28 February/March 2024 February/March 2024 PB
Previously unseen 2019 internal audit assessed
the IIP’s Overall Risk Rating as Medium/High Risk:
checks and management controls were inadequate
to ensure its effective operation
he golden passport or Immigrant
Investor Programme (IIP) was, and
remains, a grubby scheme from start
to finish granting five-year, renewable
visas to non-EU citizens in exchange
for investments over €500,000.
Insofar as it can be said to have finished, it
abruptly closed to new applications on 15
February 2023. Department of Justice ocials
told the Oireachtas Public Accounts Committee
in May 2023 that there were 3,000 applications
yet to be processed. By February 2024 the total
outstanding had only reduced to 2,700. At this
rate of clearance, it will take as long as six years
for the IIP to genuinely close.
More concerning is the fact that the outstanding
applications will be assessed by the IIP Unit of the
Immigration Delivery Service using processes
and systems that have been consistently and
repeatedly found to be utterly deficient.
The Department of Justice has been aware that
its compliance controls and management
supervision have been manifestly inadequate
since 2019 yet it has not taken the most important
remedial actions urged by successive reports.
Despite being in possession of reports highly
critical of the ability of the IIP Unit properly to
assess applications, the Department continues
to insist that the scheme is and has always been
well run and does not publicly acknowledge any
The Immigration Delivery Service version of
Simon Harris’s announcement closing the
scheme to new applicants includes the cheeky
postlude that “the Minister was satisfied that the
IIP was operated by his Department to the highest
professional standards”, an endorsement that
was singularly absent from Harriss actual press
release published by the Department of Justice
on the same day.
The Department has been equally reluctant to
publish information about the scheme. It only
published the external review commissioned
from EY, after repeated prompting by opposition
TDs, in June 2023 — notably after the scheme had
closed and after the Public Accounts Committee
had questioned ocials about the programme
— despite receiving phase one of the review in
April 2020.
The Department has never released its own
June 2019 internal audit. However, Village
Magazine has obtained a copy of this unpublished
audit and what emerges is a pattern of inaction
and passivity in the face of calls to take urgent
corrective measures – a pattern that persists to
this day. As a result of management’s inertia,
successive reports found identical problems and
recommended exactly the same improvements.
The previously unseen 2019 internal audit
assessed the IIP’s Overall Risk Rating as Medium/
High Risk which indicated that, among other
things, the governance of the scheme, its
compliance and monitoring checks and the units
management controls were inadequate to ensure
the eective operation of the scheme.
Although the internal audit explicitly insisted
that its recommendations be adopted before
commissioning an external review of the
programme, the formal response recorded by IIP
Unit’s management was a commitment: “to
acting in accordance with the outcome of the
independent external review. Such a delay was
never intended by the auditors.
Moreover, Village has learnt from Department
of Justice ocial statement that key requirements
that were the basis of the criticism of both reports
remain unimplemented to this day.
Both reports found that key policy documents
were not in place, leaving inadequate oversight
and management in the ongoing assessment of
2019 internal audit obtained by Village prescribed actions
that were instead delayed pending an external audit: ongoing
IIP investments not scrutinised at all after initial screening
By J Vivian Cooke
outstanding applications.
Even though it had first been highlighted in
2019 that the Evaluation Committee responsible
for assessing investment proposals was
operating without Terms of Reference - the IIP Unit
has still not adopted them. In the absence of
Terms of Reference, the functions of the
Evaluation Committee cannot be extended to
include oversight of the scheme – a key
recommendation to improve delivery. In addition,
the programme continues to operate without
having a Risk Management Framework document,
the adoption of which was identified as an
essential element to the proper conduct of the
Monitoring and following up of both applicants
and their investments continues to be
unsatisfactory, as it has always been for the
duration of the scheme. The Department makes
it clear that the extent of its responsibility is
purely to screen applicants and approve
proposed investments insofar as they comply
with the scheme’s requirements.
After approval, the only monitoring that the
Department conducts is to ensure that the money
promised is transferred to the appropriate Irish
bank account. Anything after that is a matter for
someone else. “The IIP Unit is not responsible for
managing or overseeing the individual projects
themselves…An applicants investment in a
particular project is a private business transaction
between the investor and the project.
This was deemed unacceptable in 2019 and in
2023 but the IIP Unit has not used the last four
and half years to correct the serious faults
identified and it shows no inclination to do so
now. 2,300 applications were processed between
2012 and 2023, using processes known to be
deficient, management controls that were
manifestly inadequate to their task and with a
chronic shortage of sta and expertise.
There are a further 2,700 that will be assessed
in the coming years under the same unacceptable
Golden visas scandalously short on
oversight by deluded Justice Department


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