The Due Diligence Dialogue is a new FACT interview series bringing together leading voices to examine the issues shaping due diligence and compliance today. Specialists across sectors and markets discuss how credible intelligence, thorough screening, and independent investigation help establish who can be trusted, whether regulatory standards are being met, and where further scrutiny is needed. The series explores the expertise and technology helping organisations identify risk, uncover connections, and make better informed decisions. In this first interview, Aran Hawker  Co-Owner CiP Türkiye l CEO CoinPanel, draws on more than a decade’s experience in Türkiye to discuss due diligence in citizenship by investment, including property checks, source of funds and the lessons from allegations of fraud.

1. You have lived and done business in Türkiye for many years, including before the Turkish CBI programme began. What aspects of local knowledge cannot be obtained from legislation, official guidance, or a desktop search?

Aran Hawker: We have been processing Turkish residency applications – primarily for European retirees – for over a decade, well before the Turkish Citizenship by Investment (CiP) programme was introduced in 2017. Additionally, we have registered and formed companies for international clients over the same period. Our deep familiarity with the workings, expectations, and standards of various government departments gives us a distinct advantage earned through hands-on experience. Because every client presents a unique set of circumstances, our experience allows us to provide tailored solutions for potential issues that may arise during residency and citizenship applications.

2. What is the difference between basic compliance checks and genuinely useful pre-transaction due diligence in a Turkish CBI property acquisition?

Aran Hawker: We strongly advise clients to purchase new-build properties from our recommended developers. We conduct thorough due diligence on every project before presenting it, verifying everything from initial building licences to the final habitation certificates. Our recommended developers include major Turkish conglomerates, powerhouse construction businesses with international footprints across 130 countries, and the world’s largest REIT owned by the Turkish Sovereign Wealth Fund.

We generally do not recommend resale properties due to the complex compliance risks involved. These include checking for previous foreign ownership (which may disqualify the property for citizenship) and unrecorded tax or debt liabilities from former owners that result in incorrect title deed valuations and failed applications. Purchasing new builds through reputable developers with proper guidance minimises these risks.

3. Türkiye has seen enforcement action relating to alleged CBI real-estate fraud. What lessons should investors and industry professionals take from those cases about independent valuations, cash rebates, and “too good to be true” offers?

Aran Hawker: While some individuals were unwitting victims of past fraud, the primary entity harmed was the Turkish state, due to lost revenue and reputational damage. Much of the fraud occurred with the explicit involvement or knowledge of applicants seeking to bypass minimum investment requirements or receive off-the-record cash kickbacks. Such actions constitute deliberate fraud and grounds for revocation of citizenship.

To avoid these risks, investors should work directly with established law firms in Türkiye rather than real estate brokers. Furthermore, official procedures and regulatory systems have been completely overhauled to prevent these practices from recurring.

4. What is one red flag that would immediately pause the processing of a CBI file?

Aran Hawker: An Interpol Red Notice would be a red flag.

5. How do you verify source of funds and wealth for clients from complex jurisdictions?

Aran Hawker: We work closely with two of the largest banks in Türkiye – one major domestic bank and one international institution. Through our long-standing relationships, our legal and compliance teams liaise directly with the banks’ headquarters compliance departments to process account openings efficiently. Because we introduce high-value investors, our clients receive VIP service and streamlined processing.

6. What are the clearest early warning signs that an investor may be dealing with an unsuitable or high-risk intermediary?

Aran Hawker: Key preliminary red flags we monitor include the use of generic, free email domains, such as Gmail, for official business; an inability or refusal to appear in person on a video call; and an inability to answer basic introductory questions regarding the specific programme during a direct conversation.

7. What evidence should a DD provider request to understand the full cost and funding trail of a CBI transaction, including source of funds, payment records, valuation documentation, taxes, fees, and any commissions?

Aran Hawker: The level of due diligence required depends on the specific scenario. Turkish banks, for example, maintain high standards regarding source of funds, requiring clear verification of whether an investor is employed, self-employed, a business owner, or a retiree. Documentation may include sales and purchase agreements, itemised cost breakdowns covering property acquisition and application fees, as well as standard proof of ID, address, and income.

8. What does ‘independent due diligence’ actually mean in practice?

Aran Hawker: Türkiye conducts its official due diligence internally without third-party providers. As a firm, we perform our own independent due diligence report on clients for two reasons: to adhere to regulatory expectations and protect our firm from representing non-compliant individuals; and to provide clients with complete peace of mind, ensuring no underlying issues exist that could jeopardise their application or lead to unexpected costs and delays.

9. It is common for Turkish citizens to seek alternative citizenships. What would you say is the common denominator between Turkish applicants applying to other programmes? Do they present as solo applicants?

Aran Hawker:  Türkiye represents a major outbound investment migration market, driven largely by families seeking enhanced travel freedom, tax planning solutions, and educational opportunities for their children in the UK, EU, or US. Acquiring alternative residence or citizenship allows families to relocate seamlessly during their children’s studies and optimise their international business operations.

10. What would be the biggest challenge for due diligence providers in processing these files?

Aran Hawker: Processing outbound documentation for Turkish applicants is highly efficient due to the Turkish E-Government platform. Virtually all required official documents are accessible immediately at no cost, available in multiple languages, and formatted for official use. Digital apostilles can often be issued on the same day without additional fees.