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If a government crony ‘investigating’ the government itself based on information supplied by the government & further limiting his review to exclude VISAs & trading in influence is “robust & serious”, I’m Jessica Rabbit.
In fact, we should kick the tires a little bit and analyse the report that "speaks volumes".

Here's the report:
gov.mt/en/Government/…

This is what created the need for the report:

And here's a thread. Buckle down. 1/
We should probably start from the "regulator", Carmel De Gabriele.

Meet the bastion between baddies on the one hand and EU passports sold by @HenleyPartners amongst others on the other.

Reassuring. 2/
Ok so the "regulator" is a septuagenarian (if not octogenarian) whose career in the civil service started under Mintoff in 1978 and somehow ended up supervising a government Agency. 3/
Surely the regulator should not have worked previously with the Agency or Authority that he is now regulating, right? Worse if it was an iced bun. That would be an indication of revolving doors / leave him open to blackmail, right?

Whoops. 4/
Moving on. Let's look at scope.

Degabriele notes that he was tasked by the #GoldenPassport scheme agency (the MIIPA) & of his own initiative opted to review the IIP files submitted by @Chetcuti_Cauchi from inception to date. 5/
Degabriele also notes that the "main IIP-related allegation" in the #EnqueteExclusive sting was that CCA could "successfully convince a minister to approve a previously refused application by re-presenting the dossier with new information".

Erm that's not quite all there is

6/
And then, bam he adds the first (of many) disclaimer. It is beyond the scope and functions of the Regulator to address the authenticity or otherwise of these allegations. Which kind begs the question as to what on earth he was looking at to begin with.... 7/
We also know that separately, his remit does not cover:
- #GoldenVISAs (there's no "regulator")
- trading in influence (a police matter)
- whether giving @Chetcuti_Cauchi access to Castille or Ministers / PS to film their adverts / promote their "charity" is right... 8/
But at least we know he looked at the files right, looked at whether they were complete, had full audit trails and ran independent background checks, right?

Nope. 9/
The useful tool only reviewed the documents provided to him by the Authority being scrutinised. Worse, in a later recommendation, the "regulator" notes that systems are so primitive as to not have any audit trails.

Fascinating. 10/
So:
(1) crony,
(2) narrow scope of review,
(3) only reviewing documents provided by the entity being scrutinised and
(4) an entity that conveniently does not use a system that leaves an audit trail. Amazing.

It gets worse.

11/
The regulator seems to focus a lot on the 100% success rate boasted about by @Chetcuti_Cauchi on camera.

But ignores that
(a) that claim is everywhere, even in bios.
(b) success could also mean a visa.
(c) a client refused in Malta could apply to Moldova or Cyprus....

12/
Observation 4 talks about how one application checked had two reference numbers & it transpired that it was an instance where CCA applied without applying, got comments then resubmitted a "fuller" application.

Sounds a lot like a reconsideration, no? 13/
It gets worse. The Regulator also inadvertently not only mentions that there is a "pre-pre application pre-vetting process" but that there is a pre-pre-pre step where a "client" is checked as to whether to go into the #GoldenPassport or #GoldenVISA queue or elsewhere. 14/
Despite these instances (reported by the Regulator himself) of pre-pre-pre vetting & pre-pre-pre feedback & lobbying, the regulator in Observation 6 finds that no application by CC was ever submitted more than once.

15/
Observation 7 undoes this further.

42% of applications contained red flags where the Passport sales agency (MIIPA) asked CCA for more information / clarifications before accepting.

16% of applications contained red flags but no documented reasoning for accepting. 16/
The regulator seems to place a lot of emphasis on the "criminal record" (not mentioned in the #EnqueteExclusive tape) but then glosses over "red flags" or in his own words "damning information" (see further down).

No wonder "bloopers" happen. 17/

theshiftnews.com/2019/10/18/fif…
Besides concluding mystically (and Barr-like) that there was "no collusion" (after excluding it from the scope), the regulator also concluded that there is "no evidence of trying to get around the selection criteria".

But the report doesn't quite say that. 18/
Observation 5 - the "external due diligence" was 1 year old by the time the applicant was recommended for citizenship. The reason - it mysteriously took 1 year to translate 58 pages.

Please make the name of that translation agency public.... 19/
Observation 9 - looks a lot like evidence of trying to get around selection criteria wouldn't you say?

20/
Observation 10 - Putting an application on hold to explain certain developments also sounds a lot like trying to find a workaround wouldn't you say? 21/
Or Observation 11 also known as the "switcheroo" or Observation 12 also known as the "fuck they realised, let's withdraw the application and apply for:

- a #Goldenvisa
- a Cypriot something
- a Moldovan something
- a St Kitts something

etc. instead. 22/
The regulator sums these up himself: 23/
So quite why he contradicted himself in the Executive summary is another matter.

24/
The conclusion is another gem.

Based on the documents provided by the Agency which he is vetting, he concluded that CCA "never engaged in any of the activities 'allegedly' mentioned in the recorded interview".

He had the recording.
He excluded the activities from scope.

25/
In closing, our dear Regulator offers some recommendations (which he himself notes have been ignored in the past) being:

A. The Malta #GoldenPassport application process has no audit trail.

26/
B. The Malta #GoldenPassport scheme rules have a loophole that allows persons convicted (with a criminal record, ie not "just red flags") to get citizenship for cash. 27/
C. Passport salespersons such as Henley or CCA are gaming the system essentially applying and if red flags are picked up and insurmountable simply withdrawing the application and moving to another regime or country with a scheme (eg Cyprus). There is no exchange of info. 28/
D. Passport salespersons are fiddling about with who is the "main applicant" vs the "dependents". This is where a lot of the scams are.

Malta itself had (to shut the EU up) originally "limited" the #GoldenPassport to 1800 main applicants each of whom could have a harem. 29/
E. Lastly & in case you're not concerned yet, the regulator notes that it is in fact the Agency that regulates salespersons who, as noted with the pre-pre-pre vetting tend to be overfamiliar with agents.

Like appearing in their promotional videos, presumably. End/
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