IM Yearbook 2023

IM
INVESTMENT
MIGRATION
YEARBOOK 2023
5 TH EDITION | €25
Migration
policy
Accelerating the global recovery?
NUMBERS THAT MATTER
• €530T: Global Wealth record
• 281M: Global Migrants
• 35-45yrs: Avg. Client Age
GLOBAL VIEWS
• Engine of Change
• Its all about EU Blood!
• Must Peter Pay for Putin?
SMART LIBRARY
• Real-Time DD
• Women, Wealth, IM
• The Race is on!

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Due Diligence
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authentication of documents and global security checks related to sanctions, enforcements, watch
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IM YEARBOOK
Contents
Facts & Figures
The Numbers that Matter 4
Editorial, Bruno L’ecuyer, CEO and Co-Founder of the Investment Migration Council
An Engine of Change, Evolution and Growth 11
In Conversation with Dimitry V. Kochenov and Elena Basheska
It’s all about European Blood 16
The IM Long Read
A Fragile World Economy and New
Opportunities for Investment Migration 20
Eric Major, CEO of Latitude and Patricia Casaburi,
Managing Director of Global Citizen Solutions
What’s Ahead for Citizenship by Investment? 22
From Refugee Past to EB-5 Professional:
One Man’s Perspective on Migration 25
The Big Picture
The IM Yearbook Travels with
Fragomen around the World 29
Geoffrey DuBoulay and Keith Issac of Polaris Citizenship &
Investment Consultancy Services
Must Peter Pay for Putin? 32
Trends and Topics
Six Thoughts on Investment Migration
in a Changing Landscape 34
Dr Juerg Steffen, CEO of Henley & Partners
Navigating a New Level of Volatility 42
Anatomy of a Source Market:
India 44
Karen Kelly, Director of Strategy and Development at Exiger
Looking Forward: Using Real-Time
Monitoring to make Risk-Based Decisions 48
Investment Migration Yearbook 2O23 - 1

IM YEARBOOK
Ronit Sharma, Founder & Managing Director of Immigrant Investor Group
What HNWIs Need to Know about
Canada’s Start-up Visa 50
Charles Mizzi, CEO of the Residency Malta Agency
From Permanent Residence to the Nomad
Residence Permit:Malta Keeps on Innovating 52
Frederico Seixas, Sales Director of Investaureum
Portugal: Europe’s New “California” 54
Interview with Austin T. Fragomen Jr, Chairman Emeritus at Fragomen
The Global Race for High-Potential
Migrants is Heating up 56
Women, Wealth and Investment Migration 60
How Migration Policy can Accelerate Recovery
from the Global Economic Downturn 62
Who’s Who
Directory of People You Need to Know 66
A Guide to the Investment Migration Council 73
IMC Qualifications and Training 82
The Investment Migration Forum Partnership
Opportunities 87
Visibility Opportunities for Your Business 102
YEARBOOK 2023
All rights reserved. Reproduction in whole or part is strictly prohibited without the written permission of
the publisher. Opinions expressed in the IM Yearbook are not necessarily those of the editor, publisher
or contributors. All reasonable care is taken to ensure truth and accuracy, but the editor and publisher
cannot be held responsible for errors or omissions in articles, advertising, photographs, or illustrations.
Publication Date: January 2023 • Printing: Gutenberg Press
Publisher: Investment Migration Council - media@investmentmigration.org
Editor: Bruno L’ecuyer - bruno.lecuyer@investmentmigration.org • Sonja Lindenberg - sonja@storycom.net
Design: Ramon Micallef - ram@box-design.net • ISBN N°: 978-2-8399-3429-9
2 - Investment Migration Yearbook 2O23

The Investment Migration Forum
Advancing Residence and Citizenship by Investment
15 th - 18 th May 2023, London , United Kingdom
350+
Delegates
50+
Speakers
55+
Countries
25+
Partners
The Investment Migration Forum will be hosting its 8 th edition in London! Renowned academics, government officials and
representatives of international organisations - as well as the world's leading professionals dealing with investor migration
and citizenship by investment - now have the London gathering entrenched on their annual calendar.
13%
60%
8%
10%
7%
Europe
Asia
USA & Canada
Middle East

IM YEARBOOK
Facts & Figures 2022/23
The Numbers that
Headline Figures
Investment migration has gone through
enormous change since it started in
the 1980s. It is today more diverse than
ever as illustrated by the figures below.
1984
The year when St. Kitts
and Nevis introduced
the first modern
CBI programme.
150-170
countries
An EU passport typically allows
visa-free travel to between 150
and 170 countries, following
multi-tiered due diligence.
$100,00 to
more than
$5 million
Investment requirements vary
greatly across countries. While
the minimum investment
can be as low as $100,000,
some countries require
multi-million investments.
400+
The IMC has more than
400 members coming from
45 different countries.
€20 billion
Investment migration is
estimated to be a €20-billionindustry.
It generates significant
societal and economic benefits,
including job creation and
notable contributions to GDP.
90%
of investment migration
pathways are offered in
so-called rich nations. Highincome
countries as defined
by the World Bank with a
gross national income (GNI)
per capita of US$12,696
or higher account for 63%
and upper middle-income
countries with a GNI per
capita between $4,046 $12,535
$12,535 account for 30%.
550+
Small businesses and
consultancies drive
investment migration
forward. There are some
550+ agents licensed
across the world.
35-45
years old
Service providers report
that in emerging market
economies the average age
of applicants is between
35 and 45 years old.
Countries with
investor pathways
for citizenship 2022:
Antigua & Barbuda
Dominica
Grenada
Jordan
Malta
St. Kitts & Nevis
St. Lucia
Turkey
Popular countries
with investor
pathways for
residence 2022
Australia
Canada (Quebec)
Cayman Islands
France
Greece
Hong Kong
Ireland
Italy
Jersey
Latvia
Malta
Monaco
New Zealand
Singapore
Spain
Thailand
UAE
UK
USA
Several other countries
had investment migration
programmes in place at
different times in the past.
In addition, around 10% of
all established programmes
have been replaced with
revised versions between
the years 2000 and 2015.
98% of the world population
acquired citizenship at
birth, while naturalisations
account for 2% of
citizenship acquisitions
around the world, according
to citizenship expert
Dimitry Kochenov.
Migration
Trends
281 million
international
migrants
The World Migration Report 2022
published by the International
Organization for Migration (IOM)
estimates that 281 million people
are living in a country other than
their country of birth. Most people
though continue to live in the
countries in which they were born
—only one in 30 are migrants.
88,000
millionaires
The world’s rich are on the move
again after a pandemic-induced
dip: 88,000 millionaires are
expected to move by the end of
2022, according to the Henley
Global Citizens Report.
Global wealth will
shrink in 2022
While 2021 was a strong year
for wealth growth, 2022 turned
out to be significantly different.
High inflation and interest rate
hikes spurred stock market
corrections. By end of April 2022,
Capgemini estimated that global
HNWI wealth had declined by
4% compared to December 2021.
+10%
Knight Frank’s Wealth Report
stated that globally the number
of people with net wealth of
US$30 million or more increased
by almost 10% in 2021.
This growth was evenly spread,
with North America (up 12.2%)
just ahead of the regional pack.
Only Africa saw a decline in
wealth, according to the report.
4 - Investment Migration Yearbook 2O23

IM YEARBOOK
Matter
25
20
Numbers and quoted percentages
may not add up due to rounding.
Wealth Growth Trends
$530 trillion
Global wealth reached a record high of $530 trillion in 2021, fuelled by strong
equity markets and a surge in demand for real assets, according to the 2022
edition of the Global Wealth report by the Boston Consulting Group (BCG).
The report finds that despite geopolitical and economic destabilizers
such as inflation and Russia’s invasion of Ukraine, approximately $80
trillion in new wealth will likely be created over the next five years.
In a notable industry shift, BCG predicts that Hong Kong will probably
overtake Switzerland in 2023 as the domicile managing the largest amount
of private cross-border wealth, ending a run of more than 200 years of Swiss
dominance. The report points out that wealth assets will continue to rise in
value in all regions. But Asia-Pacific will maintain the fastest rates of wealth
growth, with asset values poised to increase by a compound annual growth
rate (CAGR) of 8.4% through 2026. If that rate holds, the region could be home
to nearly one-quarter of the world’s wealth by 2026, according to BCG.
Switching to other parts of the world, BCG finds that wealth in the
Middle East and Africa is on track to rise by a CAGR of 5.4% over the
next five years, the biggest overall leap in regional wealth growth. In the
US, wealth growth will be slower than in past years, with an estimated
CAGR of 4.7% through 2026, down from a prior five-year average of 9.1%.
Likewise, in Western Europe, wealth growth is likely to slow from roughly
4.5% over the past five years to less than 4% annually until 2026.
7.8%
According to Capgemini’s World Wealth Report 2022, the global
HNWI population expanded by 7.8% in 2021, with 1.7million new
HNWI. While wealth swelled by 8%, or US$6.4 trillion.
While multiple factors contributed to the growth of
wealth, bull markets around the world were a primary driver.
Globally, stock markets generated healthy returns.
HNWI Population Growth in Millions
Economic Forecast
An uncertain
economic
outlook
The World Economic Forum, the IMF, the WTO and
the OECD – all international institutions have slashed
their growth outlook for 2023. Several shocks have hit
a world economy already weakened by the pandemic:
higher-than-expected inflation worldwide – especially in
the US and major European economies – triggering tighter
financial conditions; a worse-than-anticipated slowdown
in China, reflecting Covid-19 outbreaks and lockdowns;
and further negative spillovers from the war in Ukraine.
Even wealthy countries are struggling with multiple costof-living
pressures, while higher food and fuel prices are
raising the prospect of unrest in poorer countries. Analysts
expect further changes in the global economic and
geopolitical order should energy trade shift, supply chains
reconfigure, and nations rethink reserve currency holdings.
The risks to the outlook are overwhelmingly tilted to the
downside, the IMF noted. Global growth will likely decline to
about 2.6% in 2022 and 2% in 2023, which would put growth
in the bottom 10% of outcomes since 1970. Meanwhile, the
World Economic Forum expects global growth to slow
from 6.1% to 3.2% in 2022, and the WTO revised down its
forecast for global trade growth this year to 3% from 4.7%.
A further tightening of global financial conditions will be
felt disproportionately strong in emerging and developing
economies, which are already facing elevated debt levels
following the pandemic. Projections by the UN Conference
on Trade and Development (UNCTAD) estimate that
developing countries will need $310 billion to meet their
external public debt service requirements in 2022.
Meanwhile, the Economist Intelligence Unit reported
that Saudi Arabia will be the world’s fastest-growing major
economy in 2022, outperforming the dynamic Asian giants
of China, India, Indonesia and South Korea, as well as
the struggling G7 and other major emerging economies.
Real GDP growth is expected to reach 7.5% in 2022. The
kingdom has recovered quickly from a pandemic-induced
recession in 2020 and is reaping the rewards of high
global energy prices and increased energy production.
15
10
5
0
2014 2015 2016 2017 2018 2019 2020 2021
The US retained its lead for HNWI growth (13.2%) and wealth (13.8%) in 2021.
The region accounted for more than half of the 1.7million new HNWIs.
The US, Japan, Germany and China retained their top
four positions in HNWI population markets in 2021. They
comprised 63.6% of the global HNWI population.
Investment Migration Yearbook 2O23 - 5

IM YEARBOOK
Country
Attraction
The UAE,
Australia and
Singapore have
been ranked
the top three
countries in terms
of net inflows of
HNWIs for 2022,
according to
figures provided
by the Henley
Global Citizens
Report (Q2).
The top three
countries with
the highest
net outflows
of HNWIs are
Russia, China
and India.
Projected net inflows
of HNWIs in 2022
UAE 4,000
Australia 3,500
Singapore 2,800
Israel 2,500
Switzerland 2,200
USA 1,500
Portugal 1,300
Greece 1,200
Canada 1,000
New Zealand 800
Projected net outflows
of HNWIs in 2022
Russian Federation -15,000
China -10,000
India -8,000
Hong Kong (SAR China) -3,000
Ukraine -2,800
Brazil -2,500
UK -1,500
Mexico -800
Saudi Arabia -600
Indonesia -600
COUNTRY SPOTLIGHTS
Russia
Unsurprisingly, Russia has
suffered the biggest emigration
of millionaires in the first six
months of 2022. Henley &
Partners forecast net outflows
of 15,000 by the end of 2022 —
15% of its HNWI population
and 9,500 more than in 2019.
However, soon after the invasion
of Ukraine, most countries said
they would no longer accept
or process applications from
Russian citizens. Meanwhile,
Russia advanced plans to
launch its own golden visa
in January 2023 and expects
primarily Chinese to take
advantage of the programme.
China
Chinese nationals have long
accounted for approximately
80% of applicants to any
residence programme in the
world. However, international
travel bans due to Covid-19 and
currency control mechanisms
have made it increasingly
difficult for Chinese nationals
to use investment migration
pathways. Nonetheless, around
10,000 HNWIs in China planned
in 2020, taking $48 billion in
wealth with them, according
to Henley and Partners.
India
Wealthy Indians are investing
abroad at record rates, data
from the country’s central
bank revealed. In the 2021-22
financial year, Indians ploughed
$1.69bn directly into foreign
bank deposits, equity and debt
instruments, as well as into
property outside the country,
according to the Reserve Bank
of India. That is almost 40%
higher than the figure for 2020-21
and nearly six times the $292m
that Indians invested abroad in
real estate, deposits, debt and
equity in 2014/15. Rich Indians
are not just sending their money
abroad. Henley & Partners
projected that around 8,000
millionaires will have left the
country by the end of 2022.
6 - Investment Migration Yearbook 2O23

IM YEARBOOK
Investment
Trends
71%
Emerging asset classes, including ESG,
cryptocurrencies and NFTs, are high
on the agenda of HNWIs. According to
Capgemini’s Wealth Report 2022, 71% of
HNWIs have invested in digital assets.
Elsewhere, Knight Frank’s Wealth Report
pointed out that 18% of UHNWIs now
own cryptocurrencies, while 11% have
invested in non-fungible tokens (NFTs).
15%
Around 15% of UHNWIs plan to
apply for a second passport or new
citizenship and 36% of those are
planning to do so for a better quality
of life, according to Knight Frank.
80%
Some 80% of wealthy investors want
more ESG-compliant assets to futureproof
their portfolios, Knight Frank said.
The Attraction of
Big City Life
While many predicted that cities would
lose their appeal as a result of the ‘race for
space’ in the Covid-19-era, Knight Frank’s
Global Buyer Survey 2021 indicate that
the city is far from down and out. The
survey found out that 38% of respondents
that are inclined to move within the next
12 months were looking at a city location,
while 33% were considering the suburbs.
US$53 trillion
Investments that consider ESG
criteria may exceed US$53 trillion
by 2025, according to Capgemini.
21%
Knight Frank recorded an intention from
21% of global UHWNIs to purchase new
property somewhere in the world in 2022,
up from the 19% who did so in 2021.
Moreover, Knight Frank stated that
the average value of luxury residential
property increased by 8.4% in 2021,
the highest annual increase since the
firm launched its Prime International
Residential Index in 2008.
Top1O Passports
Source: Henley & Partners Passport
Index September 2022
Rank
Passport
Visa-free score
1 Japan 193
2 Singapore 192
South Korea
3 Germany 190
Spain
4 Finland 189
Italy
Luxembourg
5 Austria 188
Denmark
Netherlands
Sweden
6 France 187
Ireland
Portugal
UK
7 Belgium 186
New Zealand
Norway
Switzerland
US
8 Australia 185
Canada
Czech Republic
Greece
Malta
9 Hungary 183
10 Lithuania 182
Poland
Slovakia
Source: Arton’s Passport Index
November 2022
Rank
Mobility
score
1 United Arab Emirates 177
2 Germany, Sweden 173
Finland, Luxembourg
Spain, France, Italy
Netherlands, Austria
Switzerland, South Korea
3 Denmark, Belgium 172
Portugal, Norway
Poland, Ireland
United States of America
New Zealand
4 Czech Republic, Greece 171
Hungary, Japan,
United Kingdom, Australia
5 Singapore 170
Malta
Lithuania
Slovakia
Canada
6 Estonia 169
Latvia
Slovenia
7 Liechtenstein 168
Iceland
8 Cyprus 167
Croatia
Romania
Bulgaria
9 Malaysia 165
10 Monaco 163
Investment Migration Yearbook 2O23 - 7

OFFICIAL LIST OF MEMBERS 2022
111 Immigration Services
360 Advisory & Management GmbH
Academy Finance
Adamjee Global Solutions
Adrestia Legal
Afi Ventour & Co.
AIT Accounting & Management Services Ltd
Alam Nam
Alta Invest RCBI Solutions
Andorra Guides
Anna Grigorieva & Co. LLC
Appleby
Arden Leigh LLP
Areti Charidemou & Associates LLC
Asia Outbound Group
Atlantic Bridge
Austral Migration Consultancy P/L
BDO
Bedell Cristin
Beshara Global Migration Law Firm
BEYOND Residence and Citizenship
BIZ Consult Ltd
BLVUE Zürich Advisory AG (Ltd.)
Bond University
Bridge Partners
Budget & Migration Consultants
Bulgarian Citizenship Ltd.
Century Capital Inc.
Chetcuti Cauchi Advocates
Citizenship By Investment Unit - Antigua & Barbuda
Citizenship Invest
Citizenship Solutions
CJ International Group
CLD Legal
Dalmore Group, LLC
Davidson immigration
Davison & Davison Associates Limited
Deloitte Malta
Dentons
Discus Holdings
Dual Luxury World
Energopiisi
Erg, Family Office
Exclusive Migration
Exiger LLC
Eximius Life
FACT Due Diligence
Filimon Consulting
First Advisory Trust reg.
Fragomen Worldwide
Free Mobility Leaders
Frendo Advisory
Fresh Global Alliance Ltd
Frontgate Global Concepts
Ganado & Associates
GICG Global Information Consulting Group
GLI General Lines of Immigration Corporation
Global Citizen Solutions Limited
Global Nomad Consulting
Global Residence and Citizenship Ltd.
Globe Detective Agency (P) Ltd.
Globevisa
Go2Europe
Golden Visa Consultancy
Golden Visa Experts
Grant, Joseph & Co
Green Light Management Consultancy JLT
Grosvenor Partners
Guardian Corporate Services Ltd
Guide Consultants
Henley & Partners Montenegro
Henley & Partners Australia
Henley & Partners Austria
Henley & Partners Canada (Quebec)
Henley & Partners HKG
Henley & Partners Jersey
Henley & Partners Malta
Henley & Partners Middle East DMCC
Henley & Partners Portugal
Henley & Partners Singapore Pte. Ltd.
Henley & Partners South Africa (Pty) Ltd.
Henley & Partners Spain
Henley & Partners Switzerland
Henley & Partners UK
HEUSER RECHT UND STEUERN
Hilton Global Associates
IAS – INTERNATIONAL ATLANTIC SERVICES
IMM GROUP Co. Ltd.
Immigrant Invest
Immigrant Investor Group Inc (IIG)
immVest International Limited
Impart Immigration Consulting
Integritas Group
Intercorp International LTD
International Center for Globalization and Development
Inter-Tax Consultants
Invest & Settle
Invest in the USA (IIUSA)
Investaureum Lda
Island Living Investment Services Ltd
J and Rays Ltd
Joel Stewart PA
8 - Investment Migration Yearbook 2O23

400+ MEMBERS FROM
55+ COUNTRIES
Joseph Rowe Attorneys-at-Law and Notaries Public
Ketenci&Ketenci ILP
Khalil Masri et Fils Sarl
Klasko Immigration Law Partners, LLP
KOHELAB
KPMG Intl Malta
KSi Malta
La Vida Golden Visas
Laferla Insurance Agency Limited
Lamares, Capela & Associados
Latitude Consultancy Limited
Leary Global, Investment Migration Advisors
Lecanda Immigration and Nationality Law
Leisure World Properties Ltd
Lincoln Global Partners UK Limited
Magellan Champlain
Maisto & Associati
Mc Namara & Company - Barristors, Solicitors & Notaries Royal
Michael Kyprianou & Co. LLC
MICS Global
Mifsud&Mifsud Advocates
Migronis Ltd
Mintz Group LLC
Mirabello Consultancy AG
M-J Global
Moonline Immigration
Motcomb
MOVEANYWHERE LTD
My Global Citizenship
Neity Lloyd Maddock
New Balkans Law Office
NEXT - Gali Macedo Lawyers
Next Generation Equity
NG Global Citizens Limited
Nila Global
Nomad Gate
Novafirm SA
NSM - Nuno Sousa Moniz, Sociedade de Advogados SP RL
Optylon Krea LDA
Orience International SL
Passport Gates
PassPro Immigration Services
Paton & Mayr SLU
PDE Consulting Ltd
Polaris Citizenship & Investment Consultancy Services Limited
Prime Synergy
Professionals Ltd.
ProPanama
PT. Anugraha Askara Paramitra
QuazarHouses LLC
R P Merriman
Range Developments Ltd.
RC International
Reef View Enterprises Ltd
Residency Malta Agency
Resolute Group
RIF Trust Investments LLC
RK Global Fortune Consulting
ROC Citizenship
Roseveare Group
Rute Immigration.
Sable International Limited
Saeima (National Parliament) of Latvia
Saratoga Capital
SG - Secondpass Global
Shard Capital Investor Visa
Shirazi Immigration Law, Inc.
S-RM Intelligence and Risk Consulting
Startup Business Bureau
Steptoe & Johnson LLP
Sterling Migration
Sunrise International Legal Services
SwissTaxGroup
The Address Consulting Group
The Sovereign Group
Thomas John & Co
Trafalgar Properties LLC CBI / RBI Unit
University of Vienna
Valadas Coriel & Associados
Vanuatu Life Style Ltd
Vardikos & Vardikos
Varnavas & Varnavas
Vertex Advisory Ltd
Visa World Wide Admission
Visadoro
Visas Consulting Group Inc
Viya Global Vatandaşlık Ve Göç Hizmetleri
Danışmanlık Ticaret Limited
Vostok Consulting LLC
WDM Lex Advisory Ltd
WOLF THEISS Attorneys-at-Law
World Grenada Inc.
Xenoom Immigration Inc.
XIPHIAS Immigration Pvt Ltd.
Xumit Capital
Neda Azarmehr
Hudda Elmira Chehadé Cert (IM)
Walid Nadar
Adewale Dosunmu
Imran Mirani
Investment Migration Yearbook 2O23 - 9

PRIME HERITAGE PROPERTIES

IM YEARBOOK
EDITORIAL
An Engine of
Change,
Evolution and
Growth
World events over the last two years resulted
into the perfect storm for the global economy.
International migration and investment will
play a key role as countries brace for impact.
Bruno L’ecuyer, CEO &
Co-Founder of the
Investment Migration Council
Investment Migration Yearbook 2O23 - 11

IM YEARBOOK
Change is not the right term to
describe what the world economy
and world politics are experiencing
currently. It is too small a word to capture
the essence of what is happening. The
ongoing pandemic, the war in Ukraine,
the effects of climate change, supply chain
disruption, energy crisis, inflation, higher
interest rates and potentially a coming
recession have created an unprecedented
scenario for global migration.
Even wealthy countries are struggling
with multiple cost-of-living pressures,
while higher food and fuel prices are
raising the prospect of unrest in poorer
countries. Meanwhile, shifting alliances
and value systems are creating a new global
map of political and economic relations.
While it is still too early to say how all this
will play out, it looks certain that trends
which started to unfold throughout the
past two years will only intensify. Topics
such as diversification, regionalisation
and the protection of national borders
will continue to dominate the investment
migration agenda in 2023 and beyond.
It seems more than likely that investment
migration will continue to play an important
role in attracting foreign investment
and funding key government activities
in several countries. After having to
deal with the Covid-19 pandemic, many
countries have little, or no reserves left
to cushion the effects of the new crises.
The opportunity to raise revenue from
investment migration – given that there is
also limited room to increase taxes – will
remain a major motivation for countries to
retain or introduce investment migration
pathways. However, at the same time,
support for investment migration pathways
by supra-national entities, including the
European Union, is at its lowest level.
Reinventing an old concept
Investment migration is not a new
phenomenon. Some industry experts point
out that it was common in the Roman
Empire to grant citizenship in exchange for
money, while others say that in 17 th -century
France, under Louis the Great, it became
a widespread practice to sell noble titles
to affluent commoners to finance wars.
Investment migration today is understood
to have its origins in the Caribbean when St.
Kitts and Nevis launched the first modern
citizenship-by-investment pathway in
1984 as a tool for economic development.
Since then, the business model has
quickly evolved and was developed further
with Portugal’s introduction of residency
by investment. In 2010, four EU member
states hosted residency pathways, just
seven years later, nearly half of all member
states established them. Today, investment
migration is featured in immigration
law in most UN recognised countries,
albeit in different forms and shapes.
Globally, some 60 countries are actively
promoting their pathways, 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
– all offering paths for immigrant investors
– have long been among the favourite
destinations for high-net-worth individuals.
Citizenship-by-investment pathways
usually receive less than 1,000 applications
per year. However, Turkey seems to be
the exception, with around 7,300 new
citizenship investors between 2017 and
2020. Residency by investment is the more
popular choice. All pathways together are
receiving tens of thousands of applications
per year, generating billions in investments
that are being mobilised to create jobs
and encourage economic activity.
Revenue generator
Investment migration is estimated to
generate €20 billion annually, and income
from investment migration represents
anything between 2% and 30% of GDP
in some countries. While the economic
impact of investment migration is marginal,
investment migration income is a lifeline
for smaller countries and microstates.
Countries typically offer not just one
way to invest, but also a range of qualifying
options, which can include investments
in real estate, businesses, government
bonds, stocks and investment funds, as
well as deposits in a bank and donations
to the government or to the public good.
Across the world investment migration
has the catalyst for major infrastructural
improvements, including resorts, harbours,
airports, hospitals, office buildings,
luxury residential developments and
even an airline, which in turn have had a
massive multiplier effect on the respective
economies. Investment migration is not
only influential in delivering cuttingedge
infrastructure, investments
into companies, start-ups and R&D
programmes; it is also having the effect
12 - Investment Migration Yearbook 2O23

