Harnessing AI for due diligence in CBI Programmes. Legal and Ethical Challenges

Research output: Contribution to journalArticlepeer-review

251 Downloads (Pure)


Citizenship by Investment (CBI) programmes are defined as ‘an
exchange of national membership rights for immigrants’ financial and human
capital’ (Gamlen, Kutarna and Monk 2016 pp.6). CBIs represent an innovative
and increasingly common mechanism that allows governments to monetise
the allure of their countries to migrants, thereby converting intangible assets
into financial assets. For applicants, the incentive is a passport, primarily for
those coming from troubled regions or those nationalities who encounter visa
restrictions of one form or another. Many critics of these CBI programmes have
indicated some plausible drawbacks to their practice while further citing that
practicing countries have yet to exhaust alternatives before making such a
policy move (Williams and Hosein 2019). Substantial integrity and corruption
concerns appear to be synonymous with CBI programmes, notwithstanding their
regulatory structure (Williams and Hosein 2019). CBI programmes have been
criticised by national and international organisations such as the Organisation
for Economic Cooperation and Development (OECD), Financial Action Task
Force (FATF), the European Commission and the United States Congress. It has
been argued that the rapid emergence and growth of such programmes may
exacerbate risk of abuse and corruption and raise the possibility of curtailed
visa-free access to advanced countries (Xin, El-Ashram and Gold 2015). It is
suggested that due diligence can be facilitated and maintained using Artificial
Intelligence (AI) tools (e.g., machine learning) in CBI programmes as long
as fundamental safeguards are instilled in the development and use of such
Original languageEnglish
Article number1
Pages (from-to)3-25
Number of pages24
JournalJournal of Ethics and Legal Technologies (JELT)
Issue number2
Publication statusPublished - 1 Nov 2022

Bibliographical note

JELT is a fully open access journal, since all articles are available for all readers immediately after publication: no registration or subscription required to read, print, download and share the full-text of articles.
The works included in JELT are licensed under a Creative Commons “Attribution-NonCommercial-NoDerivatives 4.0 International (CC BY-NC-ND)” license.
JELT provides immediate open access to its content, nevertheless you may not use the material for commercial purposes or in commercial websites. Any reference to material included in JELT has to include the citation of the author and the source.


  • Citizenship
  • Artificial Intelligence
  • Investment
  • Due Diligence
  • integrity


Dive into the research topics of 'Harnessing AI for due diligence in CBI Programmes. Legal and Ethical Challenges'. Together they form a unique fingerprint.

Cite this