IM Yearbook 2019/20

IM
INVESTMENT
MIGRATION
YEARBOOK 2019/2020
Navigating
towards
Next-Generation
Transparency
An Unseen
Force for
Good
Deep Dive
Due Diligence
Delivers Level
III Security to
the Industry
Rollout of First
Global Industry
Qualifications
Finally Begins
2nd
Edition
Under the Waterline:
Billions of Dollars Flow into
Infrastructure Investment
Global Standards:
A game-changing
moment just
got closer
Who’s Who: CEOs and
political leaders share
essential insights on the
industry landscape
What’s Hot & What’s Not:
The trends, events and
developments influencing
Investment Migration
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thriving economy, helping it
become one of the fastest growing
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
INVESTMENT
MIGRATION
Meet the team
YEARBOOK 2019/2020
Navigating
towards
Next-Generation
Transparency
Deep Dive
Due Diligence
Delivers Level
III Security to
the Industry
An Unseen
Force for
Good
2nd
Edition
Garvan Keating
Chief Executive Officer
keating@countryprofiler.com
Rollout of First
Global Industry
Qualifications
Finally Begins
Global Standards:
A game-changing
moment just
got closer
Who’s Who: CEOs and
political leaders share
essential insights on the
industry landscape
Under the Waterline:
Billions of Dollars Flow into
Infrastructure Investment
What’s Hot & What’s Not:
The trends, events and
developments influencing
Investment Migration
IN ASSOCIATION WITH
Sonja Lindenberg
Editor
lindenberg@countryprofiler.com
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Giulia Desogus
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Research and Contributions
CountryProfiler staff
Printing
Gutenberg Press, Malta
Publication Date
June 2019
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ISBN
978-99957-1-538-0
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Contents
Facts & Figures....................................................................8
Industry Profile:
A New World of Possibilities.....................................12
Putting our House in Order
Bruno L’ecuyer..................................................................... 18
A Qualified Difference................................................22
New Membership Structure
for a Stronger Industry
Jacqueline Gauci ................................................................23
Investment Migration: The New Normal
Juerg Steffen.........................................................................24
Diversify to Grow
Austin T. Fragomen............................................................28
Taxing Times: Why the OECD
Didn’t Get it Right
Zac Lucas.............................................................................30
Time for Renewal
Bob Kraft...............................................................................32
Why Strategy is Everything
Edward Beshara..................................................................34
Inside China’s Migration Industry:
Too Big to Be Ignored
Larry Wang.........................................................................36
We Need to Enter an Era of Coopetition
Martin O’Connor................................................................38
Investor Citizenship and the EU:
Zooming in on the European
Commission’s Ill-Informed Analysis
Dimitry Kochenov............................................................. 40
Trends & Topics............................................................ 44
The Power of Transparency
Yakof Agius...........................................................................54
We Need to Act Responsibly
Giselle Bru............................................................................58
Regulated Consultants
Keep Fraud at Bay
Gerd Damitz....................................................................... 60
Global Citizen Tax to
Shift Industry Focus?
Armand Arton...............................................................................63
What it Takes to Build an
Efficient RCBI Programme
Stéphane Tajick...................................................................64
Furthering the Investment Migration
Industry’s Sustainability
Julia Farrugia Portelli........................................................66
The World of Investment Migration:
What’s New?......................................................................70
In Focus: Moldova
Iulia Petuhov.......................................................................72
Inside the MRVA
Charles Mizzi....................................................................... 73
Cyprus Update
Michalis P. Michael....................................................................74
3 Questions with...
Jonathan Cardona......................................................................76
How to Work Together,
How to Win Together
Due Diligence Roundtable................................................78
The Real Drivers
Behind Applications
Sonia Spencer............................................................................... 84
Disrupting the Nation State..................................... 86
The Big Picture Idea: Nation as a Service
Kaspar Korjus..................................................................... 90
Make a Real Impact
Simon Anholt................................................................................92
The Big Migration Debate:
Finding the Missing Link
Khalid Koser.........................................................................94
Expatland: The World’s Most
Influential Country
John Marcarian...................................................................95
Events..................................................................................97
Who’s Who......................................................................102
6

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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Facts & Figures
The investment migration industry has experienced exponential growth in the past years.
More than a dozen countries today offer citizenship-by-investment programmes. While these
programmes often dominate the narrative and news of the industry, many more nations
operate residence-by-investment (RBI) programmes for investors, with major global players
such as the US, the UK, Canada, Australia, and New Zealand participating in this industry.
100
60
30 7
countries offer some
form of investment
migration programme
jurisdictions are
actively promoting
their programme
programmes are
attracting the largest
share of applicants
out of the G-20 members
operate some form of
investment migration
programme
8

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
30%
Only 30% of migrating high-networth
individuals come into
countries under investor migration
programmes, New World Wealth
claims. Most still come in via work
transfers, citizenship by ancestry,
spousal visa and family visa.
80%+
Approximate
percentage of
Chinese applicants
to any residence
programme in
the world
36%
According to the 2019 Knight
Frank ‘wealth report’, 36%
of high net worth individuals
(HNWIs) already hold a
second citizenship and
passport, with 26% planning
to emigrate permanently.
10%
Refugees and
asylum seekers
constitute
roughly 10% of
all international
migrants.
At a Glance: Countries with Popular Investment Migration Programmes
Citizenship Programmes
Antigua & Barbuda • Austria • Bulgaria
Cambodia • Cyprus • Dominica • Grenada
Jordan • Malta • Moldova
Montenegro – upcoming
St. Kitts & Nevis • St. Lucia • Turkey • Vanuatu
Residence Programmes
Anguilla • Australia • Canada • Cyprus
France • Greece • Hong Kong • Ireland • Italy
Jersey • Latvia • Malaysia • Malta • Monaco
New Zealand • Portugal • Singapore
Spain • Thailand • UAE • UK • USA
5000
550+
400+
$3
billion
estimated number
of people acquiring
citizenship abroad
per year
Number of agents
licensed across
the world
Members of the
Investment Migration
Council, coming from
over 55 different countries
Value of the
citizenship-byinvestment
industry
9

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
150 – 170 countries
An EU passport typically allows visa-free
travel to between 150 and 170 countries
14 million
There are approximately
14 million high-net-worth
individuals in the world,
each with net assets of
$1 million or more.
€9.2 billion
European countries
benefitted from
investment migration
by receiving €9.2
billion during the
2008-2018 period.
2-30%
Percentage of GDP contribution of investment
migration programmes in some countries
1984
The year when St. Kitts and Nevis
introduced the first CBI programme
108,000
About 108,000
millionaires migrated
countries in 2018,
according to a study by
New World Wealth.
$5 billion
Annual investment
into US economy by
EB-5 Programme
$100,000 - $2.4 million
Range of minimum investment required by
different CBI programmes around the world
258 million
There were 258 million
international migrants in
2017, representing 3.4%
of global population.
This number has
almost tripled in
the past 50 years.
2/3rds
Two-thirds of
all international
migrants were born
in Asia or Europe.
130%
China’s wealth has
increased by 130%
between 2008 and
2018, New World
Wealth found out.
$6.7 trillion
McKinsey Global Institute
(MGI) estimates that
migrants contributed roughly
$6.7 trillion, or 9.4 per cent,
to global GDP in 2015 – some
$3 trillion more than they
would have produced in
their origin countries.
12,000
12,000 high-net-worth individuals migrated to Australia in 2018,
beating its main rival the US for the fourth year running. The USA
experienced a wealth inflow of 10,000 millionaires, followed by
Canada (4,000) and Switzerland (3,000), according to New World Wealth.
Sources: United Nations,
Knight Frank 2019 Wealth Report,
Stephane Tajick Consulting, Henley
& Partners, European Parliament
Research Service, McKinsey Global
Institute, New World Wealth,
CountryProfiler Research
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
INDUSTRY PROFILE:
A New World of
POssibilit
Growth and expansion continue to be the hallmarks of the investment
migration industry, triggering a drive towards higher standards and
a concerted effort to future-proof the industry.
12

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
ies
The rapid expansion of the investment
migration industry shows no
sign of slowing down. Across the
entire industry spectrum, every nook
and cranny has been experiencing
growth. New programmes have come online and
even more in the offing, raising questions among
industry commentators on their sustainability.
Despite the question marks, the appeal to clients
appears to continue unabated, along with the
number of new entrants seeking to service the
growing appetite for visa-free travel by the globally
mobile. The exponential growth that the
industry is enjoying has not gone unnoticed by
major international institutions and standardsetting
organisations such as the EU, the IMF and
the OECD that are all expanding their interest
and flexing their powers over the industry.
Redoubling Efforts
International organisations, policy-makers and
the media continue to view the industry with a
critical eye, though there has been a notable softening
in their stance. However, the decision of
the European Parliament to shutter golden visa
and passport programmes sent a clear message to
the industry that the concerns of policy-makers
and wider society cannot be ignored. With no
shortage of opposing voices to the investment
migration industry, it is clear that there needs
to be a redoubling of advocacy efforts to ensure
that programmes are not sanctioned, or worse
still, closed altogether. However, many believe
the current scrutiny is necessary to drive transformational
change and lead the investment
migration industry into a new era. Today, almost
everyone in the industry agrees that regulation
and common standards need to be the next steps.
Despite the headwinds that the industry is facing,
many governments are seeing and witnessing the
benefits that investment migration programmes
can bring to their countries, whether it be attracting
the best and the brightest talent via their entrepreneur
and start-up schemes or the key role
these programmes have played in bolstering infrastructure
capacity and providing a steadying
hand in times of economic uncertainty.
13

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Three Decades of Growth
The investment migration industry has grown in
leaps and bounds since St. Kitts and Nevis broke
new ground with the launch of the first citizenship-by-investment
programme in 1984. Now 35
years on, the industry marks this major milestone
with a renewed confidence, as the sector
moves beyond a niche attraction for the few and
goes ever more mainstream. The business model
has evolved over the years and was developed
further with the introduction of the golden visa
concept by Portugal. A relatively new phenomenon
is the emergence of start-up and entrepreneur
visa programmes, with which governments
seek to entice a whole new generation of global
innovators. Today over 100 citizenship and visa
programmes are in existence, generating billions
in investments that are being mobilised to create
jobs and economic activity.
Investment migration has never been far from
controversy and often maligned by policy-makers,
influencers and the media alike. The concept
of citizenship by investment in particular still
stokes resentment that programmes do little but
allow the rich to buy privileged access to their
countries. Though their sentiments may be
genuine, many of them may be surprised to learn
that five of the G-7 members and seven of the
G-20 countries have been employing some form
of investment migration programme to bolster
inward investment.
The visa, over citizenship, programmes have
long been the more acceptable face of the industry
and have been used by countries such as the
US, Canada and the UK to attract people, capital
and know-how. A major milestone and turning
point in the acceptance of citizenship and visa
programmes was the decision by two EU countries,
Malta and Cyprus, to introduce citizenshipby-investment
programmes. Globalisation has
been a good travel companion for the investment
migration industry. The global citizen who wants
access to the world for business and leisure has
become a reality that is driving demand for investment
migration products, which are becoming
ever more refined and diverse.
Big Impact
It is estimated that investment migration accounts
for $2 billion annually, industry, but it
brings in tens of billions in investment. In terms
of economic impact, programmes represent anything
between 2% and as high as 30% of GDP
in some countries, and can be a defining factor
between an economic surplus and a deficit.
Across the world investment migration programmes
have been the catalyst for major infrastructural
improvements, including resorts,
harbours, airports, hospitals, office buildings
and luxury residential developments, which in
turn have had a massive multiplier effect on the
respective economies. These programmes are
not only influential in delivering cutting-edge
infrastructure, investments into companies, startups
and R&D programmes; they are also having
the effect of generating whole new economic
sectors that did not exist before their introduction.
Governments increasingly like the idea
of raising non-debt bearing capital to diversify
their economies at a relatively low cost. But while
these programmes present a golden opportunity
for many countries, governments equally need to
be stringent in ensuring the windfall they are enjoying
today is directed exclusively towards productive
investments that will pay dividends in the
future and not be tempted to finance day-to-day
expenses, which could expose their economies to
unintended risks.
Two Tiers
As investment migration programmes evolve
and develop further, the distinguishing factors
between programmes will be about service, professionalism
and the impact of the investment.
Some 60 countries are actively promoting their
programmes, with 30 of them being the most relevant
and attracting the largest share of applicants.
Countries such as the US, Canada, Australia, and
the UK have cemented their position as preferred
destinations for people with a desire to relocate,
attracting wealthy migrants from all corners of
the world. However, the expectation is that access
to these tier-1 countries will become more exclusive.
Programmes are widely expected to go
up in price, which is reflective of their premium
status. Beyond the most desirable places in the
Now 35 years on,
the industry marks
this major milestone
with a renewed
confidence as the
sector moves beyond
a niche attraction
for the few and goes
evermore mainstream.
14

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
world to live in, more and more programmes
are coming online to compete and attract global
citizens. Turkey, Jordan, Moldova and soon
Montenegro are the latest entrants to the market
and will follow a long list of rivals, which include
Caribbean and European countries. With an estimated
5,000 applicants for citizenship-by-investment
programmes and further tens of thousands
acquiring golden visas globally, the question on
everyone’s mind is if there is too much product
for the market or if the emergence of new players
will fuel further demand. On this question the
jury is still out.
The Big China Question
China remains the dominant market for the
entire industry. While China is a great source
market, accounting for roughly 80% of applications
to any residence programme, from a business
and industry-risk point of view, there is very
much an over-reliance on one market. To ensure
the sustainability of the business model, both
programmes and agents are waking up to this
problem, and a most notable trend in more recent
years has been the increase in business coming
from new markets such as India, Vietnam, Russia
and South Africa. The recent price drop some
programmes have experienced also means acquiring
a second passport has become increasingly
affordable for people of more modest
means. This development might further widen
the already existing divide between top tier and
second tier programmes. While the strategy of
the tier-1 programmes will increasingly revolve
around ultra-high-net-worth individuals with
at least $30 million, the lower cost and more accessible
programmes might appeal to high-networth
and mass affluent clients with $1 million to
$10 million of investable wealth.
The major task for the industry and programmes
going forward will be to find the
balance between the needs of the country and
meeting the expectations of the applicants. Up to
now property investments of one kind or another
have featured prominently in all programme offerings;
however, agents report that to a large
degree acquiring property is the least preferred
route for client investment. Property investment
will always hold an appeal, but it will be on a
more equal footing with other asset classes and
investment options. There are already alternatives
in the market that are resonating with
wealthy clients, including investing in a property
fund as opposed to purchasing property, and
loan provision as opposed to equity investment.
A New Approach
Governments have to go beyond their current
vanilla-type offering and ensure investments are
being directed to where they can be most productive
for the country, its citizens and, ultimately,
the client. Countries should look at allowing
citizenship or residence applicants to invest on a
portfolio basis, whereby part of their investment
can be in equities, bonds, property, loan funds,
philanthropic causes, listed entities, private enterprises,
start-ups and angel investment funds,
which combined can provide more impact and
encourage a wider array of economic activity.
This also opens agents to the opportunity of offering
a whole host of value-added services to
their clients.
The industry will also need to have millennials
in its sights. With 23% of the world’s millionaires
being millennials, this clientele has its own expectations
of what they want and how they want to be
serviced. Millennials in particular are showing a
greater interest in impact investing and what positive
effect their contribution is having on their host
countries. The industry not only has an important
role to play in distributing capital where it can
be best utilised for society’s good, it can also help
countries gain an outsized influence. Investment
migration offers a significant opportunity for
countries to expand the concepts of residence and
citizenship, and novel proposals for what could be
best described as ‘nation as a service’ have already
surfaced. While some say this is ‘utopian thinking’,
Estonia, with its e-residency programme, is
providing a first glance at what the future might
look like. This concept could actually see countries
develop into service and product platforms
for fee-paying ‘citizens’, who can subscribe or unsubscribe
to their offering.
15

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
More Competition
The industry landscape remains very fragmented
and ripe for consolidation. Outside of the
odd whale in China, a few major players have
emerged, including Henley & Partners, Arton
Capital, CS Global, Kylin Prime, Apex and legal
firm Fragomen, which are followed by a large
number of smaller firms. Increasing competition
and a need to scale up may well see the
first wave of mergers and acquisitions occurring
sooner rather than later. Conversely, the industry
could be open to expansion and see more players
coming into the space, beyond the boutique advisory
firms that have been in place for many
years. In the same way as investment migration
consultancies are starting to offer complementary
services, such as private banking, wealth and
asset management, to their clients, traditional
advisory firms could add investment migration
as a product.
Global Standards
The decision by the European Parliament to
strongly recommend the phasing out of visa
and passport programmes sent a crystal clear
message that the investment migration model
will have to evolve materially to avoid a broad political
and social backlash. Fears of a potential increase
in security threats and low consumer protection
standards reverberate across the entire
industry. Questions on transparency and adherence
to international standards on anti-money
laundering and compliance regulations brought
the sector into the sharp focus of other countries
and international organisations such as the EU,
the IMF and the OECD which have demanded
tighter controls across the industry and tighter
background checks on applicants. This means
setting common standards for golden visas and
citizenship programmes is now a must. The industry
more than ever needs to recognise the
need to either self-regulate or accept that rules
will be imposed on it. The regulation of agents
and the development of effective consumer protection
measures are being viewed as important
steps towards improving the sector’s reputation.
The investment migration industry currently
remains largely unregulated, with only a handful
of countries having established an independent
regulator to oversee the operation of their programmes.
Huge regulatory pressures emanating
from the EU and G20-initiatives on anti-money
laundering and anti-terror legislation are requiring
the industry to embark on a major overhaul
of its customer due diligence to comply with new
global standards.
Educating an Industry
With the introduction of certification by the
Investment Migration Council, 2019 will also go
down as the year in which professional educational
programmes geared towards the investment
migration industry have been launched.
This will help demonstrate that both programmes
and agents are a step closer to reaching
the much-needed high standards demanded
by governments, policy-makers and the general
public. As the industry becomes increasingly
sophisticated in its approach, it is now recasting
itself in a new light. This is being seen positively
by the EU, which has long kept the industry on
the fringes of policy discussions. The current dialogue
between the industry and EU policy- and
decision-makers is a very welcome development
and seen as an opportunity to be more proactive
in shaping and positively contributing to the
debate at EU level.
Shanghai to Timbuktu
Countries offering investment migration programmes
are acutely aware that they risk having
their programmes suspended or forced to close
if they were to grant residence or citizenship
to individuals without thorough background
checks. Because of the importance of the sector
to many economies, programmes have implemented
KYC and due diligence standards that
now go far beyond those of the banking and the
financial services industries. Employing the services
of former intelligence officers, the industry
has moved beyond desk research and database
searches in its quest to really ‘know the customer’.
It is becoming increasingly common practice
of programmes, service providers and agents to
engage specialist agencies who intensively scrutinise
clients coming through the pipeline. From
the gleaming towers of Shanghai to the dusty
roads of Timbuktu, these firms are employing
experts on the ground to verify every aspect of
an applicant’s life and source of wealth. KYC and
due diligence procedures are particular areas
where the industry has attracted unfair criticism.
A Better Future
The industry has enjoyed some very positive
momentum over the past number of years, with
record numbers of affluent citizens seeking out
investment migration programmes. A major plus
for the industry has been the ability to attract entirely
new customer groups to the concept of acquiring
a second residence or citizenship, which
has helped expand the pool of potential clients
and, in turn, widened the choice of programmes
available. But it hasn’t all been smooth sailing.
Pricing pressures not only impacted the bottom
line but also the image of the industry. Although
today both policy-makers and the general public
are better informed about the industry’s processes
and safeguards, this doesn’t mean they are necessarily
in favour of it. The industry has no choice
but to reinvent its business as one that is more socially
and economically attuned to today’s societies.
The reward could be a better, more sustainable
and more accepted industry. n
A major plus for the
industry has been
the ability to attract
entirely new customer
groups to the
concept of acquiring
a second residence
or citizenship, which
has helped expand
the pool of potential
clients and, in turn,
widened the choice of
programmes available.
16

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Putting our House in
Order
The development of global standards for the investment migration industry needs
to be an urgent priority for the sector. Long-term success will only be brought
about if international institutions and civil society have confidence in the industry,
writes Bruno L’ecuyer, Chief Executive of the Investment Migration Council.
“The most recent
attempts of the
European Commission
to initiate a wider
discussion on the
topic by inviting
experts, civil
society and industry
representatives is a
major step forward to
a better understanding
of the industry and,
hopefully, setting
appropriate standards
in the near future.”
Investment migration is a $2 billion industry
responsible for significant investment, job
creation and societal development, and it accounts
for billions of direct and indirect revenues
in some smaller sovereign states. However, there
are currently no established global standards for
investment migration. Setting such standards
has always been of exceptional importance for
the Investment Migration Council (IMC), while
having a clear and coherent framework is now
probably more important than ever. There are
at least two reasons for that. Firstly, all involved
parties should follow a set of harmonised and
well-established rules which would certainly
contribute to better compliance with global
financial regulation. Secondly, having global
standards would contribute to an improved understanding
of the investment migration industry
and improve trust by the outside world.
The lack of global standards and good understanding
of both citizenship and residence
programmes may not only be confusing, but also
a source of distrust towards the entire industry.
Money is a sensitive topic. When brought into
connection with citizenship, which is perceived
by many as something which money shouldn’t
buy, but also with wealthy individuals who,
unlike many of us, can afford to pick and choose
their nationality, the investment migration industry
is easily yet unfairly stigmatised. A number
of studies testify that an enhanced transparency
and better regulatory framework for the industry
would mark a significant development in addressing
concerns related to investment migration
programmes.
Finding the Right Balance
While well-designed investment migration programmes
imply that the interests of the clients
and those of the governments are aligned, this is
where key issues usually arise. Plenty of mistakes
can be made, undermining the interests of both
the government and the clients. For example, the
due diligence requirements established by the
18

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
government eager to cash in on the programme
could be too lenient. While this can be presented
as a positive feature, since a visa or a nationality
is easier to acquire, this is highly problematic
in the long run. When such leniency is discovered,
it undermines the trust of other states in
the nationalities granted, reducing the value of
investment for all clients and, ultimately, undermining
the financial viability of the programme.
Similarly, programmes lacking transparency, or
where rules are not sufficiently clear and strict,
can suffer from corruption, undermining trust
and value of investments.
On the other side of the coin, the attractiveness
of a most diligently designed programme
can be radically different from real life. Studies
show that the added value of some reputable
programmes is far from clear, as the investments
they generate are not providing sufficient added
value to the countries’ economies in order to
justify the level of resources required to run the
programmes. All in all, very serious individual
scrutiny of the components of each residence
and citizenship-by-investment programme is required
before any conclusions are drawn.
Addressing Criticism and
Contributing to Professionalism
The investment migration industry has been
loudly criticised by several international institutions
and organisations. Aiming to contribute to
various improvements in the field of investment
migration, the IMC takes criticism seriously. It
is fair to say that most criticism is largely due
to the lack of global standards under which the
entire industry should be operating, as well as
lack of understanding of the application and
assessment procedures. In such circumstances,
the European Commission’s view of citizenship
programmes as a ‘risk to security’ should not
come as a surprise.
In fact, the most recent Report on ‘Financial
Crimes, Tax Evasion and Tax Avoidance’ of
the Special Committee on financial crimes,
tax evasion and tax avoidance at the European
Parliament (TAX3 Report); the Report of the
European Commission on ‘Investor Citizenship
and Residence Schemes in the European Union’;
and the Study of the European Parliamentary
Research Service on ‘Citizenship by Investment
and Residency by Investment Schemes in the
EU’, have shed a light on a number of aspects
which could indeed be problematic in the
absence of global investment migration rules.
The integrity of the applicants’ background
checks and due diligence are highly prioritised
by the European Union. This has been discussed
along similar lines in all three documents. Thus,
the Special Committee on financial crimes, tax
evasion and tax avoidance noted in the TAX3
Report that ‘citizenship or residence could be
granted through these schemes without proper
or indeed any customer due diligence having
Bruno
L’ecuyer
is the first
Chief Executive of the
Investment Migration
Council, the worldwide
association of investor
migration professionals.
Bruno leads the Secretariat
and is responsible for
all IMC operations. A
regular contributor to
international publications
such as Forbes, and
speaker at conferences
in Europe, the Middle
East and Asia, he has
held positions in London,
Paris and Hong Kong. He
has extensive expertise
and experience in
the management and
expansion of a professional
services association.
A member of the
Governing Board, Bruno
acts as its Secretary.
been carried out by the competent authorities’.
The EPRS’s Study emphasised that CBI/RBI
schemes ‘enable false statements to be made
on residency and can thereby undermine due
diligence procedures’. Finally, the European
Commission also expressed its concern noting
inter alia that ‘in most Member States the family
members of investors are not subject to enhanced
due diligence, which could entail security risks’.
Other problematic aspects emphasised by EU
institutions include transparency issues and
governance of the programmes, risks of money
laundering, corruption and tax evasion, lack of
genuine link etc.
All concerns deserve proper attention and
deeper clarification. The most recent attempts
of the European Commission to initiate a wider
discussion on the topic by inviting experts, civil
society and industry representatives is a major
step forward to better understanding of the industry
and, hopefully, setting appropriate standards
in the near future. The IMC has addressed
criticism directed towards the industry on multiple
occasions. We will participate constructively
in future discussions aimed at the clarification of
citizenship migration and at the building of trust
and confidence with international institutions
and civil society.
Furthermore, the IMC has built a strong
platform for formal education of those working
in the investment migration industry. The new
framework for Education and Training that has
been created by the IMC will provide for all levels
of background and experience. The courses aim
at promoting integrity, ethics, transparency and
best practices, and will be delivered by IMC
Education and Training. A good education is the
foundation of qualified professionals. The IMC’s
goal is to shape future professionals by helping
them improve their understanding of the industry
and enabling them to develop valuable skills
and knowledge. n
About the IMC
Set up five years ago as a non-profit industry association, the Investment Migration
Council (IMC) brings together the leading stakeholders in the field of investment
migration. It is the worldwide association of investment migration professionals
and the industry’s first and only credible self-regulatory body. As such, the IMC
gives the industry a voice and significant accountability. The IMC works towards
setting up high standards for the industry to be adhered to by all players. In particular,
IMC’s mission has been largely defined by the following five goals:
• Setting the global standards in relation to residence
and citizenship-by-investment;
• Promoting competence, continued professional development
and high ethical standards among its members;
• Improving public understanding and transparency of
investor residence and citizenship programmes;
• Contributing to the scholarly field of investment migration;
• Being the trusted partner and the leading platform for
professionals, academia and governments.
19

IM
INVESTMENT MIGRATION YEARBOOK 2019/2020
400+ members
Official List of Members 2019
360 Advisory & Management GmbH
360 Citizen Management Consultancies
A. Karitzis & Associates LLC
Abreu Advogados
Academy Finance
ACT Advisory Services Limited
ACTIVE CAPITAL / WTEC
Ahmed Ghattour & Co
AIT Accounting & Management
Services Ltd
Alves & Co
AME Second Citizenship Ltd
Andreas Demetriades & Co LLC
Andreas P. Siapanis & Associates LLC
AOM Visa Consulting
AP Group Global
Areti Charidemou & Associates LLC
ARQ Group
Astons Group Ltd.
Azevedo, Aldet & Moctezuma, Lda
BDO Consulting
Belion Partners LLP
Beshara Global Migration Law Firm
BEYOND Residence and Citizenship
Bluemina Citizenship & Residency
BLVUE Zürich Advisory AG (Ltd.)
Bond University
Bulgarian Citizenship Ltd
Callamus
Capital Union Bank
Capstone Advisory Co. Ltd
Carib International
Century Capital Inc.
Chetcuti Cauchi Advocates
Chriso Savva LLC
Christina Georgaki-Charavgi Law Office
Christodoulos G. Vassiliades & Co LLC
Ciba Invest
Citizen Lane
Citizenship By Investment
Unit - Antigua & Barbuda
Citizenship by Investment
Unit - Saint Lucia
Citizenship Solutions
CiviQuo
CJ International Group SRL
CLT International Ltd
Cosmic Business Initiation Services
Credit Suisse Group
CSB International Ltd.
Datuk Seri Dr. Nelson Pung
Deloitte Malta
Dem. A. Nicolaides & Sons Ltd
Dimitrov, Petrov & Co Law Firm
Discus Holdings
DomizilPlus Trust Office
DORDA Rechtsanwälte GmbH
Efthymios G. Navridis &
Asscociates Law Firm
Eksper Consultancy
Emmanuel Jacques Almosnino
Energopiisi
Eurofast EU
Exiger Diligence
Exiger LLC
Fakhoury Law Group
Fenech Farrugia Fiott Legal
Fidesco Trust Corporation
Fidescorp Limited
Fiduciana Trust (Cyprus) Limited
Fincasa Capital
First Advisory Trust reg.
Foster LLP, Global
Fragomen Worldwide
Frendo Advisory
Ganado & Associates
GICG Global Information
Consulting Group
Global Citizens Caribbean Inc.
Global Migration
Global Nomad Consulting
Global Residence & Citizenship
Practitioners Inc.
Globe Detective Agency (P) Ltd.
Go2Europe
Golden Visa Consultancy
Grant, Joseph & Co
Green Light Management Consultancy JLT
Grenada Citizenship by
Investment Programme
GVZH Advocates
Henley & Partners
Hestia Investments Consulting Lda
Hill & Hill Chambers
Immigrant Invest
immVest International Limited
Imperio Global Citoyen
Integritas Group
Inter-Tax Consultants
Intercorp International LTD
International Center for
Globalization and Development
International Residency Citizenship
Invest & Settle
Invest in the USA (IIUSA)
20

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
from 55+ countries
Investaureum Lda.
InvestIMM
Investment Migration Insider
Island Living Investment Services Ltd
Joseph Rowe Attorneys-at-
Law and Notaries Public
Katerina Marini & Associates Law Firm
KayHan Swiss LLC
Ketenci & Ketenci ILP
Klasko Immigration Law Partners, LLP
KLZT Law
Kosdromos Consulting S.R.L
KPMG
L Papaphilippou & Co LLC
La Vida Europe Ltd.
Laferla Insurance Agency Limited
Latitude Consultancy Limited
Law Quest
Lawrence Associates Ltd.
Lecanda Immigration and Nationality Law
Lerotheou, Kamperis & Co LLC
LTC Advisory & Services
Lund University
M-J Global Consultancy Services
Magrath Sheldrick LLP
Mahandru Associates
Maisto & Associati
Malta Individual Investor
Programme Agency
Malta Residency Visa Agency
Masri Holding Sal
Matthew Cassar
Mc Namara & Company - Barristors,
Solicitors & Notaries Royal
Michael Kyprianou & Co. LLC
Mifsud&Mifsud Advocates
Migronis Citizenship
MLH Consular Consulting
MM2H
Neda Azarmehr
Neity Maddock
New Balkans Law Office
Nexia BT
Nobel Trust Limited
Northern Pointe Development Ltd
Novafirm SA
Omega Partners International
OneWorld Ltd.
Ousheng & Partners
Papilio Services Limited
Passport Legacy
Passports Global Ltd
PassPro Immigration Services
PLAYFAIR Visa and Migration Services
Polyglot Ltd.
R P Merriman
Radu Ghergus Law Firm
Rao Consultants
RC International
Refinitiv
RIF Trust Investments LLC
Risvas & Associates Law Firm
Rosemont Consulting Sarl
Rostova & Westerman Law Group, P.A
RSM
Rutter Giappone Advocates
S-RM Intelligence and Risk
Consulting Limited
SAAD AHSAN Law Company
Saeima (National Parliament) of Latvia
Sakeenah Group
Scheibert & Associates
Shanghai Demei Law Firm
Shanghai Overseas Chinese
Exit-Entry Service Co.,Ltd
Shard Capital Investor Visa
Solomon Harris
Sothebys International Realty Cyprus
Sterling Diligence
Sunrise International Legal Services
Swiss Insurance Partners AG
SwissTaxGroup
The Belgium Office
Thomas John & Co
University of Vienna
Valadas Coriel & Associados
Valmas & Associates
Vardikos & Vardikos
Varnavas & Varnavas
VIMB Pte Ltd
Vincit Union Group
VIRIDIAN AG
Vironobilis OÜ
Visa Free Europe
Visas Consulting Group Inc
Wahaat
Wailian Overseas Consulting
Group Limited
World Grenada Inc.
World Immigration Service
XIPHIAS Immigration Pvt Ltd.
21

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Education & Training
A Qualified Difference
The Investment
Migration Council
has established a
global education and
training division to
facilitate and build
courses that offer
qualifications and
training for those
working in the evergrowing
investment
migration industry.
The development, or rather the
apparent lack, of global standards
has become one of most
pressing issues facing investment
migration. Many believe
the recent criticism of EU institutions
and international
organisations will only become louder as the
industry continues on its growth trajectory. The
main concerns surround the lack of transparency,
weak due diligence processes, possible tax
evasion, money laundering, and other misuses
of existing schemes. While such criticism may
seem overwhelming and even unfair to honest
players in the investment migration industry, the
lack of global standards, which would protect
those acting in good faith, takes its toll. It also
makes it an easy target for criticism. This is why
the Investment Migration Council (IMC) believes
that global standards, education and qualifications
for those working in the investment migration
industry will contribute to a well-respected
industry.
A Platform for Education
Bringing together the leading stakeholders in
the field of investment migration with nearly 500
members, the IMC may be used as a platform to
gather all areas of the industry together to help
establish professional standards, benchmarks,
competencies, codes of conduct and best practices
for those working in or associated with the
industry. To that end, the global IMC Education
and Training (IMCET) division has been established.
IMCET will provide education and training
for all levels of staff and experience. The core
objectives of IMCET include the following:
• Development of professional competencies
and standards for those working in
the investment migration industry;
• Certificated learning opportunities
that lead to IMC professional status;
• Education and training for all levels of staff;
• Delivery of professional training and
ongoing competency development.
The educational and training programmes offered
by the IMC and the resulting qualifications will
build solid ground for further professionalisation
and responsible growth of the industry. There
will be three different levels of qualifications:
Certification in Investment Migration; Diploma
in Investment Migration; and Post-Graduate
Diploma in Investment Migration.
The Certification in Investment Migration is
an intermediate level course to be studied over six
months. This practical introduction will lead to a
professional status with the IMC and is benchmarked
at Associate level for those working in
the investment migration industry. The course
will be taught online through IMC’s learning
management system and will offer a total of five
compulsory modules. Those who successfully
complete the programme will be awarded the
IMC Certification in Investment Migration.
The Diploma in Investment Migration will
be a course to be studied over a 12-month period.
This programme will lead to Professional status
within the IMC and will be the benchmarked
professional level for those working in the industry.
This will be the first global investment migration
course of its type at this level. Therefore,
specific entry requirements will apply. Those
who successfully complete the programme will
be awarded the IMC Diploma in Investment
Migration.
Finally, the IMC Postgraduate Diploma in
Investment Migration will be a specialist qualification
designed for senior practitioners working
in, associated with or who aspire to work within,
the investment migration industry. It will be
studied over a 12-month period. This will be
the flagship qualification of the industry. It will
combine academic rigour with a practical and
applied approach. It is designed for those senior
managers who will lead the industry into its next
phase of development. Therefore, more strict
entry requirements will apply. On completing
the Postgraduate Diploma, applicants will be
awarded the highest level of professional membership
awarded by the IMC: Fellowship. n
22

