Vanuatu Due Diligence by the FIU

Every Vanuatu citizenship application under the Development Support Program (DSP) is screened by the Financial Intelligence Unit (FIU), working since 2020 with an international specialist firm, before the Citizenship Office and the Commission look at it. One fee of US$5,000 covers the whole application. A criminal conviction is decisive: the DSP Regulations do not allow the Commission to approve a person who has one.

Due diligence is where most avoidable problems in a Vanuatu file appear. We prepare you for it before anything is lodged: we review your background with you in confidence, build the source-of-funds trail and make sure every document tells the same story. As Vanuatu law requires, it is a government-designated agent who lodges the application and requests the checks.

Who Runs the Background Checks

The checks sit within a chain of steps set by the Citizenship (Development Support Program) Regulations Order No. 33 of 2019, as amended by Order No. 39 of 2020.

1. The designated agent applies to the FIU for checks on the main applicant and every family member in the file, and supplies the applicant's passport and police or judicial clearance.
2. The FIU and its international firm carry out the checks. The 2020 amendment brought in the international specialist firm and allows the FIU or the firm to ask for further documents where reasonably needed.
3. The Citizenship Office receives the application after due diligence and checks it against the DSP checklist.
4. The Internal Screening Committee reviews the file, and the Citizenship Commission decides.

The FIU's due diligence service covers the Citizenship Office's investment programs: its notice names the DSP, the Capital Investment Immigration Plan (CIIP) and the Vanuatu Contribution Program. The CIIP was suspended in March 2025, and although industry sources report it reopened in May 2025 under amended rules, no official notice confirming the current terms has been published; in practice the notice matters most to DSP applicants.

What the FIU's January 2025 Notice Requires

On 14 January 2025 the FIU published a notice on its due diligence process for citizenship programs, applied from 16 January 2025. It says every client file must contain a valid passport copy with more than six months' validity, a valid police clearance, a notarized curriculum vitae and a government payment receipt. Three of those items shape every file we prepare:

• A notarized curriculum vitae. The notice requires one in every file; agents usually ask for one from each adult, and we confirm the requirement for your file. A CV that is vague about dates, employers or businesses invites questions, so we draft it with you to match your company records, tax filings and bank statements.
• A passport with more than six months' validity. Check every family member's expiry date. A passport renewed during the process changes the number on the file, and the change has to be explained.
• The government payment receipt. The notice does not say which government payment the receipt must show, so the agent confirms it for your file, and we plan that payment and the checks together.

The Commission has also announced enhanced due diligence and investment verification for its citizenship program. The detail is in a press release on the Office's website; we apply the current requirements to each file rather than relying on older checklists.

What the Checks Look At

The FIU does not publish its screening method, and we do not claim to know which databases it uses. Background checks for citizenship by investment generally look at five areas, and a well-prepared file answers questions in each of them before they are asked:

• Identity. Names, dates of birth and passport numbers must be the same across every document. Different spellings or transliterations need a written explanation.
• Criminal and court records. The Regulations name a police or judicial clearance from the country of origin. The FIU or the firm may ask for certificates from other countries where you have lived.
• Sanctions and watch lists. Links to sanctioned people or entities, through ownership or business partners, are a serious obstacle.
• Public profile. Adverse media and political exposure are usually reviewed. A public role, your own or a close relative's, should be disclosed and explained up front.
• Money. Where the funds for the contribution came from, and how the wealth behind them was built.

Source of Funds and Source of Wealth

These two terms are often mixed up. Source of funds is the specific money that pays the contribution and the fees: which account it sits in and how it got there. Source of wealth is the broader picture of how you came to have that money over your working life. Both need documents.

Money that has moved through several accounts, companies or countries is not a problem in itself, but every step needs a document. The government accepts only US dollars, so funds held in cryptocurrency have to be converted and the conversion has to be traceable. We explain how digital assets are converted and documented for an application.

What Leads to a Refusal

Some guides say that only convictions with long prison sentences count. That is not what the Regulations say. Clause 6(9) bars the Commission from approving a person who has a criminal conviction and sets no threshold. Other common reasons for a file to fail or stall are:

• Restricted countries. Applicants from a country treated as restricted can be accepted only if they have not lived there for the last five years and hold permanent residence elsewhere (clause 6(8)). The Regulation does not define the term or publish a list of such countries, so we check this at the assessment.
• Funds that cannot be traced. If the money cannot be followed back to a lawful source, the checks cannot be completed.
• Facts left out. A refused visa, a past business dispute or a connection to a sanctioned person that is missing from the forms does more damage than one that is disclosed and explained.
• Inconsistent documents. Different dates, names or employment histories across the file lead to follow-up questions and delay.

Due diligence also matters after the grant. A grant obtained by fraud, or made in breach of the Act or the Constitution, can be revoked later; the Citizenship Office has reported that the Commission revoked around 30 citizenships granted unlawfully.

Fee, Timing and Follow-Up Questions

The FIU due diligence fee is US$5,000 per application under the published schedule. Old guides that quote US$2,000 refer to the period before the 2020 amendment, and figures such as US$5,500 do not appear in the schedule. Neither the Regulation nor the Office's published pages provide for a refund of this fee, so plan on it being spent once the checks start; the only amount the Regulation expressly describes as non-refundable is the 25% advance on the government fee.

The 2020 amendment speaks of the FIU completing its check within 96 hours of receiving the documents. That is a target written into the rule, not a promise about your file: a file with several adults, several countries of residence or complex funds will take longer, and every request for further documents adds time. We show where due diligence sits among the other stages and their deadlines.

Changing Agent After Due Diligence

Once due diligence has been carried out, the Regulations generally keep the applicant with the same agent. A change is possible only if that agent has not moved the application forward within a reasonable period, which cannot exceed six months (clause 6(10)). Choosing the agent carefully at the start therefore matters, and we check the agent's status on the Office's list of designated agents before your file goes in.

How We Prepare You for Due Diligence

• A confidential review of each adult's background, including past convictions, pending cases, visa refusals and public roles, before any fee is paid.
• A written source-of-funds and source-of-wealth narrative, with a document for every step.
• Police certificates ordered in the right order, so that none has expired on the lodging date.
• A check of names, dates and passport numbers across every document, with written explanations where they differ.
• Answers to FIU and Office questions prepared with you, quickly and consistently, through the designated agent.

Due diligence is one stage of a longer process; we also cover the order in which a file is checked, paid for and decided.

If something in your background worries you, a conviction, a past refusal, a public role or money that has moved through several countries, raise it before any fee is paid. Ask for a free assessment: we review it with you in confidence and tell you in writing whether an application makes sense, what the checks are likely to ask for, and what the whole file will cost.