IM YEARBOOK
of generating whole new economic sectors
that did not exist before their introduction.
While the macroeconomic impact
of investment migration cannot be
underestimated, international organisations
such as the IMF urge governments to ensure
that the funds are channelled towards
productive investments that will pay dividends
in the future and not be tempted to finance
day-to-day expenses. The policymakers
equally acknowledge that income from
investment migration provides a vital source
of funding for economically weaker countries.
Market pressure
As climate change displaces more people,
many argue we need a new mechanism
to manage global labour mobility, the
world’s biggest economic resource,
more effectively and efficiently.
While trends in global mobility have
noticeably changed since the Covid-19
pandemic, they continue to be interrupted
by the war in Ukraine. The market is feeling
the absence of Russian citizens, with most
countries suspending applications from
Russian and Belarussian nationals when Russia
invaded Ukraine, stating that the necessary
due diligence checks cannot be carried out.
Turkey’s path to citizenship for investors is
the exception and has therefore seen a wave
of Russian applicants in 2022 after initially
catering primarily to Middle Eastern investors,
including Iranians, Iraqis and Afghans.
To add a twist to the story, Russia
pushed forward with plans to launch its
own investment migration pathway and
will accept applicants from January 2023.
Some analysts expect that primarily Chinese
investors will take advantage of it. One
reason is that Beijing is making it harder for
its wealthy citizens to apply for investment
migration visas in Europe and the US
in a bid to head off potential capital
outflows via residents looking to escape
the country’s zero-Covid policy. Chinese
nationals, which long accounted for the
majority of applicants to any pathway, have
not disappeared. However, many agents
report that their number has decreased.
Meanwhile, India, along with other
countries in South-East Asia, is rising to the
fore as an important source market. Some
media outlets already called it “the Great
Indian Investment Migration”. Although
India is experiencing strong economic and
population growth, the country’s infrastructure
has not kept up with this expansion. The
result is that air, water and noise pollution
are part of everyday life in India’s megacities
and are often cited as reasons why Indians
consider investment migration pathways.
Investment Migration Yearbook 2O23 - 13

IM YEARBOOK
EU challenges
Meanwhile, investment migration is facing
a barrage of criticism from policymakers
in the European Union. One reason for the
opposition is that citizenship and residency
pathways in one EU country automatically
confer rights concerning all EU member
states. These rights include free movement,
the right to vote, consular protection, and
access to the internal market. In addition,
EU policymakers argue investment
migration poses risks of money laundering,
security, tax evasion and corruption.
The perceived lack of transparency
and non-established harmonised
governance practices across member states
operating exacerbate such concerns.
In 2020, the European Parliament has
called on EU member states to phase out
their schemes, while in March 2022, the
European Commission recommended
that member states operating investor
citizenship pathways should terminate
them immediately, while it looks to regulate
residency pathways in a stricter way.
Moreover, two years after it first initiated
infringement procedures against Malta
over its investor citizenship, the European
Commission referred the case to the
Court of Justice of the European Union
(CJEU). Many industry professionals
welcome the fact that the CJEU has now
been called to rule as this would provide
much needed clarity on the matter. Sector
experts say an EU legislative framework
on investment migration is inevitable.
However, the process of adoption
of any additional legislation could take
several months if not years. Thus far,
there has been no official communication;
however, the European Parliament had
already made a few suggestions. These
included phasing-out of investor citizenship,
introducing comprehensive regulation for
residency pathways, and possibly creating
an adjustment mechanism that would
require member states operating residency
pathways to compensate other member
states for the “negative consequences”
through a contribution to the EU budget.
While the EU’s primary focus is
member states operating such pathways,
non-EU countries with visa-free access
to the European Schengen area have also
been put under the microscope. Countries
in the Caribbean operating investment
migration pathways should ensure they
apply the highest level of due diligence and
best-practice industry standards should
they wish to maintain visa-free access to the
EU. Vanuatu has already lost its visa-free
access to the EU due to the inadequate
procedure of vetting its applicants.
More to do
Boston Consulting Group predicts
that the world will continue to open to
global migrants despite considerable
political polarisation in some countries.
Investment migration is not without its risks,
but it’s also an important economic tool for
many countries. The Investment Migration
Council shares a strong responsibility
about what the future should bring
Initiatives of the Investment Migration
Council, such as the development of
common due diligence standards and an
anti-bribery code, show that the industry is
recognising the need to either self-regulate
effectively or accept that rules will be
imposed on it. In the presence of so much
pressure, the industry can only survive if
every party involved acts in a transparent
manner. It’s unfortunate that the sector
remains largely unregulated, with only a
handful of countries having established
an independent regulator to oversee the
operation of their programmes. Moreover,
to this date, there are no harmonised
procedures on how these pathways operate.
The immediate challenge for the
industry is to get all industry stakeholders
to commit to the highest standards of
transparency and good governance. It is
crucial that countries communicate how
application decisions are made and share
more information with other countries,
players in the financial services industry
and policymakers, including those in the
EU. As a democratic body with complex
bureaucratic procedures in place, the EU
relies on constructive dialogue with all
concerned partners to develop its policies.
A regular information exchange is therefore
in the best interest of all stakeholders.
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IM YEARBOOK
New mobility regimes
The investment migration landscape is
rapidly changing. Globally, a whole range
of mobility regimes are available in the
marketplace. A by-product of Covid-19, the
number of digital nomad visas available
has increased steadily, while most nations
today offer either entrepreneur- or startup
visas, which can also deliver real
economic benefits in terms of job creation,
new services and supporting a sustained
culture of innovation, to the host country.
As a customer-oriented sector,
investment migration is also gearing up to
service new client segments. The average
age of multi-millionaires in the world has
decreased over the last two decades. Service
providers report that in emerging market
economies the average age of applicants is
between 35 and 45 years old, and many of
them are young entrepreneurs spurring
demand for active investment options
as opposed to the traditional passive
alternatives. A closer look at the new
generation of mobility regimes can offer
powerful reflections to those countries
who wish to ensure their pathways
will enjoy support in years to come.
Meanwhile, around the world,
powerful demographic, economic and
technological changes are increasing
women’s financial strength and
independence. Investment migration, like
much of the wealth management industry,
has been primarily geared towards a
male clientele; however, attracting and
retaining female customers will be a critical
growth factor for agents and advisors.
A virtual future
If there was one headline that dominated
business publications this past year, it was
the arrival of the metaverse. Metaverse
technology is now a major part of
discussions on the internet, and many
believe that it will – much like the internet
did – redefine how people interact with
their environment and with each other.
In this context, virtual citizenship seems
to be a very real possibility. A properly
functioning metaverse needs several
building blocks to function, and many
believe extended reality will uplift the
user experience in the metaverse through
devices such as AR smart glasses, haptics,
hologram displays, and VR headsets.
Currently, VR is used mostly for gaming.
But in the future of the metaverse it will
be used for almost anything, including
work, education and socialising, which
would reduce the need for physical travel.
You believe the idea is far-fetched? Just
think of Estonia’s successful e-residency
programme. While e-residents are
permitted to open bank accounts, start
companies, sign documents, and pay tax
under Estonian jurisdiction and law, they
gain no rights to live in Estonia, nor do they
accrue any other kind of physical benefit.
Necessity versus nationalism
Geopolitical tensions, volatile markets, and
the threat of climate change: the diverse
and partly overlapping crises are creating
a new desire for security, and thus demand
for investment migration is not expected
to fall. Boston Consulting Group (BCG)
expects migration to exceed 4% of the
global population by 2030, or more than 350
million people, up from 280 million in 2022.
“Rather than moving toward a less globalised,
more nationalistic future where migrants are
viewed as a harbinger of unwelcome change,
we predict that the world will continue to
open to global migrants despite considerable
political polarisation in some countries,”
BCG predict. Why? Because “necessity will
trump nationalism” as cities and countries
compete for talent, residents and investment.
For many sector experts, investment
migration should not be discussed separately
from other forms of legal migration. As
climate change displaces more people,
many argue we need a new mechanism to
manage global labour mobility, the world’s
biggest economic resource, more effectively
and efficiently. There has already been a
shift in public opinion in many countries.
In the UK and the US, the tendency to see
immigration as a problem to be controlled
is in decline, while Canada says higher
immigration is necessary to fuel economic
growth. Properly managed, immigration,
including investment-based forms, is a
resource that can deliver gains for all.
Bruno L’ecuyer is Chief
BIO Executive of the Investment
Migration Council. Bruno leads the
Secretariat and is responsible for all
IMC operations. A regular contributor
to international publications and
conferences in Europe, North America,
Caribbean, Middle East and Asia, he
has held positions in London, Paris
and Hong Kong. Bruno was previously
head at a national financial services
association, acting as a bridge
between government, industry and
international policy institutions. 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 and
chairs the Advisory Committee.
Investment Migration Yearbook 2O23 - 15

IM YEARBOOK
In conversation with Dimitry V. Kochenov and Elena Basheska
“It is all about
European
blood”
The IM Yearbook sits down with Dimitry V. Kochenov
and Elena Basheska to discuss the European
Commission’s views on investment migration.
“It Is All About European
Blood, Baby!” This is the
attention-grabbing and
thought-provoking title of a
new report you just wrote.
Why did you choose this title?
Dimitry Kochenov (DK): It is just a
reflection of reality: The European
Commission makes a clear distinction
between those who acquire European
‘citizenship by blood’ and all others. When
‘blood’ is there, nothing else – such as
residence, place of birth or income – usually
matters, so the links to Europe are presumed
to be there when one can trace the right
ancestry. This means that the whole concept
of citizenship as promoted by the European
Commission is a blood-based status.
I’ll give you an example of citizenship by
decent, which makes the absurdity of this
quite obvious. So, if someone who has lived
in Australia for many generations, suddenly
finds a Greek ancestor, then this is the ‘blood
link’ that counts and that automatically
enables this person to get a Greek passport
and all the rights in the European Union.
Of course, no due diligence and no other
checks other than those about the blood
connection are carried out. However, make
sure all the line is male. Any grandmother
would ruin the construct and you will
need to spend years and/ or a lot of money
to acquire European documents.
Be it as it may, it’s clear that the only
thing that counts is the blood line. This
explains the title, and there is nothing
exaggerated about it. The blood paradigm
is only broken by naturalisations, which
amount to less than 2% of citizenship
acquisitions around the world.
Over the past eight years,
EU institutions have turned
to investment on numerous
occasions. For those who are
not familiar with the issue,
can you briefly summarise the
EU’s actions and initiatives?
DK: It all started with a debate in the
European Parliament (EP) when Malta
was about to introduce its CBI in 2014. It’s
interesting to note that back then there
was already a programme in Ireland,
which didn’t raise any red flags and was
operating in a similar way to the one
that Malta planned to introduce. And
Cyprus did not interest the EP either:
context did not seem to matter.
In other parts of the world such
as the US and Canada, programmes
were operating, too. But the European
Commission did not think critically of
these programmes. They only started
exercising pressure on Malta as a result
of the commotion in the European
Parliament, which claimed that European
citizenship should not be for sale. So,
one part of the dispute revolves around
the question whether the EU only
wants to accept the blood connection
or whether the EU wants to consider a
more open version on the modalities of
citizenship acquisition. The essence of
EU citizenship is essentially at stake.
“No sane academic voice would argue that the EU has
competence to legislate here, which is why all the documents
that the Commission released so far with the aim of attacking
the investment migration industry are not legislative
proposals, even if they attempt to push the member states,
purely politically, to alter their regulation in a certain way.”
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IM YEARBOOK
The other part of the dispute concerns
the EU’s competence. When the European
Parliament released its resolution in
2014, it underlined that the EU doesn’t
have competence on the matter. Viviane
Reding, Vice President of the European
Commission, said the same earlier when
asked about Cyprus, only to change
her mind concerning the scope of EU
law when Malta entered the picture.
Knowing that the EU has no competence,
the Commission pushed Malta, simply
by exercising political pressure, to
introduce a legal residency requirement.
In the years that followed, the
position and the tone of the EU changed
gradually as if the Union law about the
separation of competences between the
member states and the EU had changed,
which was, of course, not the case. So,
in the more recent reports of both the
European Parliament and the European
Commission, we already see that somehow
the EU institutions think they should
have a say in citizenship questions.
Elena Basheska (EB): Then, at the
end of September 2022, the Commission
announced that it would refer Malta
to the Court of Justice of the European
Union (CJEU). The Commission insists
that CBI programmes are a violation
of the principle of ‘sincere cooperation’
enshrined in Article 4(3) of the Treaty of
the EU (TEU) because it confers citizenship
in the absence of a ‘genuine link’.
To date, Malta operates
the only active formal CBI
programme in the EU;
however, you argue that
investment migration is
legally practised by the
absolute majority of the EU’s
member states. Can you
give us a few examples?
DK: Yes, in fact the backdrop to all the
above is that today almost 20 member
states offer residency by investment.
And, of course, we know very well that
accumulating residency is the easiest
path to EU citizenship, if you cannot find
blood. Moreover, most EU countries –
although they do not operate formal CBI
programmes – allow for discretionary
naturalisation on the grounds of ‘special
achievements’, which often includes
economic achievements. The difference
between the two approaches is formal
rather than substantial: CBI programmes
are specifically designed to attract foreign
investors, set clear criteria for applicants
and are marketed by service providers,
while naturalisation on the grounds of
‘special achievements’ is traditionally
less transparent in terms of qualifying
criteria and not marketed by agents.
You claim that the EU lacks
legislative competence in the
area of citizenship while the
principles of international
law also do not back the
Commission’s position. Can
you outline your reasoning?
DK: The ABC of global citizenship law is
that states are free to confer citizenship on
those whom they consider qualified under
the Hague Convention of Nationality and,
unquestionably, under EU law. No sane
academic voice would argue that the EU
has competence to legislate here, which is
why all the documents that the Commission
released so far with the aim of attacking
the investment migration industry are not
legislative proposals, even if they attempt to
push the member states, purely politically,
to alter their regulation in a certain way.
France still decides on who is French and
retains all the rights to do so, just as Malta
decides on who is Maltese and Finland on
who is Finnish. The law is crystal clear.
You argue that the European
Commission is abusing its
power and has concerted
a “large-scale political
campaign to mislead the
public”. What other elements
in the Commission’s narrative
led you to this conclusion?
DK: The Commission is routinely
demonising investment migrants – an
approach, which is questionable at best.
Its core argument in numerous documents
could be boiled to the following: thirdcountry
nationals who invest in member
states may be criminals and, therefore,
investment migration programmes create
security risks; the fact that EU citizenship
provides for cross-border rights increases
such risks further. The Commission seems
to make assumptions about investors largely
on the basis of their status as beneficiaries of
RBI and CBI programmes. The presumption
of innocence, apparently, does not enter
the picture. This is contrary to the EU
Charter and wider EU law, especially given
that discrimination based on the mode
of citizenship acquisition is prohibited.
In fact, the Commission’s attack against
investment migration assumes that it is
acceptable to target groups of EU citizens
and single them out for differentiated
treatment based on the ground on which
nationality of an EU member state and,
thus, EU citizenship had been acquired.
This type of discrimination is squarely
prohibited in EU law. Treating Europeans
differently based on the rule which made
them EU citizens is not what EU law
allows and most national constitutions
would prohibit it too. The crusade against
CBI is an assault on this principle.
What, in your opinion,
are other problematic
aspects in the European
Commission’s approach?
DK: Another critical aspect is the whole
assumption that there needs to be
some sort of link that should underpin
a person’s citizenship when we have
already seen that blood is the only one
that the European Commission and the
European Parliament are interested
in. Furthermore, it goes directly
against the EU’s internal market and
the principle of non-discrimination
on the basis of nationality – the very
core of what the EU is all about.
In fact, concrete member state
nationality is made irrelevant by the
successful operation of EU law. So, for
a child born in Luxembourg with a
Danish passport, who lives his or her
whole life there and has no connection
to Danish society, the principle of nondiscrimination
holds. Luxembourg
will not be legally allowed to mistreat
this child. The CJEU has already
ruled that member states of residence
are not entitled to question lawfully
acquired citizenship of the EU.
What other comments would
you like to make about the
European Commission’s
attitude towards
investment migration?
EB: The Commission makes frequent
references to genuine links and the
principle of sincere cooperation.
These are somewhat misplaced.
The Commission’s argument is that
a lack of genuine link undermines
the status of EU citizenship in
accordance with Art 20 TFEU and
is incompatible with the principle
of sincere cooperation enshrined in
Article 4(3) TEU. This argument of the
European Commission is very weak.
Furthermore, infringement of
the principle of sincere cooperation,
without violation of a more specific
Treaty obligation, cannot be successfully
invoked, and Article 20 TFEU which
is often put by the Commission in the
same context with the principle of
sincere cooperation does not impose
such specific obligation on member
states. It, therefore, remains unclear
how investment programmes infringe
Article 4(3) TEU. It is difficult to imagine
that the principle of sincere cooperation
could be successfully invoked in the
context of investment migration. Article
4(3) TEU concerns the achievement of
EU objectives and genuine compliance
with EU law, none of which seems
to relate to investment migration.
Investment Migration Yearbook 2O23 - 17

IM YEARBOOK
You mention that the
European institutions
used the war in Ukraine
as an opportunity to again
voice its opinion about
investment migration. What
thoughts would you like
to share about this issue?
EB: In March 2022, the EP called on
the member states with residence
by investment schemes to review all
beneficiaries of such residence status
and to revoke those attributed to Russian
high-net-worth individuals and their
families, in particular those linked to
sanctioned individuals and companies.
The Commission equally regarded the
start of the war as a pretext to voice its
opinion on investment migration, calling
for the immediate termination of existing
CBI programmes and stricter checks of
RBI in respect of Russian and Belarusian
citizens who naturalised or obtained
their residence through investment.
However, the Commission did not
make the same recommendation about
Russians and Belarusians who obtained
or are in a process of acquiring their EU
citizenship for ‘special achievements’ or
who claimed citizenship by decent. The
Commission justified such a move with
‘the difficulty to conduct the appropriate
security checks and due diligence in
these particular circumstances and in
view of the gravity of the situation’. And
again, the Commission did not express
similar concerns about Russians and
Belarusians who are acquiring their
EU residence permits on the basis of
grounds other than investment migration.
This suggests that the Commission is
fighting its own war against investment
migration in this context rather than
being genuinely concerned about security
risks. Such policy is dangerous, especially
if we know that nowadays Russian
elites in the country are expected, if not
forced, to support the war in Ukraine.
Moreover, stripping Russians and
Belarusians of their citizenship acquired
through investment may be problematic
even if that is conducted for justified
security reasons. EU member states have
conditions for withdrawal of citizenship,
including for security reasons and
such rules are equally applicable to
naturalised citizens of all nationalities
and notwithstanding the naturalisation
grounds. Applying such rules to Russians
and Belarussians specifically, as seemingly
suggested by the European Commission, is
arbitrary and discriminatory. Even
more so, according to experts in the
field, the deprivation of nationality of
citizens on national security grounds
is presumptively arbitrary and
exceptions to that are very limited.
In the report, you talk about
the “failure of structures”
and “abusive misuse of EU
law”. What aspects of this
development worry you
the most and what change
would you like to see?
DK: What worries me the most is that EU
citizenship, which was construed first to
liberate us from the bonds of nationalism,
is now being hijacked by some 19 th -century
blood nationalists who happened to
hold the upper hand in the European
Commission. I can’t believe that the
Commission’s Legal Service, which is the
in-house legal counsel to the Commission,
supported the decision to refer the matter
to the CJEU. To me all this is a clear sign
that basic checks and balances within the
Commission are absolutely hijacked by
politicians who have zero interest in citizens’
rights and in the preservation of the main
achievements of the European Union.
What line of argument do you
think the CJEU will adopt?
DK: The CJEU is in a very difficult
situation. Obviously, no one is interested
in the European Commission losing its
face. However, should the Commission
win this case, it would destroy the main
achievements of the EU. The court will
have to be extremely careful in trying
to preserve the internal market without
being too harsh on the Commission.
What I can predict is that the CJEU
will focus on the problems, which the
Commission tries to connect with
investment migration, which would be
money laundering, terrorist financing
and tax evasion. Ironically, these are the
fields in which the Commission already
has competence to act. If the Commission
thinks there is money laundering going
on, it has the competence to legislate and
should work with the member states to
make sure that legislation is operational on
the ground. So, then it would not be about
the institution of citizenship but how to
deal with the negative consequences of a
particular way of acquiring citizenship.
Do you think the case and,
ultimately the CJEU’s decision,
will have repercussions on the
countries outside of the EU?
EB: I think it depends on the outcome. If
the CJEU disapproves the Commission’s
arguments, it will probably stimulate
other member states within the EU and
even beyond to launch formal investment
migration programmes. So, the court case
will have the opposite effect of what the
Commission wanted to achieve. And again,
I don’t see how the CJEU can support the
Commission’s argument that CBIs violate
the principle of ‘sincere cooperation’ due
to the absence of the ‘genuine link’.
DK: We also need to keep in mind that the
EU is not the top market for citizenship by
investment, and we know that what the
EU thinks about it has a very limited effect
on what happens outside of the EU. And
if we are honest, declaring a war against
investment migration when you are not
actually the market leader in investment
migration is a very problematic start to
begin with. But even if the CJEU will not
uphold the current law, it will probably
not destroy investment migration at
all. Investment migration will simply
move to other regions of the world.
Professor Dimitry V.
BIOS Kochenov leads the
Rule of Law Workgroup at the Central
European University (CEU) Democracy
Institute and teaches at the Department
of Legal Studies. His research focuses
on the principles of law in the global
context, with a special emphasis
on the Rule of Law, citizenship, and
the enforcement of EU values.
Dr Elena Basheska is a Post-doctoral
Research Fellow at CEU Democracy
Institute. She combines this position
with legal research and advisory
practice in the United Kingdom.
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IM YEARBOOK
The IM Long Read
A Fragile
World Economy
and New
Opportunities
for Investment
Migration
Andres Solimano, IMC Chair as well as founder and
chair of the International Centre for Globalisation
and Development, analyses the current economic
climate and its effects on investment migration.
The world economy is uncertain and
experiencing a deterioration that is
expected to continue in 2023 only
to recover in 2024. Currently, the global
economy is effected by an unpleasant
combination of high inflation, higher
interest rates and serious geopolitical risks.
Moreover, there is the possibility of a new
debt crisis in low-income countries and
highly indebted emerging economies.
In the last three years, the global
economy has experienced the effects of the
Covid-19 pandemic followed by a global
recession. World GDP contracted in 2020
due to forced lockdowns, which created a
supply side shock as people could not go
to work and supply chains broke down.
While there was a rapid turnaround with
a strong recovery in 2021, more structural
challenges such as climate change,
entrenched inequality, the replacement of
fossil oil energy matrix to support green
growth, and environmental fragility
remained. Global institutions such as the
International Monetary Fund, the World
Bank and others still expect growth in 2022
and 2023 for the world, although they have
adjusted their projections downwards.
Nonetheless, this uncertain economic
environment may have positive effects on
investment migration flows as the insurance
value of programmes is rising. Investors will
make an extra effort to find more secure
locations where to invest their money and
secure a better environment. Countries
offering more stability, predictability
and good investment opportunities
will benefit from this development.
The shift to high inflation
After decades of 2% to 3% inflation per
year in industrial economies, since the
Covid-19 pandemic, and exacerbated
by the war against Ukraine, inflation
has accelerated and reached annualised
levels of around 8% in 2022.
Large economies such as the US, UK,
Germany and Spain are experiencing
annual inflation above 10%. Some countries,
such as the Baltic ones, have an inflation
rate hovering around 16% to 20%.
Several demand and supply factors have
contributed to the acceleration of inflation
in the world economy since 2020-21. One
reason is the accumulation of household
liquidity due to a lack of consumption
opportunities during the lockdown period.
When mobility restrictions were lifted,
this excess liquidity went directly to the
market, pushed up prices in the process.
Tied to this are also the fiscal transfers and
subsidies granted by national governments to
households in the Covid-crisis era. These have
contributed to increase aggregate demand,
leading to fiscal-led inflationary pressures.
Moreover, cost-push effects associated
with supply constraints due to strains
on maritime transport facilities and the
subsequent rise in freight rates along with
other disruptions in supply chains increased
prices, while the rise in food and energy prices,
which started in 2020 but exacerbated after
Russian’s invasion of Ukraine in February
of 2022, added to “headline inflation”.
A concern is that these inflationary
pressures may become entrenched.
Inflation dynamics over the next two
20 - Investment Migration Yearbook 2O23