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
Jacqueline Gauci, Administration Officer of the IMC
New Membership Structure for a
Stronger
Industry
Jacqueline Gauci of the Investment
Migration Council (IMC) outlines the
association’s new membership structure.
Can you give us an overview of the new membership structure?
The new membership structure is a solid commitment to further
professionalise the association and consequently, the entire investment
migration industry. It is also a commitment to standardising
the investment migration industry through a portfolio of education
and training programmes, which are being launched gradually.
There are now five membership tiers for individuals: Student,
Academic, Associate, Professional, and Fellow. There are two
pathways to IMC membership: the education route or the experience
route. It is planned that eventually the experience route will
be phased out, and the membership journey will only be possible
through the education route, except for Fellows.
Can you tell us a bit more about the two routes?
The journey through membership with the education route is the
recommended one, since this is expected to significantly strengthen
the skills and knowledge of members and by consequence the
wider industry. The first step will be the Certificate in Investment
Migration, which is intended as an online course with a multiplechoice
test at the end. This will lead to Associate membership
of the IMC. The second step will be the Diploma in Investment
Migration that will lead to Professional membership, and the final
step will be the Post Graduate Diploma in Investment Migration,
which will lead to Fellow membership. On completion of each
course, graduate non-members of the IMC will be encouraged to
join the IMC based on their educational achievement. They will be
recognised in the industry by the course designation and membership
tier they belong to.
To follow suit with other professional bodies, membership by
experience will be offered to those practitioners who meet the necessary
criteria in any membership tier to be members of the IMC.
Furthermore, there are two membership tiers for companies:
Corporate and Corporate PLUS. These remain unchanged.
Why did you feel the need to change the membership model?
Given the current level of scrutiny of the industry, we felt there was
a pressing need for the investment migration industry to demonstrate
that it can self-regulate and conduct itself in an appropriate
and professional manner. The introduction of the education route,
coupled with the launch of the education and training division,
supports our drive to enhance the industry’s standards.
How will these changes affect existing members
and what requirements do new applicants need
to fulfil in order to become IMC members?
The current nearly 500 members within the IMC will retain their
IMCM designation and be part of the Professional membership
tier where they will receive additional benefits. Those members
who have been with the IMC for five consecutive years and have
over 10 years’ experience will be encouraged to join the highest tier
of Fellow membership.
Can you summarise the benefits of being an IMC member
for those who are not yet part of your organisation?
The strength of the IMC comes from its members. Members enjoy
benefits in terms of getting access to professional development opportunities,
training and education, networking, and information
services provided by the association. The above benefits enhance
the image of the industry and promote professionalism and high
ethical standards. Being part of the leading global association concerned
with investment-related migration will support companies’
efforts to keep up-to-date on latest trends and developments in the
field. Corporate membership is also available with the additional
benefit of displaying the IMC membership logo on corporate marketing
collateral and online media.
What new initiatives do you have in the pipeline
that members should be aware of?
With the launch of the Certification in Investment Migration – at
our annual Forum held in Geneva in June 2019 – the industry sees
an overnight transformation. This entry-level course, designed to
be studied over six months, is the first global investment curriculum
of its type, and it is specifically designed for those working in
this industry. The course is taught online through our learning
management system and offers a total of five compulsory modules.
The certification has been engineered to prepare participants for
work in a changing, vibrant industry where the highest professional
standards, ethical values and enhanced competencies are
not just encouraged, but required.
Do you have a final message you’d like to share with
your current and potential members about the IMC?
The professionalisation of the industry via entry to the IMC by
formal qualifications and experience is intended to be a cornerstone
of responsible growth and development for the future. We
expect that those working in the field and those evaluating the
status and value of the investment migration industry will welcome
the formal IMC qualifications. n
23

IM
INVESTMENT MIGRATION YEARBOOK 2019/2020
DR Juerg Steffen, CEO of Henley & Partners
Investment
Migration:
The New
Normal
With 30 years of experience in
financial services and as a former
private banker, Juerg Steffen
knows what effect regulation
can have on the dynamics
of a sector. The new CEO of
Henley & Partners believes that
consolidation will be inevitable,
but that it will also drive substandard
operators out of the
market and help normalise the
investment migration industry
in the minds of international
institutions and the public at large.
As the newly appointed CEO of
Henley & Partners, Dr Juerg
Steffen certainly has big shoes
to fill, following Dr Christian
H. Kälin, who was previously
at the helm of the firm. Kälin,
who retains his position as
Group Chairman, has transformed a small firm
of wealth advisers into one of the top investment
migration firms in the world. Steffen has
ambitious growth targets, however. He has set
his sights on further developing the firm by entering
new markets, including a move into Latin
America, and shaping the entire investment migration
industry by playing an active role in realising
regulatory standards both for agents and for
government programmes.
Next Stage of Growth
After more than 20 years in the private banking
sector, Steffen joined Henley & Partners to set up
its Singapore office in 2013 and quickly made his
presence felt in the investment migration world.
“At that time, we were the first firm to look at
Southeast Asia, which then became one of our
most important markets,” says Steffen. Once he
had established the office in Singapore, offices in
Malaysia, Vietnam, Thailand and the Philippines
followed. In 2016, he moved back to Vienna to
take on the role of COO before eventually becoming
CEO at the beginning of 2019.
Steffen is taking the lead at Henley &
Partners at an exciting time in the industry’s development.
“Investment migration is entering a
new phase, emerging from its niche and some-
24

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
times misconstrued position and establishing
its place in the mainstream.” Investment migration
as a whole has experienced extraordinary
development over the past 10 years. Henley &
Partners estimates that today there are over
60 active programmes around the world, with
about 30 of those being relevant and successful.
“This remarkable forward momentum gives no
indication of slowing down. Indeed, investment
migration programmes are growing in popularity
both for investors and for states looking to
strengthen and diversify their economies and
create new opportunities for their people,”
Steffen says.
The figures speak for themselves. Investment
migration is widely credited with having brought
approximately €25 billion in foreign direct investment
into EU countries alone since 2010, and
“residence- and citizenship-by-investment programmes
have been fundamental to several of
these countries’ economic recoveries following
both the global financial crisis and the European
sovereign debt crisis,” Steffen mentions.
He has no doubt that more countries will
launch investment migration programmes,
and that the industry will gain even wider acceptance.
“When the first programmes were
launched in the Caribbean, there was strong
opposition. However, over the years, people
have come to recognise the benefits of the programmes,
and their existence has become the
new normal. I believe the same will happen in
Europe, and that we are likely to see the introduction
of many more European programmes
in the coming years.”
Resetting a Reputation
Although it occupies an increasingly established
place in the mainstream, investment migration
continues to be somewhat misunderstood
in some circles, as the sector’s increased visibility
has attracted a higher level of scrutiny by the
media, policy-makers and the wider public. “This
heightened focus, and a number of recently published
reports drawing attention to investment
migration in general, has in some cases resulted
in an unwarranted negative perception of the
industry,” Steffen says. As an industry leader,
Henley & Partners is playing an active role in addressing
this “largely unfounded perception”.
Steffen explains that over the past 20 years,
Henley & Partners has invested significant time
and capital in creating a corporate structure
that is wedded to best practice governance and
the highest levels of due diligence, even before
passing a client over for the consideration of
a sovereign state. “We have always advocated
making these strict standards of security and due
diligence compulsory in order to further improve
business practices in investment migration,”
Steffen clarifies. He notes that despite Henley
& Partners’ numerous calls for constructive dialogue
with all stakeholders, limited communication,
particularly with institutions such as the
European Commission, is one of the reasons the
“Investment
migration
programmes
are growing in
popularity both
for investors and
for states looking
to strengthen
and diversify
their economies
and create new
opportunities for
their people.”
industry has historically been misunderstood. As
Steffen observes however, the situation is changing,
as communication with all relevant stakeholders
improves.
Regulation and Consolidation
In addition to setting up its own due diligence
procedures and processes, Henley & Partners has
repeatedly called for regulation of the sector and
will continue to do so. Steffen reiterates that “the
time has come to implement a regulatory framework
that will ensure that only those committed
to the highest standards of governance and due
diligence can operate within the industry”. He is
convinced that this will drive many sub-standard
operators out of business and fuel the consolidation
of the industry.
“I am pretty sure the investment migration
industry will follow the asset management sector
in this aspect. When I started in private banking
at the age of 19, there were many small operators
in the industry, staffed by just two or three people.
However, as regulations were progressively implemented,
it became almost impossible to run a
small-scale operation. Today, any asset management
operation needs at least 10 to 20 people to
ensure proper compliance,” Steffen explains.
Dr Juerg Steffen is the Chief
Executive Officer of Henley
& Partners. Juerg has over 30
years’ experience in the financial services
industry and is widely regarded as a leader
of the investment migration industry.
After joining Henley & Partners in 2013
to set up the firm’s Singapore office, Juerg
went on to establish Henley & Partners as a
key player in what has become one of the
industry’s key regions. Later appointed Chief
Operating Officer of the group, Juerg has
played a pivotal role in growing the firm and,
indeed, the investment migration industry at
large, improving Henley & Partners’ operational
standing and developing key structures and
processes that enable the firm to keep the
industry-leading position it enjoys today.
Before joining Henley & Partners, Juerg was
a personal advisor in the family office of one of
Europe’s wealthiest families. Prior roles include
serving as a member of the management board
and head of the Wealth Planning department
of a leading private bank in Austria. Juerg
has also been a Director in the Cross-Border
Wealth Planning department of UBS in Zürich,
where he advised high-net-worth individuals
and key clients in complex matters regarding
financial, tax, succession, and residence and
citizenship planning. He has also established
and developed a private bank operation for
one of the leading banks in Switzerland and
is the editor of the definitive books on HNW
relocation to Austria and Switzerland.
25

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Open to Opportunity
While Henley & Partners is looking for takeover
targets, the firm is not yet acting as an active
consolidator. Steffen mentions that Henley &
Partners established an M&A department two
years ago, hoping that further growth could be
achieved by finding firms that it could cooperate
or merge with. However, only a handful of firms
were identified that were of interest to Henley &
Partners, and the owners of those firms did not
want to sell. “For the time being, we realised
that it is better for us to open new offices to get
into new markets. We are obviously still looking
around,” Steffen says.
Henley & Partners has enjoyed years of constant
growth, and today has offices in some 30
countries around the globe. “Because our clients
wish to have a point of contact once they arrive
in a new country, we have offices in all countries
whose programmes we promote,” Steffen says.
In terms of future expansion, Steffen notes
that Africa is an interesting growth market.
Henley & Partners already has two thriving
offices in South Africa, and the firm is in the
advanced stages of opening fully fledged offices
in two additional key markets on the continent.
Steffen’s other big plans relate to Latin America.
“This is the only region where we are not yet
active. We are definitely planning to change that
in the coming years,” he says.
“Investment
migration
is widely
credited with
having brought
approximately
€25 billion in
foreign direct
investment into
EU countries
alone since
2010.”
Advancing the Global Discourse
As the CEO of one of the leading firms in the
sector, Steffen is also keen to shape the discourse
on issues of global importance and to continue
to play a role in contributing to a more interconnected
and more tolerant world. “We have a
shared global responsibility to address the imbalances
created by deepening globalisation. It
is increasingly clear that we must find innovative
ways of approaching sovereign funding and
public finance. For countries trapped in a pattern
of negative debt, the near impossibility of breaking
the cycle via traditional methods means that
the problem is sometimes met with defeat or resignation,”
he explains. Steffen observes that the
investment migration model is a highly effective
and revolutionary means of addressing this pervasive
issue.
Steffen argues that the industry has an unmatched
capacity to expand a state’s ‘sovereign
equity’ by enlarging the number of citizens
who actively contribute to its future well-being
and insulate it from the ramifications of external
debt restructuring. “From the Caribbean to
Malta, there is mounting evidence that sovereign
equity, made possible through investment migration,
is a ground-breaking approach to ensuring
ongoing economic growth and prosperity, and a
long-term positive solution to the persistently destructive
problems caused by bad debt cycles and
limited inbound investment,” he says.
It is a solution, Steffen says, that injects new
liquidity into an economy, creates sustainable
income streams that can support public financial
needs, attracts much-needed foreign direct
investment, and provides greater national autonomy
and prosperity for all citizens. According to
Steffen, investment migration has the potential to
transform the way sovereign states and the wider
geopolitical and financial communities conceptualise
sovereign funding, foreign direct investment,
and public finance. “We look forward to
supporting countries around the world as they
adopt this innovative sovereign funding model,”
he says.
Towards the Future
Steffen points out that the recent launches
of citizenship-by-investment programmes in
Montenegro and Moldova are the latest in a
string of examples illustrating that sovereign
states around the world increasingly view these
programmes as a sustainable and vital form of
foreign direct investment, one that results in
greater long-term prosperity for countries and
their people. “I have no doubt that more countries
will soon follow suit, and that the investment
migration industry’s performance will
continue to exceed all expectations in the year
ahead,” Steffen says.
He is certain that the industry will continue
to change, evolve, and transform itself to meet
the needs and demands of global investors and
sovereign states and their people. “Investment
migration is a multi-billion-dollar industry that
drives significant liquidity streams and creates
real societal value. We believe that its continuing
growth will drive the industry towards
regulation, and that this should be welcomed.
Persistent growth will also result in an increasing
number of states around the world experiencing
the significant benefits that are derived
from hosting prudently managed citizenshipor
residence-by-investment programmes that
drive investment without adding to the burden
of debt.” n
26

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Austin T. Fragomen Jr., Chairman and Partner at Fragomen
Diversify
to Grow
Fragomen is widely seen as the leading
law firm focused on providing immigration
services worldwide. How was 2018
for your firm and what initiatives are
high on your agenda for 2019?
2018 was a good year for Fragomen. We grew by
around 10% and are now one of the biggest firms
offering immigration services. We are number
80 on the list of the world’s largest law firms, and
in the US, we are ranked number 60. From individual
private clients and small local businesses
to the world’s largest companies, we offer support
and advice on all immigration needs. In terms of
investment migration and our private client practice,
we are experiencing big movements mainly
due to the changing dynamics in the mainland
Chinese market. Thus far, mainland Chinese
nationals very much dominated the investment
migration industry, which is particularly true
when it comes to immigrating to the US. Given
the current difficulties and restrictions, key
stakeholders in this industry are eager to reduce
the reliance on the mainland Chinese market.
Hence, one of our top priorities is diversification.
We are further building and developing our referral
networks and forging new relationships
with corporate service providers, accountants,
lawyers and real estate experts in a number of
new jurisdictions. At the same time, we are educating
potential mainland Chinese clients who
may be interested in locations other than the US,
since we offer immigration services into over 150
countries.
Geographically, where exactly
are you planning to expand?
Titan of industry is not a term that is easily attributed.
Austin Fragomen could lay claim to this title, but
it is certainly nothing he would ascribe to himself.
However, with more than 4,200 employees, offices
in almost 30 countries and a ranking as one of the
top 60 legal firms in the US, it is a title that sits easily
with someone of his calibre. The IM Yearbook
spoke to him about the major trends currently
influencing the investment migration industry and
how the sector will evolve over the next years.
India is interesting; it is a massive market. We are
very well connected in India because on the corporate
side of our business we already represent
a number of major companies, particularly in
the Indian IT space. We have around 500 people
working for us in India, and are the dominant
service provider in that space. So we work off
our considerable contacts and organise seminars
in different cities and so forth. In general,
we are particularly interested in Southeast Asia.
We have been doing a lot of marketing not only
in Vietnam, Indonesia and Thailand but also
in Malaysia, which has a very interesting programme
based on real estate. We have an alli-
28

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
ance with a very strong regional law firm based
in Kuala Lumpur with offices in many southeast
Asian countries. In addition, we consider South
Africa an interesting market, and we continue to
do a lot of business in South America, particularly
in Brazil and Mexico.
Some say Africa is the rising star
of the future. Do you agree?
In Africa you have many developing nations and
some interesting frontier markets, such as South
Africa and Nigeria, which are further along and
interesting. But is the whole of Africa the way to
the future? I don’t think so.
In terms of your marketing efforts, are
digital channels playing an increasingly
important role in acquiring clients?
I still think that the traditional referral networks
will remain the main channel to generate new
business as opposed to digital media. Word of
mouth still resonates with high-net-worth individuals
and their advisory network.
There is a general anti-immigration trend
that is currently permeating immigration policy
around the globe. The bottom line is that countries
are becoming more restrictive, and programmes
will most likely become more expensive.
Take the USA’ EB-5 visa as an example.
There are executive branch proposals that the
investment threshold should be raised from
$500,000 to $1.35 million. This means investment
migration will not remain as attractive to the
mass affluent market as it is today. The industry
will lose those successful middle-class mainland
Chinese clients who have really driven the
market so far. In my opinion, the client profile
will change, and the focus now and in the future
needs to be on attracting high-net-worth and
ultra-high-net-worth individuals, as those will
be the clients who will continue to afford these
programmes. This changing client profile also
affects our marketing measures. We are dealing
with more sophisticated, wealthier people, and
attracting them through social media is not going
to work.
There are a number of programmes that are
using price as a lever to attract a broader
spectrum of applicants. Do you think these
programmes will be an attractive choice
for candidates of more modest means?
The US and the UK are still among the top destinations
for many of our clients. However, we have
seen numbers drop for the UK programme since
the investment threshold was raised a few years
ago. So, yes, we are definitely seeing the emergence
of a second tier; programmes such as those
of Malta and Cyprus are receiving a lot of interest.
These countries might not be a client’s first
choice, but they make a lot of sense if the goal is
to get access to the European Union.
Austin
Fragomen
is Founder
and Chairman of the
Executive Committee for
Fragomen, one of the
world’s leading law firms
dedicated exclusively
to immigration services
worldwide. Established
in 1951, Fragomen has
grown from a respected
domestic US immigration
law practice to a truly
global organisation.
Austin has served as
staff counsel to the US
House of Representatives
subcommittee on
immigration, citizenship
and international law and
as an adjunct professor of
law at New York University
School of Law. Also,
he has testified before
Congress on a range of
immigration issues and
before the immigration
sub-committees of the
House and Senate to
share his knowledge on
a variety of business
immigration issues.
Then there are a number of countries with
much lower entry requirements, but I would
argue that they are also less desirable destinations
for most. I am not convinced that getting
citizenship of a Pacific island nation is going to
be the best solution, especially not if visa-free
travel is the main objective. One of the other
big developments that we are seeing is that international
organisations such as the EU and
the OECD have come out against economic citizenship
programmes. The question remains if
and what actions will follow. Would the EU for
instance curtail visa-free access for individuals
from certain countries? This would definitely be
a game changer.
What would you highlight as the other
most noticeable trends at the moment?
The hot news is the emergence of entrepreneur
programmes, which are becoming increasingly
popular. However, the problem in my opinion is
that no one has really defined what an entrepreneur
is. What happens to an entrepreneur should
the business not take off? Then you just have
another immigrant who doesn’t have any money.
There are obviously ways to deal with it, including
granting only provisional residency rights
until such time the entrepreneur proves his/
her business is successful. I think some of these
entrepreneur programmes need to be tweaked
a little. However, there is certainly a market for
those programmes.
On the other hand, I think the political
support for anything that includes ‘buying
status’, and particularly passports, is decreasing.
There is too much negativity around that, and
I think it will be difficult to get new citizenship
programmes off the ground. I believe new programmes
will be leaning more towards residency
rather than citizenship. In addition, more programmes
will be designed to create employment
and economic activity, while programmes just
requiring a cash donation to government will be
harder to justify in the future. The political environment
is more frightening than many people
may realise. That is true for migration in general.
The number of migrants in the world keeps
growing due to issues such as poverty, famine,
economic crisis, wars and so forth. The rhetoric
surrounding these issues has definitely created a
negative climate, and this has a real effect on the
entire industry.
What is your outlook for the investment
migration industry over the next five years?
Despite the difficulties we talked about, I am still
bullish on the market for this type of investment.
It is positive that there are presently more people
interested in these programmes than there were a
few years ago. I also believe the high demand for
these programmes will be a counterforce to the
more restrictive trend that we are witnessing, and
it will ultimately drive government policy. n
29

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Zac Lucas, Founder of Centenal Pte Ltd.
Taxing Times:
Why the OECD
Didn’t Get it Right
Zac Lucas talks about
the Common Reporting
Standards, the OECD’s
blacklist and the need to bring
immigration consultants
into the regulatory fold.
How would you describe the current
environment and tax implications for highnet-worth
individuals and their advisers?
High-net-worth individuals are on the radar of
tax authorities around the world, and they have
to navigate a difficult and complex landscape
since the introduction of the OECD’s Common
Reporting Standard (CRS). Many wealthy individuals
who are doing business internationally
are facing the issue that they are involved in
structures that are not recognised by tax authorities
in their home countries. For instance, many
civil law countries do not recognise the concept
of a trust, which then in turn creates significant
issues once that information is reported under
CRS to the tax authorities. In addition, affluent
individuals are sometimes advised to set up
certain structures and are told that these are not
reportable, but this might not always be true.
On the advisory side, the situation is equally
complex. The proposed Mandatory Disclosure
Rules (MDR), designed to supplement the CRS,
are intended to be retroactive, and the OECD has
put October 2014 as the start date. This means
that a lot of the activities that happened in the
run-up to the implementation of the rules will
need to be looked at. One suggested method of
enforcement would involve a name and shame
mechanism, which would be a threat to the professional
reputation of advisers. This could easily
result in advisers being taken aside by government
officials when they fly in to see their clients,
based on prior MDR reports. It is now becoming
a personal security issue for tax advisers. In my
opinion, we have seen a rollout of mass surveillance
measures, and the CRS is one of them, supplemented
of course by the proposed MDRs.
“One suggested
method of
enforcement
would involve a
name and shame
mechanism,
which would
be a threat to
the professional
reputation of
advisers.”
All of this should be viewed in the context
of the big privacy push that is going through the
EU at the moment, including the General Data
Protection Regulation (GDPR). The GDPR and
the CRS are complete opposites, and not easily
compatible. It is ironic that the OECD was the
organisation that actually championed privacy
guidelines in the early 1980s, but they seem to
have forgotten about that. The European Court
of Justice (ECJ) has already ruled against an infringement
in privacy with respect to police retention
of records, and I am almost certain that
should there be a case ‘GDPR versus CRS’, the
OECD will have to significantly amend the CRS
rules.
In your opinion, can residence and citizenship
programmes potentially be used to
misrepresent an individual’s jurisdiction of tax
residence and endanger the proper operation
of the CRS due diligence procedures?
The CRS is filled with loopholes, and there are
much simpler methods for individuals who
want to circumvent the CRS to use than misuse
of a residence and citizenship scheme. I’ll give
you an example. The CRS contains an “Active
NFE” classification (Active NFE means an
entity that holds a financial account where the
relevant financial institution cannot report the
ultimate beneficial owners of the entity), termed
a “Start Up” Active NFE. Account holders may
take advantage of this classification in order to
avoid reporting under the CRS for a period of
up to two years, when in fact they never had a
real intention to start a business. The other area
of abuse, which some think is rampant at the
moment, involves the misuse of what is termed
“Managed Investment Entities”, which are typically
owner-managed personal investment companies
that grant some discretionary portfolio
management to either a bank or external asset
manager. A Managed Investment Entity is not
subject to CRS reporting by the various banks
and/ or assets managers that are connected to
the entity. Instead, the Entity itself is supposed
to do its own reporting, which some believe is
not then occurring.
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INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
But do you believe it is possible to use
the residence route to circumvent tax?
In my opinion it is very difficult. We now have
the OECD’s high-risk jurisdiction list, and most
countries that are involved in the investment
migration industry are on that list. If clients
from any of these jurisdictions seek to open a
financial account, a modestly trained compliance
team will be difficult to fool. The moment
the client produces proof of residency from
any of those jurisdictions, some fundamental
questions will be asked. Some three or four
years ago, the situation might have been different,
but today the large banks are very careful
and actively protect their reputation. To make
it through, high-net-worth individuals would
have to build up a chain of collusion that includes
their bankers, lawyers, advisers and so
on. However, ultra-high-net-worth individuals
are not putting themselves in such a precarious
position, and high-net-worth and mass affluent
individuals simply don’t have the resources to
achieve this level of collusion.
So why is it that the investment migration
industry and high-net-worth clients
are being discussed in this context?
Here we need to talk about the sloppiness of the
industry. The industry is made up of a lot of advisory
firms. They seem to know their own jurisdiction
very well but they might not be familiar
with the legal implications in other countries.
Furthermore, while there are many knowledgeable
advisers, there are still some ‘cowboys’ in
the industry who might not even ask what the
true intention of the applicant is, or the underlying
purpose.
Besides, in many markets the immigration
adviser is not necessarily the first point of
contact for high-net-worth individuals. Let’s
look at China or India. These countries do not
have open markets; you don’t get in that easily,
unless you are a brand. So consultants need to
network their way through to be introduced to
a high-net-worth family. The immigration specialist
might be the third or fourth supplier that
these families get introduced to. This also means
that in many instances the immigration consultant
just doesn’t know what happens next, and
why a residence or passport was sought.
What’s your suggestion to address this issue?
The industry needs to bring immigration specialists
into the regulatory fold, where this is not yet
the case. I don’t think self-regulation will work,
due to the lack of enforcement power. Once consultants
are regulated and subject to Anti-Money-
Laundering laws, many of the current issues will
disappear.
Zac Lucas is
the Founder of
Centenal Legal
Technology Group. Zac is a
practicing lawyer with over
20 years legal experience,
admitted to practice in
England and Wales, and is
a former Partner of various
international law firms
advising on all areas of
international private client
law. Zac has particular
expertise in relation to the
OECD Common Reporting
Standard (CRS). He has
been engaged by a number
of leading private banks,
trust companies, wealthy
individuals and families, and
a governmental authority,
to advise on the practical
implementation of the CRS.
What’s your outlook for the industry?
I think we will see more regulation. We need to
keep in mind that there are two things that don’t
win any votes: being soft on terrorism and being
soft on high-net-worth individuals. So it might
become a lot harder to access EU countries in the
future, and I think things like a simple speeding
fine will be held against applicants. We might
also see a curtailing of certain benefits, such as
visa-free travel, that these programmes offer. I
would not be surprised if the Caribbean countries
that are currently enjoying access to the
European Union might not get these kind of
perks in the future. However, all of this depends
on whether the industry will experience continuous
scandals. From a tax perspective, the future
is more uncertain as a lot of the issues that I have
flagged have yet to hit the market. Tax authorities
around the world are only now waking up
and starting to understand the information they
have received from the CRS process, and deciding
how they should react to it. A major game
changer would be if non-financial assets, such
as land and property, would be included in the
CRS. Many ultra-high-net-worth individuals are
currently investing in these asset types, basically
transforming reportable capital into non-reportable
capital. n
31

IM
INVESTMENT MIGRATION YEARBOOK 2019/2020
Bob Kraft, President of IIUSA
Time for
Renewal
America’s EB-5 Programme has been the most successful immigrant
investor programme in the world. However, a series of short-term
extensions and the constantly growing quota backlog mean its
future remains uncertain. The IM Yearbook spoke to Bob Kraft,
President of Invest in the USA (IIUSA), the industry trade association
of the EB-5 Regional Centre Programme, about the way forward.
32

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
n increase to 50,000 investor visa
units and a rise in the minimum
investment amount to roughly
$750,000 are some of the suggested
changes that Bob Kraft, President
of Invest in the USA (IIUSA),
believes are necessary but sensible enough to
ensure the future success of the EB-5 Programme.
Over the years many have called for significant
reforms of the EB-5, especially when it comes to
the Regional Centre Programme, amid concerns
about fraud. The programme has however remained
unchanged, but Kraft says the potential
for a thorough legislative overhaul has never been
greater. “For a long time, the US industry was very
fragmented in its positions, and it was only recently
that we managed to find common ground that
allows us to speak with one voice and drive the discussion
forward,” says Kraft.
30 Years Running
Since its inception in the 1990s, the EB-5
Programme has seen a total of 20 extensions,
but without the much-needed reforms. The
latest extension is running through to the end
of September 2019. The EB-5 Programme is
far too valuable to the US economy to simply
end it. According to IIUSA, the programme has
raised more than $35 billion since 2008. During
the federal fiscal years (FY) 2014 and 2015 alone,
nearly $11 billion in capital investment was invested
in EB-5 projects, accounting for 2% of all
Foreign Direct Investment net flows to the US
economy. More than 355,000 jobs were created as
a result of the programme in FY2014 and FY2015
alone. “During the 2007/2008 downturn, EB-5
money was actually responsible for a large part
of economic activity because funding from the
banks dried up. It is a great tool that has been
very effectively used across the country,” says
Kraft. He highlights that in the early days of the
programme, EB-5 money accounted for as much
as 100% of project funding, which then moved
down to 50% of project value, and today comes in
at around 25%. A whole host of projects are partly
financed by EB-5 money, ranging from hotels and
manufacturing plants to hospitals, schools and
metro systems.
Driving Reform
While many within the industry have long
acknowledged the need to overhaul the programme,
Kraft mentions that disagreement
between the various stakeholders on the way
forward meant it was difficult for US lawmakers
to put a package together that was acceptable to
everyone. They wanted the industry to work out
a solution and then come back. “One year ago,
we agreed to look beyond the animosity in the
industry and identify those areas where we were
in agreement, compromise on issues on which
we could not get together in the past, and present
a united front to Congress. Since then, we are
having weekly meetings with the groups that are
working on new legislation.”
Robert W.
Kraft is the
President of
IIUSA’s Board of Directors
and has been an active
member since 2007. He is
also Chairman, President
and CEO of FirstPathway
Partners (FPP), a firm that
helps foreign investors
become United States
citizens under Homeland
Security’s EB-5 Regional
Centre Programme.
He has more than 40
years of international
business experience
at the Executive
and Board levels.
However, bringing the industry together is
not the only hurdle. As in other countries, the
whole immigration debate is very emotional
and “has been a political football used by both
parties”. The EB-5 industry is just “a tiny piece
of the overall immigration picture, although we
are probably the most productive. However, disagreement
on the entire immigration issue has
thus far also prevented any advancement on the
EB-5 front.” IIUSA is now hoping to get its bill rewritten
and get Congress to tackle EB-5 separately
from other immigration questions. “I am optimistic
that all these efforts will lead to updated
legislation,” says Kraft.
Priority Areas
IIUSA is targeting a six-year authorisation,
“which would place the programme on very solid
footing”. The number one priority is to increase
the number of visas that can be issued. “Part
of the problem was that the cap of 10,000 visas
was interpreted in a way that family members
were counted as individual visa holders. A cap
of 50,000 investor visa units, combined with the
proper interpretation of family members and
main investors, would provide the programme
with a solid runway for growth,” says Kraft.
Still, there are some contentious issues. “We
are not in agreement with raising the minimum
investment to $1.35 million as indicated in the
recent draft regulation.” While IIUSA does not
contest the need to increase the required investment
given that it has remained at $500,000
since the programme’s inception, an increase
to $750,000 or $800,000 is seen as acceptable
from the industry’s point of view. US lawmakers,
however, are looking to other international
programmes where applicants routinely pay in
excess of $1 million. Giving the standing of the
US in the world, lawmakers believe the US programme
should be on par, if not ahead of what
other jurisdictions are requesting.
Other aspects of the regulation aim to
strengthen reporting standards and are putting
more responsibility on regional centres to protect
investors. “These elements will be beneficial, as
would be a faster processing time. We also aim
for more clarity with regard to the projects that
qualify for funding from the programme,” says
Kraft. One of the key criticisms about EB-5 is that
investment is not always channelled into rural
and high-unemployment areas as it was originally
intended. Kraft believes that more clarity
will help EB-5 to fully unleash its potential for
job creation. n
33

IM
INVESTMENT MIGRATION YEARBOOK 2019/2020
Edward Beshara, Managing Partner of Beshara Global Migration Law Firm
Why Strategy
is Everything
EB-5 has for many years been a runaway
success. But with ever-increasing
waiting times and long delays for some
nationalities, defining the right strategy
has become the most important exercise
of the immigration process, says Edward
Beshara, US Attorney at Law.
The USA’s EB-5 Programme
has long been considered the
gold standard of residenceby-investment
programmes
in the world. However, to
keep investor interest high,
stability and predictability
need to again become the
hallmarks of the programme, says Edward
Beshara of Beshara Global Migration Law Firm.
“While there is definitely a need for new, modern
legislation to ensure that EB-5 remains a competitive
choice for high-net-worth investors now and
in the future, there are also many other avenues
that applicants can explore if they wish to enter
the US. In fact, the EB-5 Programme might not
always be the first or best choice,” he adds.
Boom Years
Although in existence since 1990, EB-5 experienced
a boom in interest during the past 10 years
following the 2008 financial crisis due to a combination
of factors, says Beshara. With liquidity
squeezed and banks refusing to lend, US developers
started promoting the programme extensively
in an effort to access low-cost EB-5 funds
to secure financing for their projects. Another
reason for the rise in applications was the cooccurrence
of Canada’s decision to phase out its
federal Immigrant Investor Program. The US
suddenly became the preferred destination for
wealthy foreign investors, predominantly mainland
Chinese nationals, seeking both economic
opportunities abroad, as well as educational opportunities
for their children.
Regaining Competitiveness
“I think in some ways the EB-5 has become a
victim of its own success,” says Beshara. “The
waiting time for Chinese investors is just one
example of this.” Due to the annual ceiling limit
of 10,000 EB-5 Conditional Resident Visas for
34

