even more crucial.

FACT is proud to have contributed to that effort and to have helped shape a framework that reflects what best-in-class due diligence genuinely looks like in practice.

Keep an eye out for FACT’s July 2026 newsletter, featuring a deep-dive article on our interview services.

Key Takeaways

• FACT contributed to a white paper that sets out a rigorous, intelligence-led approach to due diligence in investment migration.
• The paper argues that information should not only be collected, but also tested, corroborated, and interpreted in context.
• Live online interviews remain essential because they reveal insights that documents and automated checks alone cannot provide.
• Skilled interviewers can identify soft intelligence signals, verify identity more effectively, and assess complex source of wealth and funds narratives in real time.
• The white paper provides a clearer, more defensible framework for applicant assessment to ensure standards remain high and constant across the investment migration sector.

To speak to FACT about due diligence services or our involvement in the IM Due Diligence Community of Practice, please contact us here.