IM YEARBOOK
years will also depend on second-round
effects such as the response of wages
to previous price hikes as well as price
adjustment policies by governments.
A key player in the future evolution
of inflation are central banks. Nowadays,
around the world, monetary authorities
are tightening monetary policy through
higher interest rates to reduce inflation.
The sources of inflationary pressures
vary across economies. While there is
some consensus that inflation in the US
is largely associated with an ‘overheated’
economy’ due to exaggerated levels of
demand in both the goods and the labour
market relative to the potential supply,
it is an open question whether this is an
accurate description of the economic reality
of America. Low unemployment is used
as an argument to back the hypothesis
of “excess demand in America”.
For Europe, the diagnosis is different,
and it focuses on the very sharp increases
in the price of gas and oil, imported from
abroad, mostly Russia. Thus, a supplyshock
story describes the inflationary
situation in Europe better while a demandside
story is more plausible for America.
Among emerging economies, inflation is
closely related to the energy price and food
price shocks coming from international
markets, so we are dealing with a mix of
supply-shock and imported inflation.
An impending recession?
As mentioned, the IMF, the World Bank,
the OECD, and the European Central
Bank have all adjusted downwards
their GDP growth forecasts for 2022 and
2023. In turn, recessions are anticipated
in 2023 for Germany, Italy and Russia,
while the two major powerhouse
of the world economy – the US and
China – will experience slowdowns.
The causes of the global slowdown
are related to the effects of higher interest
rates to fight inflation, compounded by
supply energy and food price shocks
and the effects of increased uncertainty
affecting private investment and
consumption, two main drivers of aggregate
spending and economic activity.
In addition, world trade has
declined due to supply disruptions
and new geopolitical realities, shaped
by embargoes and a shift to ‘secure
sources’ of supply – a major change when
compared to the previous rule of “cost
minimisation” that governed globalisation
in the last three decades. All these
factors are affecting global growth.
The risk of a debt crisis
During the Covid-19 crisis of 2020-21 many
governments were forced to increase
their levels of foreign borrowing. They
needed financing to fund Covid-related
support programmes set up to protect
the living standards of their people who
could not go to work and generate the
necessary income to sustain themselves.
Importantly, this borrowing was
contracted, mainly in US dollars and
took place at generally low interest rates.
However, during 2022, macroeconomic
and financial conditions have
changed dramatically. A sharp rise
in interest rates, a very strong dollar
and portfolio capital outflows from
developing nations at the periphery to
advanced economies at the centre may
eventually trigger a new debt crisis.
For context, in the early 1980s, a very
similar combination of economic factors
affected the world economy following
inflation stabilisation policies in the US
pursued by the Federal Reserve: interest
rates increased, the dollar appreciated
against main world currencies and
currencies of the periphery. In addition,
capital flight was the norm with money
flowing from economies of the global
south to the US and other advanced
economies. The result was the onset of a
debt crisis in several large economies of
Latin America, Turkey and the Philippines
including forced debt rescheduling, debt
cancelations and debt defaults. These
episodes were also accompanied by
currency crashes, recessions, dwindling
investment and portfolio capital outflows.
We have seen several debt crises in
the last three to four decades: the East
Asian crisis in 1997-98, the convertibility
crisis in Argentina in 2000-01, debt
stresses in Brazil in the late 1990s and
the global financial crisis of 2008-09.
Yet, history does not need to repeat
itself. After four decades of repeated debt
crises around the world there are better
mechanisms to anticipate them and cope
with them if they take place. Exchange
rates regimes in developing countries are
more flexible now than then, international
reserves in the hands of central banks are
higher and fiscal policy has become more
ordered and predictable. Moreover, today,
the IMF has in place a set of new financing
instruments, several of quick disbursement,
that could help avert the repeat of debt
crises. However, there is little space for
complacency as financial conditions are
fragile even in large mature economies. Just
think of the sharp decline in the value of the
pound and bond prices following the Truss-
Kwarteng regressive tax cut and spending
increase package of late September in the
UK, a policy mix that was later reversed.
Investment migration
An important consequence of the current
economic difficulties is that the global
economy is becoming more fragmented,
risky, and unpredictable. How can these
developments affect investment migration?
Two main channels are relevant: First, in a
world of heightened economic, geopolitical
and security risks, an increase in the
demand for investment migration is likely
to follow. Option theory predicts that a
vehicle, programme, or policy – think of
investment migration – that enhances
opportunities in risky environments carry
a positive price, or insurance value.
Second, governments in tough times
are in increased need of foreign capital,
talent, entrepreneurial capacities, and
cash, and therefore will view investment
migration more favourably. This already
happened after the 2008-09 global financial
crisis and is bound to happen again in the
current circumstances. Even though, the
golden years for investment migration of
the 2010s might be largely over for various
reasons, the economic need of countries for
foreign financing, along with a personal/
household demand for geographic risk
diversification, remains. Therefore, it is
very likely that investment migration will
continue to thrive for quite a while.
Dr Andrés Solimano holds a
BIO Ph.D. in Economics from the
Massachusetts Institute of Technology
(MIT). He is the chairperson of the
Investment Migration Council, as
well as founder and chair of the
International Centre for Globalisation
and Development (CIGLOB). Previously,
he served as country director at
the World Bank, executive director
at the Inter‐American Development
Bank and director of the project on
International Mobility of Talent with
the United Nations University ‐ World
Institute of Economic Research.
Investment Migration Yearbook 2O23 - 21

IM YEARBOOK
What’s ahead for Citizenship by Investment?
The idea of citizenship by investment has long provoked discussion
and debate amongst critics and supporters. The IM Yearbook has
invited Eric Major, CEO of Latitude and Patricia Casaburi, Managing
Director of Global Citizen Solutions, to share their thoughts
and opinions on the future of citizenship by investment.
Pressure from the EU
and the US is growing
to end citizenship by
investment (CBI) pathways
in Europe and beyond.
Are we seeing the end of
citizenship by investment?
Eric Major: Certainly not! Citizenship is a
sovereign matter, which no supranational
body can fully dismiss or carry off. The
question is whether they can influence a
country to cease it, to which the answer
is Yes. Some nations will be influenced,
possibly Malta and Montenegro, and
others will not be. The Caribbean
nations, I suspect fall in this category.
However, in the end, CBI will be around
for as long as independent states exist.
Patricia Casaburi: I think we will see
an evolution rather than the end of
citizenship by investment. Most countries
have a few different paths to temporary
or permanent relocation, and we are
seeing governments being creative in the
development of visas for various market
demands, hence the popularity of the
digital nomad visas in EU and beyond.
Investment migration
professionals have adopted
important self-regulatory
mechanisms, while
programmes insist that
they apply the highest
levels of due diligence. In
your opinion, why have
these initiatives failed to
convince critics so far?
Patricia Casaburi: Critics of CBI and
RBI who are part of the EU or other
governments would likely want to see
more harmonisation on the due diligence
checks, more cross-border reports and
background checks on main applicants
and family members regarding sources
of wealth, corruption, and tax evasion.
Of course, these are in place, but a lack of
standardisation and transparency exists.
Eric Major: The truthful answer is that our
industry has experienced very damaging
blemishes, even over the last three years,
which brings fair doubt to the veracity
of the industry’s claim to its high level of
due diligence: Cyprus, Vanuatu and even
Portugal quickly come to mind, let alone the
early days of the Caribbean CBIs. It’s harder
to build a reputation than it is to destroy it.
There are concerns that if
CIPs are phased out, the
economies of some Caribbean
countries will collapse. What
comments would you like
to make about this issue?
Patricia Casaburi: Some countries in the
Caribbean, like St Lucia, do not rely solely
on CBI and have a diverse tourism industry.
The population is often well-educated;
however, the islands suffer from a lack of job
opportunities and of course, are often hit by
hurricanes. So, unless these governments
propose ways of diversifying their economy
with agriculture, for example, the downfall
of CIPs would impact them hugely.
Eric Major: As I already mentioned, I do
not believe the Caribbean CIPs will be
phased out. Yes, they could potentially
loose visa-free travel privileges in the
Schengen area, but I am 100% convinced
they will continue to exist. Last I checked,
there were more millionaires in the US
than in any other country in the world,
and Americans don’t apply for Caribbean
CIPs because of Schengen access. They
buy it because it is a safe destination
that provides them a great lifestyle.
In your opinion, how should
CIP countries and the industry
best respond to the situation?
Eric Major: Let time show us how things
will play out. At this point in time, there
is nothing the industry can do to reverse
the decisions that have already been made.
However, we should encourage the CIUs
to have a 10%-15% refusal rate. Too low a
refusal rate isn’t credible in my mind.
Patricia Casaburi: Four things come to
my mind: Implementing the sought-after
standardization of due diligence, improve
communication between member states and
third countries, continuous monitoring but
also, investments that fit a bigger agenda.
For example, investments in climate change
and advancing energy targets, solutions that
ensure the affordability of rent for locals,
the creation of jobs, social programmes, and
productive investments in the economy.
What are your expectations
for citizenship and residence
by investment for the next
three to five years?
Patricia Casaburi: I predict that there
will likely be more regulation, the
introduction of an EU regulatory body
that oversees programmes at the country
level, productive investment, as well as
full cross-border transparency. We may
see the rise of programmes that cater to
other parts of the world, like the Asian
as well as the South and Latin American
markets. Motivation is also ever evolving
and geo-political events matter.
Eric Major: Lots of changes
coming, and I am still bullish!
BIOS
Patricia Casaburi is the
Managing Director of
Global Citizen Solutions. She previously
worked for The Rezidor Hotel Group
as a Corporate Account Director.
Eric Major is one of the pioneers of
the investment migration industry.
A former CEO of Henley & Partners, he
is now CEO and Chairman of Latitude
– Residency & Citizenship Solutions.
22 - Investment Migration Yearbook 2O23

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IM YEARBOOK
From refugee past to EB-5 professional:
One man’s perspective on
MIGRATION
At a time when Iran is rocked by the biggest wave of unrest and antiregime
demonstrations it has seen in years, Abteen Vaziri recalls how he had
fled the country more than three decades ago. Vaziri, who is today a key
figure in the US EB-5 industry, says due to his refugee past he has a unique
perspective on migration that many of his fellow practitioners lack.
One evening in 1989, Abteen Vaziri’s mother
told him that the family would flee Iran.
He was nine years old and in the
middle of school exams. He had studied
a lot and didn’t want to leave his home
in Tehran to not miss the test. But he
didn’t have a choice, although he didn’t
understand what was happening: “It was
odd that while my parents feared for their
lives, I worried about school,” he recalls.
Today, Vaziri sits in an office in New
York City. He is the Managing Director
of Brevet Capital, an investment firm
which has about $2billion of assets under
management. In addition to overseeing
the business operation, he manages one
of Brevet’s five funds: the Brevet Capital
Immigration Fund, an EB-5 compliant fund.
Vaziri’s family first attempted to leave
Iran in 1979 when the Islamic Revolution
shook the world. The revolution turned
Iranian society upside down and ended with
the establishment of the world’s first Islamic
state. Mohammad Reza Shah Pahlavi, the
Investment Migration Yearbook 2O23 - 25

IM YEARBOOK
leader of Iran since 1941, left the country
in January 1979 and Ayatollah Ruhollah
Khomeini, a previously exiled opponent of
the Shah, returned and took control of Iran.
Prior to the revolution, Vaziri’s father
was an officer in the Iranian air force.
Expecting a brutal crackdown on opponents
and weighing their options, his parents
– like many others – wanted to get out
of Iran. “We sold all our assets and paid
$15,000 to a group of smugglers who were
supposed to take us by horse back and
camel to the border and into Pakistan.
My aunt, my uncle and their son went
first, but my aunt got malaria in Pakistan
and died. My parents were so distraught
and didn’t want to leave Iran anymore.
So, the smugglers pocketed our money
and passports while we stayed behind.”
After the regime change, Vaziri’s father
was court-martialed and sentenced to
death. However, while he was in prison,
Iraqi forces launched a full-scale invasion
of Iran, beginning the Iran-Iraq War
in September 1980. Suddenly, military
personnel were needed. “My dad was given
a pardon but in return he had to join the
air force again. He was given back his job in
military logistics, moving and coordinating
equipment, supplies and troops.”
In 1989, when the war ended, Vaziri’s
father finally managed to obtain a fake
passport. As a military officer, he wasn’t
allowed to have a real passport. “He then
escaped to Austria and later travelled
to Germany. My mother, my sister and I
also left Iran, but we first went to France.
We then joined my father in Aachen,
Germany, where we were accepted as
political refugees,” Vaziri explained.
Vaziri arrived in Germany in November
1989, which at that time was experiencing
its own watershed moment. “I remember
that it was all over the news that the
Berlin Wall had come down. Until today,
every time I see pictures of the fall of
the Berlin Wall, I equate that in my own
mind to our own liberation from Iran.”
However, at first, things didn’t get
much easier for Vaziri. “I did not speak
the language, and everything was new
and different,” he said. Just when he had
started to settle in, another move was on
the cards: In 1991, the family relocated
to the US after they had been granted
a green card as political refugees.
They lived in Los Angeles for the first
four years, then they moved to Texas where
Vaziri completed high school. University
followed and after first obtaining a degree
in computer sciences, he also obtained
a Master of Business Administration in
Finance and later a law degree in New York.
Initially, Vaziri worked in the financial
industry, but as often in life, a coincidence
led him to his current career. He went for
a job interview for a position as a portfolio
manager, but during the interview, he
was informed that he won’t be managing
a portfolio of assets, but a portfolio of
investors. “Back then, I was familiar with the
programme because one of my cousin’s used
the Canadian programme to emigrate from
Iran to Canada. I got the job immediately.”
Vaziri worked for the North Texas EB-5
Regional Centre (NTRC) for just under
four years. During this time, he managed
the largest-ever EB-5 project in the state of
Texas. He then got recruited by Greystone
EB5 Holdings, a very large institutional
lender, to help build their EB-5 practice, and
in 2018, he joined Brevet to set up their EB-5
practice, a position he holds until today.
Although refugees leave in a situation
of emergency with much less planning
than EB-5 investors, he says he has a better
understanding of his clients’ situation than
many of his peers in the EB-5 industry.
“It’s helpful to not only know the legal and
the business side of the industry, but also
to be able to relate to the human story.
There are a lot of emotions involved when
people are moving to another country.”
“We sold all our assets and paid $15,000 to a group
of smugglers who were supposed to take us by horse
back and camel to the border and into Pakistan.
26 - Investment Migration Yearbook 2O23

IM YEARBOOK
be beneficial to the entire EB-5 industry
and could be a “huge support in the next
battle with Congress”. Vaziri concludes:
“In our industry, we often get so bogged
down with regulations, with fund raising
and yes, also, with competing. We easily
forget about the end users, but without the
investors our industry wouldn’t exist.”
Vaziri also sits on the board of
directors of IIUSA, the trade association
for the EB-5 regional centre programme.
“When I ran for the board of directors at
IIUSA in 2018, there wasn’t a single person
on the board who was an immigrant,”
he says. Today, the situation is different
as he has been joined by another board
member originally from Turkey.
But Vaziri does not want to stop
there. He wants more change and has
fresh ideas: “In the US, there are about
70.000 to 80.000 EB-5 investors, and
they don’t really have a voice. While
there are several investor associations,
they are very fragmented. I think
there’s a need for a membership-based
investor organisation,” he explains.
When the EB-5 progamme lapsed
in 2021, there was a huge vacuum of
information and a lot of uncertainty among
investors. “But investors need a reliable
source of information and an independent
body they can turn to,” he says.
Vaziri envisions a membershipbased
investor organisation would also
Abteen Vaziri currently
BIO serves as a Managing
Director at Brevet Capital
Management, a position he has held
since June 2018. He previously served
as a director at Greystone & Co,
an institutional real estate lender,
and helped build Greystone’s EB-5
real estate financing platform. He
is also a board member of IIUSA.
Investment Migration Yearbook 2O23 - 27

IM YEARBOOK
2 22
THE BIG PICTURE
The IM Yearbook travels with Fragomen around the
world to update you on policy changes and developments
in the most important investment migration markets.
Based in more than 50 offices worldwide, Fragomen’s
team is well placed to share some key observations.
Investment Migration Yearbook 2O23 - 29

IM YEARBOOK
United States
The EB-5 Immigrant Investor Visa Regional Centre
Programme has returned, and for the first time in its
history it has seen some form of longer-term authorisation. In
March 2022, the US government re-authorised the popular
programme until 2027, which allows prospective foreign
investors to invest capital into a government-approved
regional centre in order to receive permanent residency
for themselves and any qualifying family members.
The Regional Centre Programme has been increasingly
popular since its inception in 1992; however, it had historically
been authorised by Congress in short-term increments. The
programme lapsed in June 2021 and was not immediately
renewed by Congress. The entire programme was put on hold,
bar investors who had already received their initial green card.
The reauthorisation is important, especially for
prospective investors in the APAC region, including
China and India, who can take advantage of quicker
green card processing times in comparison to other
employment-based permanent residency options.
Further, new investors are also able to invest in the
programme, at a lower investment amount than the
previous minimum, and with greater protections and
benefits afforded to them. In addition, the reauthorisation
of the programme enhances benefits for foreign investors;
in certain cases, permitting investors and their family
members to receive unrestricted work authorisation and
international travel permission while waiting for their
permanent residency to be granted, having a major positive
practical benefit for investors and their families.
While the Regional Centre Programme was on hold, many
investors resorted to pursuing direct investment opportunities.
But we now see a renewed trend toward passive investment
through the quicker and cheaper Regional Centre option
building up, which will likely yield a surge in investment
migration into the US over the coming months and years.
Investors from the APAC region interested in the
US continue to take advantage of Caribbean citizenship
programmes due to their quick and relatively low-cost options,
with a focus on visa-free travel and access to the US and Canada.
The most popular programmes in the Caribbean include
Antigua, Dominica, St. Kitts and Nevis, Grenada, and St. Lucia.
Meanwhile, investors from the US remain interested in many of
the European options, with particular emphasis on Portugal’s
Golden Visa Programme. Canada is also an attractive option.
Future election will likely have a major role to play
in shaping the landscape of investment migration – the
popularity of residency and citizenship is often a result of
the political landscape of the country. However, given the
reauthorisation of the EB-5 Regional Centre Programme
as well as continued interest in other investment options,
including the E-Visa Treaty Investor and Treaty Trader
non-immigrant visa options, the interest for investment
migration in the United States has the foundation to
continue to attract foreign investors in the coming years.
EMEA
In Europe, we are seeing a global big-picture trend of
movement away from purely passive investment migration
routes, towards residence programmes which require a
tangible economic benefit to be generated by applicants.
The conflict in Russia has also seen every jurisdiction in
Europe exclude Russian and Belarussian applicants from their
investment migration routes. The Turkish CBI programme is
the outlier, continuing to accept Russian applicants, and seeing
very large numbers of applicants since the start of the year.
In the UK, the Tier 1 Investor visa closed to new
applicants in February 2022. It seems certain that we will
not see a like-for-like replacement for the investor visa.
The first half of 2022 also saw the UK’s Global Talent visa
for tech leaders receive its highest number of applicants and
successful endorsements, illustrating the continued growth
of the UK’s tech sector. The UK is likely to continue to heavily
market its global talent visa to maintain the status of its tech
sector, but there remains a critical need for a sector agnostic
investment migration route to replace the existing restrictive
innovator route, which we hope to see in the coming months.
Meanwhile, Portugal’s Golden Visa saw some important
changes in January 2022, prohibiting qualifying investments
Given the
European
Commission’s
approach, there
is an opportunity
now for EU
countries to look
at how they can
use investment
migration as part
of their foreign
direct investment
policy and for
this narrative to
be re-aligned.
30 - Investment Migration Yearbook 2O23

IM YEARBOOK
APAC
in property in the most popular areas – such as Lisbon, Porto
and many coastal towns – with the Portuguese government
aiming to drive investment in less affluent inland regions.
While property investment remains an attractive option for
many clients, we are increasingly seeing investors consider the
other options under the programme – such as an investment
in a Portuguese company or an approved investment fund.
Elsewhere, the Montenegro citizenship by investment pathway,
which has attracted a significant number of applicants given the
country’s proposed accession to the EU by 2025, will close at the
end of 2022. The programme was initially scheduled to terminate
at the end of 2021, but the government made a last-minute U-turn.
EU countries face a challenge in terms of the European
Commission’s approach to citizenship and residence by
investment pathways. In April 2022, the Commission issued
a recommendation urging EU member states to repeal CBI
programmes, with a specific reasoned opinion against Malta’s
programme. In March 2022, Malta suspended its CBI programme
for Russian and Belarusian nationals but continues to operate
the programme for all other nationals and has not announced a
formal suspension. In September 2022, the matter was referred to
the EU Court of Justice over what Brussels says violates EU law.
Both Australia and Singapore continue to attract large
number of high-net-worth individuals, mainly from the
rest of Asia. New World Wealth estimates that in 2022, the net
inflow is expected to be 3,500 millionaires to Australia and
approximately 2,800 individuals are expected in Singapore. The
consistently high inflows are partly due to Australia’s pointsbased
immigration system, which favours wealthy individuals,
business owners and professionals. Notably, Singapore is
emerging as Asia’s top wealth management centre, which should
assist in attracting many more affluent individuals to relocate
there in future through the Global Investor Programme (GIP).
Meanwhile, China’s extremely strict Covid-19 travel
restrictions are creating a new economic sphere tethered to
the political landscape. High-net-worth individuals tired of
lockdowns are leaving the country. These individuals, however,
are generally seeking to move to countries that have remained
on good terms with China, such as Singapore and Ireland, rather
than traditionally popular destinations such as the US and
Canada. The most popular programme Indian and Pakistani
investors and entrepreneurs are enquiring about is the Portugal
Golden Residence Permit Programme, followed by Canada.
Throughout the past two to three years, we have seen
a sharp increase in emigration from Hong Kong Chinese,
mainly to traditional countries like Australia, Canada,
the US and the UK. Due to the relaxation of the UK
government’s policy on British National Overseas (BNO)
passport holders, in terms of residency as well as a path to
citizenship, we have seen a spike of BNO passport holders
settling in the UK. It is estimated that more than three
million Hong Kong Chinese are eligible for BNO passports.
Restrictive health policies in Asia are waning, and most
countries will have a new focus on economic sustainability
and healthcare equality. The economic downturn and
talent competition will also likely play a part in the way
migration policy evolves in the next 12 to 19 months.
There is often an unfair perception that investment
migration sits outside the standard framework of investment
and immigration policy. Given the European Commission’s
approach, there is an opportunity now for EU countries to look
at how they can use investment migration as part of their foreign
direct investment policy and for this narrative to be re-aligned.
Meanwhile, we are seeing increased prevalence of digital nomad
visa options in Europe driven by the change in working patterns
which emerged during the pandemic – with Italy and Spain the
latest countries confirming they plan to introduce such a route.
African countries also want to jump on the bandwagon of
remote working and start-up visas. On the back of this trend,
the investment migration landscape will grow but mainly in
countries like Mauritius and South Africa. Other countries thus
far fail to succeed due to poor marketing and delivery, and, lastly,
due to a lack of appetite for these programmes in the region.
Investment Migration Yearbook 2O23 - 31

IM YEARBOOK
Must Peter Pay for Putin?
A Case of Nationality Based
Discrimination and Big Stick Diplomacy
Geoffrey DuBoulay
and Keith Issac of
Polaris Citizenship
& Investment
Consultancy
Services argue
against a blanket
ban of Russian and
Belarusian nationals
following Russia’s
invasion of Ukraine.
While citizenship by investment (CBI)
started some 38 years ago in St.
Kitts & Nevis, this industry first landed on
the shores of Saint Lucia in 2015 through
the Citizenship by Investment Act (No.14
of 2015). As mandated by the Act, the
CBI programme is administered by the
Citizenship by Investment Unit (CIP Unit).
Since officially accepting applicants in
January 2016, St. Lucia has welcomed over
one thousand persons as citizens via its CBI
programme (CIP) and generated more than
60 million Eastern Caribbean Dollars.
Blanketban imposed
Despite the substantial revenue generated,
CBI remains a topic of contention both
locally and on the global stage. The
2022 invasion of Ukraine by Russia has
placed a spotlight on CBI with most
CIPs banning Russian and Belarusian
nationals outright. Uniquely, while most
islands began the suspension of the
programme to Russians from as early
as March 4th 2022, St. Lucia originally
opted to take a different approach and
kept the CIP open to Russian applicants
even after all CBI offering islands had
decided otherwise. Unfortunately, St.
Lucia closed its doors on March 18th 2022
due to growing external pressures.
While, at the time of writing,
Russian nationals may no longer apply
to all but one Caribbean Island’s CIP, as
practitioners in an industry which seeks to
be a force for good by promoting freedom
of mobility, we must ask whether such a
blanket ban is necessary or justified. Initial
comments from St. Lucia’s government
and Unit officials painted a desire to
refrain from discriminating against
Russian applicants based on nationality.
It was stated that mechanisms were in
place to ensure that any individual with
ties to Vladimir Putin’s regime, on a
relevant sanction list or of general bad
character, could not obtain citizenship.
Noting that Russia has a population
of approximately 150 million persons as
well as a diaspora of over 20 million, it
is likely that only a fractional percentile
falls into the aforementioned categories.
Mechanisms to ensure
CIP integrity
Section 36 of the Act mandates that
the following persons may not be
granted citizenship through the CIP:
• Individuals who have been
convicted of a criminal offence;
• Individuals who are the subject
of a criminal investigation;
• Individuals who are considered to be
a potential national security risk;
• Individuals involved in any activity
likely to cause disrepute to Saint Lucia;
• Individuals who have been denied a visa
to a country with which Saint Lucia has
visa-free travel and has not subsequently
obtained a visa to that country; and
• Individuals who provide false
information in their CBI application.
These rules ensure that individuals of
unscrupulous character do not tarnish
the reputation of St. Lucia and its CIP.
Provided that the legislation is properly
administered, it is improbable that any
“bad apples” would obtain citizenship.
Compliance with the legislation is
ensured through a rigorous enhanced
due diligence process. This process is
three phased with vetting of applicants
undertaken by the Royal Saint Lucia
Police Force, the CARICOM IMPACS-
Joint Regional Communications
Centre and international due diligence
partners such as BDO, Exiger and
Refinitiv. Once complete, vetting
agencies provide comprehensive
reports on every applicant so that an
appropriate decision to either grant
or deny citizenship is made. In fact,
St. Lucia’s due diligence process has
been praised internationally for its
transparency, rigor and integrity. It is
further noted that the decision to grant
or deny citizenship is taken by a fiveperson
board of skilled, independent,
impartial non-executive directors.
The implementation of the
legislative framework through the
due diligence process described above
ensures that only individuals of good
character and suitable background,
regardless of nationality, may
obtain citizenship. This alleviates
any concerns related to sanctioned
Russians and Russians associated with
the current regime misusing CIPs.
32 - Investment Migration Yearbook 2O23

