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Enhanced due diligence on a Belgian foundation: Identifying risks and mitigating potential fraud

The challenge:

Diligencia was commissioned to provide an Enhanced Due Diligence – Level 3 (EDD-3) report on a Belgium-registered company and its key principals. Specialising in the Middle East and Africa, we also possess extensive experience conducting research across other global jurisdictions.

 

The solution:

Our investigation began with the retrieval of legal entity data from official company registers in the relevant jurisdiction. We conducted comprehensive open-source research, which included traditional media archive searches, as well as a thorough examination of online and social media platforms.

Additionally, we completed global compliance checks for both the subject company and its principals. We also engaged with no fewer than five sources who had direct, first-hand knowledge of the company, to ensure a robust and accurate assessment.

 

The result:

We presented our detailed findings to the client in the form of an Enhanced Due Diligence – Level 3 report. Below is a summary of our key findings:

Company overview: The subject company was incorporated in 2014. It is a private foundation registered with the Brussels Court Register in Belgium, with its principal place of business located in Brussels. The company’s status was marked as “active.”

Corporate structure: According to corporate records, the company is a private Stichting, commonly known as an “orphan entity.” It is essentially a non-profit organisation with no owners, governed solely by a board of directors. This entity was created through a notarial deed that outlines its purpose and governance structure. Such foundations are often used for asset holding, charitable giving, or managing complex ownership arrangements.

Risk concerns: At the time of our research , the integrity of the company was under scrutiny due to its limited public profile, lack of financial transparency and unverified capacity to meet large-scale commitments—such as a significant grant to an African country. Although the company has engaged with governments in Africa, investigative reports and expert consultations raised concerns about the credibility and feasibility of its funding promises.

Based on our findings, we advised the client that without strong due diligence processes and verifiable financial backing, engaging with this company presented considerable risks, including potential fraud, reputational damage, and legal complications. We recommended avoiding any engagement with the company unless absolutely necessary, and even then, only with stringent preventive measures in place.