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
“The USA’s EB-5
Programme
has long been
considered the
gold standard
of residenceby-investment
programmes in
the world.”
investors and their family members, and the
presence of per country limits, Chinese investors
today face an estimated waiting time of 14 years.
He points out that applicants also need to take
into account that the monthly State Department
Bulletin for available visa numbers per EB-5
category is different than the actual or real time
delays or retrogression. Beshara also mentions
that in the early days of the programme, EB-5
petitions were approved in one to three months.
As soon as the petitions were approved, investors
could apply for their conditional residence visa.
“In general, when we file a petition today, it takes
about 24 months before the government comes
back to us. Investors also need to factor in another
five to six months until they receive their conditional
green card. But as I mentioned previously,
this timeframe is extended to 14 years before
Chinese investors can apply for their Conditional
Resident Visa.” Beshara believes that speeding
up the petition and application process, as well as
increasing the number of Conditional Resident
Visas per year, would go a long way towards improving
EB-5’s overall competitiveness.
“We have to keep in mind that EB-5 is only
one of many investment migration options available
in the global marketplace, and at times the
investment opportunities offered in other countries
might sound more appealing to investors,”
says Beshara. “I always point out that the EB-5 investment
is 100% at risk from a business perspective.
Investors and their advisers need to do their
homework and look into the projects they plan to
invest in and their history of success. Businesses
and projects can fail, and there cannot be a guarantee
that investors will get their money back.”
This also applies to projects associated with a
Regional Centre licence. “While investment
through the Regional Centre Programme can be
an EB-5 compliant project for immigration purposes,
it does not mean that the US Government
is approving the business viability of the project.”
A Plethora of Options
Although new EB-5 legislation and/or US
Immigration Regulations have yet to materialise,
the US has not lost its appeal to wealthy investors.
“However, it is essential to find the best strategy
for each client,” says Beshara. In the past, Chinese
nationals accounted for 85% of EB-5 investment
volume and even though their numbers have
dropped, they still are in the majority per year,
according to Beshara. “The majority of investors
are looking for relief from the quota backlogs and
for greater certainty, and there are alternative US
visas to the EB-5 Programme that can be more
attractive, depending on the circumstances,”
he says. Many of his clients are more interested
in securing educational opportunities for their
children rather than a new residence location for
themselves. “In these cases, it makes a lot more
sense to apply for a student visa.” Another option
might be to apply for an E-2 treaty investor visa,
which works for citizens of countries with bilateral
investment treaties with the US. The E-2 visa
may be obtained in a few months, for entry of the
investor and their family.
He also noticed a substantial increase in the
volume of citizenship by investment applications
in other countries, whereby the final goal remains
to enter the US. “One solution involves obtaining
citizenship in the Caribbean country of Grenada,
a country that has both a citizenship by investment
programme and a bilateral E-2 investment
treaty with the US.” Once becoming a citizen, the
new Grenada citizen is eligible to apply for an
E-2 investor work visa for the US. This can be a
solution to fill the gap until the investor is able
to apply for US permanent residence, or it can
be an option instead of the EB-5 visa scenario.
Obtaining citizenship in Grenada may be the first
choice compared to other E-2 treaty countries,
given that high-net-worth investors can obtain
citizenship in Grenada in three months.
Despite these alternatives, Beshara believes
that new EB-5 legislation is required sooner,
rather than later. “The US remains a magnet for
immigrants coming from all corners of the world,
but in my opinion, Congress must act fast to push
through new legislation otherwise investors will
start seeking other options, some of which may
be outside of the United States.” n
Edward Beshara is Managing
Partner of BESHARA GLOBAL
MIGRATION LAW FIRM based
in Orlando, Florida since 1983. He has
been exclusively practicing US Business
Immigration Law (including the E-2 treaty
investor, intra-company executive transfers,
and National Interest petitions) and offering
approvable strategies and solutions to
foreign nationals throughout the US. He
represents corporate and individual clients
from all countries worldwide in regard to
their US immigration goals. Edward has
been representing foreign national investors
and corporate clients in regard to the EB5
process since 1991, and concentrating on
the EB5 Regional Centre and individual
EB-5 Direct process for over ten years.
35

IM
INVESTMENT MIGRATION YEARBOOK 2019/2020
Larry Wang, President of Well Trend United
Inside China’s
Migration Industry:
Too Big
to be
Ignored
Chinese nationals
are among the
top applicants
for residence
programmes across
the world; yet, they
are encountering
more barriers than
ever to realising
their emigration
plans. Larry Wang,
President of Well
Trend, talks about
the deregulation
of immigration
consultants in China,
the EB-5 backlog,
and what Chinese
clients really want.
How would you describe the current
immigration market in China?
The good news is that demand is still very strong,
despite the fact that the Chinese economy is
slowing down. December 2018 marked the 40th
anniversary of China’s reform and openingup
policy, and the appetite to go abroad by those
that got rich during the past decades continues
unabated. The bad news is that the government
has deregulated the market. From February
10th 2019, immigration consultants operating in
China are no longer required to have a licence.
My firm Well Trend has been around for 24 years,
and we are now witnessing a massive influx of
new start-ups.
Why did China decide to drop the
regulation at a time when most countries
are moving towards regulating agents
and service providers; and what effect
will this have on the industry?
I would really like to know the answer to that, but
I can only guess that the Chinese Government
wants to be seen as open. As I mentioned, we
have seen a lot of new firms coming into this
market. In one Chinese province we have seen
almost 6,000 new immigration consultants starting
to operate, and we estimate that in the whole
of China close to 20,000 new immigration consultants
entered the industry since the deregulation.
Among them are wealth managers, real
estate companies, and even travel agents who feel
they have clients interested in migration products
but don’t necessarily have the required knowledge
and experience in this industry. I am pretty
certain that a good number of these firms, probably
around 35% of the new entrants, will be gone
in a few months, and the market will ultimately
decide which firms are capable and therefore will
survive. However, in the short term this means
that clients need to choose carefully which immigration
consultant they work with.
How is the Chinese Government looking
at the industry at the moment? There
seems to have been a drive to get Chinese
to invest at home rather than abroad.
China is still encouraging people to go abroad,
but the biggest challenge these people are currently
facing are currency controls. It is not easy
for Chinese high-net-worth individuals to transfer
money abroad. Every Chinese individual is
only allowed to transfer up to $50,000 per year
36

INVESTMENT MIGRATION YEARBOOK 2019/2020
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out of China. Obviously, that is not enough for
immigration purposes. Looking at the EB-5
Programme, they need to make an investment of
$500,000. That means applicants would need to
find 10 people who would pool in their annual
quotas for moving money overseas, or use their
international network to source the funds.
What countries and programmes
are high on the agenda of Chinese
high-net-worth individuals?
For 80% of our clients the two main drivers are
securing visa-free travel for business and leisure,
and better education for their children, whereby
many families are seeking ‘native English education’.
This also explains why the US and Canada
are still the top two destinations for Chinese nationals.
The issue with many other programmes,
especially the European ones, is that they don’t
provide English-speaking educational opportunities,
and hence they are not as attractive. The
fact that education is the main driver also means
that the main applicants don’t necessarily want to
go abroad themselves.
What advice do you give them in relation
to EB-5 given the long waiting time?
In my opinion the EB-5 programme is not the best
solution for many of our clients. As I mentioned,
most Chinese just want to send their children to
the US to study. Many of my clients are well-established
and successful entrepreneurs who want to
stay in China, and they also want their children
to come back to China after completing their
studies. We are also pointing out to our clients that
once they have obtained their visa as part of EB-5,
they have to live in the US, otherwise they might
lose their status if they don’t apply for a leave of
absence. So I think the EB-5 programme is not the
ultimate solution, and depending on the circumstances,
it makes more sense to apply for a student
visa for their children.
How attractive are programmes
in Europe to your clients?
It is increasingly becoming more difficult to
enter the US and Canada, so our clients have no
choice other than to consider other countries.
Europe is becoming more and more popular in
the Chinese market. The Greek programme is
very price-competitive, and saw a lot of traction
last year. However, I think a lot of agents have
over-promoted the programme, and this year
we will not see the same momentum as last year.
The numbers will be lower. However, the investment
of €250,000 is very attractive to the majority
of people in China. In Beijing, real estate prices
are excessively high, and for the price you need
to pay for an entire house in Greece you would
only be able to purchase a kitchen in Beijing. I
also see Portugal, even though the investment requirement
is double at €500,000, as an attractive
“December 2018
marked the 40th
anniversary
of China’s reform
and openingup
policy, and
the appetite to
go abroad by
those that got
rich during the
past decades
continues
unabated.”
Larry founded
Well Trend in
1994 starting
with just two employees.
Now Well Trend has over
400 employees and offices
all over China, as well as in
Vancouver and Budapest.
Wang is regarded as an
immigration pioneer in
China since Well Trend
was one of the first to
introduce Canadian,
American, and European
programmes. Wang is
highly sought after for
his views on immigration,
having been interviewed
by all major international
and Chinese media outlets.
He is regularly invited
to speak at immigration
conferences in North
America, Asia and Europe.
market. Several years ago, there were some problems
with the programme, but I hope to see the
return of the Chinese in Portugal in 2019, especially
with the US becoming more and more difficult.
Given that it is English-speaking, Ireland
is also becoming an attractive option. In my
opinion, Malta and Cyprus need to stabilise their
programmes, also vis-à-vis the European Union,
in order for them to become more attractive. In
Malta, the process is also very slow, and we have
some clients who have been waiting for almost a
year, which is very frustrating for them.
What’s the acceptable timeframe
for Chinese clients?
That’s an interesting question, as most clients
want to get their visa as soon as possible, even
though they don’t want to go immediately. Once
they have their visa, they often ask me when they
have to be there at the latest for it not to expire.
This is an issue of trust, and therefore, they want
to hold the visa in their own hands as quickly as
possible. I would say that three to four months is
an acceptable processing time.
Many programmes are coming up with
different investment options. What is the
preferred investment route of the Chinese?
Well, I always advise clients that they first need
to focus on the immigration aspect, and not on
the return on their investment. While it is not
impossible to achieve both, I always tell them to
prioritise immigration. Overall, I am not a big
fan of the equity option and programmes that
require applicants to become a shareholder of
a company. This route is too complicated for
them. I think a loan option is a better way; it is
much more straightforward and it is also a safer
investment. In terms of real estate, I am not
saying the opportunity in some countries is not
good, but our time and energy is limited, and we
need to focus on what makes most sense to our
clients.
What recommendation would you make to
programme operators and agents seeking
to market their programmes in China?
I would advise them to focus a bit more on the
needs of the clients rather than their own. China
is a very important market that should not be
ignored. Due to the EB-5 backlog, some agents
switched their attention to other markets, such
as India and Vietnam, but even taken together,
these markets are not as large as the Chinese
market. I also feel that Chinese immigrants
should be welcome wherever they go; they are
very diligent, loyal and hard-working people.
And I am pretty certain that the Chinese market
is a lasting one that will be around for many years
to come, although it is a bit difficult to ascertain
which programmes will be popular in China over
the coming five years. n
37

IM
INVESTMENT MIGRATION YEARBOOK 2019/2020
Martin O’Connor, CEO of Kylin Prime Group
We Need to Enter an Era of
“Coopetition”
Successful industries thrive on having the culture and ability to compete vigorously
but at the same time collaborate strategically - ‘coopetition’, and the investment
migration sector is no exception, says Martin O’Connor, CEO of Kylin Prime
Group. He calls for an enhanced dialogue between international institutions,
countries and companies for the greater benefit of the market and society.
Kylin Prime has an unusual operating
model compared to many in the industry.
Can you tell us a bit more about it?
We have adopted a very specific model and
created what we call an entire ‘ecosystem’, which
means we can offer our clients holistic packages
provided by different companies within the
group. Kylin Prime Group is our master brand,
and within that group for example, we have
Kylin Prime Funds, Kylin Prime Capital, Kylin
Prime Family Office and Trusts and Corporate
Services; while Ousheng & Partners focuses on
global mobility and RCBI programmes. These
companies all work closely together focused on
investment security and return on investment;
ensuring that transparent investment vehicles
are being used.
“I believe in an
environment that
allows firms to
compete but also
to collaborate
where necessary,
for instance on
issues that are
important to
help develop
the industry
further. ”
The investment migration industry is currently
under extreme pressure, with potential
tax evasion, security threats and money laundering
often being cited by the industry’s critics. We
have set up highly regulated investment funds in
key markets that our clients like to invest in, such
as Ireland, the UK, Malta, Cyprus and Portugal.
This means our clients are subject to financial
regulation and have gone through the most
stringent due diligence and KYC processes. We
are also the majority shareholder of a European
banking institution, which gives us the additional
opportunity to offer private banking and wealth
management services to our clients. Apart from
that, we have established a think tank, the Future
Citizen Institute, which produces research and
analysis related to investment migration. We
would like to see the institute evolve into a strong
38

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
knowledge partner for all stakeholders in the investment
migration industry.
I believe in an environment that allows firms
to compete but also to collaborate where necessary,
for instance on issues that are important to
help develop the industry further. We need to
come together and support the main industry organisations
so that we speak with one voice.
How would you describe the state of the
investment migration industry at the moment?
The industry is at a pivotal moment in its young
history. The sector has matured and professionalised
quite a bit during the past three years, yet
the case for collaboration is stronger than ever
given the increased scrutiny from international
institutions such as the EU and the OECD, policy-makers
and the general public. The industry is
now entering the shakeout period. Consolidation
will be inevitable as the industry moves towards
increased levels of regulation, be it in the form
of government regulation or self-regulation. The
key players in the marketplace are clearly supporting
this direction, but this will create an environment
in which smaller firms might struggle
to survive.
What are the top three challenges
that the industry is facing?
The main challenges relate to industry reputation
and trust. Many people dislike the concept of investment
migration from an emotional mindset.
The post-Brexit Irish passport boom is a good
example of this issue. Recently, Ireland has received
some 200,000 citizenship applications from
UK nationals of Irish heritage, and in fact there
are around 6.7 million people in the UK who are
eligible for Irish citizenship. I think it is fair to say
that the majority of these people don’t have a real
interest in Ireland. They will most likely not visit
Ireland and neither will they invest in the country.
However, the public at large has no problem with
the fact that record numbers of Britons are now
seeking Irish passports. On the other hand, when
migration of high-net-worth individuals is talked
about, the narrative is rarely positive, despite these
people contributing enormously to the economy.
This brings me to the third challenge: We have
to get to the stage where the EU has a realistic
view of the industry. The recent reports from
the European Commission and the European
Parliament both reflect a lack of understanding of
how the investment migration industry operates
and what economic benefits and value it brings to
countries. The EU has to be open to hear the positive
side of the industry.
What do you think programme regulators
and the industry need to do to restore
public trust and set the record straight?
We cannot deny that there have been instances of
Martin
O’Connor
is the CEO
of Kylin Prime Group.
Highly experienced in
international affairs
and organisational
development, he has
worked in complex
business, political and
regulatory environments.
He has led teams involved
in mergers, JVs and
partnerships, and coached
executives from the
world’s leading brands.
bad practice, and it is our responsibility to clean
up the industry. We need to make sure that all
players adhere to ethical standards and professional
behaviour at all times. Organisations that
do not follow these rules should be ostracised.
We, as the industry, also need to learn to work
together effectively and prioritise long-term
benefits over short-term gains. After all, it is our
reputation that needs to be safeguarded, and I
am pretty sure that companies that will continue
to prioritise short-term gains over long-term benefits
will fall by the wayside.
So is the answer to the current situation to
encourage the EU to take a more central
role and oversee the industry, similar to the
EU’s supervision of the banking sector?
The EU is very clear in saying that the granting of
citizenship and residence are national rights, and
I don’t think the EU is interested in supervising
the sector directly. At the moment, we are seeing
that sensationalist rhetoric is shaping the debate.
Investment migration is a multi-billion euro industry.
It involves investment that can bring huge
benefits to society and economies and also involves
people’s rights. Security issues, financial
crime and tax evasion seem to be areas of concern
for the EU. Our industry has to be responsible in
these areas but the EU, as well as the OECD, also
need to be responsible in their pronouncements
and intentions and not stymie something that can
be so beneficial all around. It works both ways.
What are the big trends in the industry
that you are noticing at the moment?
From the clients’ side, we are seeing a growing
need for an all-encompassing investment and
RCBI journey. For many ultra-high-net-worth
and high-net-worth individuals, diversification of
assets is the top priority, and they are interested
in more than just getting a visa. The other trend
is that we are seeing more programmes being
introduced, and I expect this number will only
increase in the coming years, as more governments
recognise the benefits that countries with
programmes reap.
What’s your future outlook for
the next five to ten years?
If we can overcome the current issues and build
a sustainable investment migration industry, the
industry can become hugely beneficial, not just
commercially to the companies involved in this
sector but also for global society. I am convinced
that the sector can be a catalyst for global growth
and an evolution towards future citizens.
Investment migration has the chance to help
shape our future societies, redefine global mobility
and reposition our understanding of where
we are from in favour of a more fluid concept. n
39

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Prof. Dr. Dimitry Kochenov - Chairman of the board of the Investment Migration Council
Investor Citizenship and the EU:
Zooming in
on the European Commission’s
ill-Informed Analysis
The European
Commission has
no competence to
regulate, and a rather
poor understanding
of citizenship matters
and the investment
migration industry,
writes Dimitry
Kochenov, Professor
of EU Constitutional
Law in Groningen,
and Chairman
of the IMC.
In January 2019, the European
Commission released its much awaited
‘Report on Investor Citizenship and
Residence Schemes in the European
Union’. Given the negative attention the
whole issue of selling EU citizenship and
residence has been receiving from the
powers that be in the European Union, lawyers
and policy-makers could expect much more from
the Commission’s treatment of this hugely important
topic. Rather than providing a clear rulebased
analysis of the potential problems and
opportunities at hand, the Report, regrettably,
turns against the key achievements of the Union
to misrepresent EU citizenship law. Instead
of measured and careful analysis, it offers an
outline of a moral panic, ignoring all the positive
sides and inflating the negative sides of the story,
while proceeding on the false premises of archaic
nationalism and ignorance of EU law. Infinitely
more could be expected of the Commission, and
one can only hope that this first erroneous step
will not set a trend.
The Report is correct on many facts it communicates:
indeed, Bulgaria, Cyprus, Malta and,
less systematically Austria, offer EU citizenship
for investment. Moreover, 20 or more member
states offer (permanent) residence statuses for
investment, which are often convertible into
citizenship of those states. To summarise: more
than 70% of the member states opted for a policy,
which the Commission has no direct competence
to regulate, but tackles in the Report. This alone
makes the Commission’s take on investment migration
worth looking at in some detail.
Framing investment migration
Undoubtedly, there is a fundamentally important
issue at hand: investment migration is capable of
bringing huge gains, but also generates risks. The
Commission is dead silent on the former, but
is absolutely right about mentioning the latter.
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INVESTMENT MIGRATION YEARBOOK 2019/2020
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“The
Commission’s
analysis seems
to be based on
the assumption,
which is
nowhere
explained
or defended
properly, that
presence in
one of the
member states
for a period of
time before
naturalisation,
is likely to
alleviate
security risks.”
to regulate this area; b) that the reality is much
more complex than what its selective summary
purports to demonstrate.
Referring to citizenship by investment, the
Commission writes that, in essence, such ‘citizenship
is granted under less stringent conditions
than under ordinary naturalisation regimes’.
What is crucial here is to mention the differences
marking citizenship law amongst all the member
states to rationally accommodate the acquisition
of citizenship by different categories of applicants.
The sovereignty aspect of this story is also important.
Starting with the latter, states are free to confer
citizenship on those whom they consider qualified
under the Hague Convention of Nationality (Art. 1)
and, unquestionably, under EU law.
EU law is funny in a way – and this is its unquestionable,
pluralist strength. A US kid able
to find a Greek great-great grandfather becomes
an EU citizen automatically, without ever having
visited Greece; a spouse of a Frenchman in
Vietnam is naturalised without ever having lived
in France; an EU citizen does not need to give up
his or her original nationality when naturalising
in Germany, unlike any non-EU nationality
holder; and a Catholic dignitary retiring from the
Vatican becomes an Italian, automatically and
immediately. These are the groups (among, literally,
countless others) that are treated by immigration
and citizenship law differently in all member
states. The question of what is ‘legal’ does not
arise, since it is not up to the Commission to ask
or comment upon. And given that international
law, similarly to European Law, is clear: Member
states will decide as they see fit – ius soli and ius
sanguinis in this context, is, while not incorrect, a
reference to nowhere. The Commission simply
misrepresents the complexity of standing citizenship
law and policy to mount an assault on the
investment migration industry.
Besides, and equally importantly, ‘ordinary
conditions’ – as opposed to the frowned-upon
‘less stringent’ ones – imply a level of due dili-
When run in non-transparent and corrupt ways,
investment migration – like any other enterprise
– will certainly generate problems. In fact, the
Report is such that it presents the whole issue of
investment migration uniquely as a risk, rather
than an opportunity.
Silence on the benefits that the overwhelming
majority of the member states either receives
or believes to be receiving, unquestionably sheds
the Commission’s work in a deeply biased light:
the suggestion is that 20 member states are behaving
deeply irrationally, which is implausible,
and deeply political in the negative sense of the
word.
A hymn to a nationalist past
The Commission claims to have discovered what
citizenship is about, writing that citizenship ‘is
traditionally based on … ius sanguinis and … ius
soli’. This is all correct, but the Commission does
not make clear that a) it does not have the power
Prof. Dr. Dimitry
Kochenov chairs the
board of the Investment
Migration Council. He holds a Chair for EU
Constitutional and Citizenship Law at the
University of Groningen, Netherlands. His
research focuses on European citizenship
and the principles of European Union law,
with an emphasis on justice, democracy and
the Rule of Law. His latest books include
‘EU Citizenship and Federalism: The Role
of Rights’ and ‘Europe’s Justice Deficit?’
His newest monograph is ‘Citizenship’,
forthcoming from MIT Press in the
summer of 2019. Dimitry is a consultant
for governments and international
organisations in his fields of interest, and
is also co-creator, with Christian Kälin,
of the Quality of Nationality Index.
41

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
gence, which is significantly lower than what
investment citizenship promises: the entirety of
one’s finances and business connections, as well
as all the story of your past, would not normally
be dug up by independent due diligence providers,
unless you are an investor naturalising on
that ground.
This is only right: different applicants require
different standards. The ‘context’ of citizenship
acquisition, to which the Commission dedicated
a whole section in its Report, is misleading: forgetting
to mention ‘difference’ amounts to failing
to tell a true story.
Flawed reasoning rooted in
obsolete authority
The second main flaw of the Report is its failure
to come to terms with the basic meaning of citizenship
in law as an abstract legal status. Not
caring about the country and its purported values
will not make you less of a citizen in the eyes of
the law, just as caring a lot about some officially
endorsed ‘culture’ or language will not make
you a citizen, unless you are named such by law.
Pretending that this is not the case is deeply unhelpful.
When the Commission informs us that
‘the study looked for other factors … which might
arguably create a link between the applicant for
citizenship and the country concerned’, a citizenship
lawyer reading it is puzzled. It is fundamental
to realise that only citizenship can be such a
link. A Tanzanian, who spent his whole life in the
US and loves America, is still a Tanzanian unless
US law tells us otherwise. And an American who
spent his whole life in the UK – like the UK’s
Boris Johnson – is still an American, liable to pay
taxes and to renew his passport, no matter how
little he thinks of the greedy motherland.
The whole point of the text of the Report is the
Commission’s apparent desire to play a somewhat
totalitarian role: is this Maltese a ‘real’ Maltese?
What if he has never visited the European
Union? This is where the obsolete case-law of the
International Court of Justice, expressly overruled
by the EU’s own Court of Justice (!), comes into
play: the Commission refers, quite extensively, to
Nottebohm’s theory of ‘genuine links’.
What the Commission’s file handlers should
have not overlooked, however, is that ‘genuine
links’ are incompatible with a world which is not
composed of ‘genuine jails’: what the Court of
Justice confirmed in Micheletti: as per Advocate
General Tesauro, the ‘romantic period of international
law’ is over. The Court of Justice of
the European Union has expressly prohibited
member states from relying on Nottebohm in
dealing with each other’s nationals.
References to the obsolete authority are only
the start of the Commission’s puzzling campaign
of putting legal reasoning to sleep. The Report essentially
claims that since checking genuine links
is expressly prohibited by EU law in Micheletti,
member states have to ensure that such links
exist. Given that Nottebohm unquestionably is
bad law and the Commission was obliged to know
“The Commission
has been
effectively telling
20 member
states that most
likely, they are
doing it wrong,
while enjoying
no competence
to regulate
the field, and
demonstrating
rather poor
command of
the matter in
question.”
it, and taking into account the reasoning of the
Commission, trying to undermine the internal
market, established case-law on free movement
of persons, and the rule of EU law established
in Micheletti amounts, in fact, to the Commission
knowingly misleading the European Parliament,
the Council, the European Economic and Social
Committee, and the Committee of Regions, to
whom the Report is addressed. This could be an
example of the violation of the duty of loyalty,
should the Report be more convincing.
Curious assumptions about the connection
between residence, citizenship and security
In the Report the Commission is looking for solutions
to address the risks in terms of security,
tax evasion and money laundering – all vitally
relevant concerns of huge importance for the
EU and the member states. In so doing, however,
the Report, instead of outlining concrete problems
and proposing solutions, reaches a truly
esoteric level: the Commission’s analysis seems to
be based on the assumption, which is nowhere
explained or defended properly, that presence
in one of the member states for a period of time
before naturalisation is likely to alleviate security
risks. In fact, numerous recent security threats in
the EU were caused by first- or second-generation
EU citizens who never claimed to be jetsetters
or millionaires. This also undermines the
appeal of the Commission’s findings akin to ‘this
means that applicants can acquire citizenship
of Bulgaria, Cyprus, or Malta – and hence EU
citizenship – without ever having resided in practice
in the member state’. The only answer is ‘Of
course!’ in a situation where hundreds of thousands
of EU citizens have never been to the EU
in their lives, and there is no legal requirement,
either in EU or in International law, to bother
to visit one’s country of citizenship. A passport
can also be renewed from abroad, as the Court
of Justice has reconfirmed in Tjebbes, reinforcing
the point that the member states, not the EU, will
be deciding on the issues of conferral and withdrawal
of nationality.
Conclusions
The Commission has been effectively telling 20
member states that most likely, they are doing it
wrong, while enjoying no competence to regulate
the field, and demonstrating rather poor
command of the matter in question. Many will
no doubt be offended by it, while blood and soil
communitarians of all sorts will cheer.
Beyond the haphazard argumentation
and wilful misinformation concerning citizenship
in general and EU citizenship law in particular,
the Report sends a very clear message:
the Commission wants to regulate citizenship.
Ideology and incompetence have won for now,
and citizenship lawyers and scholars in all the
member states will need to mobilise to shame the
Commission for failing to do its job to make sure
the Report in question is an exception, rather
than the rule. n
42

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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Trends & Topics
2O19/2O2O
We run through the stories that mattered
the most over the past year and explore
what will likely shape the investment
migration industry in 2019 and beyond.
44