IM YEARBOOK
Post citizenship safeguards
From the inception of the CIP, dozens
of reputable Russian nationals have
become citizens with total contributions
to St. Lucia’s economy exceeding
US$2,000,000.00. Despite this financial
impact, many commentators have raised
concerned around their continued
possession of Saint Lucian citizenship.
These concerns are especially relevant
as persons may be sanctioned post grant
of citizenship and circumstances, such
as ties to the Russian regime, which were
once potentially acceptable, are now not.
The St. Lucia government, through the
Act, has put in place a revocation process
which seeks to alleviate the abovementioned
fears. Whilst international standards of due
diligence ensure that only individuals who
demonstrate sound character and can prove
clean criminal and civil records may obtain
citizenship, it does not prevent these persons
from committing crimes or performing
nefarious acts post citizenship. Further,
misdeeds of now citizens are sometimes only
brought to fore after the citizenship process
has been concluded. To protect against
these possibilities, Section 38 of the Act
empowers the Minister with responsibility
for the CIP to revoke citizenship where:
• Citizenship was found to be obtained
by false representation, fraud or
intentional concealment of facts;
• The citizen has been convicted
of an offence; and
• The citizen has performed an
act which, in the opinion of the
Minister responsible for the CBI
programme, has the potential to
bring disrepute to Saint Lucia.
This revocation mechanism, whilst
sparingly used, is an important tool which
guarantees that any person, Russian or
otherwise, who should no longer hold
citizenship, is rightfully stripped of the
privilege. Importantly, placing the power
of revocation with the Minister responsible
for the CIP allows action to be taken
expediently where necessary with damage
to the CIP’s reputation controlled. Do note
that those who have lost citizenship have a
right of appeal to the courts which serves as
a check and balance against the potential
misuse of the revocation provision.
Final thoughts
Through an analysis of the above, namely
the legislative framework surrounding
the grant of citizenship and the practical
application of that framework through due
diligence and the revocation procedure,
it is evident that Saint Lucia’s CIP is well
insulated against potential harm which may
be caused by the accepting of nationals of
any country. The original decision to not
Discrimination of persons based on nationality
only, whether in the CBI space or otherwise, has
always been and will always be unjust.
discriminate on the basis of nationality
and to continue much needed revenue
generation through the acceptance of
Russian and Belorussian nationals was
therefore an entirely sound one.
While it is agreed that Saint Lucia
should support its global partners, the
acceptance of Russian nationals by the CIP,
who are not sanctioned and not associated
with the current regime, does not in any
way undermine these goals. In fact, one
may argue that an increase in Russian
nationals obtaining CBI can hurt the
regime as high-net-worth individuals are
now able to effectively withdraw from the
Russian economy and migrate elsewhere;
thereby creating the type of brain drain
which has haunted the Caribbean region
for decades. Further, by isolating Russian
nationals from the rest of the world, are
we not aiding and abetting the cause
of the current regime? The lessons of
World War I, a precursor to World War
II, partially due to similar discrimination
against a select group of people, should
not be lost on the Western Front.
Discrimination of persons based on
nationality only, whether in the CBI space
or otherwise, has always been and will
always be unjust. A most recent example
of this was the “Muslim Travel Ban” which
was widely critiqued in 2017 for being a
near blanket ban of travel to the US by
nationals of Iran, Iraq, Libya, Somalia,
Sudan, Syria and Yemen. Article 2 of the
United Nations International Convention
on the Elimination of All Forms of Racial
Discrimination expressly condemns
racial discrimination and obliges parties
to “pursue by all appropriate means and
without delay a policy of eliminating racial
discrimination in all its forms”. It should be
noted that the convention expressly includes
discrimination based on nationality as
a form of racial discrimination and has
eighty-eight signatories including the
United States, the United Kingdom and
all EU member states. With this context
in mind, the decision taken by the Elite
West to exclude Russian nationals, solely
on account of that fact, from the global
marketplace, and attempts to pressure
Caribbean CBI offering states to do the same
is equal parts astonishing and amusing.
Role of the IMC
The Investment Migration Council, which
seeks to promote ethical standards in the
CBI space globally and lobby on behalf
of CIPs, has a vital role to play in righting
current wrongs. The situation at the time
of writing unjustly disenfranchises a select
group of persons by stripping them of equal
access to investment migration, damages
the reputation of our industry by making
us co-conspirators to a segregationist
status quo and reduces financial viability
by excluding over one hundred million
potential CBI participants. Of equally great
concern is the continued influence of global
superpowers on the decisions of supposedly
sovereign Caribbean states. The continued
meddling in the affairs of these jurisdictions
by the “First World” has led to disastrous
results such as the destruction of the banana
industry in the eastern Caribbean, and
the decline of its financial services sector.
We must ensure that CBI is not another
casualty to the Big Stick Diplomacy which
has been extended to the region time and
time again. The IMC therefore is implored
to fulfil a lobbying mandate on behalf of
CBI offering states and by extension, the
now marginalised national groups, in
both Brussels and the global arena.
Geoffrey DuBoulay is
BIOS Managing Director of
Polaris Citizenship & Investment
Consultancy Services and the Managing
Partner of the firm Floissac, DuBoulay
& Thomas in Saint Lucia. He possesses
a master’s degree in Commercial
and Corporate Law and has over 20
years’ experience as an attorney.
Keith Isaac is the Chief Operating
Officer of Polaris Citizenship &
Investment Consultancy Services
and an attorney-at-law at the firm
Floissac, DuBoulay & Thomas in
Saint Lucia. He holds a master’s
degree in Law and a Certification in
Investment Migration. He is a fivetime
former St. Lucia National Youth
Parliamentarian and a former St.
Lucia Junior Minister for Tourism.
Investment Migration Yearbook 2O23 - 33

IM YEARBOOK
Trends and Topics
Six Thoughts
on Investment Migration
in a Changing Landscape
While it is impossible to predict the future, it is possible
to consider how current megatrends and potential future
disruptions might affect investment migration in the years to
come. We look at the global shifts reshaping the world and
ask what are the implications for investment migration?
34 - Investment Migration Yearbook 2O23

IM YEARBOOK
1. Welcome to the metaverse
The idea of virtual citizenship isn’t new. In fact, it has been debated ever since
Linden Lab launched its online platform Second Life in 2003. At its peak, Second
Life reported millions of active users in self-made virtual worlds complete with
property sales, a market of virtual goods, and a functioning economy that was
worth around US$500 million in GDP around 2007, according to Time magazine.
While Second Life might not represent
the broader vision of the modern
metaverse, it can certainly be called a
metaverse pioneer. Interest in the metaverse
spiked in recent months amid a rise in sales
of non-fungible tokens (NFTs) as well as
investment from big tech companies in the
space. In fact, the metaverse has become a
mainstream topic since the day Facebook
changed its name to Meta in October 2021.
But what exactly is the metaverse?
The word itself means “beyond the
universe”. One way to describe it is the
convergence of digital and physical lives,
making the metaverse a space where
you can interact with virtual objects in
real life and with real-time information.
Philip Rosedale, Founder of Second
Life, told the World Economic Forum in
2022: “The most important meaning of
‘metaverse’ is the mission to make the
internet a live experience with other
people always there, as opposed to the
largely individual experience it is today.”
Bloomberg Intelligence expects the
market opportunity for the metaverse to
reach US$800 billion by 2024. According
to a report published by Citi Research,
the metaverse represents a potential US$8
trillion to US$13 trillion opportunity by
2030, that could boast as many as five
billion users. Likewise, Goldman Sachs
arrived at a US$12.5 trillion opportunity
if one-third of the digital economy shifts
into virtual worlds and then expands by
25%. “We believe the metaverse is the next
generation of the internet — combining the
physical and digital world in a persistent
and immersive manner — and not purely
a virtual reality world,” their report reads.
More importantly in an investment
migration context, KPMG predicts that
by 2040 the concept of digital citizenship
is thriving, and many people have
done away with their passports and
residency cards for the physical world.
The consulting firm further forecasts:
“There are at least 11 virtual nations
now with a combined population of 200
million ‘citizens’ and a GDP above US$100
billion each. Their citizens enjoy higher
incomes and live in ‘gated communities’
that have their own security. Benefits like
virtual welfare, employment, and other
amenities are vastly superior to those
provided by physical nations, creating a
substantial lifestyle gap between citizens
of physical nations and those in virtual
nations, who are dual citizens of the
physical country they reside in.”
The future of the metaverse is far
from certain, and many say the metaverse
is still several years away. However, a
likely scenario is that individuals are
physical residents of one country but meta
citizens of another because they connect
with the values, ideologies, and laws of
the meta state more than with those of
their base in the real world. Moreover,
they conduct business with like-minded
forward-thinkers in the metaverse,
attend the best universities online, and
invest in digital real estate using crypto.
It’s time to start thinking about
the metaverse because some of
investment migration’s selling points
and experiences are fast becoming
metaverse elements. Much like the
entertainment industry must decide if
it is sticking to a shrinking market for
traditional forms of amusement, or start
bringing their characters and brands into
metaverse platforms, the big question
for investment migration is: how can
it capitalise on the metaverse? Now is
the time to experiment and invest and
innovate in metaverse-based use cases.
Investment Migration Yearbook 2O23 - 35

IM YEARBOOK
2. Cryptocurrencies and investment
migration – a match made in heaven?
Cryptocurrencies hit a rough patch in 2022. Since November 2021, the crypto
market has dropped 60% - drastically falling from a market cap of $3 trillion
to less than $1 trillion in October 2022. The collapse of Sam Bankman-Fried’s
FTX exchange in November 2022 served as just another example of the
unpredictable nature of the industry. However, the onset of the so-called crypto
winter as this period of market cooling has become known is one reason why
cryptos are playing an increasingly important role in investment migration.
Given the volatility of the market, many
crypto millionaires are diversifying
part of their net worth into other hard
assets such as real estate. Both agents
and pathways report that they have seen
a surge in enquires from those who have
made a fortune from cryptocurrency
investments, as well as from those who
want to invest in digital currencies and
are looking for a crypto-friendly base.
In the past few years crypto assets
have moved from being niche products
to having a more mainstream presence.
In June 2021, the UK Financial Conduct
Authority published its fourth consumer
research publication on crypto-assets
ownership, which found heightened
public interest in, and media coverage of,
cryptos, with 78% of adults now having
heard of cryptocurrencies. Around
2.3 million now own crypto assets, up
from around 1.9 million in 2020.
In the US, Pew Research, a nonpartisan
think tank in Washington, reported that
16% of survey participants indicated
they had personally invested in, traded
or otherwise used cryptocurrencies.
Elsewhere, Newsweek Magazine cited
a survey from January 2022 by crypto
firm New York Digital Investment
Group, estimating the total number of
Americans who own cryptos at 46 million,
which is about 14% of the population.
It comes as no surprise that the
investment immigration industry is
gearing up to the use of cryptos. Portugal,
which is generally regarded a crypto
hub, and St. Kitts and Nevis, as well as
Antigua and Barbuda have emerged
as the leading investment migration
countries with crypto-friendly policies.
One key advantage of cryptocurrencies
is they do not rely on intermediaries such
as commercial banks and credit card
companies to conduct transactions, which
cuts out the inefficiencies and added costs
of these intermediaries. In the Caribbean,
it also addresses correspondent banking
issues that have long plagued the region.
Portugal is accepting bitcoin and other
cryptocurrencies for real estate investment in
its golden visa programme. While the country
had been notable for having no crypto taxes on
individuals, in October 2022 the government
proposed to impose a 28% income tax on
cryptocurrencies held for less than a one-year
period. Meanwhile, Antigua and Barbuda, as
well as St, Kitts and Nevis are members of the
Eastern Caribbean Currency Union, which
developed its own digital currency called
DCash. While it remains to be seen if DCash
will elicit the same level of enthusiasm as
bitcoin and other cryptocurrencies, it is another
example that shows that crypto assets as well as
its associated products and services have grown
rapidly in recent years and are here to stay.
36 - Investment Migration Yearbook 2O23

IM YEARBOOK
3. Sustainability: True impact or green washing?
The world is more than ever under pressure to channel money into
curbing climate change – and yet fighting climate change seems to
have slipped down on many nations’ agenda as the Ukraine war, high
energy prices and geopolitical tensions took precedence in 2022.
hardest work is still to come.
“TThe reality is that not enough has
been done in the last 12 months – some
would argue we have moved backwards,”
Hortense Bioy, Global Director of
Sustainability Research at Morningstar,
told Reuters in November 2022.
Moreover, sustainable investing
has come in for a great deal of criticism
since the turn of the year with the list
of companies and countries that have
been accused of not being as ESGfriendly
as promoted getting longer by
the day. Case in point: Human rights
advocates pointed out concerns about
Egypt’s human rights record ahead of
Cop27, the UN climate summit that took
place in the Egyptian resort town of
Sharm el-Sheikh in November 2022.
In 2020, the Investment Migration
Council highlighted that investment
migration has the potential to advance the
2030 Sustainable Development Agenda
(SDG). Investment migration brings in fresh
capital, human skills, and entrepreneurial
capacity for the receiving nation.
Some of this money contributes, often
unintendedly, towards meeting the SDGs.
For example, investment migration
income made important contributions
to the funding of physical and social
infrastructure, particularly to finance the
reconstruction of infrastructure damaged
by hurricanes that have hit the Caribbean.
Elsewhere, investments migration is
directed to business investment that create
jobs and therefore reduces poverty.
However, to ensure that investment
migration income is not overlooked
as a factor within a country’s overall
sustainability and development strategy,
countries should apply ESG criteria
to investment which form part of an
investment migration pathway. There
is a strong need for a more streamlined
and systematic approach and to better
integrate ESG factors so that investment
migration can positively impact the world.
Investment Migration Yearbook 2O23 - 37

IM YEARBOOK
4. Are you ready for the next generation of clients?
Generation Alpha, the children of Millennials born between 2010 and
2024, promises to play a key role in shaping our society within the next
couple of decades and is expected to be the generation with the largest
spending power yet. While, for the time being, investment migration
is largely driven by Gen X and Millennials customers, we ask what are
some of the typical traits we can expect from the next generations?
Generation Z, those between 1995 and
2009, are the first digital natives. They
have grown up with smartphones and
tablets and since an early age had internet
access at home. They consume mainly
digital media and are used to watch a video
summarising an issue rather than read an
article covering the topic. Due to social
media platforms such as Facebook and
Instagram, Gen Zs are constantly connected
to and influenced by their peers. Moreover,
Gen Zs tend to be highly educated,
environmentally conscious and longing to
leave a positive impact within communities.
The 2022 edition of the Wealth report
predicts that between 2021 to 2026 the
global UHNWI population will grow
by a further 28%, more than a doubling
in numbers over a 10-year period. This
growth will consist mainly of Millennials
and Gen Zs as they inherit assets and
companies from their parents or else as
innovators and successful start-up owners
particularly in the technology field.
Generation Alpha, or Gen Alpha,
is the demographic cohort succeeding
Generation Z and is made up of mostly the
children of Millennials. The name derives
from the first letter of the Greek alphabet.
Mark McCrindle, a demographer who
rose to fame for analysing and naming
generations, says members of Gen Alpha
are the first generation to have been
born and fully shaped in the 21 st century.
They are also expected to be the largest
generation ever. By 2025, they will number
two billion globally and most of them will
live in Asia – mainly in China and India.
By 2030, the first members of Gen
Alpha will be young adults, and they
are the next generation of customers
that will benefit from the largest
intergenerational wealth transfer in
history. Much like Gen Zs, Gen alpha will
be digital. They are growing up in a world
where TikTok, Roblox and Instagram
are not disruptors but the established
incumbents, McCrindle emphasizes.
While sustainability is already
important to Millennials and Gen Z
consumers, it is expected that Gen Alpha
will resonate especially strongly with
sustainability, given that they will be growing
up entirely under the threat of climate change.
There is also consensus among researchers
that Covid-19 will have a lasting impact on
this cohort since their formative years have
been shaped by a global pandemic. So, it’s
perhaps unsurprising that many believe
that Gen Alpha can be defined by their
worries towards becoming ill and not being
able to see their families for a long period.
Although the demographic transition
is still a few years away, the investment
migration community needs to start
catering for these new realities. For Gen
Z and Gen Alpha themes such as the
environment, general wellbeing, and
technology ought to be more central, while
those who wish to win them as clients need
to adapt their communication methods.
Bureaucracy, antiquated portals and slow
processes will not attract the upcoming
generations. What started with Gen Z
will continue with Gen Alpha. Those
born after 2010, McCrindle summarises,
will be more digital, global, social and
visual than any generation before them.
38 - Investment Migration Yearbook 2O23

IM YEARBOOK
5. The new reality: remote working and nomad visas
Estonia gave rise to successful companies like Skype, Wise, Bolt and
Playtech, and it was the first country to launch a digital nomad visa in 2020,
which fast became the ultimate concept for countries to attract remote
workers. Just two years later, in 2022, more than 25 countries run similar
programmes, according to a Migration Policy Institute report, making it one
of the most important trends in the immigration space in recent years.
Sparked by the pandemic, remote work
has become an integrated part of today’s
work fabric. Even as companies such as
Uber and Tesla try to reign in personnel
back to their brick-and-mortar offices, there
is consensus that remote work will remain
mainstream and an important tool for
companies to recruit and retain employees.
Concurrently, freelancing is on the
rise. In 2021, according to the US Bureau
of Labour Statistics, over 47 million
Americans voluntary quit their jobs and
trends predict that by 2027 50% of the
workforce will be freelancing in the country.
While people’s reasons for quitting their
jobs vary, of course, the inclination is that
those with a high level of education and in
possession of sought-after specialised skills,
are opting for flexible projects with several
companies instead of a stable contract
with a single business. This trend has
reduced the need of one to be permanently
based in one location to be close to his/
her place of work or business. Instead,
tech-savvy individuals are moving to far
flung exotic nations to strike a better worklife
balance, explore new places without
the need of taking a career break and, at
the same time, escape crowded cities.
This has markedly created a new niche
for countries to cater for this increased
demand of individuals wanting to work
remotely from outside their home country.
What has been termed as a ‘digital nomad
visa’ is fundamentally a programme
that gives an individual the legal right to
work remotely while residing away from
their country of permanent residence.
Some programmes have been specifically
designed for remote workers while others
have been adapted from earlier work visas.
While some variations exist among
them, they generally follow the same
idea: granting a temporary hassle-free
residency permit that allows foreigners
to stay from six months to five years. The
onset of these programmes addressed a
legal vacuum for remote workers wanting to
spend an extended period abroad working
independently, although there are still some
unanswered questions about tax liability.
Applying for a digital nomad visa
generally involves an application fee
together with proof of a certain level of
income to sustain oneself. The fees vary
from being at no cost when applying for
a visa in Georgia to US$2,000 for the
Barbados ‘Welcome Stamp’ programme.
Income requirements range from
US$1,275 per month under Ecuador’s
visa programme to US$100,000 per
year under the Cayman Islands ‘Global
Citizen Concierge Programme’. Average
rates hover around €3,000 per month
as per Malta’s ‘Nomad Residency
Permit’, and the Cypriot, Panama, and
Romanian nomad visa programmes.
With an estimated 35 million digital
nomads worldwide contributing to a global
economic value of US$787 billion per year,
it’s no surprise that countries around the
world are launching their own digital
nomad visa programmes. This new visa
trend has generally been positively received
by local communities and has spurred
several developments. Co-working and
co-living spaces have boomed, and in some
places, entire areas have been built to cater
for the influx of these new communities.
The concept of digital nomad visas
is only a few years old and essentially
still an experiment. However, judging
from the increasing number of countries
coming up with their own programmes
and the growing number of digital
nomads worldwide, it’s likely that
digital nomad visas are here to stay.
Investment Migration Yearbook 2O23 - 39

IM YEARBOOK
6. Start-ups going global
For centuries, some of the biggest companies in the US have been founded by
immigrants – just think of Levi Strauss from Germany or Elon Musk from South
Africa. An analysis by the National Foundation for American Policy from May
2022 found that immigrants have started more than half of America’s start-up
companies valued at US$1 billion or more. Attracting a start-up before it grows big
can have a huge impact on a country’s economy. For instance, Berlin-based fashion
e-commerce company Zalando grew to become the
10th biggest employer in the city over the last 12 years.
While it’s incredibly difficult for smaller countries
to attract investment from established companies
such as Google, chances are they will succeed in
attracting the founders of the ‘next Google’ to start
up in their location. This is the rationale driving
the rapid expansion of start-up visa programmes.
In 2022, around 40 nations, including
most OECD countries, had some
form of start-up-related programme
in place. In fact, migration policies in
many countries are moving away from
being focused on traditional family or
employment-related immigration and
crafted more around entrepreneurial
and highly skilled individuals. This
‘merit based’ approach is proving
popular. A growing global nationalistic
environment driven mainly by populist
ideologies is not leaving much space for
the ‘traditional’ immigration policies.
Start-up related visas attract fewer
negative sentiments, do not generally
spur contentious opinions, and garner
wider partisan support. Secondly,
if managed properly, start-up visa
programmes can potentially leave
substantial economic multiplier outcomes
on a nation’s economy creating growth
opportunities in new innovative areas.
Contrary to entrepreneur-related
visas which have been around for a while,
start-up visa programmes focus on the
potential of a business, rather than the
actual capital invested. The main goal is
that of augmenting the national start-up
ecosystem by attracting talent and ideas
from abroad. Differences exist between
various programmes, including whether
they offer temporary or permanent status,
how they are assessed and monitored,
the sectors targeted, and the investment
requirements and commitments. In
most cases only temporary renewable
residence permits are offered.
Canada is one of a handful of countries
that through its Start-up Visa (SUV)
programme offers permanent residency to
successful applicants. Most programmes
offer family members temporary residency
with working rights. Japan and Korea
conversely do not admit family members
via their start-up programmes.
There is no single method on how startup
programmes are evaluated and selected.
Unlike other immigration programmes
based on investment, net worth or skill
set, most start-up visas are about enticing
and supporting business owners before
they succeed and leave a positive impact
on the local community. Start-ups are in
essence high risk with many failing after few
years operating. Managing the associated
risks is key for these programmes.
A balance needs to be struck between
venturing on a great entrepreneurial
potential but mitigating the associated
risks through selection, monitoring and
support structures. Most governments
involve players from the local business
community and expert panels to assist
and guide immigration personnel who do
not possess the ability to assess promising
business plans. Lithuania for example has
a panel of experts, the majority of which
come from the private sector assessing
applications. The UK involves universities,
while Finland, the Netherlands, and
Malta allot their innovation and business
agencies to select applications. Some
programmes, such as those offered in
Poland, France and Spain even offer
some limited form of capital assistance
via grants and business incubators.
Attracting the right start-ups from
around the globe can reap tangible
economic benefits for countries. Replicating
the Silicon Valley success story is an end
target for many programmes. Apart from
job creation, successful start-ups sustain
and spread a culture of innovation and
entrepreneurship. They can also boost
the marque of countries, both regionally
and globally. For instance, entrepreneurs
who have followed Chile’s ‘Start up Chile’
programme over the last decade or so
have generated sales of more than one
billion dollars worldwide. Chile, which
was a pioneer in devising international
start-up programmes more than ten
years ago, has become a hub for startups
in Latam attracting in the process
international highly skilled talent.
Start-up visas are by design low-volume.
A well planned and successful start-up
visa programme needs to be supplemented
by wider policies such as incubators,
business networking avenues and tangible
investment incentives. With more countries
coming up with start-up related visa
programmes, having the right ecosystem
is what will differentiate one programme
from the other. If successful, a start-up
visa programme can enhance a country’s
standing on the global scene, create new
high growth sectors, attract talent, and
assert a government’s commitment to
entrepreneurship and innovation.
40 - Investment Migration Yearbook 2O23

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IM YEARBOOK
Navigating a
new level of
volatility
Dr Juerg Steffen,
CEO of Henley &
Partners, writes
that turmoil
and instability
have become
the common
denominators of
the 21st century,
which have
accelerated demand
for investment
migration pathways.
A
twin dynamic is at play in the
investment migration arena
as investors pursue sovereign
diversification at the same time as nation
states seek to boost their sovereign
equity – in both cases, residence and
citizenship by investment provides the
optimal solution. Relentless volatility and
uncertainty continue to drive wealthy
individuals across the world to explore
the most suitable investment migration
solutions to manage the risks of abrupt
changes in policy or legislation that could
threaten their capital and lifestyles.
Sovereign diversity
Although historically investment migration
programmes might have been considered
a convenient add-on for globally minded
investors and entrepreneurs, today, faced
with so many ever-fluxing dynamics on
the global stage, sovereign diversity has
risen to the fore, and this asset class is now
deemed a necessity. Investors are looking to
protect themselves and their families from
ongoing political insecurity and economic
instability by having the option to live,
work, and conduct business in an array of
different jurisdictions across the world.
Another paradigm shift is taking
place at the sovereign level with more
governments increasingly keen to engage
with the global community of high-networth
investors and talented individuals,
encouraging them to their shores by
introducing new immigration pathways,
including residence and citizenship by
investment programmes. Nation states can
use these programmes as an innovative
financing tool by allocating inflows to
social, infrastructure, and development
projects that benefit their citizens. In so
doing, they also boost public finances, foster
economic growth, and create employment
opportunities without increasing debt.
Crisis after crisis
The 21 st century certainly began as it meant
to go on. Merely a year into this millennium,
the world was upended in 2001 by the
9/11 attacks, a single event that catapulted
humanity into an ideological tug-of-war,
deepening fissures between sovereign states
and shaking the geopolitical scales of power.
War and volatility have also fuelled
the mass migration of people looking to
escape hardship and authoritarian rule and
added pressure to the seemingly irresoluble
refugee crisis the world confronts. The
ongoing conflict in Ukraine has become
the current centre of global political
instability as Europe responds to warfare
on its own turf. The conflict has also
awoken the sleeping dragon of ideological,
political, and economic warfare between
East and West, taking us back to an era
reminiscent of the Cold War. It has also
driven wealthy individuals, entrepreneurs,
42 - Investment Migration Yearbook 2O23

IM YEARBOOK
the Great Lockdown, albeit to varying
extents. It highlighted the immeasurable
value of freedoms once taken for granted,
emphasised the importance of robust
healthcare access, and prompted many to
explore truly effective ways of safeguarding
their wealth and lifestyles. It is now of
paramount importance to high-net-worth
individuals to mitigate exposure to volatility
at home and protect against the barrage
of multi-faceted crises that the world is
enduring by accessing a greater number
of jurisdictions through a diversified
portfolio of residences and citizenships.
The way we interact and the way we
work have changed thanks to technological
advancements and, with this digital
transformation, the world has become truly
interconnected. Many who have explored
new locations from which to work or run
their businesses during the pandemic
have started examining more permanent
options available to secure additional
passports and the rights to live in attractive,
stable, and cosmopolitan locations. And
now, more than ever, countries need
their talent and their investment to boost
their own resilience to future shocks. It’s
a win-win situation. Nation states can
leverage their sovereign equity to provide
investors with the sovereign diversity they
are looking for, to the benefit of both.
and business owners to invest in
residence and citizenship by investment
programmes in countries that offer more
stable socio-political environments
that grant them peace of mind.
Asset devaluation
Less than a decade after 9/11, international
markets suffered the global financial
crisis of 2007–2008, with the collapse of
the American housing market having
a dramatic domino effect the world
over. Now, 15 years later, on the back of
a devastating global pandemic, we are
staring yet another economic emergency
in the face, with inflation rates soaring
and a painful global cost-of-living crisis
further widening the wealth gap. The
World Economic Forum’s Chief Economists
Outlook for September 2022 was grim,
warning that a global recession is possible
in 2023, with growth stifled by “once-in-a-
generation inflation” in the US and Europe.
Economic volatility of this scale
heightens risk, and risk prompts affluent
individuals to look for ways to protect their
wealth, their capital, and their families, and
future-proof their investments. Demand
for investment migration pathways has
accelerated in recent years as wealthy
families seek to safeguard their legacies
and retain the optionality to move to, or
invest in, more secure jurisdictions. The
record inflation we are experiencing across
the world is devaluing liquid assets with
each passing day, making residence and
citizenship programmes linked to real estate
investments in budding property markets,
or those tied to funds in lucrative financial
hubs, very attractive to astute investors.
The conscientious investor
When borders shut in 2020, humankind
shared the life-changing experience of
Dr Juerg Steffen is the CEO
BIO of Henley & Partners. He
has more than 30 years’ experience
in the financial services industry and
is widely regarded as a leader in the
field of investment migration. He first
joined Henley & Partners in 2013 to
set up the firm’s Singapore office and
was latter appointed COO of the group.
Before joining Henley & Partners, he
was a personal advisor in the family
office of one of Europe’s wealthiest
families. He also served as a member
of the management board and as head
of the Wealth Planning department of a
leading private bank in Austria and was
a director in the Cross-Border Wealth
Planning department of UBS in Zurich.
Investment Migration Yearbook 2O23 - 43

