The Irish Department of Justice conducted an internal audit in 2019, which raised significant concerns about the controls of the Immigrant Investor Programme (IIP). The audit examined 18 applications under the scheme and found that in each case, the files reviewed did not provide evidence to clearly verify the legality of the source of funds provided by the applicant when the application was received. Furthermore, the audit identified that there were insufficiencies in due diligence checks, with 12 of 18 files examined lacking evidence of an affidavit attesting to the applicant’s good character, and 11 of 18 files not demonstrating sufficient evidence of background checks performed on the individuals. The audit noted that while guidelines specified that a false declaration would invalidate any permission granted, there was no process in place to investigate or perform background checks to identify false declarations.
The audit also highlighted concerns about the adequacy of checks being carried out at a local level, citing an instance where a local Irish embassy had raised several “red flags” regarding an applicant’s personal business during a site visit. The report emphasized the importance of conducting rigorous checks both at a local level and through An Garda Síochána, the Irish police force.
Following the internal audit, the Department of Justice commissioned an external review by accountants EY, which echoed the concerns raised in the internal report. EY’s review recommended implementing tighter controls on the approval process and the source of funding, as well as enhancing the due diligence process to ensure the validity of applications.
The Irish government closed the IIP on February 15th, 2023, attributing the decision to concerns about the surge in applications, primarily from Chinese millionaires, and the difficulties encountered in validating requests. The closure came with just one day’s notice, during the maternity leave of then Minister for Justice Helen McEntee, with Simon Harris, now Taoiseach, serving as acting minister at the time.