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
45

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
The
Good
News
The maturing of the
investment migration
industry is a cause
for celebration. The
industry is powering
ahead and seeing positive
momentum with an
increasing number of
programmes coming online,
rising client interest and a
wide array of new products
that are being launched.
The growth of consulting
firms expanding their
service offering to include
investment migration is
broadening the industry’s
reach and equally upgrading
it to a whole new level
of professionalism. This
is all cumulating in a
feel-good factor that has
all the ingredients for
boom times ahead.
The Great
Divide
With as many as 100 countries
operating investment migration programmes,
and still an ever-growing number of
countries entering the space, it appears
the appeal of the industry to governments
around the world is far from waning.
The most recent additions of Turkey, Jordan and Moldova are
part of a growing wave of entrants who are carving out new
niches in the market. In addition, Montenegro will soon join
the line-up. While some programmes have global appeal,
others are positioning themselves as regional hubs attracting
applicants on the basis of cultural affinity, effectively creating
viable micro-markets. The minimum investment required
by programmes today ranges from $100,000 to more than
$5 million, with the more expensive programmes appealing
to ultra-high-net-worth individuals while the more affordable
products remain attractive to high-net-worth and mass
affluent clients. Market segmentation is becoming crucial
for the industry as it progressively moves away from its onesize-fits
all approach. Customers today have more options,
and their choice is being influenced by their net worth as
well as their geographical and generational preferences.
Stability &
Predictability
The investment migration industry needs to embed certainty, predictability
and stability in its investment environment, whereby
the need for predictability is not a need for guarantees. Major
shifts in the investment amounts required by programmes,
U-turns in policy by governments, opaque guidance notices by
programme regulators and vague assurances by agents are only
some of the latest examples of the shifting sands that customers
must contend with. Uncertainty inhibits long-term investments.
Regulators are responsible for providing a stable and
predictable regulatory environment, in which investors, agents,
and customers can make long-term decisions with confidence that
short-term political goals will not impact them or their families.
A stable investment environment that offers simplicity, stability
and predictability needs to be at the heart of everyone’s focus.
Moldova
TURKEY
JORDAN
Bullish on
Blockchain
Many hail blockchain
technology as the
best innovation
since the invention
of the internet.
Blockchain technology
has become one of the
hottest topics within the
industry, and many agree
that the blockchain tech
revolution has only just
begun. More than just a
distributed database for
bitcoin, the technology’s
ability to send, receive and
store information has the
underlying power to truly
disrupt the status quo of
the investment migration
industry in the years
ahead. The implications
of decentralised ledger
technology mean the
industry could address a
myriad of transparency
issues and completely redesign
its KYC and due
diligence processes. While
the technology is in its
early days, it still offers a
myriad of technological
solutions for the industry.
Regulatory compliance,
instant payments, identity
verification, and fraud
detection, are just the tip
of the iceberg; and we can
expect further applications
that can be implemented
across the entire business
operation to come online
in 2019 and beyond.
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80/20 – The China Factor
80/20, or the law of the vital few, is an interesting
rule to apply to the investment migration industry.
Chinese nationals account for roughly 80% of all applicants to
any residence programme, with the remaining 20% coming from the
rest of the world. But a source of strength can also be a source of
vulnerability, and the over-reliance on the Chinese market appears
to be the biggest single threat to the industry. The industry’s fortunes
grow and shrink with China. A simple shift or change in China’s
economic policy that would lead to lower demand for investment
migration products could significantly impact the industry practically
overnight. Making inroads to opportunity-rich source markets such as
the BRICS and N11, which include Brazil, Russia, India, China, South
Africa, Bangladesh, Egypt, Indonesia, Iran, Mexico, Nigeria, Pakistan,
Philippines, Turkey, South Korea and Vietnam, which are all enjoying
a level of economic resurgence, becomes key. Diversification
is now the name of the game for both programmes and agents.
The Birth of the
Hybrid
Programme
The big news on the product development
front is the rise of entrepreneur
and start-up visa programmes as an
alternative to the golden visa route.
Some feel that entrepreneur and start-up visa programmes are
more politically palatable than the conventional residenceby-investment
programmes. However, whether or not this
new generation of programmes will be the Holy Grail for the
industry seems to be uncertain. The success of any programme
largely depends on whether agents and service providers
are promoting it. Some commentators believe that the extra
time and expense required to validate a client’s business idea
and develop a custom-built business plan are not making
these programmes attractive enough for consultancy firms
to put their full weight behind them. Besides, experience
from the past has shown that most wealthy investors prefer a
form of passive investment that does not require them to be
personally involved in managing their investment. The solution
could be the development of hybrid models that match a highnet-worth-individual’s
capital with local start-ups requiring
funding. The investment route can be a direct investment into
a company, regulated loan funds or a national angel investor
platform. The USA’s EB-5 programme, which matches foreign
investors with local projects, proves that this model can work.
Impact
Investing
Impact investing may
just be a trend to
some or, quite possibly,
the best strategy
to not only improve
the world but also
attract investors.
The concept is that your investment
should be both socially
beneficial and have
a positive environmental
impact while also making a
financial return. The concept
fits nicely with the overarching
goals of the investment
migration industry, and for
countries willing to embrace
the transformational change
of moving to a sustainable
circular economy, it offers
the opportunity to capture
the attention of like-minded
investors. The growing relevance
of sustainability is
only going to increase in importance
in the years ahead
and could well play a more
significant role in people’s
choice for a residence or a
citizenship programme.
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
The Demand for Absolute
Transparency
The calls for absolute transparency are louder
than ever. Media and international watchdogs demand that
programme agencies are fully transparent on how they run their
programmes and publish the details of approved applicants as well
as the number of refusals and the reasons for denial. Transparency
is now the name of the game that programmes will have to
grapple with over the next few years. The industry will need
to cooperate closer with international organisations and law
enforcement agencies to ensure that the industry remains free
from criminality. Transparency has become the most pressing issue
for everyone with a vested interest in protecting the integrity of
the programmes. In the spirit of “sharing is caring”, programme
agencies should also consider a greater exchange of information
on applicants and inform each other of rejected applicants.
These measures would send a strong signal that countries
operating visa and citizenship programmes are taking the
security concerns of their international partners seriously. Being
rejected by one programme and turning up as a newly minted
citizen of another programme does nobody any favours.
The Genuine Link
The genuine link is a topic that provokes much
conversation and philosophical debate when it
comes to the issue of investment migration and
acquiring citizenship in particular. Critics of the
industry are increasingly probing and challenging what genuine
link or connection investment migration applicants have with the
countries of which they are seeking citizenship. Supporters of
citizenship programmes counter with the argument
that citizenship of a country in and of itself is the
ultimate expression and link between the individual
and the state. While our more learned
friends may to-and-fro on the argument,
global policy-makers and the public at large are
less concerned about the philosophical argument
and are more grounded in what they perceive
as a real genuine link with their country. The
investment and acquisition of citizenship has to
be seen as just the beginning of the journey and
not the end of a process for all. Attracting the best
and the brightest is an expensive endeavour for all
involved and comes with a considerable investment
in time and recourses. Countries need to think
more creatively how they are going to harness the
power and influence of these individuals beyond the
relatively short-term investment gain. Like all relationships,
you only get out of it what you put in, and cultivating that
relationship requires countries and programmes to maintain a
physical connection with what could be roving global ambassadors
for their adopted country. Countries need to conceive new ways to
maintain the connection and employ the skills and networks of this
elite group of people for the further development of their country.
Investing in national networking gatherings with your new citizens
might just pay off more handsomely than the initial investment.
A Growing
List of
Services
There is a significant
opportunity for
countries to expand
their service offerings
to investment
migration applicants.
These countries are in a
very privileged situation,
attracting large numbers
of the world’s wealth creators
who, like all time-poor
executives and captains of
industry, often have a need
for professional and personal
lifestyle services. The
development of specialist
products supporting both
the commercial and personal
lives of these individuals,
in areas such as wealth
management, legal, financial,
consulting, advisory,
insurance and healthcare,
could have a longer-term
economic impact on
countries than investment
migration programmes
in and of themselves.
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Data is
King
You can’t do things
better if you are
not measuring them.
The crux for the investment
migration industry is the lack
of trusted data to aid and
guide decision-making. To
expand the research capabilities
of the industry, advisory
firms, regulators and policymakers
need to champion a
partnership model for funding
and producing research on
the investment migration
industry. Creating an investment
migration innovation
fund to attract scientists,
researchers, academics and
industry professionals interested
in conducting studies
would be a major step in
the right direction. Industry
stakeholders currently suffer
from poor visibility due to insufficient
data insight, ineffective
data sharing and
poor cross-industry collaboration.
However, there
is a recognition, particularly
among industry leaders, that
data access and information
sharing is important to guide
policy-making and improve
decision-making so that the
sector can deal with upcoming
issues in a more constructive
manner. Though many point
out that the industry being
“slow to change” was one the
biggest roadblocks to improving
collaboration in the first
place. To provide the level
of trust and gravitas that
would be required to get the
buy-in from the industry, a
Big 4 consulting firm with
a footprint in all relevant
markets and programme jurisdictions
could be the central
point for data collection,
the analysis of that information
and the dissemination
of the findings. This would
allow the industry to take
decisions based on trusted
data and aid in the establishment
of key performance
indicators for the industry.
Taking
the Search
out of Research
Artificial Intelligence (AI) and Machine
Learning (ML) are game-changers in due
diligence. The advances in machine learning techniques
now provide the ability for AI to manage large volumes of data
and detect fraudulent behaviour automatically. AI-enabled
solutions support modern KYC practices, resulting in better
risk analysis and assessment of potential new applicants. In
a manual process, high volumes of data, false positives and
duplicate documents create an enormous strain on time and
budget. For programmes and agents, artificial intelligence
saves time in pre-screening and allows for smart, risk-based
monitoring of applicants. It accelerates the research process
and classifies risk, allowing the researcher to delve into the
analysis of the findings. Recent research found that in the nottoo-distant
future clients will expect their first interaction with
a professional services company to be via a device, turning the
current ‘people first’ and ‘technology second’ strategy on its
head. AI chatbots are already the first interaction many clients
will have with companies and this trend is already appearing in
the business models of the most recent entrants to the sector.
A Top-Priority
Investment
The number of
cyberattacks has grown
steadily during the last
few years. Adobe, Sony,
Target, HSBC and Marriott Hotels
are just some of the household
names that suffered
high-profile hacks where the
attackers walked away with
sensitive personal and financial
information. John Chambers,
the former CEO of Cisco, summarised
it this way: “There are
two types of companies: those
who have been hacked, and
those who don’t yet know they
have been hacked.” Investment
migration programmes hold a
lot of sensitive information on
individuals. While programmes
might wish to guarantee a high
level of privacy when it comes
to sharing the names of individuals
who obtain citizenship
and visa programme approval,
applicants, their advisers and
governments need to be aware
that this is a very difficult task
given the very real possibility
of data theft and hacking scandals.
In order to mitigate this
risk, cybersecurity and encryption
need to be among the top
priorities of all investment
migration programmes.
Mixing up the Marketing
Word-of-mouth and customer referral reign supreme and are still some
of the biggest influences on buyers. The investment migration industry has, to a
large extent, remained loyal to what has been tried and tested over the years: networking events,
conferences, exhibitions and the sponsorship of sporting and cultural events, along with some
appearances in influential traditional media titles. The model has proven its worth in developing
relationships with advisory firms that refer clients. Commission agents, especially in China and
India, have completed the marketing mix. With competition heating up, increasing numbers
of programmes and a near explosion of advisory firms and agents plying for new business, a
competitive intensity is creeping into the marketing of the industry. While positive in that it is
creating wider awareness, some of the marketing practices can be reputationally harmful and, at
best, misleading. This is something the industry needs to rein in before it becomes an issue. As the
industry is seeking to attract new client groups and appeal to a younger audience – the catchword
here is millennials – a broader marketing mix will come into play, including affiliate platforms
and influencer marketing. Programmes, concessionaires, referral agents and their new marketing
partners will need to pay particular attention to the advertising and promotion campaigns that
they are running in countries across the world so that they don’t fall afoul of the local regulations
that are being increasingly enacted and enforced by consumer protection authorities.
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Everyone Needs
an Affiliate
Affiliates will be a relatively new marketing term to the
investment migration industry but one that it will
increasingly embrace over the next five years as
the sector becomes more digital in its marketing
to the mass affluent, wealthy millennials and
high-net-worth digital natives. Affiliates operate in
the world of performance marketing, where they only get paid
if and when a lead or sale is delivered to the company. For this,
they typically earn a high referral fee and/or a revenue share
on the fees charged to the client. This segment of the marketing
world is booming and can account for more than 50% of revenue
generated in some industries. The concept of embracing affiliate
marketing has been slow to penetrate the investment migration
industry, but as advisory firms and agents expand operations into new
territories and markets the ability of master marketers such as affiliates
with local on-the-ground knowledge and the ability to deploy rapid native
content marketing campaigns will be hard to match. While all that glitters
is not gold, affiliate marketing comes with its own challenges and pitfalls.
Any firm aiming to embark on this journey will need to have a firm grip
on advertising compliance requirements in all markets they target.
The Compliant
Marketer
Marketing compliance,
advertising rules and data
protection are taking on
a greater significance
for all firms today.
The global nature of the investment
migration industry makes it particularly
prone to potentially violating rules and
regulations without even being aware of
it. Regulators and consumer protection
authorities are increasingly holding
companies responsible for the actions
of anyone who is referring business to
them. The fines in countries like the
UK are not to be sniffed at, as recent
fines have run into many millions of
pounds. Marketing and advertising
are set to become hot topics, as the
industry more readily adopts mainstream
marketing channels such as TV, print,
billboards, online display adverting,
social media, content marketing,
influencer marketing, performance
and affiliate marketing channels. The
marketing and advertising regulatory
landscape is still in flux and changes
frequently. As the industry increasingly
moves out of its comfort zone, this is
an area that management will need
to pay particular attention to.
AML & GDPR
Anti-Money Laundering (AML)
and General Data Protection
Regulation (GDPR) are two unlikely
bedfellows that have been making
their way into the boardrooms and
onto the agenda of the industry’s
executive decision-makers.
Given the severe consequences of failing to
comply with AML obligations, coupled with the
vast fines (up to €20 million or 4% of a company’s
total worldwide turnover) that could follow any
failure to comply with GDPR rules, it’s no wonder
executives beyond the compliance departments
are grappling with how to meet what, at first
glance, would appear to be contradictory in
nature. AML laws place an obligation on entities
to carry out due diligence, and in doing so
collect and process personal data. In contrast,
the EU’s GDPR seeks to limit the personal data
collected and processed. Countering money
laundering was initially seen as far more
important than protecting an individual’s privacy
even if this meant trumping data protection
rules. The new thinking by regulators is more
cooperative and now obliges advisory firms
to consider AML and GDPR requirements as
complementary to each other and not mutually
exclusive. Companies will now be required to
take a more risk-based approach and prove
that their policies and procedures for data
collection and retention are appropriate to
any potential risk posed by the customer.
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"As seen in other industries,
commoditisation of the
investment migration market
is bringing prices down both
for the services providers and
the country programmes.
Therefore, we can expect
some firms to consolidate
over the next one to five
years, while others will
expand their service offering
to offer more products and
services to the same client.”
Eric Major
CEO of Latitude
Consultancy Limited
Grow Big or
Go Home
While many are feeling that
the industry is ripe for consolidation,
M&A activity hasn’t
gained any real momentum. While
there is an appetite by the top tier firms to
play a role in consolidating the fragmented
industry, there seems to be less of a desire
by the smaller mid-tier firms to be acquired.
However, many believe it is only a matter of
time until deal-making will pick up due to
rising compliance and operational costs that
might drive smaller firms, staffed by just a
few people, to the wall. Firms either need to
scale up significantly to ensure proper compliance
or join forces to achieve economies
of scale to compensate for rising operational
costs. Another factor that is expected to play
a role in driving consolidation is the desire by
larger players to continuously enter emerging
markets, coupled with rising customer expectations
that firms handling their visa or citizenship
applications have a presence in their
home and in their chosen country to ensure
a smooth process and positive customer experience.
An increasingly global footprint, or
at least a strong presence in selected source
and programme markets, will become increasingly
important for service providers to
survive and thrive under the new conditions.
Doing Good is
Good Business
The positive impact of the
investment migration industry is very
rarely reported, with the result that
the industry has an image problem.
While the industry has been responsible
for underpinning struggling economies in
a time of need or has been the catalyst for
job creation, building roads and hospitals as
well as providing infrastructure to support
countries and their citizens to develop and
thrive, much of this remains unseen by
those who oppose the concept of investment
migration. This image issue will not disappear
until the industry embarks on a comprehensive
outreach campaign and genuinely engages the
sincere concerns that the media, governments
and international institutions have with the
investment migration industry. To be seen
as good, one actually needs to do good. The
industry needs to consider some bold moves
beyond facilitating investment flows and show
how the industry and its customers can positively
impact society and the environment globally.
This could be in the form of an industrywide
philanthropic initiative, a redistribution
tax on the industry or organising a global
gathering of investment migration applicants
where investors, countries and NGOs who
require funding could be matched with investors.
Remember: people prefer to do business with
an industry that has a higher purpose.
Taxing Times
Tax is an issue that is not exclusive to the investment migration
industry; however, it has never been as high-profile a topic as it is
today as a result of the global push towards more tax transparency, the
call for the reduction of preferential measures and the introduction
of information sharing and common reporting standards.
Although investor visas and citizenship are not the deciding factor when it comes to determining
a person’s tax status, in some quarters the investment migration industry has been singled out as a
potential avenue for tax avoidance, fraud and other nefarious activities. While it is not beyond the
realm of possibilities that some clever scheme or structure could be used to avoid tax, professionals
point out that there are far easier routes than investment migration. Nevertheless, the industry will
need to prove that it is complying with all international rules that have become the new standard.
On top of that, it needs to take into consideration the expectations of the media and the general
public that the wealthy are paying their “fair share”. Investment migration professionals will need
to become a lot more tax-savvy to advise and inform their clients of any possible tax implications.
Given the fact that it is predominantly wealthy individuals who are using investment migration
programmes, in the minds of many it will be a case of ‘guilty until proven innocent’. Something the
industry needs to watch out for is the possible inclusion of property as reportable capital under the
Common Reporting Standard. Many experts believe that it won’t be long before this asset class will
also become subject to the rules. The EU, the OECD and the IMF are all paying close attention to the
industry’s response to this new tax reality, reinforcing the need for the industry to urgently establish a
global standard-setting body that can work with fellow governments and international organisations
to create a framework that would prevent the industry being used for tax evasion purposes.
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Finding and Retaining the Right Talent
Given the exponential growth of the investment
migration industry, talent development should be
high on the priority list of government agencies
and programme managers. Professionals have such a
variety of options to choose from, which means companies need to
be clear and transparent of what they offer as an employer. Salaries
and benefits are not the top drivers of employee loyalty; the real
winners of the global “war for talent” are those employers who can
offer an environment created for personal growth and development.
While the focus should be less on hiring large volumes of
candidates, the goal should be to attract and retain top-tier talent
from global institutions, regulatory bodies and corporations,
whose profiles and track records will add instant credibility.
Crypto
Payments
Cryptocurrencies
are slowly but surely
continuing their journey
towards mainstream
acceptance. Even regulators
and financial institutions that
once viewed them a taboo subject
are awakening to the opportunity
cryptocurrencies can offer them
and their industry. The investment
migration industry is one that could
benefit considerably from this new
embrace. While most programmes
do not allow applicants to pay for
investments or contributions with
cryptocurrencies, a select few are
breaking new ground and have
either added them to the payment
mix or are considering doing
so. Dubai, Sweden and
Turkey are three countries
that are close to having a
central bank-issued digital
currency (CBDC) or digital
fiat money. More and more
countries are bringing
in regulations for virtual
currencies and tokens, and
it is quite conceivable this
may be the payment method
of choice for investment
migration in the not too
distant future. With the
number of cryptocurrency
millionaires and billionaires on
the rise, this payment method
could attract a very viable group of
individuals that countries may wish
to attract to their programmes.
Due Diligence – an
Evolving Discipline
The investment migration industry does
a greater level of in-depth background
checks than other industries, including
having people on-the-ground confirming
that the provided information is correct.
Though the banking sector is often being held up as the
standard that the industry needs to attain, the reality
is that in many cases the investment migration sector is
much further ahead. While the vast majority of people
choosing the investment migration route are law-abiding
and respected individuals, no programme is completely
foolproof or watertight. Neither can it predict the future
behaviour of its new citizens. Due diligence service providers
are increasingly employing ongoing monitoring solutions
after the initial due diligence check has been carried out
to ensure no black spot remains undiscovered. Periodic
look-backs by both programmes and professional service
providers at a person’s behaviour even after his or her
visa or citizenship has been approved
would also ensure that
those individuals are not abusing
their new rights and that a
programme’s integrity is maintained.
In order to ensure future
success, programmes will need
to continuously keep pushing
the boundaries and remain at
the forefront of due diligence
innovation to give comfort to
both the industry’s partners
and its external stakeholders.
A Sheriff
for the
Industry
The regulation of agents
and service providers, along
with consumer protection,
will surely be a topic that
will feature high on the
agenda in the coming year
in the wake of a series of
scandals ranging from
the misappropriation of
client funds to investments
in property projects that
never materialised. In
some countries, Canada
being an example, service
providers are regulated,
while many other countries
require agents to register.
However, a pan-industry
regulatory body does
not exist, and countryspecific
regulators often
lack enforcement power.
Regulations for agents,
whether in the form of self
or government regulations,
would go a long way towards
achieving higher consumer
protection standards, which
are becoming ever more
important as the industry
starts servicing clients of
more modest means who
often spend a significant
share of their savings on a
residence and citizenship
programme. Investment
migration, like many
other industries, needs a
regulator with teeth and
a willingness to bite.
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Banking & Payments
The tightening of US banking regulations has seen international
correspondent banks recoil from a host of countries and sectors as they
de-risk their operations to avoid any costly regulatory issues or accusations
over fraud and money laundering. The US-imposed regulations have rippled
through the entire global banking network. While banks may all have their own customer risk
profiles, they are now obliged to apply the risk profiles of their international banking network
partners. The more stringent rules have unfortunately impaired many countries’ banking
systems and rendered some countries virtually bankless and in search of new alternatives.
Enhanced substance requirements and an aversion to processing anything that might attract
a hint of controversy are the main concerns of the banking industry, and according to many,
these are already having an impact on countries operating investment migration programmes.
Banks cite uncertainties about regulatory compliance and KYC procedures as among the main
reasons for cutting back their correspondent relationships, with the result being that entire
economies and regions are excluded from the global financial marketplace. However, on the
positive side, digital disruption is accelerating. Cryptocurrencies, despite being controversial,
and the arrival of central bank-issued digital currency (CBDC) or digital fiat money are opening
up new avenues for the industry to process transactions. Payment providers are increasingly
developing their own connections that enable them to bypass the traditional correspondentbanking
infrastructure. These developments promise to cut costs and speed up processing times
for transactions. They also present an opportunity for investment migration host countries and
entire regions to forge new partnerships and create alternative avenues for cross-border payments.
Next Stop:
Nation As a Service
The investment migration industry, with
the opening up of residence and citizenship
by investment, was most probably the first
real step in the manifestation and realisation
of the concept of nation as a service.
Estonia’s e-Residency programme, although coming from a slightly
different angle, is very much in tune with this idea. The true global
citizen has become a reality with the emergence of digital nomads,
industrial tycoons, high-net-worth individuals, globetrotting professionals
and consultants, as well as bitcoin billionaires who are
reshaping and redefining the citizenship concept. New ideas like
nation as a service and fractional citizenship, where users adopt
a pay-as-you-go subscription model for access to state services,
are gaining ground as countries try to attract the skills and taxes
of the globally mobile. This has opened up a new opportunity for
the investment migration industry to start providing value-added
services and solutions to support those global citizens in their international
work commitments and lifestyles. Greater substance
demands on applicants also mean countries need to start upgrading
their offering by providing more services in areas such as wealth
management, legal, financial, consulting, advisory insurance and
healthcare, to develop a more robust genuine link even if these
services, like the Estonian model, are virtual. The model is slowly
being proven and is certainly one to watch; we could be seeing
some exciting developments on the horizon as more countries start
to bring their concepts to this working idea. While the Estonians
have brought the virtual element to the table, and the investment
migration industry has brought the physical element, the
question is who will be the first to marry these two elements and
deliver a great jump forward in the investment migration model.
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Yakof Agius, Founder and CEO of CiviQuo
The Power of
Transparency
CiviQuo is one of the investment migration
industry’s most recent start-ups. It aims
to radically change the way the industry
promotes itself by bringing in elements of
performance marketing and building up an
affiliate network. The wider goal though, is
to bring a whole new level of transparency
to the investment migration industry, says
Yakof Agius, CEO and Founder of CiviQuo.
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INVESTMENT MIGRATION YEARBOOK 2019/2020
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Can you briefly introduce CiviQuo?
CiviQuo is the world’s first residency and citizenship
by investment e-marketplace. The platform
brings together a large selection of programmes,
licensed agents, and intermediaries from around
the world, enabling each to showcase their offering
in a very simple, transparent, and straightforward
manner. Individuals interested in RCBI programmes
do not need to browse through many
different sites to find relevant information, but
can use CiviQuo as a resource to find information
on programmes and service providers. A key
feature of CiviQuo is that service providers who
feature on the website need to disclose the professional
fees they will be charging. Clients can
also rate the service provider they’ve used. The
idea behind all this is to introduce a new transparent
formula that will ease the process for our
clients, and transform the way agents, and the industry
at large, market themselves.
How did CiviQuo come to be and
who’s behind the project?
I have spent almost five years working in the investment
migration industry, and at one point, I
got the idea to create something similar to what
booking.com is for the hotel industry, for the
investment migration industry. The investment
migration industry has traditionally followed a
very conservative marketing approach, with professional
advisers, intermediaries, and introducers
playing a key role in acquiring new clients.
Thus far, performance marketing has not really
been utilised in this industry, but I believe it is the
future. I pitched the idea to my long-time business
partner and co-founder, Ryan Darmanin, and together
we developed the concept. Just as booking.
com has changed the way we pick hotels, flights,
and holidays to destinations worldwide, CiviQuo
now aims to help clients source information and
connect them with different service providers.
How exactly do you connect service providers
and clients, and how do you approach
the area of KYC and due diligence?
Once a client has selected a programme from
the website, he or she will be able to view the different
service providers and their prices. In the
next stage, the applicant can then select a service
provider. This stage is key, because clients are
expected to input basic details which will allow
service providers to undertake a good level of due
diligence. We are aware that every agent will have
its own customer acceptance policy, while the
level of due diligence that is undertaken could
“The platform
brings together
a large selection
of programmes,
licensed
agents, and
intermediaries
from around the
world, enabling
each to showcase
their offering in
a very simple,
transparent, and
straightforward
manner.”
also vary by jurisdiction. We have developed a
standardised model for service providers to work
with, and have also gone the extra mile by providing
them the tools to be able to effectively undertake
due diligence. Exiger’s DDIQ is a built-in
feature of the website, and service providers can
either use their own subscription to access it, or
use it on a pay-per-use basis. Agents that usually
use another company’s tools can also do so, but
they need to confirm that they are assuming the
responsibility for it. Once the applicant has submitted
all the information, the service provider
receives the details and can choose whether to
accept the client or not. Basically, we are bringing
the client straight through the service provider’s
front door.
What pricing structure and revenue
model have you adopted and who has
signed up to your platform so far?
We work with two types of plans. The first
package is a free listing; however, service providers
can only be listed for two programmes,
and that’s also where our highest commission is
being applied. The other option is a subscriptionbased
model. This means that our clients pay a
monthly fee, but the revenue share will be lower.
I’ll give you an example. For the Malta Individual
Investor Programme, the highest commission is
35%, which can go down to as much as 17.5% for
a subscription-based plan. Some of the biggest
international names have already joined the platform.
We only launched it a few months ago, and
so far, we have a portfolio of 20 programmes and
26 agents, not to mention that a number of companies
are currently finalising their documentation
and will join us shortly.
Average Service Provider Fees according to CiviQuo
PROGRAMME
AVERAGE
Antigua and Barbuda Citizenship USD 12,300.00
Cyprus Citizenship EUR 37,500.00
Dominica Citizenship USD 13,999.67
Malta Citizenship EUR 44,166.67
Malta Residence EUR 14,999.86
Saint Lucia Citizenship USD 16,500.00
Saints Kitts and Nevis Citizenship USD 12,333.33
United Kingdom Tier 1 Investor Visa GBP 31,500.00
United States EB-5 USD 22,500.00
55

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
High-net-worth individuals are very
private people. Do you believe they
would be willing to rate their service
provider on an internet platform?
I am sure there are some who don’t have a
problem with that but yes, you are right, others
might not want to share that information. That’s
also why we decided to include the option of
reviewing anonymously. In fact, anonymity is
preserved even on some of the most established
and successful platforms, like eBay. While some
say customer reviews lack credibility if they are
anonymous, we can guarantee that the accounts
are real. On CiviQuo, it works like this: an agent
sends a request to a client, asking to rate its services;
a client receives that request and makes a decision
on whether he or she wants to contribute. If
the answer is yes, he or she leaves a detailed feedback
on the company’s CiviQuo page.
In what ways is this platform beneficial to
the wider investment migration industry?
Unfortunately, the industry has been heavily
criticised by the media, and getting increased
attention by government bodies. When you
look at how the industry is promoting and
marketing itself, this is not surprising. What
the industry needs right now is transparency.
Service providers know this, and many of them
talk about the need to be more transparent.
Our platform, specifically due to its two key
features - price disclosure as well as the review
and rating system - adds a level of transparency
to the industry. It is intended to build trust and
create an industry that is open about its products
and prices.
What type of client do you expect to use
your system and what role does digital
marketing play in winning clients today?
If you look at the traffic so far, the age ranges from
25 to 40 years. Looking to the future, in a couple
of years, the majority of investor migrants will
be millennials. Millennials’ behaviour differs
significantly when compared to the previous
generations. People born in the 1980s and 1990s
are assertive and sceptical; they prefer to be selfdirected
in their investments and tend to turn
to online research before making a decision.
CiviQuo has all the right ingredients to win this
age group. The platform will present them with
a trusted source of information, with a diverse
range of products and pricing transparency. This,
we feel, is much needed to convince the-hardestto-reach
generation.
Yakof Agius
is the
founder and
CEO of CiviQuo. He is
the former Chief Risk
and Compliance Officer
of the Malta Individual
Investor Programme,
and has also previously
served as resource and
IT specialist at HSBC
Malta, and Head of HR
at Henley & Partners.
If we look at your website, we see that the
fees of service providers can differ quite
significantly. What do you believe is the
reason for that, and is there a sensitivity
to price in this particular segment?
Our research shows there is. Even though you are
a high-net-worth individual, you are not willing to
splash your money around without any purpose.
In terms of the different prices, based on the
feedback we receive from service providers, my
assumption would be that intermediaries would
have to have a B2B relationship with a licensed
agent to be able to submit the application. An intermediary
has to plan for these higher overhead
costs. We also find that intermediaries might offer
services that a licensed agent is not offering. For
example, in Cyprus, most licensed agents are real
estate developers, so they can provide the vehicle
for the investment. However, an intermediary
based in China, for example, might be able to
provide the financing aspect that the real estate
developer cannot offer. These two entities are offering
the same solution, but with completely different
perspectives. As a benchmark for the fees
that are disclosed on our website we use the professional
fees for a single applicant. We are also
showing whether service providers are licensed
agents or intermediaries, and what services they
are offering. We only list service providers who
can prove to us that they can really go the last mile
and submit an application, either on their own or
in partnership with another professional firm.
Do you expect performance marketing to
become a key driver for the investment
migration industry in the coming years, and
what are Civiquo’s plans for the future?
The investment migration industry has long
recognised word-of mouth as a powerful marketing
tool. Yet service providers are limited in
the number of potential clients they can market
when relying on personal recommendations,
networking events, and so forth. Performance
marketing, on the other hand, has the potential
to work a lot better for the industry — it has
higher chances of opening up new markets and
expanding a business into new localities. It will
definitely gain in importance in the years ahead.
We are still very much at the beginning of our
journey, although we think that the industry has
an appetite for change, and is willing to try new
models of client acquisition. Going forward, our
plan is to grow and eventually start working with
other affiliates, although we will certainly be selective
with whom we will work. It is a question of
transparency, openness and integrity. n
56

SECOND CITIZENSHIP?
JOIN THE GLOBAL COMMUNITY
Strong INVESTMENT
OPPORTUNITIES
Trusted, efficient and STREAMLINED
APPLICATION PROCESS
Citizenship can be passed to
FUTURE GENERATIONS

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
“Agents are the Face of the CBI Industry:
We Need to Act
Responsibly”
Giselle Bru, Chief Executive Officer of
PassPro Immigration Services says the
investment migration industry needs to
learn from luxury brands when marketing
their products, and better engage with the
media, policy-makers and the public at large
to help them understand the industry.
How many times has a frontline member
of staff influenced your perception of
an organisation – whether positively
or negatively?
A helpful sales assistant who recommends
the right outfit for an event or a gracious waiter
who guides you through a confusing menu can
really elevate your shopping or dining experience.
On the flip side, a poorly informed customer
service representative or a bank teller who
failed to advise you on extra fees you would incur
can ruin your perception of an organisation.
No matter how well-managed, responsible,
customer-focused or tech-forward a company
may be, what you remember is your interaction
with the person you spoke to face to face.
In the Citizenship by Investment (CBI) industry,
government authorised agents are the frontline.
We are the face of the industry, and what we
do or say shapes market perceptions.
PROMOTING A HIGH VALUE INVESTMENT
Second citizenship is a highly sought-after investment
for individuals across the world who seek
greater freedom and a more secure and stable
future for themselves and their families. The
“In the
Citizenship by
Investment
(CBI) industry,
government
authorised
agents are the
frontline. We
are the face of
the industry, and
what we do or say
shapes market
perceptions. ”
benefits offered by second citizenship are considered
to hold immense value – allowing those who
acquire it to enjoy unhindered travel to some of
the most desirable destinations – both business
hubs and leisure hotspots, along with numerous
other benefits that allow them to enjoy better
global connectivity and the freedom to do business
around the world.
For government authorised agents tasked
with promoting citizenship-by-investment programmes,
it is imperative that the channels used
to educate potential clients about these benefits
defend their inherent value and do not stray into
promotional tactics that commoditise second
citizenship.
TAKING A LEAF OUT OF LUXURY MARKETING
When was the last time you received an SMS
message or a “50% off” email blast from a luxury
brand? The answer is probably never.
If we look at the marketing and promotion
of other high value products, one rarely sees
the usage of pushy or cut-price tactics. Luxury
brands almost never engage in price-led advertising
for the simple reason that the benefits offered
by high-value products are non-quantifiable.
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INVESTMENT MIGRATION YEARBOOK 2019/2020
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Instead, luxury brands use other sales, promotional
and marketing tactics that focus on:
• Storytelling – letting people who have
already acquired their products demonstrate
how they have improved their quality of life.
• Educating consumers on the brand history,
handcrafted detail and hours that go
into making a product and the inherent
quality of the raw materials used.
• Cultivating positive brand associations
and developing valuable partnerships with
other highly trusted and respected brands.
• They show rather than tell and often
get other people to talk on their behalf
– peer-to-peer references, reviews and
word-of-mouth is used extensively, rather
than intrusive and repetitive ads.
Their entire strategy is based not on “push” marketing
but on “pull” tactics – making people understand
the value of the product, trust the brand
and see it as a long-term investment in improving
the quality of their life rather than a one-time
purchase.
Maintaining not just a positive brand image
but also the high-value of the citizenship by investment
product is crucial. It directly impacts
the attraction of new investors and the capacity
to maintain good relationships with existing investors,
in addition to the far-reaching effects it
has on resident citizens and the local Caribbean
economies.
THE MEDIUM IS THE MESSAGE
As agents, we need to avoid using marketing
channels such as SMS blasts, deal-based offers,
and ads prominently featuring Caribbean passport
images – these marketing tactics perpetuate
the idea that passports can be purchased easily
for cash, with no other eligibility criteria or due
diligence safeguards.
Instead, we need to focus on tactics that build
trust and highlight the inherent high value of
second citizenship. Direct referrals are among
the strongest channels of new business in this
industry, and referrals are based wholly on trust.
We need to cultivate strong relationships with
our existing clients – who have already experienced
the value of second citizenship – and let
them act as advocates.
We also need to demonstrate the constitutional
strength of the programmes and the depth
of the due diligence process employed.
THE ROLES OF EDUCATORS AND REGULATORS
Irresponsible advertising can play a role in
fuelling negative publicity of citizenship-byinvestment
programmes. As agents, we need
to stand alongside governments and play a key
role in educating clients, the media, banks, government
policy advisors, and border control
agencies about how the industry works. We also
need to help build a more robust regulatory
environment within which we can all operate
more responsibly.
Giselle Bru
oversees
PassPro
Immigration Services,
headquartered in Dubai.
With more than a decade’s
experience, Giselle is a
trusted advisor to highnet-worth
investors and
policy-makers within the
investment migration
community. Giselle
brings together a solid
background in government
service – drawn from time
spent working at the Inter-
American Development
Bank, the Ministry of
Health and the American
Embassy in Belize – with
in-depth knowledge
of the real estate
landscape in markets
as diverse as Panama,
Belize, the Caribbean
islands and Cyprus.
As agents, we should pursue a far-sighted
communications strategy that is built less on
transactional communication and more on
educating the consumer – on the programme
mechanics, the strict and deep due diligence
requirements, and the duties alongside the benefits.
Alongside these efforts must come a strong
push for educating policy-makers, regulators, immigration
departments, and law enforcers to understand
how and why citizenship by investment
programmes operate, how they respect existing
banking, law enforcement and AML/FT regulations,
and how they contribute to the long-term
sustainable development of the countries that
offer them.
TRANSFORMATIONAL CHANGE
Most of the countries currently operating CBI
programmes are small island nations for whom
CBI receipts constitute a significant channel of
foreign direct investment, and a source of debtfree
income. Monies from CBI programmes have
not just financed infrastructure development,
they have supported social security and community
health programmes, and served as an integral
lifeline during devastating natural disasters
such as Hurricane Maria and Hurricane Irma
that wreaked havoc in the Eastern Caribbean a
few years ago. Advocacy efforts must focus on
shining a light on the positive impact of these
programmes on the countries that offer them
and their resident citizens, while also highlighting
how the self-sufficiency of these nations is in
the interest of the global community as a whole.
Cultivating media contacts who can serve as
partners in spreading this message is a crucial
way we as agents can make a difference. When
talking to the media, share a balanced message
that focuses not just on the visa-free travel benefits
afforded to investors but on the long-lasting
benefits of the programmes to the home nations.
Connect media in your home countries with
government spokespeople who can give voice to
a broader story. Try to avoid reducing the story
to statistics – annual numbers of citizenships,
nationalities of investors and the dollar worth of
the industry are empty facts; how have the lives of
these thousands of citizens investors transformed
and how have CBI receipts been utilised for community
good are the real story. Tell it well and tell
it often.
As with all industries, stronger regulation
will go a long way in helping the industry and
its players mature more rapidly. It is therefore
highly encouraging that several CBI units have
recently expressed clearer guidance on advertising
and promotional best practices.
What we say and do as agents has a long-term
impact on the future of the citizenship by investment
industry. It’s time we practice accountability
for our actions and promote the programmes
responsibly. n
59

IM
INVESTMENT MIGRATION YEARBOOK 2019/2020
Gerd Damitz, Past President of the Canadian Association
of Professional Immigration Consultants (CAPIC)
Regulated
Consultants
Keep Fraud
at Bay
While Canada has long been
self-regulating immigration
consultants, the country is
now on its way to giving the
industry watchdog more
power to investigate offenders
and enforce regulation. Gerd
Damitz, Past President of
the Canadian Association of
Professional Immigration
Consultants (CAPIC), talks
about Canada’s experience in
self-regulation and explains
why he believes that Canada
can be a role model for others.
Can you give us a brief overview of the
Canadian Association of Professional
Immigration Consultants (CAPIC)
and the regulation of immigration
consultants in Canada?
CAPIC is Canada’s largest non-profit organisation
of immigration practitioners and has some
2,500 members. All our members are regulated
by the Immigration Consultants of Canada
Regulatory Council (ICCRC), the current industry
self-regulator overseeing immigration
consultants offering paid advice, consultation,
assistance or representation services to individuals
planning to immigrate to Canada. All immigration
and citizenship consultants – there is
a total of 5,000 in Canada – need to be licensed
by the ICCRC.
When did Canada decide to regulate
consultants and how would you describe
Canada’s regulatory journey so far?
Canada started looking at regulating immigration
specialists some 20 years ago, at a
time when there were a couple of fraud cases
and missing standards shaking the industry.
However, the road to self-regulation was long
and winding. Initially, we faced strong opposition
from the law societies which challenged
the idea of non-lawyers representing clients in
immigration matters. The Supreme Court of
Canada eventually ruled in favour of immigration
consultants providing broader legal access
to the public. In 2004, the first regulator for
the industry was set up, the Canadian Society
of Immigration Consultants (CSIC). However,
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INVESTMENT MIGRATION YEARBOOK 2019/2020
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in the years that followed, CSIC was heavily
criticised by the public and practitioners alike,
due to internal mismanagement, and eventually
CSIC stopped operating. The Immigration
Minister at the time then asked for submissions
from candidates interested in becoming
the regulator of immigration consultants, and
we, as CAPIC, assisted and supported the bid of
the ICCRC, the current regulator. However, the
problem of unauthorised practitioners persists
to the present day.
Is fraud a big issue in the industry?
Not so much in terms of regulated professionals,
though black sheep are everywhere. However, it
is a huge problem on the unregulated side. Thus
far, there is very little we can do. The ICCRC was
established as a not-for-profit corporation and
has no regulatory power to pursue unauthorised
immigration practitioners within Canada.
They can only forward related complaints to
the Canada Border Services Agency (CBSA),
which naturally will concentrate their resources
on very serious cases. Besides, most unauthorised
practitioners are based outside of Canada,
which makes it even more difficult to deal with
fraud cases. We have been lobbying intensively
over the past years to provide the ICCRC with
the statutory power to proceed with complaints
against unauthorized practitioners and obtain
also more enforcement power with respect to
regulated consultants. In our opinion, it is important
that a regulator has international reach
and the power to negotiate agreements with
foreign government departments in order to
address unregulated practitioners operating
outside Canada, but handling Canadian immigration
files. I am happy to add that our efforts
are bearing fruits. In April 2019, the Government
of Canada proposed in a federal statute the creation
of a new body, the College of Immigration
and Citizenship Consultants (CICC), to govern
and regulate immigration and citizenship consultants
and ensure their professional conduct.
Under the current plans, the system will retain
self-regulatory elements, but the College would
have the powers and tools required for vigorous
oversight, enforcement, investigations and punishment
to root out fraudulent, unregulated immigration
and citizenship consultants and hold
them accountable for their actions inside and
outside of Canada.
CAPIC has been instrumental in shaping
Canada’s legislation and creating a regulated
environment for the profession. What would
you highlight as the main challenges along
the way to this newest federal statute?
The biggest challenge was to convince the
consultant community in the first place. I do
not exaggerate when saying that initially there
were only a handful of people who believed in
the idea of self-regulation by federal statute.
Gerd Damitz
holds a BA/
MBA in
Corporate Planning &
Human Resources. Besides
his decade-long experience
as an expert in Strategic
Planning and as a General
Manager of a Stock
Exchange Registered Corp,
he has been a professional
Canadian Immigration
Consultant for the last 20
years. He also held various
executive positions in
associations significantly
defining the existing
immigration consultant
industry structures. He is
a Past President of AICC, a
Founding & Past President
of CAPIC, a Founding
Director of the Regulator
ICCRC, and received
for his contribution
several industry awards.
For many years he has
been a leading Industry
Association representative
at meetings with the
Canadian Government and
Members of Parliament.
We spent many hours trying to convince our
colleagues that this would be the tool to overcome
existing deficiencies. The next step was to
convince government and policy-makers, and
we haven’t stopped lobbying to this day. Selfregulation
is a privilege, not a right, which the
Government of Canada can remove, as it has
previously done. We have been talking to all
members of parliament, not just to government,
showcasing that self-regulation is working. We
know that there has been room for improvement,
but the point is that both the industry
and the regulator are learning from mistakes
and improving accordingly. So we lobby on the
micro and the macro level, and also focus our
attention on the media and the general public. A
major point has been about getting journalists
to make a clear distinction between regulated
consultants and unregulated practitioners, and
the message seems to be getting through. In addition,
we are running a number of initiatives
to show the general public the benefits of the
current system and are present in communities
where we offer free immigration clinics.
Do you believe Canada could be an example
for other countries to follow, and do you
have any advice for professionals seeking to
address negative perceptions of the industry?
I think Canada can be an example, even for
countries and organisations in the European
Union. Canada is a federal state and lobbying
here means dealing with many provincial governments
who actually have a lot of power. In a
way, it is pretty similar to the situation in Europe
with its different actors who all follow their
own agenda. We know from experience that it
requires a lot of patience to achieve a common
position that works for all, but the only way to
get there is to convince different parties in different
regions with rational arguments. It is very
important to make it a bi-partisan subject, and
in my opinion the key words are ‘consumer protection’.
Consumer protection is in the interest
of everyone; politicians, policy-makers and the
industry itself, since we all know that one bad
apple spoils the whole barrel.
What’s your outlook for the future?
We still have a lot of work ahead of us. Federal
elections are scheduled for autumn 2019, so it
is very important for us to continue lobbying
to all parties. Even though right now it looks
like we will be able to continue with elements
of self-regulation, the potential of a full government
regulation remains. We argue that we are
a young industry, self-regulated only for about
15 years, but the sector is maturing quickly. If
you compare this with the law societies that are
200 plus years old, we have come a long way in a
relatively short period of time. n
61