IM YEARBOOK
Anatomy of a Source Market:
INDIA
India is on track to become an economic superpower and is
one of the hottest growth markets for investment migration.
Immigration firms and consultants report record enquiries
from the South Asian country, and according to Henley &
Partners, around 8,000 millionaires left the country last year.
Wealth diversification, access to markets, along with better
education opportunities and greater mobility, are key motivators
for Indians to invest in foreign countries. While India’s migration
market had long been focused on the US, today’s investors
are showing interest in a greater number of destinations.
Growth story
A country with 1.42 billion inhabitants, India’s story is one of growth
and expansion. After decades of socialism, India implemented
wide-ranging economic reforms in the early 1990s that had a
positive impact on growth, consumption, urbanisation as well as
wealth creation. At the start of the 21st century, India recorded an
annual GDP growth of 6% to 7%, and from 2013 to 2018, India was
the world’s fastest growing major economy, surpassing China.
In 2022, despite a slew of challenges including macroeconomic
headwinds stemming from Russia’s war in Ukraine, elevated
crude oil prices and tightening liquidity globally, India’s economy
continued to outperform most of its global peers. The IMF expects
growth of 6.8% for the 2022/23 period – in the G20 only Saudi
Arabia will grow faster. A recent Morgan Stanley report finds that
the country has the conditions in place for an economic boom
by 2030. Fuelled by investments in manufacturing, the energy
transition, and the country’s advanced digital infrastructure, India
will likely grow into the world’s third-largest economy by the end
of the decade as its GDP is going to double to US$7.5 trillion.
India’s rich
In 2023, India will likely surpass China as the most populated
country, and by 2030, it will be home to 1.5 billion people – a market
full of potential and too big to be ignored. More importantly, the
number of wealthy individuals in India is on a steady rise. According
to Knight Frank India, ultra-high-net-worth individuals increased
by 11% in 2021 to more than 13,600. This was the highest percentage
growth of any country in the Asia-Pacific region, with Knight
Frank citing “equity markets and digital adoption as factors
driving growth in the super rich category of India”. By 2026,
some 19,000 Indians are projected to have net assets of $30
million, while the number of individuals with more than US$1
million is expected to surge by 77% between 2021 and 2026.
Why invest abroad?
With so much growth at home, it begs the question why are
Indians interested in investing and moving abroad? Ravi Kanth
Gangishetty, CEO and founder of RK Global Fortune Consulting,
says India’s wealthy elite “thinks indeed twice today to move
out of India”. While India has grown by leaps and bounds in
the last 25 to 30 years, and “there are lots of new business and
investment opportunities available,” he says, environmental
concerns, low quality of life, corruption issues and weak
regulation are major factors in people’s decision to emigrate.
Varun Singh, managing director of Xiphias Immigration,
also admits that “India’s growth story remains strong”, and
in-country consumption holds great promise for businesses
seeking high-yielding investments. “However, the aspiration of
families to become cosmopolitan and transnational, as well as
their desire to diversify their financial assets globally, is driving
families to migrate internationally through investment,” he says.
Client profile and motives
Investor migrants from India are a diverse mix of business
owners, new-age entrepreneurs, corporate executives, and
skilled professionals. As diverse as their background, so too are
their motives. A top priority of Asian parents is the desire to
give their children the best education possible. Many of India’s
second and third-generation business owners send their children
abroad to study and to gain valuable work experience before
asking them to return home and join their parents’ companies.
“Diversification of geographical risks, in terms of wealth
portfolios and access to developed nations” is another driving
force for well-established businesspeople and corporate
executives, according to Sumit Singh, Managing Director of
44 - Investment Migration Yearbook 2O23

IM YEARBOOK
Indian families are becoming
increasingly globalised and
have shown a great appetite
for investment migration in
recent years. Three Indian
immigration experts share
essential insight into the
Indian investment migration
market and explain what
Indian clients really want.
Xumit Capital. He also mentions proper retirement planning with
enhanced quality of life and access to good health care, as well as
the prospect of easier travel. An Indian passport provides visa-free
access to only 60 nations, mostly in Asia, Africa, and the Caribbean.
Investor migrants under the age of 35, meanwhile, are
predominantly start-up entrepreneurs who want to scale their
companies. They are driven by the desire to relocate or set up
their businesses in the most conducive start-up ecosystem. Indian
start-ups often have foreign investors, and for many it is a logical
choice to move their business closer to investors and venture
capital. Besides, in India, the ease of doing business hasn’t improved
much despite various initiatives by the Modi government.
Destination appeal
English-speaking nations are the first choice of Indian
investors, and the US has long been the dream destination of
many Indians. The UK, Canada, Australia, and New Zealand
are equally sought-after destinations, while Singapore
and Dubai are also on the radar of investor migrants.
Meanwhile, families are becoming more open to relocating
to Europe, and European nations such as Portugal and Greece,
where English is still widely spoken, are actively considered.
In addition to the language factor, the size of the Indian
diaspora in the destination country is also playing a role in
Indian’s investment migration decisions. According to a UN
report, 18 million people from the country lived outside their
homeland in 2020 - almost half of them in the US or the Gulf
region. All experts feel this is an important factor that should not
be underestimated. For example, says Gangishetty, many Indians
are aware that the CEOs of several top US IT companies are from
India, so they send their children, especially those studying IT
and software development, to the US for their higher education.
Preferred investment routes
Traditionally, Indians relied on student or employmentbased
visas if they wanted to spend extended periods
abroad. However, as a result of changing migration policies,
in combination with the Covid-19 pandemic, India’s upper
class has come to appreciate the more predictable and
permanent nature of investment migration programmes.
From all the options, residency pathways are often more
popular among Indian investors as India does not allow dual
citizenship, unless investors opt for the Overseas Citizenship of
India (OCI) option, an immigration status permitting a foreign
citizen of Indian origin to live and work in India indefinitely.
The EB-5 visa to the US is still the most sought-after
programme by the Indian HNI community, but other pathways
are actively considered. “For Indians with entrepreneurial
bent, Canada is the best destination for migration. Federal
and provincial programmes have different dynamics and
different level of engagements, which suit many businesspeople
in India,” says Sumit Singh. However, he highlights most
Indian investor migrants want to “avoid business risks
and thus prefer to be a sleeping-partner in a venture”.
He has also noticed a spike of interest from Indians
in the residency programmes of Portugal and Greece,
mostly due to “the ease of investment” as real estate
is the favourite asset-class of Indian families.
Attracting Indian HNWIs
Asked about cultural differences, Varun Singh comments:
“Indian investor migrants are a tad different than investors
from other countries.” Since they are not yet very familiar
with the concept of investment migration, they take a
little longer to decide, he explains. Moreover, Sumit
Singh says, Indian investors are “risk-averse by nature”.
He feels more awareness campaigns and roadshows
in India would help in winning investor trust.
Varun Singh, meanwhile, points out that foreign
immigration consultants who want to attract Indian
high-net-worth clients need to promote the destination
country first, as this is still the primary factor driving the
migration decision. To many, the investment route and
the project are of secondary importance, while success
stories of other Indians and the presence of Indian culture
are elements that leave a mark on Indian investors and
have the power to influence an investor’s decision.
Investment Migration Yearbook 2O23 - 45

IM YEARBOOK
Overcoming challenges
Once a decision has been taken, Indian investor migrants must
overcome several obstacles in order to start their migration
journey. Before 2004, transferring money overseas was a
cumbersome procedure involving numerous approvals from the
Reserve Bank of India. Although India has liberalised foreign
exchange transactions, Indian residents are only allowed to
remit $250,000 per year. “This means investors take two to
three years to deploy their capital overseas. Furthermore, not
many Indian banks are supportive of such large transactions
for migration purposes,” Sumit Singh explains.
Another challenge revolves around the source of funds
requirements. India is still a cash-rich country and proving the
source of funds is quite often a problem for investors who either own
property or inherited large sums of money. Moreover, the experts
point out, with so many hurdles in the way, even genuine Indian
investors are sometimes not willing to wait and invest in a process,
which can take years depending on the destination country.
Future attraction
Looking to the future, all experts believe demand for investment
migration from Indian nationals will remain high. There is also
the expectation that the new generation of start-up programmes
in developed countries such as Canada, the United Kingdom,
Australia, and others will appeal to Indian entrepreneurs. “Although
India has been a great haven for new startups, new entrepreneurs
and innovators are looking to launch their start-ups in developed
markets not only for the environment and infrastructure they
provide, but also for market access,” says Varun Singh. Gangishetty,
meanwhile, noticed also the “reverse trend” of US Green Card
holders of Indian origin migrating back to India. India’s economic
growth has created a lot more opportunities in recent years,
making moving back a much more attractive option today.
Sumit Singh is the Managing Director
BIOS of Xumit Capital, an India-based global
investment & migration advisory firm. He has more than
15 years of experience in assisting high-net-worth clients
with capital management and resettlement solutions.
He is also a SEBI Registered Investment Advisor and an
Associate Member of the Investment Migration Council.
Ravi Kanth Gangishetty is founder and CEO of RK
Global Fortune Consulting, a boutique Indian investment
migration firm. He has worked for more than 11 years
in the immigration consulting services sector.
46 - Investment Migration Yearbook 2O23

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IM YEARBOOK
Karen Kelly
Director of Strategy & Development
Exiger
Looking forward:
Using real-time monitoring to make risk-based decisions
Exiger’s Karen Kelly says Russia’s invasion of Ukraine
has shown that continuous monitoring of previously
screened applicants is becoming ever more important.
In the weeks and months since the
Russian invasion of Ukraine in
February 2022, the importance of due
diligence has once more been highlighted.
Residency and citizenship by investment
(RCBI) pathways have of course been
impacted, with increased scrutiny on
their due diligence standards and overall
compliance programmes for the assessment
of individuals seeking a foothold in those
jurisdictions. The impact has not been
limited to the investment migration
industry, however. Any organisation doing
business with those connected to high-risk
jurisdictions such as Russia, including
large and small financial institutions and
corporations, has had to re-evaluate those
relationships and reassess the effectiveness
of their compliance programmes.
Monitoring works
In the immediate aftermath of Russia’s
invasion and the first of many waves of
sanctions targeting Russia and Belarus,
Exiger worked closely with partners
across all industries. This included those
in the investment migration industry,
looking back at their existing and previous
relationships; and in the context of RCBI
programmes, at previously approved
applicants. This covered targeted sanctions
and adverse media searches of previously
screened individuals and companies,
and often their close associates, for
any new and elevated risk arising from
direct or indirect sanctions exposure.
For our partners in the investment
migration industry, this exercise served
to validate and reinforce the necessity
and effectiveness of technology-enabled
monitoring of previously approved
applicants. Over the last five years, we have
seen ongoing, real-time monitoring, after
the initial due diligence report has been
delivered, go from a ‘nice-to-have’ to a
necessary component for programmes with
which we work. We strongly recommend it
as a best practice for all programmes and
due diligence providers working with them.
It was rewarding to confirm that,
while conducting re-screening exercises
for our clients, we did not uncover any
adverse information or risks not already
unearthed through our regular monitoring
of applicants. Notably, through the use of
an effective monitoring programme, our
clients learned of new adverse information
or risks in near real time, rather than at
the time of the re-screening exercise. Done
right, monitoring can and does alert a
programme to serious findings that come
up after an applicant is approved, putting
the programme in a position to proactively
address these issues rather than scrambling
to react after it has become a problem.
A necessary shift
Investment migration pathways are
playing catch-up when they rush to
re-check and re-screen previously
approved applicants when a new risk
or threat comes to the surface, like the
Russian sanctions risk. What the industry
demands, and what the new standard for
best practices requires, is a shift from a
“look back” mindset to “look forward”.
Today’s monitoring technology
offers RCBI pathways the opportunity
to avail themselves of the right real-time
information, putting them in a position
to identify individual applicants with
new and serious red flags. Moreover,
a monitoring programme centralises
volumes of information across complete
applicant populations into a single data
set, allowing programmes to identify
patterns of risk and changing trends in
risk exposure over time. Armed with
good data sooner, programmes can make
good decisions, and can look forward.
In the case of Russia in 2022, a
centralised view and analysis of Russian
applicants could identify almost
immediately what percentage of a pathway’s
48 - Investment Migration Yearbook 2O23

IM YEARBOOK
Over the last five years, we have seen ongoing, real-time
monitoring, after the initial due diligence report has
been delivered, go from a ‘nice-to-have’ to a necessary
component for programmes with which we work.”
total applicant population was impacted
by sanctions, and at what level (and the
likely percentage of new applicants who
would present this risk). This is the type
of critical data point to have in hand when
weighing decisions about imposing or
lifting restrictions on those applying to
investment migration programmes.
The recent concerns over Russian
applicants are just one example, and not
the first, of how risk and risk appetites can
change quickly. Other sanctions regimes
will inevitably come about and may shift
the focus to other jurisdiction or groups.
New and different risks may surface raising
greater concern for investment migration
pathways due to changing attitudes.
We see rising awareness around
Environmental, Social, and Governance
(ESG) risks across other industries, and
now in investment migration as well.
With a whole-population approach
toward monitoring and analysis, adverse
media and enforcement actions could
identify rising risk in a particular region
related to violations such as forced labor
or unsafe working conditions. If an
RCBI programme is aware of this risk
early, they can not only develop targeted
strategies to reassess previously approved
applicants with such red flags or in that
particular region, but also incorporate
those strategies into the risk framework
going forward for new applicants.
Monitoring is now widely embraced
by investment migration pathways. The
next big step is consolidating that data
and analysis for all applicants centrally,
allowing programmes to take a holistic view,
looking forward to continuously improve
and refine their compliance programmes.
Doing so will demonstrate to the industry,
and to the general public, that they are
prepared to address the changing risk
landscape and committed to accepting
only the highest quality applicants.
BIO
Karen Kelly is Director of
Strategy & Development for
Exiger’s Immigration, Citizenship, and
Visa (ICV) Practice. She has 14 years
of experience managing due diligence
solutions for residence- and citizenshipby-investment
(RCBI) programs,
financial institutions, and corporations,
as well as developing specialized
due diligence training programs.
She also helped lead a large-scale RCBI
program review focusing on policies
and procedures, workflow, operational
support, and system implementation.
Investment Migration Yearbook 2O23 - 49

IM YEARBOOK
What HNWIs need to know about
Canada’s Start-Up Visa
Ronit Sharma, Founder & Managing
Director of Immigrant Investor
Group, outlines the key advantages of
Canada’s Start-Up Visa Programme.
Canada is a G7 country with one of the
world’s best performing economies
over the past decade. It offers a
cosmopolitan, family friendly lifestyle
with several world-class cities that provide
well diversified business environments,
excellent education institutions, vibrant
social scenes, and a wealth of cultural
events. These are some of the reasons
why Canada is a popular place for startups,
entrepreneurs and innovators.
The Start-Up Visa Programme
(SUVP) to Canada is the premier investor
immigration programme to Canada, which
is currently being used by high-net-worth
Individuals (HNWIs) seeking a long-term
residency / citizenship plan for their family.
From pilot to permanent
In 2013, the Government of Canada
launched the SUVP to Canada as a pilot
programme and in 2018, the programme
was made permanent. The objective
of the programme is to attract talented
entrepreneurs to Canada who have
innovative and technology-related ideas
which may be successfully launched in
Canada. The SUVP is sector agnostic as
long as the start-up is innovative, unique
and disruptive, thereby qualifying and
meeting the government’s guidelines.
The government has trusted various
Designated Organizations (DOs) such
as incubators, angel groups and venture
capital groups to administer and mandate
the programme. The role of the DO is to
ensure that start-ups meet the government’s
criteria and make a minimum investment.
They also need to issue a letter of support,
which will then be submitted with the
applicant’s immigration application. The
investment requirements with the DO’s
are limited to the angel group stream
and venture capital group stream and are
CA$75,000 and CA$200,000 respectively.
Co-investment and
co-partnership
What is unique about the SUVP to
Canada is that the government allows
for co-investment and co-partnership
structures with a maximum of five
individuals per startup. Most applicants
in the queue applied for the incubator
stream, which is the easiest and least
expensive route to apply as no investment
capital is required. This, however, allows
for low quality start-ups in the system, and
unfortunately, there is a greater chance
of being rejected. Immigrant applicants
should be cognizant of the offerings in
the marketplace and should not focus
on the price. Instead, the focus should
be on the genuineness and viability of
the start-up and ensure that the required
early-stage capital is being raised.
Over the past decade, second
residency and second citizenship
programmes have expanded globally.
However, investor immigration to Canada
has been in existence for approximately
30 years and has always been a top
choice among HNWIs. Canada does
not offer immediate global mobility
but a medium to long term second
residency solution so the children
can study, real estate investments
can be made, business opportunities
can be explored and eventually a
retirement plan can be crafted.
From a North American standpoint,
the SUVP competes directly with the US
EB 5 Immigrant Investor Programme
which is currently priced at US$800,000.
In this regard, the SUVP to Canada is
priced quite competitively in the range of
CA$250,000 to CA$350,000. Immigrant
Investor Group Inc. works with a few
select angel groups and venture capital
groups who have real start-ups that
require early-stage capital to launch.
Increased quota allocation
The current official government processing
time to obtain Canadian permanent residency
under the SUVP to Canada is 32 months.
However, in October 2022, the government
aggressively increased the quota allocation
for applications under the SUVP over the
next three years, and it is anticipated that the
processing times will come down again to
18 to 24 months. One major advantage of the
SUVP to Canada is that once an applicant
receives Canadian permanent residency, it is
unconditional from the first day. Therefore,
even if the start-up fails, the applicant will
retain their Canadian permanent residency.
The SUVP to Canada has essentially
replaced the Quebec Immigrant Investor
Programme where immigrant applicants had to
invest CA$1,200,000 to the government for five
years at zero percent interest which was funded
via a one-time finance payment of CA$360,000.
The last intake period of the Quebec Immigrant
Investor Programme was August 2019.
In conclusion, the SUVP to Canada is
a win-win programme. Canada’s start-up
ecosystem can develop the next unicorns
and high-net-worth families can obtain
Canadian permanent residency which will
eventually lead to Canadian citizenship.
Ronit Sharma is the Founder
BIO & Managing Director of
Immigrant Investor Group Inc. Ronit
Sharma also serves as a Global
Director for Immigration Solutions
Law Group, Global Partner for JTH
Lawyers Inc. and Strategic Partner of
Latitude Residency & Citizenship.
50 - Investment Migration Yearbook 2O23

INVESTOR IMMIGRATION
SPECIALISTS
START UP
VISA PROGRAM
to Canada
Angel Stream
Incubator Stream
Venture Capital Stream
Ronit Sharma
Founder & Managing Director
Immigrant Investor Group Inc.
Canada Mobile / WhatsApp: +1.647.295.7664
ronitsharma@immigrantinvestorgroup.com
www.immigrantinvestorgroup.com
*please get in touch to review B2B collaboration opportunities*
INTEGRITY
SERVICE
EXPERTISE
TRUST

IM YEARBOOK
From Permanent Residence to the Nomad Residence Permit:
Malta keeps on innovating
Malta is one of the most popular destinations and jurisdictions for second
residency, and the country’s appeal as a place to relocate to remains high. The
IM Yearbook catches up with Charles Mizzi, CEO of the Residency Malta Agency,
to understand how the agency has established itself as a leader in the industry.
like charity, begins at
home,” says Charles Mizzi, “and
“Success,
this is one of the principles
on which Residency Malta is built. The
Agency actively invests in the people who
make it what it is, and this holistic view
of development has helped propel the
Malta Permanent Residence Programme
(MPRP) towards its continued success.”
With the firm belief in people
development as an important business
driver, over the past year, Residency Malta
has continued training its staff and investing
in its HR, as a way of refining its work and
delivering output of the highest standards.
“Whether it’s customer service, investigative
analysis or technical skills, our people
need to be at the forefront of their area of
expertise, so that we can add value to every
stage in the application process,” says Mizzi.
The Agency simultaneously invested in
its IT systems, enabling more streamlined
and efficient operations and an overall
improvement in processing time. “We
are now promising a four- to six-month
processing time for the MPRP without
compromising on due diligence,” he
adds. “This brand promise has become
an important feature of our programme
and an effective selling point.”
Service to agents
MPRP applications may only be submitted
to Residency Malta via licensed agents.
“Our relationship with agents is crucial
to the management of the MPRP,”
highlights Mizzi. The agency continues
to strive towards more communication
with agents to keep them updated, while
listening to their feedback, exchanging
ideas and working towards a better
product for everyone involved.
Towards this end, Residency Malta
recently launched an Agents’ Portal, a
useful tool which allows agents to securely
check the status of their applications, while
also giving them access to other data and
reports that help them organise their work.
“This aspect of our digitalisation has also
added value both to agents and their clients
and has allowed us to keep our promise
of quality and value for anyone who gets
in touch with Residency Malta,” he says.
Product diversification
Malta is a treasure trove of opportunities,
and Residency Malta has taken upon itself
the role of making sure this is properly
marketed and availed of. Staying in touch
with the dynamic market is one of the ways
in which the agency diversifies its product
and makes sure to unlock the full potential
Malta has to offer to the right applicants.
The launch of the Nomad Residence
Permit is one such example of this. In
2021, Residency Malta began offering
a one-year residence permit for digital
nomads from non-EU countries. This
product was successful not only in terms
of numbers, but also in its ranking on
international sites. The agency – in
collaboration with the country’s business
promotion body, Malta Enterprise – also
launched a Startup Residence Programme,
for individuals from third countries who
would like to use Malta as a launch pad
for their innovative startup and scale up.
Malta’s attractions
“All our programmes offer a strong
proposal with added value,” says Mizzi.
“But a contributor to our success is
Malta itself. We are offering residency
on an island that builds a balanced bridge
between Mediterranean island life and a
metropolitan lifestyle. English is a national
language making communication between
locals and expats easy. Our history and
heritage have given the island its character,
and this has continued to evolve with
the times. Our local infrastructure is
constantly improving, and the digital
infrastructure is ideal for those wishing
to work remotely from our shores.”
Malta is also ideal for family relocation.
The island is safe and family-oriented,
boasts one of the best healthcare systems in
the world and offers a variety of educational
institutions in addition to easy flight
connections and access to the rest of the EU.
Meanwhile, Malta has reaped great
benefits from the agency’s success, with
revenue invested in the Consolidated Fund
and the National Development Social Fund,
which in turn provide important financing
for Malta’s infrastructure, health, education,
heritage, and philanthropic projects.
“Residency Malta has one mission
– unlocking Malta’s potential as a home
away from home while adding value to our
country. We will continue to push towards
efficiency, transparency and integrity, while
keeping our solutions fresh in a highly
dynamic market,” Mizzi concludes.
52 - Investment Migration Yearbook 2O23

IM YEARBOOK
Portugal:
Europe’s New “California”
American interest in Portugal is at an all-time high.
Frederico Seixas, Sales Director of Investaureum, explains why.
The Portuguese Golden Visa has
never been as popular as it is
now. According to the Portuguese
Immigration and Border Service (SEF),
in the first eight months of 2022, US
citizens accounted for 17.5% of all golden
visa applications. They consider the
programme an easy route to establish
residency in Europe as it offers them
mobility in Europe, a solid plan B, and
possibly a profitable investment. In fact, the
Alentejo region in Portugal has recently
been dubbed the Portuguese “Napa
Valley”, and we have seen huge interest
from the US in our two Alentejo projects.
There are, of course, various reasons
why Americans are leaving their country.
Here is an excerpt from an article in the
New Yorker: “Our democracy is in crisis.
Many institutions of our government are
dysfunctional and getting worse. Our
electoral system has produced, in a single
generation, two Presidents who received
fewer votes than their opponents. A changed
media landscape has – with the shrewd
assistance of malicious actors at home and
abroad – loosened our collective grasp on
reality. Our politics have become alarmingly
acrimonious. … Technology is enriching
some and leaving many others behind.”
Residence Permits (ARI) US Applicants - Years 2021 & 2022
30
20
10
0
N/A
N/A
N/A
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
54 - Investment Migration Yearbook 2O23

IM YEARBOOK
US applicants’ share of overall Portugal
golden visas (approved applications)
20
5,2% 6,3% 11,6% 17,5%
15
10
5
0
JUN 2020 2021 2022 (Jan-Aug)
US investors in Portugal
fall typically into five
main categories:
• Retirees
• Plan B seekers
• Digital nomads
• Parents of children
living in Europe
• Crypto investors
RETIREES. The Annual Global
Retirement Index 2022 has named Portugal
the fourth best country for retirement.
Portugal has great weather, a central
location, good connections to the rest of
Europe, a safe society, great health and
education, as well as a relatively affordable
cost of living. Many Americans dream of
spending their retirement years travelling
within Europe. Portugal’s Golden Visa
ensures seamless travel on the continent.
PLAN B SEEKERS. In today’s world,
having a plan B is no longer an option.
It is a requirement. Considering the
current political and social atmosphere,
having a plan B in a calm and stable
country has become more important
than ever. According to the Global
Peace Index 2021, Portugal is the fourth
safest country in the world. This is a
huge motivation for investors who want
to secure their family’s future in a safe
country. Apart from security, the quality
of life, education, and health care in
Portugal are among the best in Western
Europe, accompanied by a nice and mild
climate and many world-class beaches.
PARENTS OF CHILDREN LIVING OR
STUDYING IN EUROPE. The pandemic
has brought about travel and visa
limitations for many wealthy American
parents, who were suddenly not allowed
to make short trips to visit their children
working or studying in Europe. It turns
out that this temporary confinement
has triggered demand among affluent
parents for more permanent solutions
that allow unrestricted travel to Europe.
DIGITAL NOMADS. In addition to the
Golden Visa, Portugal recently launched
a one-year digital nomad visa. Remote
workers are now able to live and work
in the country for up to 12 months. To
qualify, applicants must earn at least
€2,800 per month – roughly four times
Portugal’s minimum wage. Of course,
the Portuguese Golden Visa continues to
be attractive for US-born digital nomads
who want to establish a base in Europe.
CRYPTO INVESTORS. Investors who
want to secure their crypto earnings
through a tangible asset, should consider
the real estate option under Portugal’s
Golden Visa. Investors can also opt
for Portugal Golden Visa investment
funds if they are already familiar with
non-traditional investments. There are
funds that focus on crypto investments.
In Portugal, traders and investors aren’t
subject to certain taxes on their crypto
earnings. Also, the crypto community in
the country is growing, which means that
investing in the country opens the door to
all kinds of networking opportunities.
The Bottom Line
The Portugal Golden Visa stands
out because of its flexibility. It allows
for various investment methods that
cater to different styles of investment.
Moreover, Portugal is calm, safe,
welcoming, and generally a pleasant
place to live. Welcome to Portugal!
Frederico Seixas is the
BIO Sales & Marketing Director
of Investaureum. He has 25 years
of experience in the real estate
sector, of which seven are directly
with the investment migration
industry. The Investaureum Group is
a Portuguese Real Estate Investment
Group, specialised in Prime/Unique
Real Estate Chartered/Heritage
investments that are eligible for the
Portugal Golden Visa programme.
Investment Migration Yearbook 2O23 - 55

IM YEARBOOK
Interview with Austin T. Fragomen Jr, Chairman Emeritus at Fragomen
The global race for
high-potential migrants
is heating up
Austin Fragomen shaped modern immigration
practice like no other and built the largest migration
focused legal firm in the world. In January 2023, he
has passedon the leadership of the firm to Lance
Kaplan and Enrique Gonzalez. The IM Yearbook
caught up with Austin Fragomen to relive some
of his career highlights and gain his thoughts on
the current trends influencing global migration.
What memories or
recollections do you
have of your entry into
immigration law?
As a law student I was very interested
in international law, and I took as many
international law courses as I could.
When I graduated from law school, I
went to work for the house judiciary
committee, the US house representatives,
and I became the staff council to the
immigration subcommittee. Back then,
the US immigration system was very
much focused on family reunification
and humanitarian immigration, and
although it had some allowance for
business immigration, this was limited.
56 - Investment Migration Yearbook 2O23

IM YEARBOOK
When I arrived at the Committee in the
1970s, the big issue was how corporations
could move people around the world. It
was very laborious because there was no
non-immigrant category that allowed
for work on a temporary basis. I got
involved in making changes to certain
visa categories to ease the process.
I thought this was a big growth
opportunity, which turned out to be
accurate. In the years that followed,
companies really embraced these new
methods and opportunities to move people
around the world. We then decided to
build an immigration practice, which had
two prongs to it: the private client and the
corporate practice. And we maintained
this dual approach throughout the years.
Fragomen was founded
in 1951 as Elmer Fried.
Looking back, during which
period did you experience
the greatest growth?
In 1990, there was a major reform of the
immigration Act, which greatly increased
the number of visas allotted to business
immigration and created the EB-5
category in the US. That provided a lot
of additional opportunities. Previously,
the US didn’t really have a programme
for investment migration. Back then that
space was dominated by some Caribbean
countries, South American countries, and
some other obscure places that I found
most of the investors didn’t know where
they were. I remember someone in Hong
Kong once asked whether world maps
are handed out along with the visas so
that the investors knew where to go.
Meanwhile, we saw big demand
for global representation from major
corporations. They, of course, had
operations around the world and asked us to
represent them. We did that first through cocouncel
in places like Canada, the UK and
Brazil. Then, in 1999, we opened our first
foreign office in Belgium and subsequently
got more involved in global emigration and
represented people moving out of the US.
The private client side only got
international following the introduction
of the US EB-5 regional centre programme
in 2005. Before that, the EB-5 system in the
US was not very popular, it just had around
1,000 applicants per year. It simply was too
complicated since investors had to have an
active business with at least 10 employees
What strategy did you
apply to scale the firm and
transform it from being a
small boutique law firm
into a global organisation?
In most countries, we were co-counseling
with another law firm initially. We only
opened our own office when we had
enough critical mass. Frequently, the
co-counsel would merge into our firm.
Of course, the situation was a little bit
different in each country. For instance,
after PwC in Australia decided to
divest themselves of their consulting
businesses in the early 2000s, we bought
the immigration business from them.
We never opened an office and then
tried to get clients. We always made sure
we had clients first. Our clients were
mainly the global operations of US-based
companies that we represented, so this
made it easy to expand. Once the US
regional centre system was established,
we were able to look at US immigration.
The first country – besides the Caribbean
islands – which had a robust and active
immigration system was Canada. We used
that particularly for Asian and South African
clients. As the residency and citizenship by
investment sector really took off, it became
a large part of our private client business.
What can you tell us about
Fragomen’s footprint today?
We now have a staff count of some 6,000
people. The important thing is that through
various layers of subsidiaries, we own all
the offices that we have throughout the
world, except for a few locations in Latin
America where we have a network of
providers with whom we have a different
economic arrangement. Ultimately, we’d
like to have offices in all the principal
countries where there is enough activity
and that warrant to have an office.
We have a handful of locations where
we are going to be opening offices. We
were a little bit late in South-East Asia, so
we recently opened an office in Thailand,
and will probably be opening offices in the
Philippines and in Japan next. We didn’t
have a good coverage there before. We
had offices in Singapore, Malaysia, and
China. We thought at some point we will
have offices across China, but right now the
business in China is impacted due to all
the Covid-19 the restrictions. Importantly,
however, in many countries we managed
to build up local business, even in China
we represent several Chinese companies
for immigration purposes around the
world. We are competing with the Big Four
primarily, not with other law firms. They
have offices everywhere, so it’s important
for us to have offices in major locations
that offer a certain volume of work too.
2022 marked the year where
geopolitical tensions moved
centre-stage again, and the
economic outlook for 2023
has turned sour. How do you
think this climate will affect
investment migration?
The prospect of a recession hasn’t
really impacted employment so far,
but it will to a degree. We can expect
that to happen, but it is not going to be
anywhere near the impact that Covid-19
or the 2008/2009 financial crisis had.
More importantly, labour migration is a
growing business, regardless of what’s going
to happen to the economy. As long as we have
population growth, labour migration will
grow too. In fact, if you track the number of
labour migrants against population growth,
the growth line is pretty much the same.
I think countries will really start
focusing on the skill gap problem that
they have. Many countries need people
with specific skills. However, their
educational and training systems lag
Investment Migration Yearbook 2O23 - 57

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IM YEARBOOK
behind and countries are not able
to fill those needs domestically. On
top of it, there is the demographic
problem, with several countries just
not having enough workers. On the
other hand, many developing countries
are experiencing strong population
growth. Therefore, migration will be a
major factor moving into the future.
How can host countries best
try to attract skilled workers?
I think countries need to and will start
institutionalising their need for migrants,
and they will further decouple work visas
from employment. Some countries have
already launched programmes to attract
high-potential migrants. An example
is the UK’s ‘High Potential Individual
Visa’, through which graduates of the
world’s top universities can get a work
permit in the UK without having a job
offer. Elsewhere, in 2021, Canada allowed
about 50,000 foreign students to stay
for 18 months after graduation to seek
employment, during a time when the
economy was reopening from Covid
shutdowns and companies needed to hire.
I am certain we are going to see
a lot more international cooperation.
Countries will work closely together to
place job seekers across borders. The
Global Compact for Migration, which has
been adopted by most of the countries in
the world, sets up best practices for every
aspect of migration. For the first time
countries are really coming together and
talking about how they can use migration
as a tool for development. Moreover,
there’s a parallel UN Organisation called
the Global Forum on Migration and
Development. I am the chairman of the
private sector group in the Global Forum
on Migration and Development, so I do
a lot of work with different countries
around the world on migration policy.
We see a lot more coordination and
transparency, as well as sharing of best
practices. This is very different compared
to the situation a few years ago.
Yet immigration remains
one of the most controversial
policy issues in many parts of
the world, including the US
and Europe. What thoughts
would you like to share about
migration, public opinion,
and political support?
I think that the general attitude
towards immigration is becoming more
positive in the sense that people are
realising that countries require some
level of immigration. I think Covid-19
helped in a weird way because in
many developed countries, immigrants
made up a large part of the ‘essential
workers’ that kept everything moving.
Moreover, countries are making
statements about their need for
immigration. For instance, Japan just said
they need more people because they have
a massive shortage of workers. Of course,
what’s negative is irregular immigration.
Since Donald Trump has announced
that he wants to run for president again,
I think we will have several more years
of intense analysis of immigration
in the US. Europe has substantial
problems with irregular immigration
too, but I think overall the attitude
towards immigrants is slightly better.
In a previous interview
with the IM Yearbook, you
were not very convinced
that start-up, entrepeneur
or innovator visas would be
economically successful.
Today, almost every country
runs these programmes.
Have you noticed any
significant improvements?
There’s a renewed interest in these
programmes as countries are trying to
attract innovators and entrepreneurs to
create jobs. But I am still of the opinion
that no one has figured out how to run
them. How do you identify people who
are the process of being successful?
Some programmes look at how much
money a start-up has attracted from
angel investors. However, the presence
of venture capital doesn’t mean that you
are going to have a successful company.
However, I think we are going to
see more digital nomad programmes,
which are going to allow people to live
somewhere and not have to make an
investment. I think that offering will
compete to some extent with traditional
investment migration programmes.
India is currently one of
the hottest markets for
investment migration.
Yes, what’s interesting about India is that
there’s a lot of circular migration. We
see a lot of Indians coming to the US to
study because they think they have more
opportunities here and it’s a good career
steppingstone for them, but many of them
are returning to India, where they set up
their own companies or take up senior
positions in large Indian companies.
It’s one of the big success stories in the
migration field: People leaving a country,
acquiring a higher level of education,
and then returning and applying
those skills in their home country.
What key lessons have
learned along the way that
would you like to share with
practitioners across the world?
From my experience, and in retrospect, I can
say that recessions or other forms of turmoil
only have a minimal impact on migration.
The one thing that we really need to be
aware of are politicians who can be harmful
to the migration system due to their general
xenophobia. They are the people that as an
industry we really must be concerned about.
What are your plans for your
retirement? I find it hard to
believe that someone like
you will just sit back and
enjoy the Florida sunset.
I will certainly keep my affiliation with my
firm as chairman emeritus. My plan is to
continue being involved in migration policy.
I will be somewhat less involved with clients,
but I will offer advice at the policy level and
support organisations such as the IMC.
BIO
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 subcommittees
of the House and Senate
to share his knowledge on a variety
of business immigration issues.
Investment Migration Yearbook 2O23 - 59

IM YEARBOOK
Women, Wealth and
Investment Migration
Women’s economic power and financial independence
are growing rapidly around the world, yet they are often
overlooked by the financial and wealth management industry.
The IM Yearbook asked four experts: how well are
women served in an investment migration context?
Investment migration – much like the
entire wealth management industry
– is geared towards a predominantly
male clientele. Since, historically, men
were the main income earners and
entrepreneurs, they were also making
most investment and financial decisions.
However, women’s wealth is growing.
McKinsey found out that women already
control more than a third of total US
household assets, and their portion is
expected to grow throughout the coming
generational wealth transfer. In the UK,
60% of wealth will be in female hands by
2025, according to a forecast by the Centre
for Business and Economic Research.
In recent years, financial service firms
and wealth advisors have made a concerted
effort to attract more women investors,
who today are assuming more powerful
roles in personal and family investing and
decision making. This raises the question:
have investment migration consultancies
also noticed a rise in female clients?
On the rise
Alexander Varnavas, managing
partner at Varnavas law firm in
Greece, comments: “For the past two
years, women have formed 40% of our
clientele, which is an increase from the
first years operating in the investment
migration industry in Greece. Even
though the rest of the 60% is technically
male-dominant, this does not imply that
their significant others had no major role
in the planning and execution of their
investment plans through our services.”
He adds that his firm had
“executive-level men entrusting
their sisters, spouses or daughters to
manage million-dollar investments
on their behalf, or more accurately,
with minimum involvement from
them, as they entrust women in their
lives to manage the whole process”.
Paul Williams, CEO of La Vida, said
he hasn’t noticed a particular shift.
“We treat everyone the same and
find their needs are similar,” he said. In
family applications, “the main applicant
is sometimes the husband, sometimes
the wife”. However, in terms of single
applications, women are in the minority. “I
would say far less than men, possibly 10%.”
Jennifer Lai, Wealth & Residency
Planning Managing Director at DL
Holdings Group, says that around half
of her clients are women. She adds that
traditionally Asian culture considers ‘men as
breadwinners’ and ‘women as homemaker’.
However, migration is seen as a family
matter, and she has had many cases where
the husband started the initial conversation
and then leaving it to his wife to follow up.
In addition, she says that among her
clients she has had many successful female
entrepreneurs, professionals and executives
in senior management, either married
or single. “They are the decision-makers
on many aspects, including investment
migration.” Lai concludes that women are
60 - Investment Migration Yearbook 2O23

IM YEARBOOK
playing a more important role in investment
migration, not only as a result of the gender
equality debate, but also because they have
become more successful in business, which,
in turn, has strengthened their position
when it comes to family decision making.
Different attitudes
In the US, Edward Beshara, Managing
Partner of Beshara Global Migration Law
Firm, also saw the percentage of female
clientele growing from around 25% a few
years ago to 35% today. But the change is
not just in the numbers: “While female and
male clients usually have the same business
and immigration goals, women are detail
oriented in regard to the particulars of
the investment and will always use dual
diligence to the extreme by reviewing
the details and processes of investment
migration,” he said. Lai also perceives
women as detail-oriented, assessing and
analysing every step of the process. Male
clients, she says, do not focus so much on the
process but look more into the end results.
Analysing women’s relationship and
attitudes towards the wealth management
sector, EY pointed out that many women
view the industry as male-oriented and
unwelcoming. Meanwhile, a research
study commissioned by Merrill, “Seeing
the Unseen: The Role Gender Plays in
Wealth Management,” took an expansive
view of the subject, delving into the stories
of women investors and their financial
advisors. Among the study’s findings are
that only 8% of women investors have
experienced negative gender assumptions
from their financial advisors and that
such incidences of bias are usually subtle.
But, as the research emphasises, there
are multiple areas of unconscious bias,
underscoring the need for advisors and
executives to evaluate their own behaviors.
The status quo
Varnavas says “a lack of accommodation for
women” in an investment migration context
would not surprise him. “Unfortunately,
women still have to deal with misogynistic
practices. For centuries it had become
normalised to underestimate them,
and many professionals up to now have
not adapted and openly accepted that
businesswomen have a profound position
in every industry,” he adds. He believes his
firm is on a solid path. “Even though it was
not deliberate, our establishment is made
mostly of female professionals,” he adds.
While most women do not explicitly
look for female advisers, many place a
high value on establishing a personal
connection with their adviser. Varnavas’
firm contracted 80% of the businesswoman
who approached the firm in 2022. “Our
corporate strategy is about taking every
inquiry seriously. We communicate with all
of our clients promptly, we do put the time
to answer thoroughly, and we ensure that
we respect the intelligence and boundaries
of clients in our follow-up routines.”
Lai also said her firm has “successfully
connected with women on the personal
level and on the coroproate level”. However,
she does not think she needs to change
her service provision to “serve by gender”.
For her, it’s always about providing
quality and professional services that
are in tune with the client’s demands
and interests, irrespective of gender.
A long list of male-focused industries,
such as automobiles and real estate, have
revamped their product and service models
to meet women’s needs in recent years. As
unprecedented sums of assets shift into
the hands of women over the next decade,
consultancy firms in the investment
migration space have no choice but to ensure
they attract and retain women investors.
BIOS
Edward Beshara is the Managing
Partner of Beshara Global Migration
Law Firm. He represents corporate
and individual clients from all
countries worldwide in regard to their
business and family US visa goals.
Jennifer Lai is the Managing Director
of Wealth and Residency Planning
at DL Holdings in Hong Kong. She
previously worked for more than 10
years at Henley & Partners and held
various roles during that time.
Alexander Varnavas is the Managing
Partner of Varnavas Law Firm 1978
and a leading lawyer in real estate
and investment migration law. He
has introduced the private client
practice of the firm, representing
HNWI and UHNWI to invest in Greece.
Paul Williams is founder and CEO of
La Vida. He qualified as a Chartered
Accountant and held several senior
positions at multi-national companies
before forming La Vida in 2002.
Investment Migration Yearbook 2O23 - 61

IM YEARBOOK
How migration policy
can accelerate recovery from
the global economic downturn
Dr Khalid Koser, Executive Director of the Global Community Engagement
and Resilience Fund, says migration is critical for growth while the economic
importance of highly skilled migrants far outweighs their numerical significance.
The Covid-19 pandemic and the
conflict in Ukraine have distracted
and distorted global migration
policy and diverted resources away
from it; with lasting implications which
will become exposed during the global
economic downturn and slow its recovery.
Globally, migration came to a
standstill during the pandemic; by
April 2020 more than half the world’s
population was under some form of
lockdown. Continuing restrictions
on entry and exit in some parts of the
world (especially China), social and
economic impacts of the pandemic
which have exacerbated poverty,
changes in work patterns and lifestyle
choices, and continuing disruption
to airline schedules and pricing, are
all factors why migration has not yet
recovered to its pre-pandemic rates.
Focus on Ukraine
The conflict in Ukraine has had significant
migration impacts, particularly on
mobility in and out of Russia, but almost
the entire policy focus has been on the
forced migration of about seven million
people displaced internally, and a further
approximately seven million refugees mainly
to other European countries, many of whom
have started to return. Ukrainians are not
the majority of the world’s refugees, and
globally the number of refugees is far fewer
than the number of voluntary migrants.
Migration is critical for global
economic growth, providing labour,
skills, and money. The failure to recover
migration rates more quickly, as well as
an understandable emphasis on refugees,
will exacerbate the global economic
downturn, and slow its recovery.
Three Goals
In the short term, global migration policy
should have three goals. One is to ensure
that workers can continue to migrate, inside
but especially outside their countries.
But this is challenging because during
recessions, historically, migrants have
tended to be scapegoated, with politics
demanding that restrictions are increased
while economics demands that they be
lowered. A partial solution is to enable
the many millions of migrant workers
who lost their jobs during the pandemic,
but mostly were unable to return home,
to re-enter the labour market. As the
furor over the Qatar World Cup reminds
us, however, it is also essential that
migrant workers’ rights are respected.
The economic significance of highly
skilled migrants far outweighs their
62 - Investment Migration Yearbook 2O23

IM YEARBOOK
The failure to recover migration rates more quickly, as well
as an understandable emphasis on refugees, will exacerbate
the global economic downturn, and slow its recovery.
rarely fosters the serendipity required
for innovation. Particularly important is
to promote the migration of students, for
example through expanded scholarship
schemes, and to ease employment and
residence requirements that often mean
they cannot remain after their studies.
US$500 billion
numerical significance; and a second
priority should be to ensure that talent can
flow freely, accepting for the moment that
the significant pools of talent in Russia and
China currently remain largely inaccessible
to the global economy. In certain sectors, for
example financial services, the acceleration
of online work because of the pandemic
can resolve this challenge. But in others,
like healthcare and education, people
need to be present. One of the lessons of
the pandemic is also that remote work
One of the lessons of
the pandemic is also
that remote work rarely
fosters the serendipity
required for innovation.
The pandemic and the wider implications
of the Ukraine crisis, for example on
global food supplies, have made more
people more reliant on money traditionally
remitted by migrants to their families at
home. The World Bank estimates that in
2021 over US$500 billion was remitted
globally, and that remittances were
recovering quickly following their collapse
during the pandemic. A third target
should be policies geared to maintaining
the recovery of remittances, including
increasing competition within the sector
to drive down commission rates.
Achieving these goals requires a
re-allocation of financial and human
resources to migration at the national,
regional, and global levels. The return on
investment will make that worthwhile: It
will accelerate the recovery from the global
economic downturn, but also promote the
diversity of social and cultural exchanges
that were lost to the pandemic and are at
risk because of political extremism.
Dr Khalid Koser is founding
BIO Executive Director of the
Global Community Engagement &
Resilience Fund (GCERF). An academic
by training, Khalid is Professor of
Conflict, Peace and Security at
the University of Maastricht. As a
global advocate for migrants and
refugees, he chaired the World
Economic Forum Global Future
Council on Migration for six years,
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.
Investment Migration Yearbook 2O23 - 63

IM YEARBOOK
CONGRATULATIONS:
YOU ARE NOW
PART OF THE IMCET
COMMUNITY LET’S
CELEBRATE YOUR
SUCCESS!
Below Is The Official List Of
IM Certified Practitioners
Adewole Adenle
Darien Ellul
Jude Clemoes
Nevnihal El Afifi
Stefanie Fetzer
Aggelos Nizamis
David Adeola Olabode
Jusztina Rebeka Juhasz
Nguyen Hai Yen
Stewart Koesten
Agnes Varga
David Paillé
Katarzyna Aldycka
Nguyen Minh Tri
Sue Nickason
Aimee Lisle
Dishita Sheth
Kathy Rivera
Nguyen Thi Lan Phuong
Sylvania Tobierre
Alan Huether
Dmitry Dudarev
Keith Isaac
Nguyen Thi Minh Thu
Sylwia Wolos
Aleksandra Smolen
Dmitry Shishkin
Keni Ma
Nguyen Thi Minh Trang
Tajma Brown
Alexander Zvarkovskiy
Dom Barnes
Kenny Arevalo-Lebrun
Nikisha Delabanque
Tertius Relihan
Alexei Sakharov
Eddy Leviten
Kervin Leonice
Nikkita Nair
Tessy Ekpunobi
Aliza Thompson-Nurse
Edwina Keyser
Khanh Do
Nora Gomori
Theodore Prillaman
Analida Vallarino
Eleni Acquarone
Laila Alrasheed
Olakitan Arogundade
Theresa Okeke
Anastasiia Chekina
Eliot Brendon Mc Gillivary
Laila El Orfi
Opinder pal Singh
Tishanna Higgins
Anca Patrascu
Elizabeth Davison
Laura Austin
Pablo Ostrick
Trafford Busuttil
Andres Gutierrez
Elmarie Theron
Lesikel Ali
Patrick Ansah
Tran Thi Truc Linh
Andrew Hesner
Erica Lake
Lilla Krifaton
Pelin Güngör
Tran Tuan Anh
Andria Petrou
Evelyne Hantig
Linda Boiteau
Philip Paschalides
Vadym Shevchenko
Anna Ponte
Fabia Francis
Lisa McShine
Pierre-Étienne
Valentina Alekseyevna Sammut
Asim Mahmood
Gabriele Avellino
Lucy Mckenzie
Balthazar-Lacasse
Valeriano Anibarro
Audra DeFalco
Gianella Farrugia
Ludovic Mapessa
Rachel Micallef
Vanda Marlok
Bobbi Jo Kutch
Hangama Wanner
Lukas Harries
Rebecca Williams
Vanessa Lima
Bojana Minic
Hanna-Liina Linnasmäe
Madalena Monteiro
Renee Pindar
Varun Singh
Bruno L’ecuyer
Hassan Sattar
Marcus Lionel
Richard Jacks
Veronica Bulat
Caterina Assunta Passini
Hudda Elmira Chehadé
Maria Grech
Roddy Denness
Victor Lawson
Cedric Leblanc
Ibifuro Sekibo
Maria Kouri
Roderick Cutajar
Victoria Atanasova
Chameil Neecola Joseph
Irene Davidson
Marie Lou Cutajar
Rohit Kapur
Viviana Echeverria Pascual
Chelita Virdee
Irina Walsh
Matteo Cicero
Roleece Brookes
Yanica Woods
Cheryl Francis
Jacques Plante
Michael Martin
Rosendo Guimaraes da Costa
Yuan-Yu Hung
Chris Siwei Chen
James Muscat Azzopardi
Michel Soler
Samantha Julien-Fontaine
Zachary Busuttil
Christian Wayne
James Swenson
Mohamed Isaydou
Samuel Morrell
Zain Ahmad Butt
Christina Georgaki
Jamie Alleyne
Mohammad Asghar Ali
Sara Rebolo
Zamaris Saxon
Christopher Clowes
Jaynelle Lake
Mounir Bendaoud
Sarah Young
Zarah Gaba
Claire Joseph
Jennifer-Lynn Kent
Mphuthumi Soga
Sasha L’ecuyer
Zeleka Peters
Clare Monique Aquilina
Jessica Debono
Mtonya A. G. Deterville
Sebastien Pham
Zoe Dowe
Dalia Akl
Johannes du Toit
Muhammed Yusuf Coban
Seethalakshmi Ramanathan
Community Malta Agency
Daniel Ohana
John Richardson
Nani Yuningsih
Shanda Toussaint
Staff Members
Daniel Saint-Davis
Jose Luis Garcia Reyna
Natalia Fridlender
Shane Qu
Residency Malta Agency
Daniel Twomey
Joshua Lake
Neil O’Leary
Sharlene Isaac-Louison
Staff Members
64 - Investment Migration Yearbook 2O23

RIF TRUST & LATITUDE GROUP:
A GLOBAL MARKETING AGENT FOR THE ST LUCIA
CITIZENSHIP BY INVESTMENT PROGRAMME
“I’m excited about this new partnership with
RIF Trust and Latitude as we’ve enjoyed a
mutually beneficial relationship for some
time. The new agreement will see both
sides collaborate on the planning and
implementing marketing strategies across
key areas, leveraging our programme’s
strong brand and RIF Trust and Latitude’s
experience to make St Lucia a number
1 option.”
– Mr Mc Claude Emmanuel, the Chief Executive
Officer of the Citizenship by Investment Unit
of St Lucia
LOOKING TO PARTNER WITH US?
North & South America, Europe & Asia: info@latitudeworld.com
Middle East and Africa: contact@riftrust.com