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
The 5 th Investment Migration Forum
Save the Date
1 st - 4th June 2020
Save the Date
1 st -4 th June 2020
62
investmentmigrationforum.org

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
Global Citizen
Tax to Shift
Industry Focus?
Armand Arton has long been
calling for the introduction of
a levy on investment migration
programmes to source funding
for humanitarian assistance
and development projects that
can help address the wider
causes of migration. As the
industry is reaching maturity,
“we have the opportunity to do
things right,” Arton writes.
Global citizenship has helped shape a brighter future for the
1% of the world’s high-net-worth individuals and their families,
fortunate enough to access bigger and better opportunities
across the globe. While the industry’s focus was primarily on
offering second residence or citizenship to the 0.001% of the world’s
migrants who can afford the investment, it has neglected one of the
most pressing opportunities in its realm: extending the same benefits
to those who can’t. The failure to do so not only
hurt the industry’s reputation but it allowed it to
become a target of unwarranted attacks. Migration
has endured for thousands of years, affecting millions
of people from all walks of life, each with the
goal to either survive, or the desire to strive.
Global Citizen Tax
The idea of the Global Citizen Tax was first introduced
in the midst of the refugee crisis back in
2015. As global challenges continue to grow, the
Global Citizen Tax initiative becomes even more
relevant and needed. As an industry reaching
maturity, we have the opportunity to do things
right. A united industry represents a stronger
force, and initiatives like the Global Citizen Tax
could help accelerate its growth while advocating
for the other 99%. With the potential to raise
over €1 billion over the next five years, the Global
Citizen Tax would be fuelled through the contribution
of investors who would add between 1%
and 5% to their prescribed investment for second
residence or citizenship in an EU member state.
Current Migration Crisis
Despite the lack of news surrounding the continued
influx of refugees flooding from the
Middle East and North Africa into Europe, migration
remains a dominant trend that continues
to exact a large toll on the families who flee
for a better life, the countries receiving them,
and the international institutions and NGOs
charged with providing basic humanitarian assistance.
According to the UN High Commissioner
Armand
Arton is the
founder and
president of Arton
Capital. His professional
designations include
Chartered Investment
Manager (CIM) and
Fellow of the Canadian
Securities Institute
(FCSI). He graduated
with a BA in Finance from
Ecole des Hautes Etudes
Commerciales (HEC)
and an International
Baccalaureate from
College Jean-de-Brébeuf.
for Refugees (UNHCR), “as of 30 June 2018, there were a total 70.4
million people of concern”. Their figures also reveal that last year
alone, more than 116,647 refugees and migrants risked their lives
crossing the Mediterranean Sea to reach Europe. Meanwhile, the
global refugee population continued its upward trend reaching
20.2 million by mid-2018. UNHCR estimates that the average time a
refugee from Syria will remain in that status is 17 years – creating a
lost generation of families and children who may
spend their formative years in limbo. In addition,
the number of people who have lost their lives
at sea is devastating – an estimated 14,281 people
since 2015, half of whom were women and children.
This is nearly the same number of families
who invested in a second residence or citizenship
in the EU during the same period.
Industry Solution
The global citizenship industry should be part
of the solutions by joining hands with partners,
governments and international organisations
to address such challenges. Various European
countries that are accepting refugees are also
in many instances attracting foreign investors
through their Global Residence and Citizenship
Programmes for investors, including Cyprus,
Malta, Portugal, and Spain. In Europe, such programmes
have attracted more than €15 billion in
capital over the past 10 years. It can be broadly assessed
that the volume of these programmes for
the period 2017-2018 has reached over €2.6 billion
globally, growing annually at nearly 25%. Based
on these numbers, the volume of direct economic
benefits from the implementation of such
a Global Citizen Tax on the popular immigrant
investor programmes could reach as much as €1
billion in the next five years.
By shifting our focus on sharing a global responsibility
and ensuring the industry enforces
its mission to empower sustainable migration, we
are advocating to unite the resources of 1% of the
world to help the remaining 99%. n
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
What it takes to build AN
Efficient RCBI Programme
For the past four years, I have been reviewing
most of the world’s business migration
schemes. Every year I analysed and
dissected 100 such programmes for our
database and our reports. All that knowledge
enabled us to understand trends in the industry,
mechanisms behind the programmes, and
which nationals are drawn to what programme.
It also allowed us to predict which investment
migration programmes will be successful and
which will struggle to gather momentum. In our
latest Government Report , we wrote about how
governments can use investment migration to
strengthen their economy. The report spans 100
pages, but I will try to summarise it.
What’s your country’s economic need?
Eight of the ten countries with the worst Current
Account Balance in the world have a CBI programme.
This, of course, is not a consequence
of the programmes, but rather the reason why a
CBI came to be. It generally takes a large amount
of political sacrifice to launch a CBI, but it can
be justified when it substitutes drastic austerity
measures. All investment migration programmes
should be built based on specific economic needs
of a country. It is important to assess those needs
and build a programme that makes sense. A high
amount of government debt and high unem-
Stéphane Tajick,
President and
Chief Advisor of
STC, highlights
what governments
should keep in mind
when designing an
investment migration
programme.
ployment are the most common woes that governments
want to tackle. In most cases, efficient
RCBI programmes can help heal the country’s
economy if they are backed by logic and data.
Understandably, CBI programmes have a greater
impact in small countries, given that an additional
revenue of $200m a year affects smaller economies
more than larger ones.
It is also important to consider regional
needs within a country, since disparity can exist.
Certain regions have stronger pull factors than
others, which could affect the goal of any policy.
For example, in Spain the need for real estate
investment was pressing after the 2008 financial
crisis. The investor programme with a real estate
option was created in 2013. However, over the
years, the number one investment destination
was Barcelona, the region that needed it the least,
and where people today suffer from housing unaffordability.
This means that assessing regional
needs, and making sure that push and pull
factors are addressed, is immensely important.
Tracking performance
Every serious investment is tracked and assessed
along the way. Investment in an RCBI
programme should be no different, especially
when it’s made to be an economic development
policy. Tracking performance is not only impor-
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INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
tant to assess if the policy is working, but also to
optimise its impact and to make sure it doesn’t
overheat certain markets. For example, an entrepreneur
programme created to address high
unemployment should start lowering its output
once unemployment starts approaching the
desired number. The example of Barcelona and
the Spanish investor programme showed that
untracked performances could also have a negative
impact on the economy, because in this case
the real estate market overheated. It should be
noted that the Barcelona property market didn’t
overheat because of the investor programme;
nevertheless, the investor programme should
prevent investment in overheated property
markets. Therefore, tracking price indices is as
important as implementing quotas, for the policy
to have the desired effect. Meanwhile, whatever
your country is offering in exchange of investment
must be competitive in the global market.
A CBI programme of a country with a poor passport
in terms of visa-free travel will not gather
much revenue. At the same time, it will be hard
for a country to attract innovative start-ups if it is
not ranked high as a place to do business in.
High level of transparency and due diligence
Investment migration has been under a lot of
criticism in the last few years, most of which is unfounded
and unfair. The EU parliament singled
out RCBI schemes as a security risk, although
these apply a higher level of due diligence than
any other residence or citizenship pathway. It’s
becoming a norm to have four-tier due diligence
system applied to any programme. Transparency
about the number of applicants and investment
received should also become a norm. One thing
we advise governments to do is to follow the
Quebec model of adding an extra layer of defense
by having solid intermediaries between the government
agency and the applicants. In the case
of the Quebec Immigrant Investor Program, these
are financial intermediaries that serve the purpose
of filtering applications, holding the investment
funds in escrow and marketing the programme.
Pricing and market research
It’s important for every government to do its
research on competing RCBI products before
launching their own programme. Like any
product, it should be priced based on production
costs and market price. Market price can be
obtained by comparison with similar countries;
after that it really depends on the production
level – are you looking for 100 applicants a year
or 1,000? But production costs are much more
obscure when it comes to a RCBI product. There
are direct costs associated with it, such as processing
the application, marketing the programme,
due diligence on files and so on. Then there are
other costs that are more abstract, such as the
cost of having an extra citizen. An easy estimate is
to take the government budgets at different levels
for the year and divide these by the population.
That’s a high number, but it’s the benchmark I
Stéphane
Tajick is Head
Advisor of
Stephane Tajick Consulting
(STC). STC has become
a leading provider of
data and reports for the
investment migration
industry with detailed data
from 150 world cities and
reports covering over 200
immigration programmes
catering to entrepreneurs
and investors. Prior to
setting up STC, Stéphane
was involved in different
sectors ranging from
hospitality to retail.
use for RCBI programmes that are supposed to
have positive economic impacts. Factors such as
whether a country is providing free university
and health care also need to be taken into consideration
when fixing eligible ages for children and
parent dependents.
Someone needs to make money in
order to sell your programme
In order for the investment migration industry
to promote a RCBI programme, it needs to be
profitable for them. It’s not a question of greed;
working on a new programme takes considerable
investment. The industry needs to know it’s
going to be profitable for them to do so. This is
a key aspect that was overlooked for many years,
and makes a significant difference in terms of
the popularity of a programme. Commission is
a possibility, but not the only one. The Quebec
Immigrant Investor Programme, for example,
allowed financial intermediaries to offer financing
to investors, and by providing those services,
they were able to earn significant revenue that
made the programme particularly attractive to
them. They were, in turn, able to commission
immigration consultants that send them clients.
Besides, for large firms scalability plays a role.
Five to ten applicants are not enough to support
the investment they need to enter a new programme,
while the potential to duplicate administrative
and application processes is important.
Entrepreneur and start-up programmes often
lack this, since most of them require a custombuilt
business plan.
Avoiding sudden changes
A few years ago, the UK tier 1 investor programme
was amended, and had its investment
amount increased from £1m to £2m. This sudden
price change led to a collapse in demand during
the following year. It took a few years for the
demand to recover, and this after an important
loss in earnings. At this point, it should be said
that the decision in itself to increase the amount
is not subject to debate. Rather, it’s about how
they went on to implement those changes. 21st
century policy-making is not only about making
the right policies, but also limiting the negative
impact policies could have. In this case, other
than the loss of earnings, there was a negative
impact on the industry professionals that supply
candidates to the programme. Due to significant
drop in demand, their revenue suffered and staff
were laid off; firms that were in a fragile state
most likely collapsed. This is why such changes
must take place over time, and price changes
should be phased in. Significant changes, such
as a price drop, are only recommended if a government
wants to bring its programme back to
life. Even if a government wants to close a programme,
it’s recommended to phase it out, and
government should announce its intentions long
before. Otherwise, this might affect the reputation
of the investment migration industry, and
that of all other interconnected industries. n
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Furthering the Investment Migration
Industry’s Sustainability
EU member states with the sovereign right to manage their own national economic
policies are feeling the weight of increased pressure from EU institutions and
international lobby groups to make changes to, or even phase out, their residency and
citizenship by investment programmes. Julia Farrugia Portelli, Malta’s Parliamentary
Secretary for Citizenship, Reforms and the Simplification of Administrative Processes
speaks to the IM Yearbook about Malta’s stand and perspectives in this regard.
The Maltese programmes for residency
and citizenship-by-investment (RCBI)
have both been categorical achievements.
Over a brief period of time, my country launched
robust propositions that quickly caught the eye
of investors looking to having alternative opportunities
for relocation, mobility, education, and
global business. Our programmes are now well
established in the sector, and we believe they give
competitors a good run for their money.
We ascribe to this success several elements
– a robust framework, strategic marketing in receptive
regions, and a thorough due diligence
process that ensures only the most fit-and-proper
individuals and families are accepted and granted
Maltese residency and citizenship.
Beyond doubt, by far the most attractive
feature is our country itself. With an economy
that keeps punching above its weight, a government
that’s open to entrepreneurship, innovation
and business, and an increasingly cosmopolitan
lifestyle in a safe and stable jurisdiction, choosing
Malta becomes easy.
“Indeed, our
processes are
considered a
benchmark to
be emulated in
the industry, and
we are willing
to share our
best practices
so that we can
work towards
standardisation
in the sector.”
Our Challenges
Sometimes, then, success brings on its own set of
challenges. Notwithstanding the sovereign entitlement
of Member States and countries to offer
second citizenship and residency, notwithstanding
being enablers of mobility, offering global
citizens better family situations and fresh opportunities
to do business, there is a mounting pressure
on phasing out these programmes.
Although we are not on the same page, we acknowledge
and understand the concerns that are
being voiced in various echo chambers. They disregard
the valuable direct contribution to sovereign
wealth and state economies. They overlook
the legitimate global demand brought about by
regional political and economic volatility. They
discount the fact that the percentage of individuals
granted citizenship and residency in the EU
via investment is a minute fraction of those naturalised
by other means, where the due diligence
process is nowhere like that employed by RCBI
programmes.
We acknowledge the apprehension that disreputable
individuals may be able to find their
way into the Union. However, we are confident
these fears can be allayed by a guarantee of thorough
due diligence that leaves no stone unturned
in filtering out these individuals.
We say this with the comfort that Malta
already applies the highest of standards in enhanced
due diligence checks. Indeed, our processes
are considered a benchmark to be emulated
in the industry, and we are willing to share
our best practices so that we can work towards
standardisation in the sector.
Despite this, all investment migration programmes
should aim for attaining the highest
standards to ensure that integrity and reputability
become benchmarks across the industry. For
the sake of transparency, Malta also regularly
publishes the names of new citizens, and takes
all the necessary steps to uphold European regulation
on anti-money laundering, counter terrorism
and tax avoidance.
The Future Ahead
In this context, it is clear that the way forward
for sustainable RCBI programmes is one of strict
self-regulation, applying the highest operational
standards that appease the most demanding of
regulators. n
66

United Kingdom Cyprus Antigua & Barbuda
Grenada
St Kitts & Nevis Malta Dominica Greece Canada
Antigua & Barbuda Turkey Moldova St Lucia
Montenegro
London l Dubai I Istanbul I Kiev I Hong Kong
beyond-immigration.com