IM YEARBOOK
Fellow Member Certified IMCET Professional
Certified IMCET Professional
Certified IMCET Professional
Theresa Okeke IMCM
Managing Director
CBI Agent | Luxury
Resort & Second-
Home Realtor®
Valentina Sammut
IMCM
Founder and Chief
Executive Officer
Varun Singh
IMCM
Managing Director
Paul Williams
IMCM
CEO
Alexander Varnavas
FIMC
Managing Partner
FRONTGATE GLOBAL CONCEPTS, LLC
Theresa Okeke is the Managing Director of Frontgate Global Concepts,
a bespoke Investment Migration consultancy firm specializing in the
Grenada CBI program. Based in Atlanta, GA., with offices in West Africa
and Canada, Frontgate Global collaborates with the most trustworthy
local partners to ensure a successful compliance process. Our investor
representation services are highly personalized, and we serve as a trusted
resource for the E2- Visa & Canadian Start-up Visa program. Theresa
has IMC certification in Investment Migration and is a licensed resort
& luxury second home realtor with Berkshire Hathaway. With diverse
backgrounds in international business and public service, helping
our clients successfully navigate the application process to achieve
mobility & their second-home goals is what motivates our team.
BIZ CONSULT LIMITED
BIZ Consult Limited is the leading exclusive provider of customer oriented
immigration services with the focus on the residency and citizenship by
investments, due diligence, compliance. BIZ Consult offers its clients and
their family members — which include high net worth individuals from
the Commonwealth of Independent States, Asia and Middle East — the
full support with documents, translations, legalisation, and real estate
since 2014. The company provides its services with the highest professional
standards. BIZ Consult founder Valentina Sammut is an IMC certified
professional. Our team of legal professionals provides sound advice with
respect and diligence with strict confidentiality and data security. The
company is an approved accredited agent by the Malta Community Agency.
XIPHIAS IMMIGRATION
XIPHIAS Immigration is one of the leading Investment Migration
firm in India. The organization has nurtured long-term client
relationships by offering innovative ideas and developed associations
with global powerhouses such as Europe ,Canada, UK, Australia,
US and New Zealand. ICCRC, CANADA and MARA, AUSTRALIA
officially recognize XIPHIAS Immigration through its certified
consultants. The organization has collaborated with eminent
attorneys and legislators for assistance with processes in their
respective countries. The team is knowledgeable and experienced
and provides services with honesty ,integrity and professionalism.
LA VIDA GOLDEN VISAS
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.
VARNAVAS LAW FIRM 1978
We are an awarded Law Firm based in Athens, with expertise in Real
Estate Law and Investment Immigration. Our dedicated team consists of
trustworthy and highly trained lawyers, notaries and financial advisors,
who provide our domestic and international clientele with high-quality
legal services. Experienced for over 40 years to support prestigious
companies and high-net-worth individuals from all over the world, we
have developed an entirely client-focused practice, fulfilling diversified
objectives and expectations. Being the first ‘Greek’ IMC Members,
since 2015, and believing in teamwork, we pursue the establishment of
long-term collaborations with lawyers and professionals dealing with
investor immigration programs worldwide, to provide global, multidimensional
solutions related to the Golden Visa program in Greece.
1201 W Peachtree St.Suite 2300
Atlanta, GA 30309
T: 1-800-425-9212
M: 1-404-407-5555/ 1-404-910-8835
W: www.frontgateglobalconcepts.com
E: info@frontgateglobalconcepts.com
146, Fl. 4, Constitution Street,
Mosta, MST 9055, Malta
W: https://bizconsultmalta.com/
T: (+356) 99 020 654
E: info@bizconsultmalta.com
Contact: Valentina Sammut - Founder
and Chief Executive Officer
8th Floor BMTC Depot
Koramangala 6th Block
Bangalore 560095 KA INDIA
www.xiphiasimmigration.com
+91-9019 400 500
Belmont House, Belmont Road,
Uxbridge, UB8 1HE England
W: https://www.goldenvisas.com/
T: +44 207 060 1475
E: info@goldenvisas.com
Contact – Paul Williams – CEO
6 Loukianou St. Kolonaki,
10675, Athens, Greece
T: +302106400300
E: legal@varnavas.gr
W: www.varnavas.gr
66 - Investment Migration Yearbook 2O23

IM YEARBOOK
Charles Mizzi
IMCM
Chief Executive Officer
RESIDENCY MALTA AGENCY
Residency Malta Agency is the Government entity responsible for
managing and promoting the Malta Permanent Residence Programme.
The programme grants beneficiaries from third countries the right to settle
permanently in Malta and travel visa-free across Schengen for 90 out of
180 days. Beneficiaries can enjoy residency in a safe and stable country
boasting excellent educational opportunities and economic prosperity.
All applications submitted through licensed agents undergo a rigorous
due diligence process to ensure that only fit-and-proper individuals are
granted residency. The Agency also manages the Nomad Residence Permit
– a one year residency permit for digital nomads and remote workers.
Zentrum Business Centre, Level 2
Mdina Road, Qormi QRM 9010, Malta
T: [+356] 2203 4000
e: customercare.residencymalta@gov.mt
w: residencymalta.gov.mt
Contact: Roberta Rodoligo – Senior Manager
Hui Li (Eric)
Managing Director
HELLENIC INVESTMENT FUND CO IKE
Hellenic Investment Fund Co IKE, a real estate developer in Greece,
serves the demand of income generating properties as well as high-end
family residential properties by one-stop full package services including
property management, relocation and family centered support. We
strive to earn the deep and lasting trust from our clients consistently.
Hellenic Investment Fund Co IKE
78 Posidonos, Alimos, Athens, Greece 17455
T: +30 2109848813
M: +30 6949698967
E: eric@hif.gr
W: www.hif.gr
Ricardo Cambra
La Duke
IMCM
Managing Partner
CLD LEGAL
With more than15 years of experience and successful advice in immigration
matters, real estate, tax and estate planning and corporate law, CLD
Legal assist businesses, investors, families, and individuals to choose the
right residency program in Panama, suited to their needs. Our highly
experienced and knowledgeable professionals accompany our clients
through all the stages. Contact and book a private meeting to evaluate
your options: Friendly Countries Visa; residence as a retiree or pensioner;
residence as a Foreign Professional; Permanent residence for Italian
citizens; Visa for SEM Business workers; Work visa within 10%; Domestic
workers; Reasons for family reunification; For economic solvency; among
other visas of temporary, permanent residence or by special policies.
Samuel Lewis Avenue & 55 East St.,
Obarrio, Building SL 55, 21st Floor
Panama City, Panama
1. Headshot in CMYK –
www.cldlegal.com
Please use one of the below pictures.
Marco Cerrato
IMCM
Partner
MAISTO E ASSOCIATI
Maisto e Associati is an independent Italian tax law firm, established in
1991, with 60 professionals (including 11 partners) divided among its offices
in Mian (main office), Rome and London, consistently ranked as tier 1 in
the Italian tax scene. The Firm has developed a unique expertise in the
private clients sector and in particular in advising over 100 families on
their relocation to Italy under the Italian Forfait Tax Regime. Within this
specific practice area, the Firm has acquired extensive knowledge and
expertise on the immigration law aspects of the relocation, assisting clients
throughout the entire procedure for the obtainment of the investor visa
(the Italian visually elected HNWIs) and the related residence permit.
Maisto e Associati
Piazza Filippo Meda,
5, 20121 Milan, Italy
2. Full Name and Designation –
+39 02776931
Barr. Tessy Ekpunobi
milano@maisto.it
Investment Migration Attorney
www.maisto.it
3. Company Name and Logo in CMYK
Fellow Member /
Certified IMCET Professional
Barr. Tessy Ekpunobi
FIMC
Investment Migration
Attorney
GLOBAL RESIDENCE AND CITIZENSHIP LTD. (GRCL)
Global residence and Citizenship Ltd. (GRCL) is a full-service
international Law Firm in Nigeria, with a sister company in Canada,
specializing in international migration with a specialty in Second/
Alternative Residency and Citizenship programs. With over 25 years of
International Migration experience, we have successfully assisted over
3000 clients to legally obtain citizenships and permanent residency
through Investment Migration Programs including but not limited to:
Start -Ups, Provincial Nominee, Real-Estate/Donation options, and
significant investments option of some EU, North America and the
Caribbean that offer alternative residency/citizenship programs. Our
global team of legal professionals and affiliates ensure that all clients
are treated with respect and confidentiality, all files handled with
competence and efficiency geared towards a successful outcome.
GLOBAL RESIDENCE AND CITIZENSHIP LTD
GLOBAL MIGRATION AND INTERNATIONAL REAL ESTATE LAW FIRM
N0. 20, 641 Rd. Off 64 Road. Off 6 th Avenue.
Gwarimpa. FCT. Abuja. Nigeria
Tel: +234.805.897.3551. +1.513.729.7703
Nº 20, 641 Email: Rd. globalresidences@gmail.com
Off 64 RoadOff 6th Avenue.
Gwarimpa. URL: FCT. https://global-residence-and-citizenship.business.site/
Abuja. Nigeria
T: +234.805.897.3551 Contact: Tessy Ekpunobi • +1.513.729.7703
Esq. – Investment Migration Attorney
E: globalresidences@gmail.com
W:
4.
https://global-residence-andcitizenship.business.site/
A 120-word write-up describing the main activities of the organisation
Contact: Global Tessy residence Ekpunobi and Citizenship Esq. Ltd. – (GRCL) is a full-service international Law Fir
Canada, specializing in international migration with a specialty in Second/Alterna
Investment Migration Attorney
With over 25 years of International Migration experience, we have successfully a
citizenships and permanent residency through Investment Migration Programs in
Provincial Nominee, Real-Estate/Donation options, and significant investments o
Caribbean that offer alternative residency/citizenship programs.
Investment Migration Yearbook 2O23 - 67
Our global team of legal professionals and affiliates ensure that all clients are tre
files handled with competence and efficiency geared towards a successful outco

IM YEARBOOK
Anubhuti David
Global Proposition
Director, Customer
Risk Intelligence
REFINITIV
For over a decade Refinitiv, an LSEG business, have been a trusted due
diligence provider supporting governments, regulators, civil society, as
well as agents and law firms in mitigating risks related to Citizenship by
Investment (CBI) and Residency by Investment (RBI) programmes.
Being the only due diligence provider in the market leveraging our
World-Check Risk Intelligence proprietary data, our Investment
Migration reports offer accurate, quality insights, ratings and analysis
into the potential risks associated with applicants and co-applicants,
no matter where they are located. Our thorough research and
background checks covers areas of core identity and integrity risks
as well as emerging risks, safeguarding your programme from illicit
money flows, sanctions, and related reputational vulnerabilities.
5 Canada Square,
Canary Wharf, London, E14 5AQ
Contact: Anubhuti David – Global Proposition
Director, Customer Risk Intelligence
E: Anubhuti.David@lseg.com
T: +44 (0)20 7542 3881
W: https://www.refinitiv.com
Karen Kelly
IMCM
Director, Strategy
& Development
EXIGER
Exiger has been a pioneer, innovator, and leading provider of due diligence
and advisory services to the investment migration industry since 2006.
As a trusted partner to the largest and fastest growing Residency and
Citizenship by Investment (RCBI) programmes operating today, we
bring cost-effective and efficient, technology-enabled solutions to the
industry. Exiger has developed specialized methodology and reporting
for the investment migration industry, including a one-of-a-kind risk
assessment. Our award-winning AI technology platform, DDIQ, is
also changing the way programmes manage applicants and agents
by anticipating their most pressing needs. With over 200 full-time
research staff speaking 35 languages in research centers around the
globe, we empower you to make the world a safer place to do business.
1675 Broadway, Floor 15, New York, NY 10019
www.exiger.com
Contact: Karen Kelly – Director,
Strategy & Development -
kakelly@exiger.com,
+1 778 945 7318
Jennifer Lai
Wealth & Residency
Planning Managing
Director
DL HOLDINGS
Headquartered in Hong Kong, DL Holdings has offices in Shanghai, San
Francisco, Singapore and Tokyo. We provide customized global family
office, private banking, investment banking, and residency planning services
to the clients. We currently have assets under management and investment
over US$3 billion, of which nearly US$2.1 billion is under DL Family Office.
The group holds Type 1, 4, 6 and 9 licenses issued by HKSFC, as well as
Singapore RFMC fund management license, Cayman Islands SIBL fund
management license and more than 18 HK Limited Partnership Funds (LPF).
Unit 2801, 28/F, Vertical Square 28
Heung Yip Road, Wong Chuk Hung, Hong Kong
Contact: Jennifer Lai - Wealth & Residency
Planning Managing Director
Certified IMCET Professional
Laura Austin
IMCM
Managing Director
MINTZ GROUP
Mintz Group is the partner of choice for due diligence, investigations, and
background screening, anywhere in the world. Since 1994, Mintz Group has
worked with governments, corporations, investors, and the legal, financial,
and talent advisors who need actionable facts to assess risks, protect
reputations, and win disputes. Mintz Group has employed a uniquely
transparent and practical approach to fact gathering and has provided
impartial facts that are comprehensively researched, properly sourced, and
stand up to the toughest scrutiny. Headquartered in New York City, Mintz
Group has offices in 18 countries across nine time zones, with a team that
speaks more than 35 languages, and has successfully conducted over 40,000
investigations in 100+ countries. To learn more, please visit mintzgroup.com
110 Fifth Avenue, New York, NY 10011
T: +1 646.713.4121
M: +1 612.618.1222
E: laustin@mintzgroup.com
W: www.mintzgroup.com
Patricia Casaburi
IMCM
Managing Director
GLOBAL CITIZEN SOLUTIONS
Global Citizen Solutions is a boutique consultancy firm focused on
residency, citizenship programs, investment and global mobility. With
offices in Portugal, the United Kingdom, Hong Kong and Brazil, our
multicultural and multilingual team will guide individuals and families
from start to finish, providing expert advice considering freedom, mobility,
taxation, and security. Our international team is devoted to fulfilling our
client’s personal and financial needs, knowing that each situation is unique.
Av 24 de Julho 4,
3 Esquerdo, 1200-161 - Lisboa - Portugal
E: patricia@globalcitizensolutions.com
T: +351 936 122 186
W: https://www.globalcitizensolutions.com
68 - Investment Migration Yearbook 2O23

IM YEARBOOK
Fellow Member Certified IMCET Professional
Fellow Member
Fellow Member /
Certified IMCET Professional
H. Ronald Klasko
FIMC
Managing Partner
Andres Solimano
IMCM
Chairperson
Bruno L’ecuyer
FIMC
Chief Executive
& Co-Founder
Dario Aquilina
IMCM
Digital Channels Officer
David Chen
FIMC
Executive Director &
Managing Partner
KLASKO IMMIGRATION LAW PARTNERS, LLP
H. Ronald Klasko is a leading U.S. lawyer representing treaty investors
(E-2) and green card investors (EB-5). Ron was the lead attorney on Matters
of Walsh and Pollard, the key precedent for E-2 visas and co-counsel
on a 2022 lawsuit reopening the EB-5 regional center program. His firm
is the North America Regional Representative office of the Investment
Migration Council, of which Ron also serves on the Governing Board.
Ron regularly speaks on investment migration globally and is known for
pioneering innovative immigration solutions. Under Ron’s leadership,
Klasko Immigration Law Partners is regularly recognized by Chambers
Global and U.S. News and World Report. Ron was President and General
Counsel of AILA and served five terms as Chair of the EB-5 Committee.
INVESTMENT MIGRATION COUNCIL
The Investment Migration Council (IMC) is the worldwide forum for
investment migration, bringing together the leading stakeholders in
the field. The IMC sets global standards, provides qualifications and
publishes indemand research in the field of investment migration aimed
at governments, policy-makers, international organisations, and the
public. It is an impact focused Swiss-based membership organisation in
special consultative status with the Economic and Social Council of the
United Nations since 2019 and registered with the European Commission
Joint Transparency Register Secretariat (ID: 337639131420-09).
INVESTMENT MIGRATION COUNCIL
The Investment Migration Council (IMC) is the worldwide forum for
investment migration, bringing together the leading stakeholders in
the field. The IMC sets global standards, provides qualifications and
publishes indemand research in the field of investment migration aimed
at governments, policy-makers, international organisations, and the
public. It is an impact focused Swiss-based membership organisation in
special consultative status with the Economic and Social Council of the
United Nations since 2019 and registered with the European Commission
Joint Transparency Register Secretariat (ID: 337639131420-09).
INVESTMENT MIGRATION COUNCIL
The Investment Migration Council (IMC) is the worldwide forum for
investment migration, bringing together the leading stakeholders in
the field. The IMC sets global standards, provides qualifications and
publishes indemand research in the field of investment migration aimed
at governments, policy-makers, international organisations, and the
public. It is an impact focused Swiss-based membership organisation in
special consultative status with the Economic and Social Council of the
United Nations since 2019 and registered with the European Commission
Joint Transparency Register Secretariat (ID: 337639131420-09).
VISAS CONSULTING GROUP (VCG)
As one of the most prestigious immigration firms in China, VCG 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. Visas Consulting Group
perfectly understands the balance between the needs of the clients
and the laws of immigration. To fulfill people’s pursuit for a better life
is always at the heart of VCG’s philosophy: Visas to your future.
1601 Market Street, Suite 2600
Philadelphia, PA 19103
T: 215.825.8600
E: rklasko@klaskolaw.com
W: www.KlaskoLaw.com
Contact: H. Ronald Klasko – Managing Partner
16 Rue Maunoir 1211 Geneva – Switzerland
T: (+41) 22 533 1333
E: info@investmentmigration.org
W: investmentmigration.org
Contact: Bruno L’ecuyer - Chief Executive
16 Rue Maunoir 1211 Geneva – Switzerland
T: (+41) 22 533 1333
E: info@investmentmigration.org
W: investmentmigration.org
Contact: Bruno L’ecuyer - Chief Executive
16 Rue Maunoir 1211 Geneva – Switzerland
T: (+41) 22 533 1333
E: dario.aquilina@investmentmigration.org
W: investmentmigration.org
Contact: Dario Aquilina – Digital Channels Officer
29/F Huaihai Plaza, 1045 Huaihai Road,
Central Shanghai, 200031 – China
T: (+86) 21 6415 8666
E: dchen@visas.to
W: www.visas.to
Contact: David Chen - Executive
Director & Managing Partner
Investment Migration Yearbook 2O23 - 69

IM YEARBOOK
Fellow Member Certified IMCET Professional
Certified IMCET Professional
Jacqueline Gauci
IMCM
Head of Membership
Services
Marie’ Lou Cutajar
IMCM
Head of Education
& Training
Nadine Goldfoot
FIMC
Managing Partner
INVESTMENT MIGRATION COUNCIL
The Investment Migration Council (IMC) is the worldwide forum for
investment migration, bringing together the leading stakeholders in
the field. The IMC sets global standards, provides qualifications and
publishes indemand research in the field of investment migration aimed
at governments, policy-makers, international organisations, and the
public. It is an impact focused Swiss-based membership organisation in
special consultative status with the Economic and Social Council of the
United Nations since 2019 and registered with the European Commission
Joint Transparency Register Secretariat (ID: 337639131420-09).
INVESTMENT MIGRATION COUNCIL
Marie’ Lou is the Head of Education and Training at the Investment
Migration Council, where she acts as the point of contact for all training
related enquiries. She is responsible for the day to day co-ordination
and administration of the training programme, making sure that
all those who enroll for the course get all the assistance that they
require and experience a positive learning journey. Marie’ Lou is also
leading several projects within the IMCET, focusing on the growth of
the education and training portfolio – with the intention to enhance
professionalism and setting standards of best practice in the IM industry.
FRAGOMEN
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.
16 Rue Maunoir 1211 Geneva – Switzerland
T: (+41) 22 533 1333
E: membership@investmentmigration.org
W: investmentmigration.org
Contact: Jacqueline Gauci –
Head of Membership Services
16 Rue Maunoir 1211 Geneva – Switzerland
T: (+41) 22 533 1333
E: imcet@investmentmigration.org
W: investmentmigration.org
Contact: Marie’ Lou Cutajar –
Head of Education & Training
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 – Managing Partner
Fellow Member
Dr. Christian H. Kaelin
FIMC
Chairman
Geoffrey DuBoulay
IMCM
Managing Director
HENLEY & PARTNERS
With over 25 years of institutional experience and more than 35 offices
worldwide, Henley & Partners is by far the largest globally integrated
pure play residence and citizenship advisory firm in the world. Through
the provision of bespoke residence and citizenship by investment
solutions, we have helped thousands of individuals and families, their
advisors, and many sovereign states to generate value. Our outstanding
people and systems provide a world-class advisory service underpinned
by strict confidentiality, data security, and limited transaction risk.
POLARIS CITIZENSHIP & INVESTMENT
CONSULTANCY SERVICES LIMITED
Polaris is a licensed Authorised Agent for Citizenship by Investment in
Saint Lucia. Built on the infrastructure, ethics and values of its sister firm,
Floissac, DuBoulay & Thomas, a full service commercial and corporate law
firm founded in 1960, Polaris takes a bespoke, hands-on and personalized
approach to CBI which is client focused, solution oriented and regulatory
compliant. Our advisors are all trained and qualified attorneys with over
fifty years’ experience in the legal, investment and advisory sectors. All our
processing officers have obtained certifications in investment migration
and are IMC certified practitioners. Our competence, expertise and
ethos have led to an over 98% success rate on submitted applications.
20 Grosvenor Place
London, SW1X7HN
United Kingdom
T: (+44) 207 823 1010
E: uk@henleyglobal.com
W: henleyglobal.com
Contact: Dr Christian H. Kaelin - Chairman
POLARIS
INVEST IN PARADISE. MAKE IT HOME
Quadrant Row, 9-11 Brazil Street
P.O Box 722, Castries – St. Lucia
T: (+1) 758 714 7373/ (+1) 758 452 2887
E: info@polariscitizenship.com
W: www.polariscitizenship.com
Contact: Geoffrey DuBoulay – Managing Director
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Sachit Kumar
IMCM
Managing Director
GLOBE DETECTIVE AGENCY (P) LIMITED
Established in 1961, GDA is the pioneer and leader in private Investigations
in India with Global expertise. Headquartered in New Delhi with a network
of 20 branches, GDA specializes in Enhanced Due Diligence worldwide for
the investment migration industry in 40 countries. This includes a “deep
dive” into a subject’s background to verify information, acquire relevant
inputs and fill gaps through field resources. It also includes authentication
of documents and global security checks related to sanctions, enforcements,
1,200 watchlists originating from more than 80 countries and identification
of politically exposed persons. 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) 9311042007
E: sachitkumar@globedetective.com
W: www.globedetective.com
Contact: Mr. Sachit Kumar – Managing Director
Certified IMCET Professional Certified IMCET Professional
Dr. Maria Grech
Senior Associate
Fabienne de Blois
IMCM
Associate Director
Estelle Nogues
IMCM
Head Stakeholder
Concierge
MUSCAT AZZOPARDI & ASSOCIATES (MA&A)
Set up in 1971, Muscat Azzopardi & Associates (MA&A) are a team
of multilingual advocates with an international outlook, advising
private and corporate clients. MA&A has built up invaluable
experience in advising on legal and practical issues that arise when
considering a second citizenship or an alternative residence.
Our global portfolio of high net worth and ultra-high net worth
individuals are highly appreciative of our guidance. Our lawyers
share a special work ethic and personally guide clients - not just
by assisting our clients through every step of the process, from the
first contact to the actual acquisition of a Maltese citizenship or of
residence in Malta, but we continue to serve our clients beyond.
S-RM
S-RM helps many of the world’s leading organisations understand, manage,
and mitigate reputational and regulatory risk. For over seven years, our
dedicated 45+ practitioner team has been helping citizenship and residency
by investment agencies make nuanced decisions. We work across all sectors
and jurisdictions that form the focal points for the citizenship and residency
by investment industry, including in fragile and informal economies, and in
jurisdictions where information is hard to access and understand. Supported
by a further 180+ practitioners across S-RM’s seven global offices, our teams
are experts in civil and commercial registration processes and in navigating
complex media landscapes. We pride ourselves in our ability to discreetly
gather commentary through enquiries in the circles that Applicants operate in,
helping you understand the warning signs of corruption, illicit financial flows
and identity fraud, as well as the factors that may mitigate these concerns.
INVESTMENT MIGRATION COUNCIL
The Investment Migration Council (IMC) is the worldwide forum for
investment migration, bringing together the leading stakeholders in
the field. The IMC sets global standards, provides qualifications and
publishes indemand research in the field of investment migration aimed
at governments, policy-makers, international organisations, and the
public. It is an impact focused Swiss-based membership organisation in
special consultative status with the Economic and Social Council of the
United Nations since 2019 and registered with the European Commission
Joint Transparency Register Secretariat (ID: 337639131420-09).
40, Villa Fairholme, Sir Augustus Bartolo Street,
Ta’ Xbiex XBX 1095, Malta
Tel: (+356) 2133 6196
Mob: (+356) 9993 0258
4th Floor Beaufort House,
15 St Botolph Street,
London, Greater London, EC3A
7DT, United Kingdom
T: +44 (0)7393 010932
E: F.deBlois@s-rminform.com
W: www.s-rminform.com
16 Rue Maunoir 1211 Geneva – Switzerland
T: (+41) 22 533 1333
E: estelle.nogues@investmentmigration.org
W: investmentmigration.org
Contact: Estelle Nogues –
Head Stakeholder Concierge
Mtonya A. G.
Deterville
Attorney-at-law /
Notary Royal
GLOBAL MIGRATION AND INVESTMENT SERVICES
Global Migration and Investment Services (“GMIS”), is an Authorized Agent
of Citizenship by Investment Saint Lucia. We support our clients as they
navigate the Citizenship by Investment process. We assist in completing
applications while providing timely, efficient and professional services in
accordance with the CIP Legislation. Our team is led by a dynamic duo of
lawyers, (sisters) who are IMC certified. They possess extensive diplomatic
and immigration experience as they have lived in several countries
throughout the world. Our goal is to ensure our clients’ success within the
shortest possible timeframe. We are supported by and affiliated with the
law firm of Deterville & Associates which is built on a legacy of providing
exceptional legal services. A perfect cocktail to a seamless experience.
Attorney-at-law | Notary Royal
99 Chaussee Road | P.O. Box 835 |General Post
Office | Castries | LC04 101 | Saint Lucia
W: www.detervilleassociates.com
E: lawyer@detervilleassociates.com
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In a bid to reduce our carbon
footprint, we will no longer
be printing mountains of
material, therefore the
following pages includes
information about IMC
initiatives in the coming year.
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A Guide to the Investment Migration Council
investmentmigration.org
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Who’s Who
GOVERNING BOARD
Andrés Solimano
(Chairperson)
Bruno L’ecuyer
Nadine Goldfoot
David Chen Ronald H. Klasko Christian H. Kalin
Geneva, Switzerland
Head Quarters
Investment Migration Council
16 rue Maunoir
1211 Geneva, Switzerland
Office: +41 22 533 1333
Email: info@investmentmigration.org
IMC London Office
Contact: Nadine Goldfoot
1st Floor, 95 Gresham Street
London EC2V 7NA,
United Kingdom
Office: +44 (0) 20 7090 9156
Email: london@investmentmigration.org
IMC New York Office
Contact: H.Ronald Klasko
54 W. 40th Street, Suite 516
New York, NY 10018
Office: +646 787 1371
Email: newyork@investmentmigration.org
IMC Hong Kong Office
Contact: Denis NG
Unit E, 29/F, Tower 1, Admiralty Centre,
No,18 Harcourt Road, Admiralty, Hong Kong
Office: +852 3101 4100
Email: hongkong@investmentmigration.org
IMC Caribbean Office
Contact: Christopher Willis
95 Solaris Avenue, 2nd Floor,
Camana Bay, PO Box 30745,
Grand Cayman,
Cayman Islands, KY1-1203
Office: +1 (345) 325 3030
Email: caribbean@investmentmigration.org
IMC Dubai Office
Contact: David Regueiro Santalla
Office No. 2804, U-Bora Tower,
Business Bay, Dubai
Office: +971 (0) 4 520 6775
Email: dubai@investmentmigration.org
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ADVISORY COMMITTEE
Bruno L’ecuyer IMCM
(Committee Chairman)
Prof. Dr. Andrés Solimano
IMCM
Prof. R. James Breiding
Paul Williams
ACA IMCM
Peter Vincent Anastassis Yiasemides Edward Beshara
IMCM
Inigo Lecanda Crooke
FIMC
Alexander Varnavas
IMCM
Michael Frendo
IMCM
Jennifer Lai
IMCM
Tiago Gali Macedo
IMCM
Philippe Foret
Eric G. Major
IMCM
Kieron Sharp
IMCM
Prof. Dr. Khalid Koser
Prof. Dr. Christian Joppke Austin T. Fragomen Boriss Cilevics Ghada al Atrash
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About Us
We are the worldwide
association for
Investment Migration,
bringing together the
leading stakeholders
in the field and giving
the industry a voice.
Our Mission
Our mission is simple
and straightforward:
it is about setting the
global standards for
others to follow and
promoting competence
and ethical behaviour.
Additionally, we improve
public understanding
and transparency of the
industry through various
initiatives, including
academic research.
We are the leading
platform for
governments, academia
and professionals.
Structure of the IMC
- Legal form: non-profit Swiss-based
Association (Art 60 seq Swiss Civil Code)
- A solidly funded association, through
membership & donors
- Professional, full-time secretariat headed by a CEO
- The leading industry firms are already members
- World’s most-respected experts on the
governing board and advisory comittee
The leading industry firms
are already IMC members
- Refinitiv
- Henley & Partners
- RIF Trust
- Visas Consulting Group
- Fragomen Worldwide
- Exiger DD
- Latitude
- Polaris Citizenship & Investment
…and many more
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Three Essential
Reasons to Join
1. Achieve greater industry-wide
visibility to grow your business
2. Build and contribute to a worldclass
network of contacts
3. Learn about all the latest
developments taking place
Membership
Criteria
To become a member, one must
have proven expertise within the
sector, a good reputation, and a clean
professional and personal record.
The IMC has very strict membership
admission criteria to ensure
its members are of the highest
professional standards.
The IMC offers different levels of
annual memberships for individual
practitioners, academics, firms,
associates, governments and
affiliates. Membership packages
include the below, each offering
various levels of benefits.
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Two Routes to Membership
Two Routes to Membership
1. Membership by Education
1. Membership by Education
The journey to membership via the education route is the
recommended one since this strenghtens the skills and knowledge
of members and by consequence the wider industry.
The journey to membership via the education route is the recommended one since this
strenghtens the skills and knowledge of members and by consequence the wider industry.
2. Membership by Experience
To 2. follow Membership suit with by Experience other professionals bodies, membership by
experience is offered to those practitioners who meet the necessary
criteria in any membership tier to be members of the IMC.
To follow suit with other professionals bodies, membership by experience is offered
to those practitioners who meet the necessary criteria in any membership tier to be
members of the IMC.
Application can filled online on www.investmentmigration.org/membership
Application can filled online on www.investmentmigration.org/membership
Membership Levels
Membership Levels
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Corporate Membership Benefits Benefits
Corporate Membership Benefits
Individual Membership Benefits
Individual Membership Benefits Benefits
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Application Process Timeline
Application Process Timeline
Investigative Due Diligence
Investigative Due Diligence
Our Due Diligence checks on prospective members are carried out by a roster of Due
Diligence firms. They apply a leading edge methodology to generate information from a
broad range of sources, including on-the-ground, in-country investigative intelligence.
Our Due Diligence checks on prospective members are carried
out by a roster of Due Diligence firms. They apply a leading edge
methodology to generate information from a broad range of sources,
including on-the-ground, in-country investigative intelligence.
Types of risks identified:
- Criminal activity
- Misrepresentations or factual omissions
Types - Unreported of risks identified:
financial issues
- Criminal - Civil litigation activity
- Misrepresentations - Character issues or factual omissions
- Unreported - PEP checkfinancial issues
- Civil litigation
- Character issues
- PEP check
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FAQ’s
Why does the industry need the IMC?
Until the IMC was established, there was no body to act as a bridge
between governments, academia, and practitioners. The IMC brings
all stakeholders together in an independent manner, and the interests
of all stakeholders are considered for the benefit of the industry.
How many members are participating?
Today, there are nearly 500 members from over
55+ different countries and territories.
Can anyone join?
To become an active member, you must be a practitioner with proven
expertise and experience in investor immigration, have a good reputation
and a clean professional and personal record. Each application is assessed
on its individual merit and considered by the governing board.
Contact Us
Secretariat:
London:
New York:
Grand Cayman:
Hong Kong:
Dubai:
info@investmentmigration.org
london@investmentmigration.org
newyork@investmentmigration.org
caribbean@investmentmigration.org
hongkong@investmentmigration.org
dubai@investmentmigration.org
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IMC Qualifications and Training
IMC Qualifications and Training
IMC Qualifications and Training
82 - Investment Migration Yearbook 2O23
investmentmigration.org/education
Contact: imcet@investmentmigration.org
investmentmigration.org/education
Contact: imcet@investmentmigration.org
Contact: imcet@investmentmigration.org