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
The World of
Investment Migration:
What’s New?
The investment migration landscape is fast evolving, with a
greater number of countries launching residence, entrepreneur
or citizenship programmes. The IM Yearbook has reached
out to the industry to see what’s hot and what’s not.
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INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
Greece
Greece has won the laurels of attracting
record number of applications to its golden
visa programme in 2018. The country issued
a total of 11,445 visas to investors and their
family members last year, with China being
the top source market accounting for more
than 6,800 visas. Since the introduction of the programme in
2013, Greece issued more than 35,000 golden visas. However,
mired in controversy, according to agents the outlook for 2019
is less rosy. Demand will likely drop, partly as a result of newly
brought in measures that include a ban on paying for property
through credit card terminals, which have allegedly been
used to circumvent Chinese capital restrictions in the past.
Portugal
The shine seems to have come off Portugal. Once
the bellwether for the industry in terms of attracting
applicants, the golden visa programme has taken
somewhat of a dip. The total investment in the
programme dropped 31% in February compared
to the same month in 2018 according to figures
released by the country’s Foreigners and Border Service (SEF).
The programme may well attract further controversy because
many applicants who entered the programme did so with the
expectation that after a number of years they would be able
to apply for citizenship. Soundings coming off from Portugal’s
government seem to indicate that this may be a remote possibility
for those applicants who have not actually relocated to Portugal.
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
The UK
Despite the unknown outcome of Brexit
negotiations, the UK appears to remain an
attractive destination among wealthy migrants,
especially among the Chinese. In 2018, Chinese
applications for the Tier 1 investor visa have
reportedly increased by 19%, and accounted for 63%
of the 228 applications last year, up from 50% in 2017. Uncertainty
surrounding the programme’s future was seen as one reason that
prompted applications. In addition to the UK’s Brexit woes, the
government had announced that it would stop the investor visa
programme amid concerns that adequate compliance checks were
not being conducted. While this decision was overturned following
strong opposition, new rules, especially with regard to source of
funds, were introduced to reform the programme. Besides, the UK
programme could see another windfall from Brexit: The investor
visa might become an attractive option for those Europeans who
may wish to live in the UK but will not be able to do so as easily as
right now once Brexit takes place. Meanwhile, the UK government
discontinued the Tier 1 entrepreneur visa category, replacing it with
the “start-up visa” and “innovator visa” categories, hoping these
will spark economic growth, particularly in the UK’s tech sector.
Austria
Austria has one of the oldest, and, in fairness, one
of the programmes that is held in most esteem.
However, it is also one of the least transparent,
with no clearly defined and predictable path to
citizenship. Little is known about the programme’s
processes nor about the number of applications,
but the programme continues to have its appeal (so we’ve heard).
Flying in the face of Europe’s drive for greater transparency and
sharing of information, it appears that Austria didn’t get the memo.
Thailand
Much like its tourism tagline “Amazing
Thailand”, the country is carving out its own
niche in the market, with retirees looking
to Thailand for their second lease of life.
Initiated by the Thai Government to attract
wealthy travellers, families, investors, and
entrepreneurs, the Thailand Elite Residence Programme offers
applicants extended stays in the country, between five and 20
years, at a one-time cost of approximately $16,000 or $68,000,
depending on the option chosen. While the main target
markets are business travellers needing fast entry and exit in
and out of the country, thus far most demand is stemming
from retirees who, if they stay in Thailand for more than 180
days per year, stand to benefit from an attractive tax regime.
Moldova
Moldova is the other European newcomer
on the investment migration scene. As one of
Europe’s least developed countries, it might
appear an unlikely place for the launch of a
successful citizenship-by-investment programme.
However, the country’s location and cultural mix
definitely holds a very unique appeal. The programme provides
access to 122 destinations, including Russia, the post-Soviet
states and Turkey, while visa-free access to the Schengen area
is the cherry on the cake. It is the first programme of its kind to
offer this unique combination of visa-free travel destinations.
In Focus: Moldova
Iulia Petuhov, Head of the Moldova Citizenship-by-Investment
Programme, lays out the key elements of her country’s programme.
What was the main objective
behind the introduction of
Moldova’s CBI programme?
Moldova is undergoing a comprehensive
process of modernisation
and economic innovation.
However, as is the case with
all sovereign states, we are
in a competitive market for
foreign investment and for the
necessary liquidity that must
be injected into the Moldovan
sovereign balance sheet. This is
where the Moldova Citizenshipby-Investment
Programme
(MCBI) comes in. Not only will
there be a stream of non-debt
bearing capital flowing into our
development fund, but we also
believe that MCBI will act as a
global marketing platform that
demonstrates the value of the
Moldovan economy to potential
FDI investors. We expect that
there will be significant crossover
between MCBI investors and
FDI. The programme is in its
early days; however, MCBI has
a unique proposition in terms
of market access, price point
and the potential for further
investment in a deeply fertile
corporate environment. We are
now seeing our first applications
nearing completion.
What are the big issues that
newly launched programmes
have to deal with?
The core issues that all participants
in the investment
migration industry must publicly
and demonstrably manage are
governance and due diligence.
We should all work together to
ensure a common set of rigorous
standards that demonstrate
how seriously we take these
issues, and possibly develop a
roadmap towards some sort of
supra-national regulation. We
must demonstrate the societal
value creation of the industry,
and also that the industry is at
the same level as international
capital markets when it comes
to KYC and sources of funds
procedures. Secondly, while we
are in a competitive market
place, we believe that demand
for these programmes is so
strong that there is no need
for any programme, Moldova’s
included, to significantly reduce
their fees. We should all have
confidence in the value of the
product. You don’t see investment
bankers drop their fees,
so why should sovereign states?
What sets Moldova’s
programme apart from
its competitors?
We are confident that our offering
will be very attractive
to the global HNWI investor
base. Moldova has a unique
proposition, with visa free
access to Schengen as well as
to the post-Soviet space and
Turkey. We have already seen
applications that are specifically
driven by our unique offering.
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INVESTMENT MIGRATION YEARBOOK 2019/2020
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Turkey
Demand
for Turkey’s
citizenshipby-investment
programme
has taken off
spectacularly following a hefty
price-cut in late 2018. Under
the real estate option, the
minimum investment is now
$250,000 instead of the original
$1 million. The deposit option
decreased to $500,000 from $3
million, and the fixed capital
investment option’s lower limit
is now $500,000, whereas
the original amount was $2
million. Foreigners who would
like to create jobs in exchange
for Turkish citizenship only
need to employ 50 people
instead of 100 as required
previously. One reason for
Turkey’s attractiveness is that
it provides a route to the US
in the face of a growing EB-5
backlog. According to industry
professionals, a growing
number of applicants choose
to first invest in a Turkish
passport and then apply for the
E2 entrepreneur visa through
their new Turkish citizenship.
“Turkey received 250
applicants during the first
year of the programme.
However, given that the
government has significantly
decreased the necessary
minimum amount of
investment in all options, it
is clear that the number of
investors will multiply in the
coming years. Meanwhile,
as Montenegro closes the
chapters one by one to
reach member state status
of the European Union, the
value of the Montenegrin
passport is expected to
increase sharply.”
Laszlo Kiss
Managing Director of
Discus Holdings
The US
Demand for the USA’s EB-5 programme continues
unabated, despite a growing quota backlog for certain
nationalities. Hopes are high that one of the most
successful residence-by-investment programmes
in the world will soon receive a facelift. The EB-5
programme has been running on numerous shortterm
extensions, with the current extension expiring in autumn
2019. However, the industry is optimistic that the programme will be
maintained despite the anti-immigration rhetoric of the ruling political
establishment. Discussions on the modernisation of the programme
are reported to be at an advanced state. The new version of the
programme could see the visa ceiling expand from 10,000 to 50,000
per year, but on the flipside, cost could also increase, with the current
minimum investment of $500,000 going up to north of $1 million.
Malta
As a member of the EU, Malta has been one of the
great success stories of the investment migration
industry. With Malta’s warm and sunny weather,
historic charms and Mediterranean lifestyle, it is easy
to see why the island has become one of Europe’s
top destinations. Malta’s residency-by-investment
programme proved to be a reputable, advantageous and competitive
programme, attracting over 1,500 applications since its introduction
in 2015, according to the Malta Residency Visa Agency (MRVA).
The country’s citizenship-by investment-programme, the Malta
Individual Investor Programme, is equally successful. Thus far, 900
applicants completed the programme, generating over €760 million in
direct payments to the Government of Malta. Malta’s citizenship-byinvestment
programme has been capped at 1,800 applicants but the
Maltese government has already announced its intention to extend
the programme. However, it is considering more stringent criteria.
Inside the MRVA
Charles Mizzi, the
new CEO of the
Malta Residency
Visa Agency,
provides insights
on the Malta
Residence and
Visa Programme ’s
performance and
shares his thoughts
on the industry’s
way forward.
The Malta Residency and Visa Programme
(MRVP) was introduced in 2015 in order to
enhance Malta’s sovereign wealth and to
attract foreign, quality talent and investment to
the country, while offering second residency benefits
and international mobility to global citizens.
During the past 18 months, the programme has
seen a huge rise in demand. So far, the programme
has attracted over 1,500 quality applications.
Most applicants hail from China, while we are also
seeing interest from other regions such as the
Middle East, Russia, Turkey, South Africa, and India.
The high application volume has been particularly
challenging to process. Our
primary aim is to find a balancing
act between efficiency and
maintaining the strict processes
we employ to ascertain the
most rigorous of due diligence
checks on all applicants and
their dependants. Integrity is
the be-all and end-all objective
of a sustainable, reputable
programme. The Agency is young
and small, and it has to grow
So far, the
programme
has attracted
over 1,500
quality
applications.
in tandem with the programme’s rapid success. As
the relatively new CEO, this is my priority – to see
the Agency develop and strengthen its operations,
while studying and analysing new opportunities.
We expect the industry to continue on its
growth path, with more countries starting to offer
residence-by-investment opportunities. We believe
that the future of any residence-by-investment
programme depends on strict self-regulation that
upholds the highest of standards. There is no
doubt that the concerns of industry critics and
lobby groups with regard to transparency, security
and good governance are putting pressure on all
countries offering investment
migration programmes. Malta
already implements a rigorous
four-step screening process,
while also adhering to international
anti-money laundering
legislation. However, we understand
these concerns, and
we are ready to share our best
practices for them to become
a benchmark in the industry.
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Cyprus
Cyprus’ citizenship-by-investment programme
helped bring the Cypriot economy back to boom
mode. It served as a great boost for the struggling
real estate sector since most investors preferred
to invest in property. However, acknowledging
that some aspects of the programme needed
to be improved, Cyprus recently unveiled a series of reforms.
Among the changes were stricter criteria for applicants who
now need to undergo background checks by a specialised
due diligence firm, the introduction of an annual cap of 700
passport approvals to main applicants, as well as a requirement
for applicants to already be in possession of a Schengen visa.
Estonia
Having successfully broken new ground with
e-residency, Estonia could well be the dark
horse of the investment migration race and
should definitely be on everybody’s watch
list. After attracting almost 55,000 e-residents,
the country is now looking to bring this
level of innovation to providing visa-free travel, which could
well turn out to be a game-changer for global mobility.
Canada
Canada has had a long-term on-off relationship
with the investment migration industry.
Despite being one of the frontrunners
of this industry, the end of the Canadian
Federal Immigrant Investor Program is quite
possibly the single most important factor
that contributed to the success of America’s EB-5 programme.
However, for those wishing to move to a new country, Canada
is still an attractive choice given its multi-cultural, safe
living environment. Quebec is the focal point of Canada’s
investment migration industry. Unlike many of its counterparts,
relocation though is not an optional requirement but a must
for applicants of the Quebec Immigrant Investor Program.
Montenegro
Montenegro’s citizenship-by-investment
programme is probably going to be the next
big European contender in the investment
migration arena, with a lower pricing structure
than many of its European competitors.
Already an Adriatic yachting hotspot with
stunning natural beauty, Montenegro is emerging as a luxury
destination offering interesting investment opportunities,
with some calling it ‘the next French Riviera’. Many in the
investment migration industry believe that Montenegro’s
programme will rapidly gain in importance as the country
moves closer to European Union membership.
Cyprus Update
Michalis P. Michael,
Chairman of Invest
Cyprus, sheds
some light on
the new rules for
Cyprus’ citizenshipby-investment
programme.
Cyprus, as a dynamic business centre, places
great emphasis on attracting foreign direct
investment as a key tool in achieving sustainable
economic growth. The Cyprus Investment
Programme was introduced to continuously reinforce
the reasons why investors choose Cyprus,
acting as a prime incentive for international
investors to not only invest in our country, but
also to make Cyprus their home. The programme
contributed significantly to the recovery and
growth path of the Cypriot economy, while
proving a valuable instrument towards developing
key economic sectors and particularly the real
estate sector, at a time of economic distress.
During the past few years, we have witnessed a
significant upward trend in the global investment
migration industry, raising $14 billion in FDI in 2018.
However, the industry is also under continuously
increasing attention. For EU countries, this was reflected
in the recent report by the EU Commission,
highlighting concerns over security, control
mechanisms and exchange of information amongst
member states. Cyprus supports all coordinated
action to improve collaboration between EU countries,
but also supports the essence of the country’s
national right to establish its own policies.
On our part, we are constantly implementing
modifications to our programme to ensure and
safeguard its viability, as well as to protect investors.
Last year’s measures included the introduction
of a Code of Conduct for service providers, limiting
applications to 700 per year and establishing professional
due diligence processes for applicants. In
February 2019, new modifications were introduced,
including the need to be a holder of a Schengen
Visa in order to apply for naturalisation, the inclusion
of investments in the shipping sector and in
Registered Alternative Investment Funds as eligible
investments, the obligation to maintain the required
investments for a period of at least five years
from the date of naturalisation, and many more.
In addition, an Annual Implementation Report that
includes the number of naturalisations, geographical
area of the applicants and the sector in which
the investments were made, will be prepared for
the sake of transparency and correct information.
We expect that the programme will continue
to attract foreign investment from a variety of
countries; and I am referring to investments of
substance, that forge real ties with the country
and advance Cyprus’ economic growth. Our
efforts are focusing on ensuring significant economic
benefits from the programme, not only
in the real estate and construction activity, but
also in other sectors; and most importantly, in
terms of the real economy. Overall, we do aim
at enhancing cooperation at EU level in this
regard, and we are always at the disposal of the
EU Commission to share information, and ensure
security and transparency in relevant practices.
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The Caribbean
Region
Dubbed the global
capital of ‘citizenshipby-investment’,
the
Caribbean provides
the highest number
of programmes in the
world. The Caribbean
programmes offer a
quick route to citizenship;
applications are usually
approved with three to
four months following
the date of submission.
However, with five
countries operating
programmes – St. Kitts &
Nevis, St. Lucia, Antigua
& Barbuda, Grenada
and Dominica – all
with similar benefits,
clients may find it
hard to distinguishing
one from another.
St. Kitts & Nevis
While St. Kitts & Nevis is
credited with inventing
the concept of economic
citizenship way back in 1984,
the programme is currently
feeling the spotlight of
international media attention as it is facing
allegations of fraud and financial irregularities,
with agents and developers being accused of
offering citizenship at way below governmentsanctioned
rates through real estate trickery.
Antigua & Barbuda
Antigua & Barbuda has
made headlines with its
crypto-friendly stance.
The government has
amended the country’s
citizenship by investment
programme to allow payments in
Bitcoin and other cryptocurrencies.
Dominica
The Financial
Times CBI
Index has
ranked
Dominica’s
citizenship
programme the best
programme for two
consecutive years. Dominica
has continuously focused
its efforts to strengthen its
security checks, introducing
a complex multi-tiered due
diligence process and adopting
legislation and regulations
that match international
standards. One advantage of
Dominica is that dependent
children can be included
up to the age of 30 years.
However, this is also possible
in Grenada and St. Kitts.
“The RCBI
market has
reached
maturity,
while new
entrants
confirm that
the need for
such programmes persists. Ultimately, each
programme positions itself differently, and
thus attracts different kinds of applicants.
As the market expands, the requirements
will also become more complex, and for
governments that operate with a long-term
vision, being able to adapt and respond
proactively is crucial. We are optimistic
about the future of Dominica’s citizenshipby-investment
programme. The focus on
integrity, reputation and transparency is
what maintains Dominica’s unique position
comfortably at the forefront of the industry.”
His Excellency Emmanuel Nanthan
Head of Dominica’s Citizenship
by Investment Unit
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
St. Lucia
St. Lucia was a late-comer to
the investment migration scene,
having launched its programme
only in 2016. Thus far, the
application volume has been
considerably lower than that of
competing Caribbean jurisdictions, and some 330
persons have reportedly been granted citizenship
during the past three years. St. Lucia seeks to
position itself as a holistic lifestyle location and,
going forward, it wants to offer its new citizens
ample opportunities to build get involved in the
economy and create strong ties to the country.
Grenada
Grenada, on the other hand, is
fast establishing a reputation
as the most prudent and
dynamic country for second
citizenship investment in the
Caribbean after appointing
Thomas Anthony, a former due diligence
specialist, as CEO of its citizenship unit.
However, Grenada’s biggest plus is its visa
treaty with the US, which allows Grenadian
passport holders to apply for the E2 visa that
enables one to live, work and study in the USA.
Anguilla
Anguilla is the
new contender
in the region,
having launched
its Residence for
Tax Purposes
(RTP) programme in 2019. The
Caribbean island is a British
Overseas Territory (BOT) and
hence cannot create a citizenship
by investment programme like
other Caribbean jurisdictions.
Anguilla has suffered significant
damages from hurricanes, and
the programme is seen as a way
to generate foreign investment
to help with recovery efforts.
Foreign nationals are required
to make an annual lumpsum
tax payment, purchase
property and create genuine
links with Anguilla such as
holding bank accounts. However,
in times of greater scrutiny
and international pressure
on all things tax, Anguilla’s
tax residence programme
still has to prove its worth.
“All applicants to our Residence for Tax
Purposes (RTP) programme will be subject
to a thorough and enhanced due diligence
process. We expect this programme to
grow significantly as the market becomes
more aware of the benefits. It will be
particularly attractive to Canadians, UK
nationals and Europeans who cease to be
tax resident in their home country and
live very international lives that see them
spend on average less than 90 days per
year anywhere in the world but intend
to make Anguilla their tax residence.”
Philip Kisob
CEO of Select Anguilla
3 Questions with…
Jonathan Cardona
CEO of the Malta Individual Investor Programme Agency
Four years since the launch of Malta’s Individual Investor
Programme (MIIP), what have been the results?
The programme has been very successful – around 1,000 families
were approved, of which over 900 completed the programme successfully,
generating over €760 million in direct payments to the
Government of Malta. This means that over €460 million have
been deposited into the National Development and Social Fund
run by an autonomous agency. The functions and duties of the
agency are to contribute towards significant projects of national
importance, supporting advancement in education, research, innovation,
justice, employment, and public health. Furthermore,
approved applicants have also reached out to local NGOs and
philanthropic organisations, making a direct contribution of approximately
€4 million. However, Malta’s economy is not dependent
on the revenues generated through the programme;
they are an additional boost. In recent years, we have been
experiencing GDP growth rates of around 6 to 7%, making Malta
one of the most dynamic economies among all EU countries.
How do you expect the investment migration
industry to evolve over the coming years?
Establishing global and common standards will be the way forward, as
currently, the investment migration industry remains largely unregulated.
This means that the level of international scrutiny is bound to increase.
Malta has been advocating for the introduction of industry-wide
standards ever since its programme was launched, while it remains
one of the few countries that have established an independent regulator
to oversee its operation. To this end, Malta continues to retain the
world’s top citizenship-by-investment programme for the very high
due diligence standards it set up. Recommendations have also proven
that firms and agencies worldwide need to invest heavily in their due
diligence to match this bar; these are much needed efforts that will
help maintain this ongoing success without exposing the industry to unnecessary
risks. The investment migration industry is also looking into
developing professional qualifications as a standard for its employees.
This will help demonstrate that such programmes are a step closer to
reaching the much-needed high standards and a high level of scrutiny.
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Vanuatu
Vanuatu is the only Pacific island nation with a
citizenship-by-investment programme. A former
British and French Colony, Vanuatu remains a
member of the British Commonwealth. While
for many professionals the programme is not
regarded as being in the top tier league, Vanuatu
passport-holders enjoy visa-free travel to more than 120 countries,
including the UK, the Schengen Zone and Russia. Vanuatu’s Daily
Post reported that an estimated 1,800 passports were issued via the
country’s citizenship by investment programmes in 2018 and that
last year on average five people became new citizens every day.
Jordan
A safe haven in a region of conflict, Jordan is one
of the more recent entrants to the investment
migration arena, offering programmes for both
citizenship and residence. While Jordan is
doing well on the tourism front, and has been
repeatedly named as a 2019 must-visit destination
by travel guides and international media, the kingdom’s decision
to formalise a route to economic citizenship was mainly
motivated by a desire to attract investors to its ailing economy,
which has been severely affected by the conflicts in Iraq and
Syria with public debt approaching $35 billion. However, it
remains to be seen whether Jordan’s programme proves popular
not only for investors from the Middle East but beyond.
New Zealand
New Zealand’s
investor visas
are probably
the industry’s
‘best-kept’
secret.
Although requiring a relatively
large investment amount,
the New Zealand investor
programme offers investors
great flexibility, allowing
applicants to choose from a
wide range of investable assets,
including new residential real
estate developments, bonds,
funds and private or public
company equity. New Zealand
has two investor visas, which
either require an investment
of NZ$3 million or of NZ$10
million, whereby a combined
total of 2,000 applications were
approved since 2008. While
the country’s new law that
restricts property purchases
by foreigners has hit global
headlines last year, industry
practitioners do not expect it
to have any direct impact on
investor visa applicants as the
law does not affect residential
real estate investment
under the investor visa.
“While demand for Australia is
high and is expected to remain
so, the biggest potential for
growth is in New Zealand.
Many high-net-worth investors
have obtained residency or
citizenship in New Zealand
as a safe country that offers
refuge from many of the
challenges facing other larger
countries such as population
size, water shortages and
climate change. For many New
Zealand is still an undiscovered
country, and the current
lower demand is generally
due to a lack of awareness
of the investment migration
opportunities available.”
James Hall
Managing Director
of ANZ Migrate
What updates and new initiatives
are in the pipeline?
To date, the requirements and regulations have
not changed. However, updates for the programme
will be in place in the near future, which will
reflect the feedback obtained from a public consultation
exercise and from the report issued by
the European Commission earlier this year. We
went through this whole process to ensure that
the updated and revised programme continues to
attract successful individuals who can contribute
to the country, while having in place the necessary
safeguards that would counter any potential risks.
Australia
Australia has become the top destination
globally for migrating high-net-worth
individuals. An estimated 12,000 millionaires
moved to Australia last year, which means
the country has surpassed the USA, which
welcomed 10,000 new millionaires, according
to a report by New World Wealth. Meanwhile, Australia’s
Significant Investor Visa continues to appeal to Chinese
nationals, with the visa number for the permanent residence
visa being subclass 888 – meaning triple fortune in Chinese
numerology. With 88% of applicants in Australia originating
from China, it becomes clear that the Australian government
is prepared to further encourage growth of this market.
Ireland
With a fast-growing economy, an Englishspeaking
environment and EU member
status, Ireland has become one of the
most preferred residence-by-investment
destinations. Recently released figures show
that the Irish Immigrant Investor Programme
has approved 700 applications and has raised more than
€500 million since opening in 2012. The large majority of
investors – more than 90% – are Chinese, with Americans
coming in a very distant second, accounting for only 2%.
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
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TABLE
How to
Work
Together,
How to
WIN
Together
Three due diligence experts share their
thoughts and opinions on how teamwork and
intelligence can be a winning combination
for the investment migration industry.
La AS KK
Laura Austin
Senior Manager, Head of
Investment Migration Due
Diligence at BDO Consulting
Adam Skowronek
Head of EDD Case Management
and Client Consulting for
EMEA at Refinitiv
Karen Kelly
Director of Strategy &
Development at Exiger Diligence
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INVESTMENT MIGRATION YEARBOOK 2019/2020
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How would you describe
the current operating
environment in the
investment migration industry
for due diligence providers?
The investment migration industry is enjoying
AS
exponential growth, with more potential applicants
becoming interested in participating in the programmes, and
more programmes becoming available. The need for adequate
due diligence practices has been recognised in the industry,
and many agencies have significantly improved their practices
in this regard. However, with the increased competition
and push for a faster, more seamless application process,
the industry is requiring due diligence service providers to
propose a viable, competitive and comprehensive product.
Indeed, the importance of due diligence in the investment
La
migration industry has never been more emphasised
or better understood. Much of the recent increased emphasis
placed on due diligence stems from heightened industry
scrutiny, which has helped to highlight the necessity of
comprehensive and robust due diligence. As the importance of
due diligence is further highlighted to this industry, there has
been an influx of new due diligence providers to the market.
This is a reflection not only of the increased emphasis on due
diligence, but also of the growth of the industry as a whole.
KK
I have personally been involved in due diligence for
this industry for more than 10 years, and what I have
witnessed during that time is an increasing level of engagement.
We, at Exiger, are working closely together with our programme
partners and we are discussing methodology, reporting and
analysis, with an increasing emphasis on technology. Our
clients are actively taking part in determining the best due
diligence approach for them to facilitate decision-making. I
hope to see that becoming the norm across all programmes.
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What issues are currently
high on your agenda?
I think that the industry has a good level of understanding
AS of the importance of a comprehensive and robust
due diligence process, but the practical aspects of how to
achieve and maintain the highest quality of background
verification still remain unclear for too many agencies. We
are working tirelessly to educate agents and governments
operating investment migration programmes, to guide
them on best practices in due diligence, whilst also listening
closely to their specific concerns and requirements.
KK
Exiger is working with programmes not only on thirdparty
due diligence, but also on building and maintaining
robust and efficient compliance programmes that can stand
up to regulatory scrutiny now and in the future. This includes
providing advice on best practices and standard-setting, as
well as offering technological solutions to automate efficient
workflows and manage high volumes of applicant information,
due diligence and ongoing monitoring of applicants.
Our priorities as a due diligence stakeholder closely align
La
with the priorities of the investment migration industry,
and advocacy efforts are at the top of our agenda. BDO is a
participant in the IMC’s Special Task Force (STF), and we are
eager to participate, along with our industry counterparts, in
the establishment of due diligence industry standards and in
the drafting of specialist reports. We understand the significant
responsibility we have through our position as a major due
diligence provider, and we view these efforts as essential to the
protection of the industry and in the interest of all parties.
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
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What are the key KYC and
AML challenges faced by
programme operators and
agents, and how do you
help address them?
We firmly believe that ongoing monitoring after initial
KK
due diligence is a key challenge of KYC across the
board today. Risk analysis is another important challenge
faced by those in this industry – the main question remains
how to employ a risk-based approach that is defensible
before regulators in order to evaluate applicants’ suitability.
Exiger offers assistance to programmes through a number
of means to address this challenge, including offering a
comprehensive ‘risk matrix’ with our due diligence findings, and
organising an advanced due diligence course for programme
staff with a focus on employing a risk-based approach.
AS
I’d like to point out that the investment migration industry
remains largely unregulated from an AML perspective.
In the European Union, the 5th Anti-Money Laundering
Directive of 2018 requires enhanced customer due diligence
on third-country nationals who apply ‘for residence rights or
citizenship in the Member State in exchange of capital transfers,
purchase of property or government bonds, or investment
in corporate entities in that Member State’. Nevertheless,
many other agents operating IM programmes elsewhere
in the world remain unregulated. This is why the best KYC
and due diligence standards need to be shared among the
practitioners to improve the overall due diligence process
within the industry. Service providers such as Refinitiv have
the unique experience and understanding of both the KYC
requirements and best practices from the financial services
industry, and so we play a vital role in educating agents and
operators within the investment migration sector in this regard.
What are the key areas
that need to be considered
as part of a due diligence
process, and to what extent
is the scope of due diligence
widening today to incorporate
new areas of assessment?
Ongoing, real-time monitoring of applicants after the
KK
initial due diligence report has been delivered, is becoming
an increasing need for programmes. This is something more
sophisticated due diligence providers can offer. For a defined
period following initial due diligence, regular monitoring for
serious red flags can alert programmes to potential reputational
concerns with an applicant, so that they are in a position to
proactively respond. In more general terms, programmes are
increasingly recognising the need for comprehensive inquiries,
such as site visits and reputational checks that go beyond what
they may have previously done in-house. Desktop web searches
and traditional sanction as well as watchlist screening alone are
not enough to stand up to the increasing scrutiny on the industry.
We agree that the scope of due diligence is widening
La
today through the application of ongoing monitoring
solutions that serve to extend the ‘shelf life’ of the initial due
diligence investigation. It has existed in the financial services
industry for many years, and while it is a relatively new concept
to the investment migration industry, the implementation of
such a solution is seen as a best practice for RCBI programmes.
At BDO, we approach our due diligence with a wide lens,
encompassing research pertaining to the specific applicants,
as well as research on their surrounding and influencing
factors, businesses, associates, and sources of wealth. Other
areas of our research pertain to an applicant’s reputation;
personal, professional and political affiliations; and criminal,
civil and fraud issues, to name a few. This wide research lens,
coupled with our risk-based approach and an eye towards
behavioural patterns, leads us to uncover the most relevant
and significant findings during the course of our research.
I would mention the three most important elements in
AS
CBI/RBI-oriented background verification research: the
confirmation of the applicant’s identity; their risk profile; as well as
the validity of the source of their wealth (SOW). While the first two
are arguably straightforward, the scope of a comprehensive source
of wealth assessment has grown exponentially over the past few
years, including assessment of the subject’s known assets, reported
versus estimated value of the real estate properties, individual
salary, as compared to the industry estimate, detailed directorship
and employment records, source of wealth of immediate family
members and ancestors. It should also be noted that SOW
research is always inherently tied to risk research, since every
negative article found may have a significant effect on the wealth
profile assessment. It would therefore not be enough to keep the
risk scope limited to only sanction lists, AML/TF and political
exposure, but expand it to litigation, regulatory, bankruptcy and
law enforcement checks, as well as all-encompassing public
domain research, including a widest possible selection of search
engines, corporate information databases, and news aggregators.
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AI-powered tools are fast
becoming the new standard.
What risks and opportunities
do they represent? Could
you provide an insight into
other tools and technologies
that are playing an
important role today?
The due diligence research process can be roughly divided
AS
into data acquisition and data interpretation. Recent
advancements in AI-powered recognition of natural language
allows for progressively faster public domain scrubbing, where
relevant information pertaining to the applicant is readily
presented to a research analyst. With the significant increase
of digitised information and the increased volume of data in
recent years, the tools that facilitate faster and more precise
research are of utmost importance to the due diligence process.
For example, litigation checks for applicants from China could
take weeks if conducted manually, but with robotic desktop
applications, the research through vast datasets can be performed
within hours by machine, and only the relevant information
remains to be analysed by humans. Another example where
AI technology proves exceedingly useful is seamless passport
or identity verification – with facial recognition technology
becoming more and more advanced, the document and digital
identity verification, which remain the core components of
the due diligence process, becomes faster and more precise.
Although it is true that AI has a lot of benefits, there is
KK a misconception that AI might wholly replace human
analysts. Indeed, with AI the routine tasks of data collection
and risk categorisation have become more automated. It can
be harnessed to understand language and context. AI can
be refined to eliminate “noise” such as duplicates and false
positives. It can also follow leads and be taught to extract
data from deep web sources. AI can monitor thousands of
sources in multiple languages and create alerts for new red
flags, continuously refining a comprehensive risk profile for
an applicant. However, the most notable AI-powered tools
consist of a seamless collaboration between human and
artificial intelligence to permit a person to exercise critical
thinking and analysis in the most efficient manner.
We agree that AI-powered tools alone do not constitute
La
a sufficient or holistic solution. For due diligence to
be at its most comprehensive and sophisticated, there is a
requirement for both enhanced due diligence processes
utilising local intelligence sources, coupled with far-reaching
technology products, to include continuous monitoring
solutions. A hybrid, ‘people+’ approach, using both technology
and human intelligence, allows for the most comprehensive
intelligence that is subject to thoughtful human interpretation
and the critical analysis of the results. This type of due
diligence solution satisfies industry best practices.
Immigrant investor programmes
have slightly different due
diligence requirements. Does
the industry need to agree
on a common standard, and
how could this be achieved?
We do see differing standards amongst programmes, and
KK
this can be around a number of due diligence elements
including jurisdictional scope, the level of reputational inquiries
and documentation checks. The differences may be a result of
budgetary constraints, the risk profile of applicants, or other factors.
A minimum agreed-upon common standard could benefit the
industry in terms of transparency and industry reputation. Setting
such standards would involve more than an agreed scope list - it
would entail a close examination of due diligence methodology
and reporting standards by due diligence providers, as well as a
review and comparison of required documentation and disclosures,
after which a baseline could be established across programmes.
The lack of AML regulation and KYC specific guidance
AS
puts the industry at higher risk of money laundering, tax
evasion and fraud, particularly because of the international reach
of the programmes. While minor differences in requirements
are likely to appear among IM agencies on a regional basis,
a high global standard of due diligence in citizenship and
residence investment programmes needs to be achieved.
Due diligence services firms need to come together with the
agents and operators to share best practices and set minimum
requirements. One such initiative is the cooperation between
the Investment Migration Council and due diligence firms to
continue educating agencies on best practice and encourage
them to cooperate so that no singular oversight diminishes the
industry’s reputation as a whole or threatens national security.
Overall, I’d say the industry is moving in the right
La
direction with regards to establishing common due
diligence standards, and in light of the joint advocacy efforts
and STF established by the IMC, the participating due
diligence providers will be collaborating and working together
to establish best practices for the industry. This collaboration
will require in-depth research, transparent sharing of due
diligence processes and coordinated identification of the
best practices for the industry as a whole. Successful sharing
and collaboration at both the programme- and due diligence
provider-levels will work to enhance the overall quality of
due diligence programmes, and will add to the ways in which
we can further protect the investment migration industry.
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From a due diligence
perspective, what else
can be done to improve
the industry’s reputational
image and risk profile?
The two most important factors are strong programme
La
governance, including consistent and transparent due
diligence practices, and a coordinated public relations approach.
It is the responsibility of the programmes and industry as
a whole to organise a coordinated and calculated strategy
aimed at educating the public, and improving the overall
reputation of the industry. This strategy should be built on
the idea of transparency between the industry and the global
community. Consistently communicating positive industry
headlines to the public through strong PR representation
will be crucial to shifting—albeit slowly— the general
understanding and perception of investment migration.
Transparency is key – not only with regards to due
KK
diligence scope and methodology, but also in how
applicants are evaluated both during the application process and
beyond. Some programmes can be more proactive in describing
their due diligence standards and in engaging experienced and
reliable due diligence providers able to meet those standards.
Programmes should also be transparent with regard to any
ongoing monitoring that is performed on approved applicants,
the technology employed to monitor, how frequently monitoring
occurs, and the kinds of red flags that elicit a response by the
programme. Beyond that, increased transparency around the
risk appetite of programmes, use of innovative technologies such
as artificial intelligence, and the methodology used to assess
risk and suitability of applicants, may help silence critics.
We agree transparency will always be an important part
AS
of the industry. Immigration investment schemes have
been accused of being a gateway for bad players and illicit funds,
often times due to occasional shortcomings of insufficient due
diligence processes. Since the programmes have gained more
momentum in the public eye and more readily available to
a much greater pool of potential applicants, agencies should
strive to be perceived as hallmarks of comprehensive due
diligence consumers, working together and with diligence
providers, to establish a better reputation of the industry as
a whole. The best due diligence standards should be applied
globally by all industry members, and increased transparency
of the sector would improve the industry’s image too.
Obtaining information on
private individuals and their
sources of wealth can be more
challenging depending on
the jurisdiction. How do your
particular research processes
deal with this situation?
Any complete and exhaustive due diligence exercise starts
AS
with robust understanding of information and nature of
sources available in any given jurisdiction, particularly countries
with limited online data availability. Comprehensive desktop
research should always be complemented by inquiries with
local registrars, litigation and regulatory bodies to eliminate
any information gaps and provide a complete profile of the
applicant’s source of wealth. In less transparent jurisdictions,
where the access or objectivity of obtainable information
may be breached, the information collected through human
intelligence remains of critical importance. While comprehensive
industry enquiries will not equal the information obtained
through registrar checks, they often bring in great value in terms
of background information or fill in the gaps of the desktop
research process, providing a comprehensive background
check of the verification of the subject’s true net worth.
We approach source of wealth in a number of different
KK
ways to present the clearest overall picture to our client.
This includes attempting to verify declared information
concerning shareholdings, employment, real estate, and
other assets; obtaining information on the business activities
of affiliated companies; using AI to scour open sources and
subscription databases for information directly related to
wealth and income; and consulting human sources. Every
piece of an applicant’s wealth history is not always in the
public record, but through these various tools and techniques
we are able to triangulate a powerful wealth ‘story’ that can
be compared with the story presented by the applicant.
La
Generally, we examine a few key areas that provide insight
on an individual’s financial position and source of wealth.
While the process we follow and the specific sources of this type
of information change from jurisdiction to jurisdiction, and also
largely depend on the public availability of records, our in-country
intelligence resources are aware of local laws and sources, and
they follow the best methods for obtaining as much information
as is available to paint a picture of the applicant’s source of wealth.
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How do you expect the
due diligence practice
to develop in the years
ahead? What changes do
you anticipate in terms of
regulatory requirements,
strategies and techniques?
The landscape of international due diligence is
La
continually shifting and changing, as new technologies
are developed, sources of information come and go, and
regulatory requirements regarding data privacy change. The
most impactful of these variables to the due diligence process
is likely changing regulatory requirements, and we anticipate
that other countries will soon enact GDPR-like regulations,
resulting in the alteration or complete closure of certain
information sources. If this type of regulation does in fact
get enacted, the source information on which due diligence
relies is likely to change in many countries. What this means
to the due diligence process will vary from country to country,
and we will have to wait and see what the initial impacts
will be. In general, given the number of variables existing
in international due diligence, providers have learned to be
flexible, adaptable and creative, and despite of changing external
factors, programmes can count on providers to be aware of the
changes, to adapt in the best way possible, and to always have
the best interest of the investment migration industry at heart.
More players are now understanding what the external
AS
due diligence service provider role is and what part of the
process needs to be completed in-house. While the public domain
checks and human intelligence collection and analysis can be
outsourced to due diligence service providers, the documented
decision-making process remains a responsibility that cannot be
outsourced. More expertise will be applied internally among the
agencies operating investment migration programmes to cater
for this part of the due diligence process. Externally, the service
providers collecting background verification information will all
need to move towards a faster and more precise service, which
can be achieved with the technologically advanced research and
analysis tools. The increased transparency requirement combined
with the scrutiny of the public eye will lead to better due diligence
and documented decision-making processes globally, which in
turn will lead to stricter and more secure processes preventing the
abuse of the programmes and the improved perception of these.
This industry is such that there is change every day,
KK
either with regards to the availability of information, new
technologies, client expectations, or regulatory requirements.
We are constantly looking to new resources and tools to
mitigate against any future changes in terms of publiclyavailable
information. We will also continue to invest in and
adapt technology into our due diligence process to make
research more automated and efficient, which means having
more resources available to devote time to analyse and identify
risk. It is looking like the industry will move towards the
adoption of minimum due diligence standards; developing
efficiencies now will better position us to offer cost-effective
solutions to our clients to meet those requirements.
What would be your one
piece of advice to programme
operators and agents?
My advice would be to engage in very transparent
La
relationships with due diligence providers to
ensure the agreed-upon level of due diligence is being
met, and also to publicise their commitment to robust due
diligence programmes, in order to help alter the global
perception of investment migration. In light of the scrutiny
and challenges currently facing the industry, it is the
responsibility of all interested stakeholders to participate in
some capacity in the greater reputation-focused efforts.
KK
Ask due diligence providers questions. It is important
to understand their methodology, sources, technology,
and compliance — how they are going about confirming or
obtaining certain information — as well as the limitations.
We encourage the programmes with which we work to ask
us questions, and we are as transparent as possible when it
comes to the resources used, how we confirm information
in a compliant manner, and the limitations of what we can
confirm. When a programme is evaluating an applicant and
consulting a due diligence report, they should understand
exactly what steps a provider took to, for example, verify the
existence of a business, so that they can better quantify the risk.
Never underestimate the value of risk management.
AS
While the enhanced due diligence process may seem
difficult to implement initially, the stakes are extremely high
with threats to national and international security, the risk
of fraud and money laundering, damage to the reputation of
the programmes and the entire industry. Due diligence is the
key solution to ensuring programmes are safe and not abused
by criminals, and that they can be implemented or improved
easily because of the available expertise and the willingness to
share best practices and knowledge among industry actors.
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
CITIZENSHIP BY INVESTMENT:
The Real Drivers
Behind Applications
Civil unrest, visa-free travel and statelessness are just a few of the
reasons behind the recent uptake in applications for citizenship and
residency by investment (CRBI). S-RM analyst Sonia Spencer explains
the current environment around these sought-after programmes.
Source: Henley & Partners Passport Index
In recent months, the CRBI industry
has been the backdrop for controversy.
Bulgaria revoked the citizenship
of Russian telecoms millionaire Sergei
Adoniev who had been convicted of fraud
in the United States in the 1990s. In March,
the European Parliament voted to phase out
CRBI programmes.
As a due diligence provider for several CRBI
programmes globally, S-RM knows first-hand
that the recent CRBI headlines paint a skewed
picture. This is particularly true for applicants
from the Middle East, whose profiles, in fact,
closely mirror the wider global political, security
and economic trends in the region. The volume
of CRBI applications jumped significantly after
the 2011 Arab Spring, as citizens tried to escape
worsening security across the region. From major
Iraqi cities, applications now regularly come
from engineers and surgeons who are unable to
gain secure employment at home, after years of
conflict and instability. Similarly, middle-class
Syrians are drawn to CRBI options due to the
country’s civil war.
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While citizens of areas of major civil unrest,
not surprisingly, tend to be subject to restricted
international movement, business travellers and
expats from these regions choose to apply for
CRBI programmes in order to gain better employment
and education opportunities. A Syrian
surgeon living and working in Qatar is ineligible
for Qatari citizenship, which is strictly patrilineal,
transferred by blood through the male line.
However, travelling for business is difficult on
a Syrian passport, which grants visa free travel
to only 32 destinations; and obtaining a visa
can be difficult with many countries cautious
that Syrians will then claim refugee status. The
surgeon also cannot return to Syria to renew his
passport due to safety concerns. The stark differences
in opportunity afforded by different passports
is illustrated by the Henley Passport Index,
a ranking for free movement. In this ranking,
Iraq, Syria and Lebanon are placed in 104th, 103rd
and 97th place, respectively. This means that
Lebanese citizens, for example, can access only
44 out of 195 countries without a pre-arranged
visa. Of these, 14 are small island nations — including
Niue, the Pitcairn Islands and Tuvalu
— not known for their education or business
opportunities. A European or Commonwealth
affiliated CRBI programme is therefore highly
appealing.
Sonia Spencer
is an Analyst
at S-RM, a
global risk consultancy
that helps clients manage
regulatory, reputational
and operational risks. S-RM
provides background check
due diligence and training
support to citizenshipby-investment
and
investor-visa programmes
run by government
agencies worldwide.
Statelessness is another reason for CRBI applications.
When the UAE was founded in 1971,
those who couldn’t prove their presence at unification,
or lacked the necessary tribal affiliations
were not allowed to claim UAE citizenship. NGOs
have estimated the number of stateless individuals
in the UAE to be between 10,000 and 100,000
people — numbers which persist due to patrilineal
citizenship laws, assigning statelessness to
the children of stateless parents. With the necessary
financial backing, many are understandably
drawn to apply for CRBI programmes to escape
statelessness for themselves and their children.
Particularly for Middle East applicants, the
coverage of CRBI programmes by newspapers
and politicians requires more nuance. Criminals
do apply, as do controversial oligarchs. Stringent
due diligence investigations are essential to keep
out the minority of criminals and other fraudulent
applicants. But the very large majority of
applicants reviewed by S-RM are professionals
and business owners from countries such as Iraq,
Syria, Yemen and Lebanon. Most apply not as a
cover for illegal activity but because they want
better employment and education opportunities.
This is a far less headline-grabbing narrative. It is
also much more reflective of the motivations of
applicants from some of the world’s least secure
and most unstable countries.
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The Big Read
Disrupting
the Nation State
Children born today will grow up with a radically different
understanding of how governments should serve them, writes
Kaspar Korjus, the former head of Estonia’s e-Residency Programme.
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“As a
consequence,
governments like
ours in Estonia
are evolving fast
into borderless
digital nations in
order to better
serve and benefit
from the rise
of these new
world citizens.”
I’ve been thinking a lot about the future
recently. Partly because it was a requirement
for my job — as the former head of
Estonia’s e-Residency Programme — but
more importantly, it’s because my wife has
given birth to our first child. My wife and I grew
up during the collapse of the Soviet Union and
the rebirth of Estonia as a free country, followed
by the rapid reforms that led to it become the
world’s most advanced digital nation. However,
I firmly believe that our son is going to grow up
through even more interesting and transformative
times in the years ahead. Despite much of
the negativity in the news right now, the overall
trend appears to be positive for the opportunities
that await him and other children entering
our world right now. The internet and other advances
in digital technology are enabling more
people to live and work globally with greater
freedom, independent of any fixed location. As
a consequence, governments like ours in Estonia
are evolving fast into borderless digital nations in
order to better serve and benefit from the rise of
these new world citizens.
Back to the Future
It’s completely understandable if you are wary
of any attempt to predict the future though.
Most predictions are not usually very accurate.
Consider the movie Back to the Future 2, which
I’m looking forward to watching with my son
soon. It’s a prediction of 2015 that was made in
1989. In their vision of the future, all technology
has advanced to the next level — so cars can fly,
skateboards can hover, and clothes can talk — but
people’s lives are actually still stuck in the 1980s.
The problem is that we tend to focus on how
technology will advance, but not on how that
new technology will alter the way we live our lives
in more fundamental ways.
In one scene, a family is sitting round a
dinner table while the children are absorbed
with their devices, including one that looks like
Google Glass. So far, this is quite well predicted
— as people with more parenting experience
than me will know only too well. However, all of
the devices suddenly start ringing together, and
the daughter then looks up to say “dad, it’s for
you”. So the movie correctly predicted the proliferation
of (what seem to be) internet connected
devices, but couldn’t imagine the transformative
impact they would have. It’s obvious to us today
that there wouldn’t be a single home phone line
anymore because our communications are now
individualised. As if to reinforce my point, the
future Marty McFly then says he’ll take the call
next door, before trying to hide messages coming
through on the family’s ‘futuristic’ fax machines.
This demonstrates how we keep projecting our
existing ways of thinking onto our visions of
the future, and fail to see the most significant
changes before they happen.
So to predict the future, we need to think
less about advanced new technology, and more
about new ways of thinking, enabled by technology.
We must embrace the reality that concepts
we consider entirely normal now could rapidly
change — or disappear entirely.
I believe we haven’t fully appreciated how
the internet is about to change our world in other
ways too. Perhaps the most important industry
about to undergo digital disruption is governance.
Our concept of nations might seem permanent
to us now, but these are relatively new
concepts, and they are not immune to disruption
either. It is this change that I believe will have the
furthest reaching impact during my son’s lifetime.
The Evolution of Nations
For millions of years, humanity was restricted to
small groups of nomadic hunters and gatherers
until new innovations enabled us to farm in fixed
locations. As a consequence, human settlements
began to grow, and yet more innovations were
required — such as currencies — to govern these
communities and enable people to diversify into
different societal roles. Those settlements grew by
trading and interacting with each other, and then
even larger structures of governance emerged
to oversee this. The biggest reorganisation then
took place with the industrial revolution, which
further concentrated our communities in evergrowing
cities that could manufacture on a large
scale, to meet the demands of large populations.
From this, our nations were born.
This is where we are now — a very small
period in human history in which the world’s
population has been restrained by geographic
boundaries. A nation is assigned to us at birth,
and then it usually stays with us for life. This
random allocation of the world’s population determines
our life opportunities more than almost
any other single factor. That wouldn’t make sense
for any other aspect of our lives though.
Take Facebook groups, for example. There
are Facebook groups for almost every area of
interest in the world. But imagine if you were
assigned a Facebook group at birth, then had to
remain within that specific online community for
the rest of your life — unless you went through a
lengthy and expensive process to switch to a different
group. The abundance of Facebook groups
is undoubtedly a good thing, but they work
better when everyone has the freedom to choose
which ones they want to join and contribute to.
Personally, I wouldn’t want to be stuck in a flat
earth group!
In a similar way, different nations have different
values and opportunities too. It’s only relatively
recently that large numbers of people on
our planet have gained the power to travel, communicate
and trade across borders. I take this
freedom for granted now, but my parents could
only dream about these opportunities when they
were my age. Now I’m the one dreaming about
the even greater freedoms ahead of us if we can
choose nations as easily as Facebook groups.
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“The main
advantage
of being an
e-resident right
now is the ability
to start and run a
trusted locationindependent
EU
company with
minimal cost
and hassle. ”
Our nations are now undergoing a digital revolution,
which will radically reshape them once
again — this time into borderless online communities
with services that can be accessed anywhere
there is an internet connection. Consider
the fact that Estonia already offers almost every
public service online. As Estonian President
Kaljulaid recently pointed out, Estonia is the first
digital society with its own state, although plenty
more will follow.
That’s why we launched e-Residency, in order
to scale up our digital nation by offering our services
to even more ‘users’ around the world. The
main advantage of being an e-resident right now
is the ability to start and run a trusted locationindependent
EU company with minimal cost
and hassle. So we are essentially exporting our
business environment to those who don’t have
the same advantages as us. However, this is only
the start. I recently asked what would happen
if Estonia offered ‘estcoins’ to e-residents for
example, and the Head of our Tax Board speculated
that e-residents could one day be offered
services, such as health cover and pensions, paid
for through personal taxation.
We now receive frequent visits from policymakers
in other states who are interested in
learning from the success of ‘e-Estonia’, and even
launching their own e-Residency programmes.
If all countries could attract members online as
easily as Facebook groups, then they can develop
unique selling points for their own e-services.
This digital development is good for everyone,
everywhere, because it will improve the quality of
governance globally if people can freely choose
which nation they want to access e-services from.
For a glimpse of that future, let me tell you about
my son’s experience.
Welcome to Ruufus’ World
Our child was given his ID number almost immediately
after he was born into our advanced
digital nation of Estonia. This forms the basis
for his secure digital identity, which he will use
throughout his life for authenticating himself
online, and accessing e-services from both the
public and the private sector. While we were
busy admiring our new child at the hospital, the
doctor was busy entering the first data about him
into our state’s Population Registry — such as his
name, sex, date of birth, and the fact that we are
his parents.
This information is really useful straight
away because various parts of government would
need it to better serve us as new parents, such as
by scheduling health checks, supporting with
child care and allocating our parental leave allowance.
This would generate added hassle for
new parents in most countries, but in Estonia
the information begins flowing automatically
between departments and agencies along our
secure, decentralised information network
known as the ‘X-road’. When we got home from
the hospital and finally took our eyes off our child
long enough to open up a computer, we logged in
using our own secure digital identities, and used
our permission as parents to add one more vital
bit of data — his name, Ruufus. This is his story so
far, but it’s going to get far more interesting.
By the age of 7, Ruufus will be starting school
to learn to read, write and code, like all other children.
That doesn’t mean we expect him to code
an app one day, any more than we expect him to
write a novel; but these are the basic skills that he
will need to understand the world around him.
Ruufus’ time at school will coincide with rapid
advances in the development of artificial intel-
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ligence and blockchain technology, and this will
be used by governments to make smarter decisions,
and deliver vastly more efficient public services.
Ruufus probably won’t have the option of
a career in the civil service ahead of him, but he
will instead prepare for new jobs that we can’t yet
begin to imagine. His schoolwork will be set and
completed digitally and — unfortunately from
his perspective now— that means we’ll always
know if he has homework to do.
Ruufus won’t just grow up in our digital
nation, but also in a truly digitalised world
where e-services are trusted by everyone, and
offline concepts like ink signatures, scanning
and posting will seem absurdly old fashioned. I
know this seems scary to many people around
the world now, but our experience in Estonia
has given us the opposite perspective. Storing
important personal data on paper isn’t just inefficient.
It’s also dangerous. In contrast, we can see
exactly who is accessing our digital data and then
challenge any use that we consider to be unjustified.
Blockchain-like technology is already being
used to protect our health records by providing
a public ledger, which can never be altered or
erased.
By the age of 15, Ruufus might want to start
earning his own money for the first time. He
won’t need to restrict his employment opportunities
to local businesses however, as it will
be just as easy to collaborate with people (and
instantly get paid by them) on the opposite side
of the planet. Cryptocurrencies currently show
no sign of disappearing, so it is more likely that
they will have evolved by then into viable decentralised
currencies in which he’ll want to
receive payments. That means governments will
have needed to figure out how to accept (and
tax them) at this point too. But perhaps governments
don’t have to ‘tax’ Ruufus by then anyway.
Governments can instead earn their main source
of income by selling their services globally in the
form of monthly subscriptions — much like how
Netflix currently delivers its service. We would
have to ensure that this is done in a way that
improves the welfare of everyone, such as those
in need of healthcare. By using smart contracts
based on blockchain technology for example,
Ruufus could start allocating his money directly
to those that need it with greater transparency
and efficiency, without the need for government
middlemen.
At age 18, Ruufus might want to go explore
the world for himself. Fortunately, he won’t have
to save up his money or do too much planning
first because so much of his life will already be
location-independent, including his source of
income. This is already the reality for an increasing
number of ‘digital nomads’ today, but Ruufus
will have the added opportunity to choose which
nations he wants to serve him globally. The rise
of Estonia as a leading digital nation came as a
surprise to many, so perhaps Ruufus will also
choose to be an e-resident of nations that seem
surprising to us now because developing nations
that embrace digital disruption could quickly
overtake developed countries that don’t.
Like me, I hope Ruufus will always be proud
to be Estonian; but everyone benefits from increased
engagement with other countries. He
could choose to run a company in Botswana to
access the emerging African business environment.
He could choose to pay personal taxes (or a
subscription) to South Korea to benefit from their
world leading health cover and social protection.
During his 20s, Ruufus might want to settle
in one location, or live across many. One very important
difference to most people today though
is that he can make this decision more freely
without the need to live next to his place of work
or study. Remote work is already acceptable in
many industries, and it will soon become the
norm. This will help alleviate some of the biggest
challenges of modern life today, such as the stress
and expense of living in crowded cities, as well as
the pressures caused by migration.
Consider the disruptive impact of elevators,
for example. Before they were introduced, the
upper floors were the least desirable because
they were the least accessible; but now it is the
opposite. In a similar way, Rufus might not feel
the need to migrate to London or Berlin in order
to find work. I do hope he has even more freedom
to travel than me; but he could also enjoy the
freedom to access opportunities from around the
world — while living in our beautiful Estonian
countryside, if he so wishes.
In 30 years time, Ruufus will have been building
up his pension through his subscriptions to
Japan, but he may also have enough money to
invest more heavily in a country of his choice.
Right now, ‘investing in a country’ just means investing
in property and businesses within a particularly
country. Ruufus, however, might have
the option to literally invest in a country.
After examining white papers from various
countries, Ruufus could choose to invest in crypto
tokens issued by the one with the best plan for
the future. Perhaps Ruufus enjoyed visiting the
tiny island nation of Fiji during his travels and
now wants to invest in their digital development.
In the digital era, there will be no reason why
nations can’t scale up and achieve vast growth
in the same way that great start-ups do today. If a
nation like Fiji can use the investment to deliver
services that solve people’s problems globally,
then the country could achieve astronomical
growth.
Ruufus has an enormous head start in this
emerging digital world, where far too many
people currently face financial exclusion because
the services they need are either unaffordable or
unavailable in their location. By the time he is
older than me though, I hope those advantages
that we enjoy as Estonians will be available to
everyone. n
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IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Interview Kaspar Korjus, Former Head of
Estonia’s e-Residency Programme
The Big Picture Idea:
Nation as
a Service
Estonia’s e-Residency Programme is partly the brainchild of
Kaspar Korjus, the former Head of the Programme. He talks about
the programme’s start-up phase, major achievements and its future
potential. He says that as more countries build digital services of
their own, the idea of nation-as-a-service comes into sharper focus.
Can you give us a brief introduction
to Estonia’s e-Residency Programme
and tell us how it came about?
Estonia is a small country, with a population of
just 1.3 million. After the collapse of the Soviet
Union, when we regained our independence
in 1991, we were faced with the challenge of
scaling up our nation. We looked to technology
to improve our competitiveness in the absence
of any other meaningful natural resources. We
modernised and digitised many of the old analogue
systems, and carved out a niche as a hub
for tech start-ups. E-Government was also high
on the agenda. A digital ID card was introduced
that gives access to a wide range of e-services, including
making payments, accessing full health
records and online voting.
We then developed the idea to take this
concept a step further by giving people from
across the world access to our public and
private online facilities – and the e-Residency
Programme was born. E-residents are allowed to
open a business in Estonia and run it remotely,
while accessing many of our e-services. The idea
was to make life and business easier for freelancers,
digital nomads, business owners, and entrepreneurs,
working in a diverse range of sectors,
including IT, financial services and travel.
How was the Programme received initially?
We launched the e-Residency Programme in
2014, and at first, it wasn’t an easy sell. There was a
lot of scepticism in Estonia about who would actually
want to be an e-resident of our country. We
had to change 10 plus laws, which means politicians
and policy-makers questioned the concept.
We were also not sure if the Programme would
be a success, but we realised we were onto some-
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After gaining
a BSc and MSc
in e-Business
at Lancaster University,
Kaspar returned to
Estonia. He started
working on e-Residency
in 2014, when it was little
more than an idea in the
minds of a few people.
He spearheaded the
Programme and served as
its Managing Director until
the end of 2018. Today, he
advises governments on
e-services and is available
for keynote speeches.
thing when we attracted the attention of world
business and opinion leaders, and got the international
media to talk about e-Residency. Among
the first foreign e-residents were Edward Lucas,
Senior Editor of the Economist, and American
venture capitalist Tim Draper. These early adopters
bought into the concept more than anything
else because initially we did not have many services
on offer. It was only when the programme
took off that we started developing a suite of services
for Estonia’s e-residents.
Since the launch of the programme, our e-
resident population has grown to approximately
50,000 people in 160 countries. The majority
of them are from Finland, Russia, Ukraine,
Germany, the USA, UK, Japan, China, and India;
but the programme is increasing Estonia’s reputation
all over the world. From a political point of
view, this fits our national security policy, which
is based on building international alliances and
raising global awareness of our country.
What services can e-residents access and
what types of people are making use of it?
E-Residency cannot be compared to any other
residency product or citizenship. E-Residency
does not confer citizenship, tax residency, residence,
or right of entry into Estonia or to the
European Union. It is not a visa or residence
permit. Once approved as e-residents, foreigners
receive a digital ID, which gives them digital
access to services such, as a company creation
and banking and payments, while they can digitally
sign documents and contracts. E-Residents
can also access Estonian government services for
businesses. The Programme has been designed
with location-independent entrepreneurs in
mind, but it also proved particularly attractive
to people who are financially excluded or disadvantaged.
For example, we saw a surge in interest
from Turkey when PayPal stopped operating
there. Many don’t realise that there is a huge
group of people who cannot sell their products
and services on the digital marketplace because
they cannot access certain apps and financial services.
What economic impact does the
Programme have on Estonia?
Not all e-residents contribute taxes to Estonia, but
when they do it is because they set up a company
that is legitimately tax resident in Estonia. Many
e-residents also generate economic activity when
they use our business environment, and conduct
business with other Estonian companies and
service providers. Estonia has never been a tax
haven, but rather an administrative haven.
E-residents have created some 6,600 companies
in Estonia and, according to an economic
impact analysis by Deloitte conducted in 2017,
have contributed €14.4 million to the Estonian
state and economy. This figure is projected to
reach almost €2 billion by 2025, based on the forecasted
growth of the e-resident population.
How do you see the concept evolving further?
Last year, a roadmap for e-Residency 2.0 was
launched, which mainly aims to improve the
current services, make the system more efficient,
and help more Estonian companies and
industries serve e-residents. One idea is the creation
of an Estonian school-franchising model
that would create a global network of Estonian
schools, which offer a certain standard of education
for e-residents’ children. This might be
particularly attractive to digital nomads. Another
idea is to collect social tax from digital nomads
to provide health insurance cover, and access to
a pension fund.
We have also looked at the concept of a digital
nomad visa, which would give digital nomads
the ability to stay in Estonia for one year but also
give access to a 90-day Schengen Visa to enable
them to live and work in the EU. However, the introduction
of such a visa is still being discussed,
and it remains to be seen whether it will become
a reality.
In my opinion, e-Residency is just the first
step towards a model that can be described as
‘nation-as-a-service’, whereby nations offer different
services and citizens can choose what
services they would like to use from a particular
nation. People are becoming more global
and borderless, but there are no nations that are
global. This means that there is a huge demand
for new services and solutions, and governments
could become service providers like any other
company. n
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INVESTMENT MIGRATION YEARBOOK 2019/2020
Simon Anholt, Adviser and Publisher of the Good Country Index
Make a
REAL
Global Impact
Simon Anholt says
the investment
migration industry
needs to become a
force for good if it
wants to win over the
industry’s critics.
Can you tell us a bit about your research
into global perceptions of nations? Can
countries influence their image?
No, they cannot, at least not through public relations
and marketing campaigns. However,
many governments believe they can, and this
may be partly my fault. I came up with the term
‘nation brand’ in 1996. My original observation
was that the reputations of countries behave like
the brand images of companies and products.
Unfortunately the term gradually morphed into
“nation branding”. Nation branding sounds as
if the image of a country can be manipulated or
influenced, but countries are definitely not in
control of their images. I have been compiling the
Nation Brands Index, a huge annual poll of international
perceptions of countries, since 2005, and
it shows that there is absolutely no correlation
between what countries say about themselves
and how people perceive them. Yet the notion
that a country can simply advertise its way into a
better reputation has proved to be a resilient one.
So what do countries and governments
wanting a better image need to do?
Countries are judged by what they do, not by
what they say. While it is possible and necessary
to market certain economic sectors and products,
such as a tourism destination, an investment opportunity
or the export of goods, governments
cannot influence the overall image of their
country simply by launching a PR or marketing
campaign. These campaigns are nothing more
than government propaganda, which people
rightly ignore. Countries can only improve their
image by changing the way they behave. If a
country wants to be admired, it must be admirable,
and it must make itself relevant to people
from other nations. This means that the country
must participate usefully, productively, and imaginatively,
in the global conversations on the topics
that matter to people elsewhere and everywhere.
The list of those topics is a long one, and it includes,
amongst others, climate change, poverty,
migration, economic stability and human rights.
There is plenty of research that shows that this
investment can pay off: for example, a 1% improvement
in a country’s image can lead to a 38%
increase in foreign direct investment.
Governments that have introduced RCBI
programmes have come under increased
scrutiny in recent years, with international
organisations, policy-makers and the
public often being critical of its concepts.
What’s your view of the industry?
In my opinion, selling residence and citizenship
should be viewed as an economic activity just like
any other. It is a new form of foreign investment
for countries and a useful additional source of
foreign income. From an economic point of view,
it can either be justified or not justified. If it generates
more revenue for the country than it costs,
economic objections against it cannot be valid.
In fact, most objections are not based on economic
grounds, but rather have a socio-cultural
subtext. For many people, belonging to a nation is
a sacred thing, which should not be shared with
people who weren’t born into that nation or who
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haven’t been through a certain amount of trouble
to be part of it. My personal view of this attitude
is that it demonstrates one of the worst sides of
human nature, a flat refusal to share one’s good
fortune with those less fortunate than oneself.
The better side of human nature would be that if
you are lucky enough to live in a rich country, you
should be happy to share your good fortune with
others if it doesn’t materially diminish your own
prosperity or opportunities.
On an EU level, we often hear the argument
that passport and visa programmes offered
by one member state affect the entire
European Union and that these programmes
are effectively exploiting an EU right.
This argument also doesn’t make any sense at all.
Let’s look at another example. If a company from
one member state builds a factory in another
member state and starts polluting the air in that
member state, they are exploiting EU rights in
the same way, aren’t they? It might sound as if I
am defending the investment migration industry.
I have no interest in doing so; however, to me
it seems ethically inconsistent that RCBI programmes
are viewed differently than any other
activities that countries engage in order to attract
capital. The entire debate shows that humanity
has yet to learn to transfer its loyalty to an entity
larger than the nation state. In my opinion, this
has to happen soon. We live in an age where
we are facing gigantic global challenges, from
climate change to migration to terrorism. They
are all international challenges, and need to be
tackled internationally.
Can you explain this a bit more?
Today our problems are not national; they are
global, yet only a minority of people feel loyalty and
commitment to something bigger than their own
country. My research has shown that only about
10% of the world’s population is what you might
call naturally cosmopolitan. Those are people that
distinctively feel they are members of the human
race first, and citizens of their own nation second.
The majority of people are still stuck on the idea
of the nation state, which was invented in 1648. We
went through an enormous amount of trouble to
fix people’s loyalty to the nation state. Wars were
fought over the nation state; active brainwashing
took place to win people’s loyalty for something
that was artificially created. To be clear, I am not
talking about the love that we feel towards the
land that we grew up in, such as a region with its
distinctive landscapes and its people. The love for
one’s country can be profound and meaningful,
and is entirely different from loving your nation,
which is more like saying you love your country’s
government or its army.
The European Union is the noblest experiment
in the history of humanity: it was the first
time in history that a large number of countries
had the wisdom and maturity to give away
Simon
Anholt is an
independent
adviser to various Heads
of State and Heads of
Government, and during
the last 20 years has
advised 55 countries on
strategies for enhanced
economic, political and
cultural engagement
with other countries. He
devised the concept of
nation brand in 1996,
and is the founder and
publisher of the Anholt-
IPSOS Nation Brands
Index, a large annual
opinion poll that measures
international perceptions
of countries. He also
launched the Good Country
Index in 2014: the first
ever study of what each
country contributes to the
common good of humanity,
and what it takes away,
relative to its size. Simon
Anholt has served as Vice-
Chair of the UK Foreign
Office’s Public Diplomacy
Board and has a Master’s
Degree from the University
of Oxford. He holds an
Honorary Professorship
in Political Science and
is the author of six books
including two best-sellers.
His TED talk launching
the first edition of the
Good Country Index has
been viewed more than
5.5 million times and was
ranked the fifth ‘most
inspiring’ TED talk ever.
a tiny part of their sovereignty in return for the
common good. This is one of the reasons why I
am so bereaved at the UK’s decision to leave the
EU. But even the EU is basically a self-interest
society: it is still defending its members against
competition from the rest of the world. It still
looks inwards. Of course, 26 countries looking
collectively at their own interests is a whole lot
better than 26 countries looking separately at
their own interests; but if we continue like this,
we will be defeated by climate change, migration
and terrorism, and other global challenges.
The only way we are going to tackle them is by
working collectively, and the investment migration
industry might be able to play a role in this.
How would you see that happening?
I think it would be a fascinating idea if one could
convert the idea of investment migration into
something internationally useful, which doesn’t
only benefit the country that is running the programme
but also creates broader benefits. The
industry needs a global approach, and much like
countries, if it wants to be internationally recognised
as a force for good, it needs to become a
force for good. As a start, countries could agree
to accept a certain number of economic migrants
and refugees to match the number of investment
migrants they are allowing in their country.
But the real opportunity is much bigger than
this. Very wealthy people are increasingly philanthropic.
I reckon that one could have a very
fruitful summit with all those investors who are
interested in better residence or citizenship arrangements
for themselves, as well as in supporting
good causes. They could be brought together
with countries operating these programmes, as
well as with NGOs and representatives of the
international community. We know that investment
migration results in a substantial flow of
capital, but instead of directing this capital flow
from one country to another, we could see how
that revenue stream could be best distributed to
solve some of the most pressing global problems,
while delivering the payback to the investors that
they require.
What do you think of the idea
of nation as a service?
It is great concept because it is attempting to
separate out and neutralise the crazy emotions
that people feel about nationality, and regards
the state as what it really is: a set of services. It is
just being cool-headed about it, and that’s what
we need in our current age of global challenges.
I think the task for the future is to find a narrative
that brings nationalists and internationalists
together. The idea that nationalists and internationalist
have to be enemies has emerged in
the last 10 years and appears to have been very
broadly accepted, which is odd because you
couldn’t imagine a better case for cooperation,
given the challenges that we are facing. n
93

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Khalid Koser, Executive Director of the Global Community Engagement and Resilience Fund
The Big Migration Debate: Finding the Missing Link
The migration debate is complex and emotional. Investment migration
only accounts for a small part of worldwide migration, yet the industry
has the potential to help shape a more productive discussion.
Few issues excite controversy like migration, and when global
leaders in Europe, the US and other parts of the world,
discuss migration, they usually talk about threats rather than
opportunities. “But the reality is most countries around the world
need migrants to fill vital gaps in their workforce and to keep their
economies going”, says Khalid Koser, Executive Director of the
Global Community Engagement and Resilience Fund (GCERF).
While refugees might be the face of migration in the media and
in public perception, the large majority of the world’s 258 million
migrants have moved across borders voluntarily. What worries
Koser most is that “we are quickly losing the
space for a sensible, honest and informed debate
about migration. There is a polarisation of views,
between those who champion migrants and see
all refugees as heroes, and those at the other end
who believe all migrants, and especially wealthy
migrants, are criminals. Of course, the truth is
somewhere in between, and one of the key challenges
is to overcome these generalisations”.
Most voluntary migrants are working-age
adults and can actively contribute to economic
growth in their destination countries. For businesses,
their different and complementary skills
can positively influence innovation and enhance
productivity. Research even shows that many
times immigrants actually work harder than
their native hosts. Obviously, Koser says, it would
be hard to argue on a purely economic case for
countries to take in migrants - there always will
and has to be a humanitarian element. “But I
think we need to cross the red line that has been
somewhat drawn between humanitarian and
economic arguments.”
Migration of the Highly Skilled
He stresses that there is a compelling case for
countries to counter intolerance towards migrants,
especially when it comes to attracting
highly skilled migrants. “For them it is not all
about salaries, they are mostly after higher
living and working standards, including good
healthcare, educational opportunities for their
children and, most importantly, a safe living environment.”
According to Koser, countries that
cannot get on top of xenophobia will simply lose
out on the global competition for talent, because
the people that they want to attract will simply
not want to live in an environment that is hostile
towards foreigners of all shades.
So what can governments do to bring their
people along? Koser says the issue for politicians
is that “the topic of migration is almost toxic.
The downsides for them are greater than the
upsides”. He sees the reason for this in the fact
that migration certainly costs in the short term,
Dr Khalid
Koser is
Executive
Director of the Global
Community Engagement
and Resilience Fund. An
academic by training,
Khalid is Professor of
Conflict, Peace and
Security at the University
of Maastricht, as well as
non-resident fellow at
the Brookings Institution,
Chatham House, and the
Lowy Institute. As a global
advocate for migrants and
refugees, Khalid chairs the
World Economic Forum
Global Future Council
on Migration, edits the
Journal of Refugee Studies,
and was appointed MBE for
services to asylum seekers
and refugees. He chairs
the Board of Trustees
for the sustainable
development charity
Raleigh International.
especially when countries have to deal with a large inflow of migrants
due to wars and economic crises. However, there is ample
academic evidence that in the long term, migration, and the successful
integration of migrants into the job market, pays off. “The
trouble is that politicians think in four to five year cycles, and there
are easier ways to win votes than making a credible case for the
long-term benefits of migration.”
According to Koser, it would be beneficial if corporates, business
leaders and even immigrant investors openly champion the
debate. “If they speak out and showcase why migration and a
diverse workforce was beneficial for their businesses
and the economy, I am sure people would
listen.” The discussion also needs to move away
from philosophies, such as multiculturalism and
assimilation, and focus on the more practical
aspects such as giving migrants the chance to get
a job, which then translates into wider opportunities.
This, he says, is particularly true for the
22.5 million refugees, who often spent many years
in refugee camps where they are being cared for
in terms of accommodation and food, but “what
they really want is work”. Koser sees great opportunity
for companies and institutions to utilise
refugee skills to a much wider extent. This could
include anything from manufactures tasking
refugees with basic assembly jobs, to providing
them with access to IT equipment and technology.
This would allow them to carry out data processing,
translation and online education jobs,
and perhaps even writing code for companies
around the world. “There is no end to what could
be done, and this would also give refugees access
to up-skilling initiatives and the opportunity for
a better life.”
Making a Positive Impact
Besides, more research is required about ways to
influence politics and perceptions that are clearly
misinformed. “My advice would be to look to
other areas of public policy and countries where
confidence plummeted after a crisis. Take Japan,
which managed to re-build confidence in its
economy after the nuclear disaster.” Then there
are other ways to bridge the gap between humanitarian
and economic arguments, between
burden and benefit. “Investment migration just
accounts for a small percentage of overall migration,
but it generates significant funds, which in
part could be used to address some of the causes
of migration such as famine, poverty and climate
change.” It is unrealistic to believe that migration
can be stopped completely, according to Koser.
Therefore, it is important that countries find
ways to cope with it, and investment migration
can become part of the solution. n
94

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
John Marcarian, Founder of Expatland Global Network
Expatland:
The World’s Most Influential Country
Expats may account for just 3% of the world’s population, but they are
changing the world and reshaping societies — and their dominance
is growing as expats are expected to account for a larger share of
the world’s population in the decades ahead, says John Marcarian.
If Expatland were a country, it would have
a population of 244 million people, which
would make it the fifth largest in the world.
Expatland is growing at a fast rate of 300,000
people a month, and includes a mixture of nationalities:
nine million Americans, three million
Germans, and more than one million Aussies, to
name a few. This virtual country is hosting the
most productive citizens, which, according to John
Marcarian “are the 3% changing the world”.
Expatland arose from John’s personal expat
journey — a long-time expat himself, Marcarian
understands that moving to a new country isn’t
something that comes without challenges. With a
mission to help facilitate a smooth transition into
the new life of an expat, he wrote the Expatland
book in 2015, with information and practical
advice on taxes, education, cultural differences,
retirement, and local laws.
95

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
Supporting Expats
In 2018, Marcarian launched the Expatland
Global Network, an organisation that provides a
one-stop-shop for all the services an expat needs
for a smooth integration, to support people who
are looking to join the expatriate community in
various cities and regions across the globe.
The Expatland Global Network is made up of
Expatland teams. E-teams consist of professionals
who provide support, services and products, which
fall into four categories: tax and finance; health
and wellness; logistics; and lifestyle. Operating at
a city level, each E-team operates under the leadership
of a group leader, responsible for ensuring
that a client has a good experience as he or she
moves through the team, which delivers all the
essential local knowledge relevant to a specific
location. “Expatland is a free of charge service for
the expat — our clients don’t even need to sign up
to become a member, we simply introduce them
to service providers, which then charge the usual
fees,” Marcarian explains.
“We launched Expatland less than a year ago
and it has already spread to many global locations,
with more than 16 E-Teams in Singapore,
Sydney, Hong Kong, Los Angeles, Budapest,
Frankfurt and London, amongst others, with
a goal to have 50 E-Teams by the end of 2020,”
Marcarian says.
There are two types of Exapatland members:
a global executive and a global founder establishing
a company or moving a business across
borders. “Our customer base is diverse, with
clients coming from Europe, the Asia-Pacific,
Africa and the US,” Marcarian says. “Potentially,
I believe there can and should be a collaboration
between Expatland and the RCBI industry,
given that moving abroad for any reason necessitates
the interaction between the expat and the
local E-Team. I believe there would be demand,
though we have not yet developed the channel.”
John
Marcarian is
a chartered
accountant, international
tax advisor, and the
founder of both CST Tax
Advisors and Expatland.
At CST, he provides tax
consultancy to clients in
multi-markets, including
global expatriates and
businesses moving across
borders. Based on his
knowledge of common
expat issues and his own
experience as a widely
travelled Aussie expat,
John wrote the Expatland
guide book in 2015.
Global Dominance
Expatriates contribute significantly to the countries
they move to — the skills they bring, the taxes
they pay, and the jobs they fill; these positive contributions
to host economies cannot be ignored,
and according to Marcarian, global growth rests
on the shoulders of expats. “Expatriates bring
with them a unique set of skills, international experience,
and contacts, diversifying the local talent
pool. In fact, our research reveals that immigrants
add to the GDP of the country they are moving to
regardless of their socio-economic status. In addition
to contributing to economic output, expatriates
have a strong impact on society as a whole,”
he says. “Take Atlanta for example, there are
50,000 Germans living in the city. They brought
their knowledge, skills and ideas, which means
they affect local culture, food, and even the local
way of doing things.”
Future Outlook
“Expatland is destined to grow with the potential
to become the third largest country in the world,”
says John Marcarian. The latest revised projection
is that the number of international migrants
will exceed 405 million by 2050, or nearly 7% of
the global population — and Marcarian says he
will not be surprised, as it seems that a recordbreaking
number of people want to be expats:
“Research from Gallup World Poll reveals that
750 million people around the world would move
to another country if they could.”
E-Teams have already been established in
some of the top expat destinations, with many
more cities launching in 2019. “Our network is
growing quickly, and we are actively looking
for new destinations to expand to, typically the
top expat cities,” Marcarian says. So where do
expats want to live? The answer is all over the
world, but the richest metropolitan areas tend to
attract a larger number of expats. “The majority
of potential migrants would like to move to the
US, followed by London and other bigger cities.
However, a number of new locations emerged
recently, including Austin, Abu Dhabi, and Doha
— wherever you have a strong economy, you see
expats being attracted.”
“Overall, the rise of China has had a major
impact on our members and the cities in which
we are planning to expand our network. The Belt
and Road Initiative spans all the way from China
to Europe by land and by sea routes; it also includes
countries like Sri Lanka and Kenya. It is
bringing new investment and massive infrastructure
projects that will transform the key locations,
making them the most cosmopolitan and
multicultural cities in the world,” Marcarian says.
“However, if we look at the biggest market for
us to develop, it’s definitely Africa. Africa holds
much promise — it has arguably become the
world’s most attractive investment destination,
and African economies offer tremendous opportunities.
We have just developed our first E-Team
in Kenya, and potentially, there are 55 countries
to look into in terms of company expansion.” n
96

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
events
CALENDAR OF UPCOMING
2019-2020
97

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
EVENTS
2019-2020
The Investment
Migration Forum
DATE & VENUE
03-06 June 2019 - Geneva
The Investment
Migration Forum
DATE & VENUE
13-14 June 2019 - Beirut
ORGANISED BY
The Investment Migration Council
ORGANISED BY
Promoteam
WEBSITE
investmentmigrationforum.org/
WEBSITE
promoteam.me/rendez-vouz/
cbipf-beirut-2019/
Global Investment
Immigration
Summit 2019
DATE & VENUE
21 June 2019 - Johannesburg
ORGANISED BY
BLS Global
WEBSITE
events.citizenshipinvestment.org
2019 AILA/GMS
Annual Global
Immigration Forum
DATE & VENUE
16-18 June 2019 - Orlando
ORGANISED BY
The American Immigration
Lawyers Association (AILA)
WEBSITE
agora.aila.org/Conference/Detail/1554
Caribbean
Investment
Summit 2019
DATE & VENUE
19-22 June 2019 - St. Kitts
ORGANISED BY
Citizenship by Investment
Programmes Association (CIPA)
WEBSITE
cis2019.events
IIA Autumn
Conference
DATE & VENUE
20 September 2019 - London
ORGANISED BY
IIA
WEBSITE
iiaconference.com
Global Investment
Immigration
Summit 2019
DATE & VENUE
21 September 2019 - India
ORGANISED BY
BLS Global
WEBSITE
events.citizenshipinvestment.org
Residency &
Citizenship Conclave
DATE & VENUE
27-28 September 2019 - New Delhi
ORGANISED BY
GMN Media
WEBSITE
www.citizenshipconclave.com
98

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
The Global
Citizen Forum
DATE & VENUE
10-12 October 2019 - Yerevan
ORGANISED BY
Arton Capital
WEBSITE
www.globalcitizenforum.org/yerevan-2019/
Residency &
Citizenship Expo
@ IREIS 2019
DATE & VENUE
31 October - 02 November 2019 - Abu Dhabi
ORGANISED BY
Dome Exhibitions
WEBSITE
www.citizenshipexpo.com
China Offshore
Summit
DATE & VENUE
12-14 November 2019 - Shanghai
ORGANISED BY
MX Media Group
WEBSITE
shanghai.chinaoffshoresummit.com.hk/en/
13th Global
Citizenship
Conference
DATE & VENUE
11-13 November 2019 - London
ORGANISED BY
Henley & Partners
WEBSITE
www.henleyglobal.com/gcc2019-overview/
Investment
Immigration
Summit Mumbai
DATE & VENUE
February 2020 - Mumbai
ORGANISED BY
Beacon Events
WEBSITE
investmentimmigrationsummit.com/mumbai/
IIUSA EB-5 Advocacy
Conference
DATE & VENUE
March 2020 - Washington
ORGANISED BY
IIUSA
WEBSITE
iiusa.org/dc2019/
The Investment
Migration Forum
DATE & VENUE
01-04 June 2020
ORGANISED BY
The Investment Migration Council
WEBSITE
investmentmigrationforum.org/
99

Malta: An Investment Location for the Future
Considered one of Europe’s best-kept secrets, many are still amazed to discover
the plethora of benefits associated with investing and living in Malta.
Situated just off the European coast beneath Sicily, the small island of
Malta has established itself as a leading financial center, offering foreign
investors stability, security, and innovation. The Mediterranean island has
experienced above-average economic growth in recent years, as investors
and travelers alike tap into the island nation’s enormous potential. During
the first half of 2018, Malta had the fastest growing economy in the
Eurozone, boasting an economic growth rate of more than 5%.
Considering this exponential growth and Malta’s incredible lifestyle
benefits, an increasing number of people are looking to make greater
investments in the island. Malta’s acclaimed citizenship-by-investment
program offers investors the opportunity to obtain citizenship in exchange
for a substantial economic contribution to the country and forge genuine
links with the island.
Growth of real gross domestic product (GDP) in EU
member states in the 3 rd quarter 2018 (compared to
the same quarter of the previous year)
Malta
Romania
Latvia
Poland
Slovenia
Hungary
Greece
Ireland
Cyprus
Denmark
Bulgaria
United Kingdom
1.0%
0.9%
0.8%
0.7%
0.7%
0.6%
1.3%
1.3%
1.7%
1.7%
1.9%
3.6%
0.0% 0.5% 1.0% 1.5% 2.0% 2.5% 3.0% 3.5% 4.0%
Citizenship-by-investment
gold standard
Developed by the Government of Malta in partnership with
Henley & Partners, the Malta Individual Investor Program (MIIP) is
considered the most successful and credible citizenship program in
the world. The minimum capital contribution for a single applicant is
approximately EUR 1 million, which consists of a donation to the country’s
development fund, a real estate purchase or rental, and an investment in
government-approved financial instruments.
The MIIP has set the industry benchmark in terms of application processing,
applying the world’s strictest due diligence standards and vetting of
applicants. Each applicant and their included family members have to
pass a strict four-tier due diligence process to ensure that all individuals
entering Malta through citizenship-by-investment have no association with
any criminal activities or form of corruption.
Location, location, location
Malta is situated in the very heart of the Mediterranean ocean yet close
to the European mainland, providing a perfect bridge between a secluded
lifestyle and international access. Residents of Malta can enjoy the island
lifestyle, surrounded by spectacular natural beauty, while still being within
close reach of top business destinations.
The Maltese passport provides visa-free or visa-on-arrival access to over
180 destinations worldwide, including Australia, the USA, the UAE, Hong
Kong, Japan, and all the countries in Europe’s Schengen Area. As a full
member of the EU, the country also enables settlement in any other EU
member state.
With its strategic location, this small island nation has also established itself
as an important shipping hub, granting easy access to Eastern and Western
Mediterranean ports. Malta also boasts excellent flight connections and
has a number of direct daily flights to Europe and North Africa. London
is a short three-hour flight away, while the business hub of Dubai can be
accessed in five hours.
Source: https://www.statista.com/statistics/263008/gdp-growth-in-eucountries-compared-to-same-quarter-previous-year/

Mediterranean lifestyle
Malta is often referred to as an open-air museum and has a history that
dates to 5,000 BCE — the island’s skyline is dominated by 16 th -century
architecture. The country is home to three UNESCO World Heritage
Sites. Among them, its capital Valletta donned the illustrious crown of
‘European Capital of Culture’ in 2018.
Along with its rich history, Malta offers 300 days of sunshine, sea-sculpted
shores, and azure waters. The island’s lifestyle is modern and welcoming,
and the influences of its location are evident in local food. Dishes feature
a mix of Mediterranean cuisine with strong influences from Italy, created
from fresh ingredients from the local land and sea.
A secure haven for your family
An EU member since 2004, Malta provides its residents with the same
benefits afforded to European citizens, such as access to the world’s best
educational and medical facilities and security under the protection of the
region’s strong legal system.
Malta is considered one of the safest countries in terms of natural disasters
and crime. According to the 2018 edition of the World Risk Report, the
island nation ranks as the second safest in the world behind Qatar on the
172-nation ranking of disaster risks. The crime rate on the island is also
almost non-existent.
The country has earned a reputation for being highly family-oriented —
many of its public places and establishments are welcoming of and cater
for children. Malta has excellent local and international public and private
education, with all schools teaching in English. The standard of health care
in Malta is among the highest in the world, with a wide network of clinics
and the renowned private Saint James Hospital servicing residents.
Thriving real estate industry
Malta’s real estate market has shown outstanding resilience during the
2008 global recession and continues to grow in sales. The purchase of real
estate on the island archipelago is at an all-time high. During the first half
of 2018, property prices in Malta increased more than any other country
in the world.
The increasing number of buyers looking to purchase real estate in Malta
is driven by various factors, including the opening of branches of some of
the world’s most influential financial institutions, online businesses, and
reinsurance companies. Malta offers an abundance of property options,
including apartments, maisonettes, ‘houses of character’, palazzos, villas,
and bungalows.
An attractive place for business
A flexible and highly trained multilingual workforce is one of Malta’s
main assets and helps to ensure the country’s competitive edge through
high-quality production at costs that are highly competitive in relation to
the rest of Europe. Investors operating in Malta also benefit from easy
access to European and Middle Eastern markets and the EU’s free trade
agreements. Further bolstering Malta’s business appeal is its membership
to the World Bank, the International Monetary Fund, the World Trade
Organization, and the International Labour Organization.
The Maltese government understands that a healthy private sector and
an overall pro-investment climate contributes to the country’s sustainable
development. To this extent, Malta Enterprise was created with an
objective to support private businesses operating in the country, and its
services are priceless to new investors entering the market. It provides
assistance in data analysis, helps with identifying potential partners and
clients, and guides investors through the legal system.
Future-facing investment destination
In 2018, Malta became the first country in the world to establish a
regulatory framework for blockchain technology. The island nation has
also long been a front runner in the iGaming and fintech industries.
The country’s online gaming industry has shown impressive growth over
the past few years, supporting local employment and bolstering revenue for
the island. The sector accounts for a substantial part of Malta’s economy,
contributing over 12% of the country’s overall GDP.
The global leader in
investment migration
Henley & Partners is the global leader in residence and citizenship planning.
Our highly qualified professionals work together as one team in over 30
offices worldwide. With a local office in Malta, our experienced global
team is best-placed to guide you through your citizenship-by-investment
journey.
The firm also runs a leading government advisory practice that has
raised more than USD 8 billion in foreign direct investment. Trusted by
governments, the firm has been involved in strategic consulting and in the
design, setup, and operation of the world’s most successful residence and
citizenship programs.
For more information on acquiring alternative residence or citizenship, call
+356 2138 7400, e-mail malta@henleyglobal.com, or visit henleyglobal.com

IM INVESTMENT MIGRATION YEARBOOK 2019/2020
WHO’S
WHO
IM Yearbook connects you
with the industry’s major
firms, executives and
professional advisers.
102

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
Advisory & Legal
ANZ Migrate...................................................................................................................................104
BEYOND Residence & Citizenship.........................................................................................104
Deloitte.............................................................................................................................................. 105
Deloitte LLP..................................................................................................................................... 105
Energopiisi S.A...............................................................................................................................106
Fidesco Trust Corporation.........................................................................................................106
Fragomen LLP................................................................................................................................ 107
GANADO Advocates.................................................................................................................... 107
Global Information Consulting Group (GICG)................................................................... 107
HAZELALLEYNE Law Office................................................................................................... 107
Henley & Partners.........................................................................................................................108
Integritas Group.............................................................................................................................108
Klasko Immigration Law Partners...........................................................................................108
L Papaphilippou & Co LLC - Advocates & Legal Consultants........................................109
La Vida..............................................................................................................................................109
PassPro Immigration Services...................................................................................................109
Rosemont International...............................................................................................................110
Rostova Westerman Law Group, PA.........................................................................................110
RSM Malta........................................................................................................................................110
Vanuatu Investment Migration Bureau....................................................................................111
Visas Consulting Group................................................................................................................111
Industry & Professional Association
Investment Migration Council..................................................................................................108
KYC & Due Diligence
BDO USA, LLC...............................................................................................................................104
Exiger.................................................................................................................................................106
Globe Detective Agency (P) Limited....................................................................................... 107
Refinitiv..............................................................................................................................................110
S-RM Intelligence and Risk Consulting Limited.................................................................110
Sterling Diligence............................................................................................................................111
Logistics Services
DHL....................................................................................................................................................106
Marketing & Promotion
CiviQuo Limited............................................................................................................................ 105
Media
CountryProfiler Malta.................................................................................................................. 105
Investment Migration Insider....................................................................................................108
Programme Agency
Citizenship by Investment Unit, Antigua & Barbuda........................................................104
Citizenship by Investment Unit, Government of St. Kitts and Nevis............................104
Citizenship by Investment Unit, Saint Lucia........................................................................ 105
Dominica's Citizenship by Investment Programme...........................................................106
Malta Individual Investor Programme Agency (MIIPA)...................................................109
Malta Residency Visa Agency...................................................................................................109
103

IM
INVESTMENT MIGRATION YEARBOOK 2019/2020
JAMES ALAN HALL
MANAGING DIRECTOR
ANZ MIGRATE
ANZ Migrate, based in Singapore since 2003 provides immigration services to
Australia and New Zealand. We support clients throughout Asia and around the
world. We work with premier partners offering solutions for business development,
property development, residential real estate, commercial real estate, managed
funds and investment opportunities. We are owned and managed by a Registered
Migration Agent for Australia (0428740) and Licensed Immigration Adviser for
New Zealand (200800600). Our team speaks English, Mandarin, Cantonese,
Bahasa Indonesia, Vietnamese, Burmese, Tagalaog and Khmer.
1 North Bridge Road #23-07,
179094 - Singapore
T:(+65) 6100 2878
E: info@anzmigrate.com
W: www.anzmigrate.com
Contact: James Alan Hall
- Registered Migration Agent
LAURA AUSTIN
HEAD OF INVESTMENT
MIGRATION DUE DILIGENCE
BDO USA, LLC
BDO delivers advisory services around the globe, and the Investigative Due
Diligence Practice draws on deep experience to uncover risk and provide critical
intelligence from our 1,500+ global offices in over 160 countries. We understand
the need for the highest quality due diligence, conducted by our experienced
investigators and expansive global network of resources. We also offer a
proprietary monitoring solution, eConnaissance®, which is the first of its kind
in the Investment Migration (IM) industry. BDO is a corporate member of the
IMC and is actively committed to supporting IM programmes and their ability
to positively influence the global community. With our international presence,
outstanding reputation, industry expertise, knowledge of best practices, and
advanced technology, BDO is unmatched in the IM industry as a leading provider
of due diligence and monitoring services.
100 Park Avenue, New York, NY 10017- USA
T:(+1) 212 885 7493
E: laustin@bdo.com
W: www.bdo.com
Contact: Laura Austin
- Head of Investment Migration Due Diligence
HAKAN CORTELEK
CHIEF EXECUTIVE OFFICER
BEYOND RESIDENCE & CITIZENSHIP
BEYOND Residence & Citizenship houses leading specialists in the Immigrationby-Investment
field. BEYOND’s seasoned, globally minded and locally connected
professionals united in London over a decade ago to provide seamless service
and successful outcomes for their clients. BEYOND offers multi-jurisdictional
solutions worldwide with its extensive partnership networks. The team also
engages in government advisory, education consultancy, international real estate
and due diligence services. Leveraging core operations in Dubai, Hong Kong,
London, Istanbul and Kiev, BEYOND has had extensive experience serving clients
from Russia, China, Turkey, West Africa, the Middle East, South-East Asia and
the Americas. By comprising the most globally aware and experienced team,
BEYOND’s platform effectively serves direct clients and intermediaries in all
Residency- and Citizenship-by-Investment programmes.
Dubai - United Arab Emirates
T:(+97) 150 691 8860
E: hakan.cortelek@beyond-immigration.com
W: www.beyond-immigration.com
Contact: Hakan Cortelek
- Chief Executive Officer
CHARMAINE DONOVAN
CHIEF EXECUTIVE OFFICER
CITIZENSHIP BY INVESTMENT UNIT, ANTIGUA & BARBUDA
The Antigua and Barbuda Citizenship by Investment Unit (CIU), is managed
by a team of professionals and is responsible for processing all Citizenship
by Investment applications, issuing Agent Licenses, approving Authorized
Representatives, Projects and Business Investments. The ultimate responsibility
of the CIP rests with the Office of the Prime Minister. www.cip.gov.ag
Pavilion Drive, Coolidge, St. George’s - Antigua
T:(+1) 268 481-8400
E: info@cip.gov.ag
W: www.cip.gov.ag
Contact: Charmaine Donovan
-Chief Executive Officer
LES KHAN
CHIEF EXECUTIVE OFFICER
CITIZENSHIP BY INVESTMENT UNIT, GOVERNMENT OF ST. KITTS AND NEVIS
Les Khan, PMP, MSOC, BBA, is Chief Executive Officer of the St. Kitts and Nevis
Citizenship Investment Unit. He has over 20 years of experience with large
financial organizations and risk management companies globally. Mr. Khan has
been intimately involved in the revamping of the Citizenship by Investment Unit
in St. Kitts and Nevis, and is an expert on citizenship programmes within the
Caribbean. Mr. Khan has also led initiatives to automate the CBI programmes and
has been instrumental in leading regional conferences, bringing representatives
from the various regional CIU’s together with representatives from the US, UK,
Canada, EU and the IMF.
The Citizenship by Investment Unit, 1st Floor,
Ministry of Finance Building, P.O. Box 597,
Golden Rock - St. Kitts, West Indies
T:(+1) 869 467 1474
E: ciuunitskn@gmail.com
W: www.ciu.gov.kn
Contact: Les Khan - Chief Executive Officer
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NESTOR ALFRED
CHIEF EXECUTIVE OFFICER
CITIZENSHIP BY INVESTMENT UNIT, SAINT LUCIA
As the youngest Citizenship by Investment Programme (CIP) in the Eastern
Caribbean, the vibrant island of Saint Lucia is committed to offering unique
benefits with unmatched respect and integrity. Inheriting decades of knowledge
and experience from our Caribbean neighbours, Saint Lucia has the privilege
to employ the best industry standards and offer competitive advantages to our
investors. Highly reputed for its ideal climate and quality of life, the investment
programme to become a citizen of Saint Lucia is among the most attractive in
the industry, offering a brighter future through our simple yet highly efficient and
optimised application process.
5th Floor, Francis Compton Building
Waterfront, Castries, LC04 301 - Saint Lucia
T:(+1) 758 458 6050
E: info@cipsaintlucia.com
W: www.cipsaintlucia.com
Contact: Nestor Alfred
- Chief Executive Officer
YAKOF AGIUS
FOUNDER &
CHIEF EXECUTIVE OFFICER
CIVIQUO LIMITED
CiviQuo is the world’s first residency and citizenship by investment e-marketplace.
The platform brings together a large selection of programmes, licensed agents
and intermediaries from around the world, enabling each to showcase their
offering in a very simple, transparent and straightforward manner. Individuals
interested in RCBI programmes do not need to browse through many different
sites to find relevant information but can use CiviQuo as a resource to find
information on programmes and service providers. A key feature of CiviQuo is that
service providers who feature on the website need to disclose the professional
fees they will be charging. Once clients have filed their RCBI application, they can
also rate the service provider used. CiviQuo brings a new transparent formula
that eases the process for individuals and transforms the way agents market
themselves.
Aragon House, Level 1, Dragonara Road,
St. Julians, STJ 3140 - Malta
T:(+356) 2034 1608
E: info@civiquo.com
W: www.CiviQuo.com
Contact: Yakof Agius
- Founder & Chief Executive Officer
GARVAN KEATING
CHIEF EXECUTIVE OFFICER
COUNTRYPROFILER MALTA LTD
CountryProfiler (CP) is an international media company that specialises
in the publication of country reports and investment guides on the world’s
most innovative and high growth markets for trade, foreign investment and
international financial services. CountryProfiler publications provide blue
chip companies, their executive management and professional advisors with
global business intelligence and market insight they require when managing
cross border operations, investing or doing business with new markets.
CountryProfiler’s publications are considered to be among the most prestigious
economic intelligence products available.
64, St Anne Court, Flat 2,
Bisazza Street, Sliema SLM 1642 - Malta
T: +(356) 2034 2034
E: puglisevich@countryprofiler.com
W: www.countryprofiler.com
Contact: Melissa Puglisevich - Office Manager
JURGA MCCLUSKEY
PARTNER, HEAD OF IMMIGRATION
(EUROPE AND THE MIDDLE EAST)
DELOITTE LLP
Award-winning immigration expert with over fifteen years’ experience, Jurga
McCluskey leads Deloitte’s UK immigration practice. Deloitte provides global
immigration services to both corporate and private clients. The team comprises
170 experienced professionals, and is complemented by other member firms,
covering over 151 countries, making Deloitte one of the largest immigration
providers globally. Recommended advisor, Anthony Michael leads Deloitte’s
Private Client immigration practice, which serves high-net-worth individuals and
private businesses with their global immigration strategy. Anthony is assisted
by Kathryn Crane who is an Associate Director in the team. The team provide
dedicated end to end support for short term and long term visas, residence
permits, permanent residence and citizenship applications.
2 New Street Square, London,
EC4A 3BZ - United Kingdom
T:(+44) 20 7007 7668
E: jmccluskey@deloitte.co.uk
W: www.deloitte.co.uk
Contact: Jurga McCluskey - Partner, Head of
Immigration (Europe and the Middle East)
CHRIS CURMI
DIRECTOR
DELOITTE
Deloitte Malta provides a market leading immigration service. Headed by UK
Chartered Accountant Chris Curmi and former senior diplomat Jonathan Galea
Deloitte’s dedicated multilingual immigration team offers an unparalleled level
of experience and competence in representing clients in Malta. Deloitte Malta is
not only a successful immigration practice in one of Europe’s most successful
economies, with almost 500 professional staff it is a distinguished provider of
audit, tax, consulting, financial and risk advisory services to an extensive array of
international private and corporate clients.
Deloitte Place, Mriehel Bypass,
Mriehel BKR3000 - Malta
T:(+356) 2343 2000
E: ccurmi@deloitte.com.mt
W: www.deloitte.com/mt
Contact: Chris Curmi - Director
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CHARLES SCHIAVONE
COUNTRY MANAGER
DHL
DHL is the global market leader in the industry and “The Logistics Company for
the World”. Our popular International Express door-to-door delivery service is
available when you’re sending document or non-document shipments anywhere
around the world. DHL Express remains a pioneer, constantly providing new
solutions for its customers, solutions that make it the market leader. While
maintaining the largest market share, DHL sets very high levels of service and
always seeks to serve the customer in the best possible way. Having a constant
presence in the Maltese market since 1983, DHL has acquired a deep knowledge
of critical shipments as well as unparalleled experience in the specialised
handling of express deliveries for each industry sector.
MIA Cargo Village, Luqa, LQA 3290 - Malta
T: (+356) 2180 0148
E: Charles.schiavone@dhl.com
W: www.dhl.com
Contact: Charles Schiavone - Country Manager
H.E. EMMANUEL NANTHAN
HEAD OF THE CITIZENSHIP BY
INVESTMENT UNIT, DOMINICA
DOMINICA’S CITIZENSHIP BY INVESTMENT PROGRAMME
Dominica’s Citizenship by Investment (CBI) Programme has a proud history of
welcoming individuals and families to join their Global Community, and reap
the benefits of what it means to be a Dominican. As one of the oldest economic
citizenship offerings world-wide, the programme provides applicants with the
prospect of greater mobility, wealth and freedom. Established in 1993, Dominica’s
government legislated programme has cultivated a reputation for a smart yet
simple approach, with streamlined processing and strong due diligence at the
heart of the product. The Programme is officially administered by the Dominica
Citizenship by Investment Unit (CBIU), adhering to the highest professional
standards.
Citizenship By Investment Unit (CBIU)
1st Floor, Financial Centre, Ministry of Finance,
Kennedy Avenue Roseau,
Commonwealth of Dominica
T: (+1) 767 266 3974
E: cbiusecretary@dominica.gov.dm
Contact: H.E Emmanuel Nanthan - Head of
the Citizenship by Investment Unit, Dominica
MARY TSIGANOU
VICE PRESIDENT/FINANCIAL
& LEGAL CONSULTANT
ENERGOPIISI S.A.
ENERGOPIISI S.A., a well-established investment consultancy with strong and
long-term experience with international investors, provides integrated services
including solutions for all legal, financial, tax or technical issues on your
investment in real estate and the entire procedure for obtaining a residence
permit. To date we have successfully assisted with over €190 million of foreign
investments in Greece and have issued a remarkable number of residence
permits, business visas and D-type investment visas. With a dynamic list of over
1,000 exceptional properties, we also manage a large number of properties,
offering specific guaranteed income to investors. Trust us to handle your request
from beginning to end.
42, Amalias Avenue, 105 58 Athens - Greece
T:(+30) 210 45 14 892
E: info@goldenvisa-greece.com
W: www.goldenvisa-greece.com
Contact: Mary Tsiganou - Vice president/
Financial & Legal Consultant
KAREN KELLY
DIRECTOR, STRATEGY
& DEVELOPMENT
EXIGER
Exiger is a global leader in delivering enhanced and automated due diligence,
consulting and application process management solutions to CIUs, RIUs,
governments, banks and corporations worldwide. A trusted provider to immigrant
investor programmes since 2006, Exiger has partnered with many of the world’s
largest and fastest growing global CBI and RBI programmes. Exiger’s AI powered
automated due diligence solution, DDIQ, and applicant management system,
Exiger Insight AMS, are changing the way CIUs and RIUs manage applicants and
agents. Exiger has over 190 full-time research staff speaking over 30 languages
in research centers in Washington, D.C. metro, Vancouver, Bucharest, London and
Hong Kong.
1095 Avenue of the Americas, 5th
Floor, New York NY 10036 - USA
T:(+1) 778 945 7318
E: kakelly@exiger.com
W: www.exiger.com
Contact: Karen Kelly - Director,
Strategy & Development
JOSEPH R.R. ESCHER
MANAGING DIRECTOR
FIDESCO TRUST CORPORATION
Based on a genuine interest in understanding client needs, Joseph Escher, the
first director general of the Financial Services Department of Saint Christopher
and Nevis, joined Fidesco Trust Corporation in 1998. With a proven expertise in
the formation of Companies, Foundations, Limited Partnerships, and Trusts, Mr.
Escher enjoys the unique opportunities for personal client interaction in the
Citizenship advisory part of the practice. As authorised person for the Saint
Christopher and Nevis Citizenship by Investment Program, Fidesco specialises in
providing a discerning clientele with the chance to evaluate a new life path in the
Caribbean’s longest running CBI offering. Regularly fielding direct enquiries and
referrals from around the globe, Fidesco is always ready to assist.
The Sands Complex, Suit C23 George Street,
Saint Kitts, KN 0106 - Saint Kitts and Nevis
T:(+1) 869 466 6989
E: info@fidesco.com
W: www.fidesco.com
Contact: Joseph Escher
- Managing Director
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NADINE GOLDFOOT
PARTNER
FRAGOMEN LLP
Fragomen is the world’s leading exclusive provider of immigration services. With
more than 50 strategically located offices worldwide, we provide immigration
services in more than 170 countries. Our Worldwide Private Client Practice
helps individuals—from investors, high net worth individuals and entrepreneurs
to executives, professionals, artists, athletes, students and their families—to
navigate and plan for their long and short-term movement around the world.
Available in multiple countries, alternative citizenship and residency programmes
promote economic growth through investment and offer immigration benefits to
investors seeking to expand and secure their personal and financial security and
stability, leverage global business opportunities and enhance their quality of life.
1st Floor, 95 Gresham Street, London
EC2V 7NA - United Kingdom
T:(+44) 2070 909 156
E: NGoldfoot@Fragomen.com
W: www.fragomen.com
Contact: Nadine Goldfoot - Partner
DR ANTHONY CREMONA
PARTNER
GANADO ADVOCATES
GANADO Advocates is a leading commercial law firm with a focus on the
corporate, financial services, maritime/aviation, fintech/blockchain and
private client sectors, servicing a broad international client base, consisting of
HNWI’s, UNHWI’s, family offices, trustees and other fiduciaries, blue-chip and
multinational corporations. The firm’s well-resourced and dedicated Private
Client team provides unparalleled advice in various areas, from citizenship
and residence (handling applications under Malta’s MIIP and MRVP from
commencement to completion) to estate and succession planning, the setting
up of trusts and foundations, tax advice and conveyancing. GANADO Advocates is
the exclusive member firm in Malta for Lex Mundi – the world’s leading network
of independent law firms with in-depth experience in 100+ countries worldwide.
171, Old Bakery Street,
Valletta, VLT 1455 - Malta
T:(+356) 2123 5406
E: acremona@ganadoadvocates.com
W: www.ganadoadvocates.com
Contact: Dr Anthony Cremona - Partner
ATEF EL KADI
DIRECTOR
GLOBAL INFORMATION CONSULTING GROUP (GICG)
GICG is a multinational firm offering second citizenship and residency solutions
as well as client advisory services to global High Net Worth Individuals.
Established in 1996, GICG is a pioneer figure in the investment immigration
industry, providing expert advices on regulatory and legal matters. Our dedicated
team of 30 associates operates in four different continents with offices in Malta,
Cyprus, Caribbean region, Turkey, Egypt, Montenegro and Moldova. GICG provides
a complete service, taking full responsibility of the citizenship and residency
application process, prioritizing confidentiality and personalized service. Our
strong expertise has resulted in a 100% success rate in all applications made
using our services.
Villa Zimmerman, Maisonette no.2,
Ta’Xbiex Terrace, Ta’Xbiex - Malta
T:(+356) 2133 7030
E: info@gicg.net
W: www.gicg.net
Contact: Yanica Caruana – Senior
Lawyer, Head of Malta Operations
SACHIT KUMAR
DIRECTOR
GLOBE DETECTIVE AGENCY (P) LIMITED
GDA is the pioneer and leading private investigation firm in India, where it has been
established for over five decades. Headquartered in New Delhi having a network
of 20 branches, GDA specializes in Enhanced Due Diligence worldwide for the CBI/
RBI industry, which includes a detailed “deep dive” into a subject’s background
to verify information and acquire any relevant inputs to fill gaps through onthe-ground
resources. It also includes authentication of documents and global
security checks with regard to subjects vis-a-vis sanctions, enforcements, watch
lists and identification of politically exposed persons (PEPs). GDA’s highly skilled,
professional approach is personalized and rigorous. GDA is aware that important
decisions are made partly/wholly based on the information that we provide.
601-603, Eros Apartments, 56, Nehru Place,
New Delhi 110019 - India
T:(+91) 931 104 2007
E: sachitkumar@globedetective.com
W: www.globedetective.com
Contact: Sachit Kumar - Director
DENIECE ALLEYNE
PARTNER
HAZELALLEYNE LAW OFFICE
HAZELALLEYNE Law Office is a full service law firm and authorized corporate
service provider located in the heart of Basseterre, St. Kitts that advises clients
about a wide range of matters in a warm and friendly atmosphere. The Firm
prides itself on delivering a high level of timely, efficient and professional service
to all clients; regardless of the nature of the matter. Its two founders are Ms. Lisa
Hazel–Claxton and Ms. Deniece Alleyne. They are called to the Bars of England
and Wales and St. Christopher and Nevis. Ms. Hazel–Claxton is a Notary Public.
Victoria Road, Basseterre, St. Kitts - West Indies
T:(+1) 869 465 3986
E: info@hazelalleynelaw.com
W: www.hazelalleynelaw.com
Contact: Deniece Alleyne - Partner
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INVESTMENT MIGRATION YEARBOOK 2019/2020
DR JUERG STEFFEN
CHIEF EXECUTIVE OFFICER
HENLEY & PARTNERS
Henley & Partners is the global leader in residence and citizenship planning. Each
year, hundreds of wealthy individuals and their advisors rely on our expertise and
experience in this area. The firm’s highly qualified professionals work together as
one team in over 30 offices worldwide. The firm also runs a leading government
advisory practice that has raised more than USD 8 billion in foreign direct
investment. Trusted by governments, the firm has been involved in strategic
consulting and in the design, set-up, and operation of the world’s most successful
residence and citizenship programmes.
20 Grosvenor Place, London
SW1X 7HN - United Kingdom
T:(+44) 207 823 1010
E: uk@henleyglobal.com
W: www.henleyglobal.com
Contact: Dr Juerg Steffen
- Chief Executive Officer
FRÉDÉRIC VILLA
MANAGING DIRECTOR
INTEGRITAS GROUP
The Integritas Group is a multidisciplinary firm providing corporate services such
as a company formation, company maintenance, corporate structures, mergers
and acquisitions, redomiciliation, residence, citizenship, shipping and trust
services to its clients. Integritas Corporate-Services Ltd is authorised to submit
citizenship and residence application on behalf of applicants to the Maltese
authorities, through its Approved Agents, Mr Frederic Villa and Dr Alexia Muscat.
Mr Frederic Villa is also a member of the Investment Migration Council. Integritas
Trustees Ltd is authorised by the Malta Financial Services Authority to provide
trustee and fiduciary services. The Integritas Group was founded and is headed
by Frederic Villa, a Swiss and Italian national. He speaks Italian , French , English,
German and understands Spanish.
114/3, The Strand, Gzira GZR 1027 - Malta
T:(+356) 2385 0611
E: info@integritas-trustees.com
W: www.integritas-trustees.com
Contact: Frédéric Villa - Managing Director
CHRISTIAN HENRIK
NESHEIM
FOUNDING EDITOR
INVESTMENT MIGRATION INSIDER
Investment Migration Insider is the #1 publisher for the investment migration
industry. We are the news website of reference for the industry and home to the
most trusted information on residence and citizenship by investment. Our readers
are professionals from immigration companies, property developers, law firms,
wealth advisories and family offices, as well as policy-makers, and even heads of
state. We feature breaking news, commentary on current events, interviews with
key figures, an extensive overview of relevant conferences, and the only job listing
site dedicated exclusively to the CBI/RBI industry. Visit us on imidaily.com
Stendervegen 37, 5542 Karmsund - Norway
T:(+34) 658 200 403
E: cn@imidaily.com
W: www.imidaily.com
Contact: Christian Henrik Nesheim
- Founding Editor
BRUNO L’ECUYER
CHIEF EXECUTIVE
INVESTMENT MIGRATION COUNCIL
The Investment Migration Council (IMC) is the worldwide association for investor
migration, bringing together the leading stakeholders in the field and giving the
industry a voice. The IMC sets the standards on a global level and interacts with
other professional associations, governments and international organisations in
relation to investment migration. The IMC helps to improve public understanding
of the issues faced by clients and governments in this area and promotes
education and high professional standards among its members.
16 Rue Maunoir 1211 Geneva - Switzerland
T: (+41) 22 533 1333
E: info@investmentmigration.org
W: investmentmigration.org
Contact: Bruno L’ecuyer – Chief Executive
H. RONALD KLASKO
MANAGING PARTNER
KLASKO IMMIGRATION LAW PARTNERS
Klasko Immigration Law Partners provides a full spectrum of immigration
services to businesses, individuals, and organizations throughout the world.
The firm is one of the largest and most respected immigration practices in the
U.S., delivering cutting-edge immigration advice and representation to clients
internationally. Klasko attorneys frequently lecture businesses, investors, agents,
wealth managers, and other lawyers on the intricacies of immigration law.
Klasko Immigration Law Partners is recognized for providing creative solutions to
the most complex issues in immigration law. The firm has extensive experience
working both with nonimmigrant investors applying for E-2 (treaty investor) and
L-1 (intracompany transferee) visas, and with immigrant investors applying for
permanent residence status through the EB-5 and EB-1-C programs.
1601 Market Street, Suite 2600,
Philadelphia, PA 19103 - United States
T:(+1) 215 825 8600
E: info@klaskolaw.com
W: www.klaskolaw.com
Contact: H. Ronald Klasko - Managing Partner
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LEANDROS
PAPAPHILIPPOU
MANAGING PARTNER
L PAPAPHILIPPOU & CO LLC - ADVOCATES & LEGAL CONSULTANTS
L Papaphilippou & Co LLC was founded in 1963. Through constant and consistent
work, it is now one of the leading and most respectable law firms in Cyprus. The
firm advises on cross-border mergers, acquisitions of companies, international
liquidations, international civil and criminal litigation, establishment and
protection of brands and intellectual property (IP), admiralty and shipping,
banking and finance, competition, regulatory, fiduciary, immigration as well
as international tax planning corporate and commercial and real estate. Our
Immigration and Citizenship Department is well respected, and our lawyers
provide structured and sound legal advice in relation to the acquisition, sale or
lease of residential or commercial property.
17 Ifigenias Street, 2007 Strovolos P.O.
Box 28541, 2080 Nicosia - Cyprus
T:(+357) 2227 1000
E: info@papaphilippou.eu
W: www.papaphilippou.eu
Contact: Leandros Papaphilippou
- Managing Partner
PAUL WILLIAMS
CHIEF EXECUTIVE OFFICER
LA VIDA
Based in London, UK, La Vida Golden Visas facilitates the acquisition of residency,
immigration and citizenship through investment. We make what looks like an
expensive and difficult option, affordable and complex free. With clients covering
more than 60 countries worldwide and over 15 programme options, we understand
your reasons and we have the best solution for your needs. Today’s Golden Visa
has become an essential requirement for many high net worth families. Let us
help you achieve your goals. Visit our website at www.goldenvisas.com for full
details on the investment and real estate options available in the Caribbean, USA
and Europe.
Argyle House, Joel Street, London
HA6 1NW - United Kingdom
T:(+44) 207 060 1475
E: info@goldenvisas.com
W: www.goldenvisas.com
Contact: Paul Williams
- Chief Executive Officer
JONATHAN CARDONA
CHIEF EXECUTIVE OFFICER
MALTA INDIVIDUAL INVESTOR PROGRAMME AGENCY (MIIPA)
Malta harbours the perfect ambience to relocate your business and settle down
your family in a stable and prosperous country. The Malta Individual Investor
Programme has been attracting successful and high-net-worth families to
contribute positively towards the Maltese society. Malta has also been at the
forefront of the Citizenship by Investment Industry and has worked closely with
international institutions to ensure the programme gives the peace of mind to
both the individuals applying and to all other related stakeholders.
Mediterranean Conference Centre,
Old Hospital Street, Valletta VLT 1645 - Malta
T:(+356) 2122 5232
E: info@iip.gov.mt
W: www.iip.gov.mt
Contact: Monica Farrugia
– Chief Officer, Operations and Finance
CHARLES MIZZI
CHIEF EXECUTIVE OFFICER
MALTA RESIDENCY VISA AGENCY
The Malta Residency Visa Agency is the Government entity responsible for
managing and promoting the Malta Residence and Visa Programme. The
programme grants beneficiaries from third countries (including non-Swiss
and non-EEA) the right to settle permanently in Malta and travel across the
Schengen zone visa-free. Beneficiaries can enjoy residency in a safe and stable
country boasting excellent educational opportunities and economic prosperity.
All applications submitted through accredited agents undergo a rigorous due
diligence process to ensure that only fit-and-proper individuals are granted
residency.
Clock Tower, Level 1,Tigné Point,
Sliema, TP 01 - Malta
T: (+356) 2203 4000
E: customercare.mrva@mrva.eu
W: www.mrva.eu
Contact: Anthony Tomaselli Chetcuti
– Client Relationship Manager
GISELLE BRU
CHIEF EXECUTIVE OFFICER
PASSPRO IMMIGRATION SERVICES
PassPro is one of the most respected Government Authorized Agents for second
citizenship in the Middle East with a trusted reputation for providing ethical advice
on the citizenship by investment programmes of Dominica, Antigua and Barbuda,
St Kitts and Nevis, Grenada, St. Lucia and Cyprus. PassPro offers end-to-end
application guidance – supporting with documentation, translation, attestation
and legalization – and is highly experienced in dealing with complex applications
of challenging nationalities. Our core team hails from the Caribbean and has
processed applications covering more than 30 client nationalities over the course
of their careers. Our experienced consultants possess specialized knowledge in
real estate, regulatory compliance and financial due diligence and we visit our
jurisdictions often, ensuring our clients always receive first-hand, up-to-date
advice.
501, Al Habtoor Business Tower,
Dubai – United Arab Emirates
T:(+971) 4554 1449
E: info@passpro.co
W: www.passpro.co
Contact: Giselle Bru - Chief Executive Officer
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INVESTMENT MIGRATION YEARBOOK 2019/2020
PHIL COTTER
MANAGING DIRECTOR
REFINITIV
Refinitiv is one of the world’s largest providers of financial markets data and
infrastructure, serving over 40,000 institutions in over 190 countries. It provides
leading data and insights, trading platforms, and open data and technology
platforms that connect a thriving global financial markets community – driving
performance in trading, investment, wealth management, regulatory compliance,
market data management, enterprise risk and fighting financial crime. For more
information visit: www.Refinitiv.com
Refinitiv, 5 Canada Square, London E14 5AQ
- United Kingdom
T:(+44) 207 542 4356
E: Sylwia.wolos@refinitiv.com
W: www.refinitiv.com
Contact: Sylwia Wolos
- Director, Enhanced Due Diligence
SIMON HUXFORD
SOLICITOR
ROSEMONT INTERNATIONAL
Rosemont International provides an all-around multi-disciplinary and multijurisdiction
private client and corporate service. We assist individuals and their
families in structuring and administering their financial world in the best possible
fashion. Professionally qualified and experienced staff can assist you, your family,
and your business. Accountants, solicitors, notaries, trust and tax advisors can
help guide you through the intricacies of the modern tax and estate planning
requirements in the jurisdictions where you reside, operate and hold assets.
We have first-hand experience of operational, regulatory and financial issues
faced by entrepreneurs in practice and work accross civil law and common law
jurisdictions. With offices in strategic locations (Monaco, Malta, Andorra, United
Kingdom, Hong Kong, Singapore, Vietnam and Mauritius) we are able to offer an
integrated service including residence and immigration support.
Le Monte Carlo Sun, 74 Boulevard d’Italie,
MC9800 - Monaco
T:(+377) 9777 4600
E: consulting@rosemont.mc
W: www.rosemont.mc
Contact: Simon Huxford - Solicitor
IRINA ROSTOVA
FOUNDING PARTNER
ROSTOVA WESTERMAN LAW GROUP, PA
Rostova Westerman Law Group, P.A. is a U.S. immigration and nationality law
firm with a focus on the EB-5 migration programme for investors. Our attorneys
oversee hundreds of EB-5 petitions, have experience successfully appealing
denials, litigating adverse decisions in federal court, and have vast experience
in resolving complex admissibility issues for investors and their family members.
Our firm represents investors from every continent and performs quality control
checks of EB-5 filings prepared by other migration firms. Founding Partner Irina
Rostova applies her background in banking and understanding of accounting
principles and financial structures to her work with investors and is passionate
about advocating for and promoting the EB-5 investor migration programme in
Eastern Europe.
4901 NW 17th Way Suite 303
Ft. Lauderdale, FL 33309 - USA
T:(+1) 786 408 3183
E: admin@usainvestorvisas.com
W: www.usainvestorvisas.com
Contact: Irina Rostova- Founding Partner
DR TIMOTHY ZAMMIT
TAX & IMMIGRATION LAWYER
RSM MALTA
RSM Malta is a member of RSM International, the seventh largest network of
independent audit, tax and consulting firms encompassing 116 countries, 750
offices and 41,000 people internationally. In Malta, we employ a unique talent pool
of over 190 staff in Audit, Business Advisory, Outsourcing, Immigration and Tax.
We assist clients with their residence or citizenship by investment requirements,
provide tax advisory and structuring, licensing, compliance and disruptive
technologies related services. Our setup enhances business efficiencies, reduces
internal bureaucracy and underpins our client focussed culture. It also assists
our clients in readily connecting to partners providing leading advice and great
value for money by understanding clients’ needs while helping to achieve them -
experience the power of being understood.
Mdina Road, Zebbug ZBG 9015 - Malta
T:(+356) 2278 7000
E: timothy.zammit@rsm.com.mt
W: www.rsm.com.mt
Contact: Dr Timothy Zammit
– Tax & Immigration Lawyer
HEYRICK BOND GUNNING
CHIEF EXECUTIVE OFFICER
S-RM INTELLIGENCE AND RISK CONSULTING LIMITED
S-RM is a global consultancy that helps clients manage regulatory, reputational
and operational risks. Our proven expertise, natural curiosity and personal
accountability delivers unequalled standards of service and advice across every
sector in which we operate. This is supported by forward-looking, technologyempowered
services that enable organisations and individuals to make
informed decisions that minimise business interruption and unlock commercial
opportunities in 140+ countries.
4th Floor, Beaufort House, 15 St Botolph St,
London, EC3A 7DT - United Kingdom
T:(+44) 207 495 9140
E: info@s-rminform.com
W: www.s-rminform.com
Contact: Nick Thorley - Director
110

INVESTMENT MIGRATION YEARBOOK 2019/2020
IM
MELISSA KELLEY-HILTON
PRESIDENT
STERLING DILIGENCE
Sterling Diligence, formerly Bishops, is a leading global investigations, corporate
due diligence, and executive screening firm. Ethical, discreet and trusted by
leading Fortune Global 500 companies, we partner with each client to ensure
our engagement results in timely and relevant information on a global scale.
Our dedication to providing reliable, transparent, and actionable results, equips
clients with the right information to make key strategic business decisions.
Sterling Diligence has extensive resources in over 190 countries and territories
with in-market resources. Our team of diverse professional investigators and
award-winning executive leadership combined with our cloud solution, Sterling
GlobalIQ, provides unparalleled expertise.
One State Street Plaza 24th Floor,
NY 10004 - New York
T:(+833) 231 5766
E: melissa.kelley-hilton@sterlingdiligence.com
W: www.sterlingdiligence.com
Contact: Melissa Kelley-Hilton - President
JAMES ELCOCKE-HARRIS
CHIEF EXECUTIVE
VANUATU INVESTMENT MIGRATION BUREAU
The Vanuatu Investment Migration Bureau (VIMB) is a global network of
government authorized representative offices for the promotion of Vanuatu’s
Citizenship by Investment Programme – the Vanuatu “Development Support
Programme” (DSP). VIMB has assembled an unrivalled team of experts to provide
the highest levels of service and reliability for agents and applicants to apply for
citizenship with complete peace of mind. Headquartered in Vanuatu and operated
internationally by Vanuatu citizens who know and understand the DSP intimately,
VIMB is the primary global distributor of the Vanuatu Citizenship by Investment
Programme.
B&P House. Lini Highway, Port Vila - Vanuatu
E: info@vimb.vu
W: www.vimb.vu
Contact: James Elcocke-Harris
- Chief Executive
DAVID CHEN
EXECUTIVE DIRECTOR &
MANAGING PARTNER
VISAS CONSULTING GROUP
Visas Consulting Group (VCG), one of the most prestigious immigration firms in
China, has been dedicated to the achievement of the immigration dream of the
wealthy elites since 1997. With the assistance of VCG, thousands of families not
only successfully acquire the residency in their desired destination but also swiftly
fit into the new life. In the wake of the fourth wave of Chinese emigration, Visas
Consulting Group has become a comprehensive overseas service provider that
can take care of the client’s life in every aspect. Staying true to its motto: “Visas to
Your Future”, VCG is ready to keep you company during your emigration journey
at every step.
29/F Huaihai Plaza, 1045 Huaihai Road
Central, Shanghai, 20031 - China
T:(+86) 21 6415 8666
E: dchen@visas.to
W: www.visas.to
Contact: David Chen
- Executive Director & Managing Partner
111

For over 20 years, Henley & Partners has worked closely with governments to pioneer citizenship-by-investment programs,
including the Malta IIP, which today is the world’s leading program. Malta offers safety and security by providing a better quality
of life and the right to live, do business, and study in all EU member states. +356 2138 7400 | malta@henleyglobal.com
Antigua · Australia · Austria · Canada · Croatia · Cyprus · Dubai · Greece · Grenada · Hong Kong · Jersey · Latvia · Malaysia · Malta · Moldova

Secure your family’s future with Maltese citizenship
Define your Future
Montenegro · Philippines · Portugal · Singapore · South Africa · South Korea · St. Kitts · St. Lucia · Switzerland · Thailand · United Kingdom · Vietnam

Due Diligence
at Your
Fingertips