IM YEARBOOK
Certification in Investment Migration ‐ Cert (IM)
Overview and Objectives
The Certification in Investment Migration is an intermediate
level course designed to be studied over about 6 months.
This practical introduction leads to a professional status
with the IMC and is benchmarked at Associate level for those
working in the IM industry. This is the first global Investment
Migration course of its type - specially designed for those
working in the industry. The course is taught online through
our custom Learning Management System and includes
5 compulsory modules.
Target Audience
All staff working in, allied to, or intending to work
in the industry
Advisors
Agents
Lawyers/paralegals
CIP programme staff
Regulators and government staff
Compliance professionals
Financial services practitioners
Investment advisors
Assessment
The programme is assessed via:
Two hour, online, multiple choice test
100 multiple choice questions to be answered
70% Pass mark
Certification and Designation
Individuals who successfully complete the programme will
be awarded the 'IMC Certification in Investment Migration'.
The certificate carries with it the designation Cert (IM)
and leads to membership of the IMC.
Example designation - Carmen Swift Cert (IM); IMCM (Associate)
Professional Status
On successful completion of the Certification,
Non-IMC Members will become eligible to apply for membership
of the IMC at Associate level.
Course Format
Delivered online via an easy to use,
comprehensive Learning Management System (LMS)
Accessible by a range of mobile and laptop technologies
Needs to be completed within 6 months, however actual
study time is around 25 hours
Comprehensive support materials including:
— comprehensive module manuals
— interactive e-learning modules
— case studies and examples
— specimen test questions
Entrance Requirements
Applicants should possess:
Good educational background
Ability to complete the readings and comprehend core
principles in the English language
How to Apply
To apply for the Certification in Investment Migration course,
please go to investmentmigration.org/education to enrol online.
Rationale for Taking the Certification
The IMC Certification is a groundbreaking initiative
designed to prepare participants for work in a new
and vibrant industry where high professional
standards, values and enhanced competencies
are required. This certification will:
Provide verifiable evidence of competency
(knowledge, skills and behaviours)
Provide a practical focus and benchmarking of
your work in the industry
Help you to reduce risk in your firm and enhance
the firm’s reputation
Enhance your career prospects
Keep you abreast of developments in the industry
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Programme Structure / Course Format
Module 1
Module 2
Citizenship and Residence by Investment
Industry Overview
Understanding Citizenship and Residence
Ways of Acquiring the Status of Citizenship
The Concept of Residence
Development and Characteristics
of Investment Migration
Citizenship and Residence by Investment:
Assessing the Arguments
Ethics, Conduct and Professional Standards in
Investment Migration
Ethics
Codes of Conduct
Corporate Culture and Values
Integrity
Competence
Transparency
Marketing of Citizenship & Residence by
Investment Programmes
Practical Application of the IMC Code
Whistleblowing
Module 3
Module 4
Anti-Money Laundering (AML)
and Financial Crime Prevention (FCP)
Nature of AML, Terrorist Financing (TF) and
Sanctions
Terrorist Financing
Sanctions
Key International AML and Sanctions Bodies
Suspicious Activity Reporting
Concept of Risk Management
Bribery and Corruption
Cybercrime
Investor Migration — Know Your Customer (KYC)
and Customer Due Diligence (CDD)
Generic KYC and CDD
Customer Due Diligence
Types of Due Diligence
Politically Exposed Persons
Customer Risk Rating
CDD Gone Wrong – Regulatory Action
Citizenship by Investment and Residence by
Investment – the need for CDD
Minimum Standards for Agents
Module 5
Personal Data: Management and Protection
What is Personal Data?
Principles of Data Protection
Risks Associated with Inappropriate Management of
Personal Data
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New Modules Added to IMCET Portfolio
Module 6
Module 7
Demand for Residence and Citizenship by Investment
The expansion of dual citizenship provisions
and their implications
Key demographics of demand for CBI and RBI
programmes
People’s motives in participating in CBI and RBI
programmes
The differences in demand from different
countries of origin
Examine the impact of Covid-19 on demand
General factors that determine patterns of
demand
Factors that lead to increased and decreased
demand
Common Reporting Standard and Mandatory Disclosure
Rules
The reporting framework established by the
OECD Common Reporting Standard
The different financial institutions involved in
the domestic CRS reporting process
CRS due diligence processes and procedures
and its application to entity and individual
account holders
Contents of a CRS report and various financial
account information reporting requirements
Understand the contents of MDR disclosure
Identify circumstances when a client will be
required to file an MDR disclosure
IMCET's training portfolio now consists of 7 specialised modules. Students can choose to create their own learning journey
through a combination of 3 compulsory and 4 elective modules to convert successful completion into the renowned
‘Certification in Investment Migration’ and hold the designation Cert (IM) and considered a certified IM practitioner.
Students can now also choose to study modules individually at their own leisure in the bitesize option – no need to make an
outright commitment to the entire course, but still with the option to graduate as a certified IM practitioner.
Speak to us today for more information.
3 Compulsory Modules
+
2 Elective Modules
Ethics, Conduct and Professional Standards in
IM
Anti-Money Laundering and Financial Crime
Prevention
Investor Migration – Know Your Customer and
Customer Due Diligence
Citizenship and Residence by Investment
Personal Data: Management and Protection
Demand for Residence and Citizenship by
Investment
Common Reporting Standard &
Mandatory Disclosure Rules
=
Awarded the IMC Certification in Investment Migration, Cert (IM)
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IMC Education & Training (IMCET)
IMCET is the investment migration industry's only provider
Education & Training (IMCET)
of certificated professional education and training
programmes for advisors, agents, lawyers, programme staff
and others working in or associated with the industry.
IMCET IMCET is is the a newly investment constituted migration division industry's of the only IMC provider whose
of courses certificated and qualifications professional education are designed and to training enhance the
programmes for advisors, agents, lawyers, programme staff
and others working in or associated with the industry.
IMCET is a newly constituted division of the IMC whose
courses and qualifications are designed to enhance the
technical knowledge, competencies and expertise of those
working in or associated with the industry.
The IMCET courses are delivered through a flexible range of
learning methods to enable individuals to study in a way that
technical suits them knowledge, at a time competencies and in a format and that expertise works for of those
working their lifestyle. in or associated with the industry.
The IMCET courses are delivered through a flexible range of
learning methods to enable individuals to study in a way that
suits them at a time and in a format that works for
their lifestyle.
All education enquiries to imcet@investmentmigration.org
All education enquiries to imcet@investmentmigration.org
investmentmigration.org/education
investmentmigration.org/education
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2023
15 th - 18 th May 2023
investmentmigration.org/forum/
Investment Migration Yearbook 2O23 - 87

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About the Forum
The Investment Migration Forum is the largest and most important residence &
citizenship by investment event in the world. Renowned academics, government
officials, representatives of international organisations, as well as the world’s
leading professionals dealing with investment migration will be gathering in
London for the 8 th edition of the Forum.
The three day event will cover a variety of related subjects which are of interest
to the academic, professional and government community. Expect 300+
participants from over 40+ countries.
A limited number of partnership opportunities are available for highly respected
firms to participate in the success of the Forum and to improve their visibility.
About Us
The Investment Migration Council (IMC) is the worldwide forum for investment
migration, bringing together the leading stakeholders in the field. The IMC sets
global standards, provides qualifications, and publishes in-demand research in the
field of investment migration aimed at governments, policy makers, international
organisations, and the public. It is an impact focused Swiss based (non-profit)
membership organisation in special consultative status with the Economic and
Social Council of the United Nations since 2019 and registered with the European
Commission Joint Transparency Register Secretariat
(ID: 337639131420-09).
Who will Attend
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Why should you be part of our Forum?
Why should you be part of our Forum?
Investment Migration Yearbook 2O23 - 89

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A Who’s Who from Government,
Academia and Business
Prof Dimitry Kochenov
CEU
Prof
Democracy
Dimitry
Institute
Kochenov
Budapest & CEU Legal Studies
CEU Democracy Institute
Department, Vienna
Budapest & CEU Legal Studies
Department, Vienna
Laura Austin IMCM
Managing
Laura
Director,
Austin IMCM
Mintz Group, New York
Managing Director,
Mintz Group, New York
Eric Major IMCM
CEO, Eric Major IMCM
Latitude, London
CEO,
Latitude, London
Joe Lynam
Former Disinformation
Specialist, Joe Lynam Brussels
Former Disinformation
Specialist, Brussels
Kieron Sharp IMCM
CEO,
FACT Due Kieron Diligence, Sharp London IMCM
CEO,
FACT Due Diligence, London
Marina Brizar
UK Director,
Talent Beyond Marina Boundaries, Brizar
London
UK Director,
Talent Beyond Boundaries,
London
Peter Vincent
International Security
Consultant, Virginia
Peter Vincent
International Security
Consultant, Virginia
David Regueiro IMCM
COO,
RIF Trust, Dubai
David Regueiro IMCM
COO,
RIF Trust, Dubai
Chairman,
Henley & Partners, Zurich
Chairman,
Henley & Partners, Zurich
Nadine Goldfoot IMCM
Managing Partner,
Fragomen, London
Nadine Goldfoot IMCM
Managing Partner,
Fragomen, London
Karen Kelly IMCM
Director - Strategy &
Development,
Exiger, New York
Karen Kelly IMCM
Director - Strategy &
Development,
Exiger, New York
Chairman,
Fragomen, New York
Chairman,
Fragomen, New York
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Expected Attendance
Based on the success of the past Forum and high demand of the industry, we expect
to have well Based over on the 300+ success delegates of the attending past Forum the and next high Forum demand in 2023. of the industry, we expect
to have well over 300+ delegates attending the next Forum in 2023.
Investment Migration Yearbook 2O23 - 91
8

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Previous Forum Partners
FACT
D U E D I L I G E N C E
POLARIS
INVEST IN PARADISE. MAKE IT HOME
FACT
D U E D I L I G E N C E
POLARIS
INVEST IN PARADISE. MAKE IT HOME
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PR PR PANAMA
EXPORT EXPORT AND AND INVESTMENT INVESTMENT PROMOTION PROMOTION AUTHORITY
Investment Migration Yearbook 2O23 - 93
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Testimonials from Past Forums
An excellent Investment Migration Forum
after a 2 year absence due to the global
pandemic.”
Peter Vincent
International Security Consultant, USA
The Investment Migration Forum offers an unrivaled platform
for industry discussion and participation. I have been involved
with the Forum from the beginning, and I consider it an honor
to be closely aligned with the Investment Migration Council.”
Laura Austin
Managing Director, Mintz Group, USA
The team did a great job and hope to be a partner at next
year’s Investment Migration Forum. Congratulations!”
Steven Pepa
Managing Director, Saratoga Capital, Cyprus
Undoubtedly the most important annual meeting for
RCBI professionals, service providers and
governments. Connecting with like-minded delegates
offers us all an opportunity to drive our visions
forward to ensure the sustainability of the industry.”
Charles Mizzi
CEO, Residency Malta Agency, Malta
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We were delighted to be able to attend the 2019 Investment Migration Forum
as a Silver Partner. This was a great event, which gave us the opportunity
to connect with potential partners that have access to the High-Net-Worth
Customer base that want our products, and that need International Medical
Insurance as a part of the requirements for residency and/or citizenship
by investment. It was also of great benefit for us to learn more about the
current global investment migration trends.”
Charles W. Nyren
Head of Business Development, Cigna, UK
The Forum provides an excellent platform for
investment migration professionals from around the
world to meet, exchange ideas and learn about the
industry’s latest trends. As both a sponsor of this
year’s event as welll as the President of the
not-for-profit trade association for EB-5 Regional
Center professionals (IIUSA), I fully encourage all EB-5
professionals to participate in next year’s event.”
Bob Kraft
President, IIUSA; CEO, FirstPathway Partners, USA
A truly excellent event - it goes from strength to strength
each year! Thank you to you and the team for all your
exceptional work.”
Nadine Goldfoot IMCM
Managing Partner, Fragomen, London
This is where you want to be. Meet the core
of global migration industry.”
Richard Kurland
Immigration Lawyer & Policy Analyst, Kurland Tobe, Canada
Investment Migration Yearbook 2O23 - 95

IM YEARBOOK
Become our exclusive Gala Dinner Partner
EUR 60,000
Become our exclusive Gala Dinner Partner
EUR 60,000
Be recognised as the most important partner for our first London Investment Migration
Forum.
Be recognised as the most important partner for our first London Investment Migration
We are organising a once in a lifetime opportunity to jointly host a spectacular evening in
Forum.
one of the worlds most recognisable historic buildings featured in many movies such as
Harry Potter, Mission Impossible, Paddington, Sherlock Holmes, Lawrence of Arabia and
We are organising a once in a lifetime opportunity to jointly host a spectacular evening in
many more.
one of the worlds most recognisable historic buildings featured in many movies such as
Harry Potter, Mission Impossible, Paddington, Sherlock Holmes, Lawrence of Arabia and
For one night only the cathedral will close its doors to the public and host our closing event
many more.
starting with a welcome choral concert under the dome, a welcome cocktail reception in
Admiral Nelsons Chamber, followed by a gastronomic dinner in the Crypt with musical
For one night only the cathedral will close its doors to the public and host our closing event
entertainment. The event will include presentation of the IMC recognition awards with the
starting with a welcome choral concert under the dome, a welcome cocktail reception in
opportunity to make a welcome speech.
Admiral Nelsons Chamber, followed by a gastronomic dinner in the Crypt with musical
entertainment. The event will include presentation of the IMC recognition awards with the
opportunity to make a welcome speech.
*Sponsorship can be shared between up to 3 companies.
Corporate / Corporate PLUS Members with the IMC are eligible for a 5% / 10% discount on the above mentioned packages.
Kindly contact events@investmentmigration.org for further information.
Prices exclude UK VAT charged at 20%.
*Sponsorship can be shared between up to 3 companies.
Corporate
96 13- Investment
/ Corporate
Migration
PLUS
Yearbook
Members
2O23
with the IMC are eligible for a 5% / 10% discount on the above mentioned packages.
Kindly contact events@investmentmigration.org for further information.
Prices exclude UK VAT charged at 20%.

IM YEARBOOK
We have worked hard with our partners to bring you an exhaustive list of terrific benefits
as follows:
5 Delegate passes including access to all social functions
1 table of 10 delegates reserved at the Gala Dinner
Company profile on forum webpage and forum delegate book
Exhibitor display table at the forum
Company logo to appear on forum holding slide in plenary room
Keynote presentation during one of the plenary sessions
Welcome signage at Gala Dinner venue
Company logo in forum delegate book
Full page advertisement to be included in forum delegate book
Company logo to appear on general forum signage
Social media coverage
Company hyperlinked logo on forum webpage
Company name on the cover of forum delegate book
Web advertisement on IMC website for a period of 6 months
Rotating advert (x2) to be shown during breaks on the
main screen
Private Meeting room to be reserved for 4hrs during the Forum
Panel discussion participation with your company logo
to be displayed on a screen
To receive list of delegates 1 week prior of the forum
(Includes: Name, Company & Country)
Company logo & hyperlink to appear on all forum mailshots,
both pre & post forum
Working Lunch “case study” presentation
(optional attendance by delegates)
14
Investment Migration Yearbook 2O23 - 97

IM YEARBOOK
Forum Partnership Opportunities
Delegate passes including access to all social functions
Delegate Company passes logo in including forum delegate access book to all social functions
Company logo profile in on forum forum delegate webpage book and forum delegate book
Company Full page advertisement profile on forum to webpage be included and in forum delegate book
EUR 20,000 EUR 17,000 EUR 13,000 EUR 9,000 EUR 5,000
EUR 20,000 4 EUR 17,000 3 EUR 13,000 2 EUR 9,000 1 EUR 5,000 1
4 3 2 1 1
100 words 80 words 60 words 50 words 40 words
100 words 80 words 60 words 50 words 40 words
Full Exhibitor page display advertisement table to be included in forum delegate book
Exhibitor Company display logo to table appear on general forum signage
Company logo to appear on general forum holding forum slide signage in plenary room
Company Panel discussion logo to participation appear forum with holding your company slide in logo plenary room
to be displayed on a screen
Panel discussion participation with your company logo
to Company be displayed logo & on hyperlink a screento appear on all forum mailshots,
both pre & post forum
Company logo & hyperlink to appear on all forum mailshots,
both Social pre media & post coverage forum
Social Keynote media presentation coverageduring one of the plenary sessions
Keynote Company presentation hyperlinked during logo on one forum of the webpage plenary sessions
Company hyperlinked name on the logo cover on of forum webpage delegate book
Company To receive name list of on delegates the cover 1 of week forum prior delegate of the forum book
(Includes: Name, Company & Country)
To receive list of delegates 1 week prior of the forum
(Includes: Web advertisement Name, Company on IMC & website Country) for a period of 6 months
Web Rotating advertisement (x2) on to IMC be shown website during for a breaks period on of the 6 months main screen
Rotating Private Meeting advert (x2) room to to be be shown reserved during for breaks 4hrs during on the the main Forum screen
Private Working Meeting Lunch “case room study” to be reserved presentation for 4hrs during the Forum
(optional attendance by delegates)- Reserved only for first 2 partners
Working Lunch “case study” presentation
(optional Full page advertisement attendance by on delegates)- outside back Reserved cover, inside only front for first cover 2 or partners other
prominent position of forum delegate book (first come first served basis)
Full page advertisement on outside back cover, inside front cover or other
Mention prominent of position company of forum by Forum delegate Chair book in opening (first come speech first served basis)
Choice Mention of of stand company location by Forum in exhibition Chair hall in opening (first come speech first served basis)
Choice One mailshot of stand to location all delegates in exhibition one week hall before (first come the event first served basis)
One Reserved mailshot delegate to all table delegates near one stageweek before the event
Reserved delegate table near stage
Partner delegate passes, included in partnership agreement, are not tranferable. The pass can only be used by a representative of the partnering
company in their capacity as a delegate
Partner Speakers delegate (panel/keynote) passes, included passes included partnership as part agreement, of package are not tranferable. The pass can only be used by a representative of the partnering
company in their capacity as a delegate
Speakers (panel/keynote) passes included as part of package
Corporate / Corporate PLUS Members with the IMC are eligible for a 5% / 10% discount on the above mentioned packages.
Kindly contact events@investmentmigration.org for further information.
Corporate Prices exclude / Corporate UK VAT charged PLUS Members at 20%. with the IMC are eligible for a 5% / 10% discount on the above mentioned packages.
Kindly contact events@investmentmigration.org for further information.
Prices 15 exclude UK VAT charged at 20%.
98 - Investment Migration Yearbook 2O23
15

IM YEARBOOK
Forum Partnership Opportunities
Welcome Cocktail Reception / Networking Cocktail Reception Package
A Welcome Cocktail Reception or Networking Cocktail will be held on the first or second day of the event to meet all the delegates.
Delegate pass including access to all social functions*
Company logo to appear inside Forum delegate book
Company profile on Forum webiste and Forum delegate book
Branded Tent Cards during reception
EUR 15,000
1
50 words
Web advertisement on IMC website for 4 months if package is booked by 31 March 2023
Exhibitor display table
Full page advertisement to be included in Forum delegate book
Company logo to appear on general Forum signage
Welcome Address at the Cocktail Reception**
Lunch Break
Gain more visibility during Lunch Break on 1 of the conference days. (1 per day)
Benefits
EUR 6,000
Company logo on Forum webpage
Company Logo in Forum delegate book
Company Logo on signage at two Forum lunch breaks
Delegate pass including access to all social functions* 1
Networking Break
Get additional light on your company during Networking Breaks on 1 of the conference days. (2 per day)
Benefits
Networking Break
Partner
EUR 5,000
Company logo on Forum webpage
Company Logo in Forum delegate book
Company Logo on signage at four Forum networking breaks
Delegate pass including access to all social functions* 1
* Partner delegate passes, included in partnership agreement, are not transferable. The pass can only be used by a representative
of the partnering company in their capacity as a delegate
** To be co-ordinated with the programme committee.
Corporate / Corporate PLUS Members with the IMC are eligible for a 5% / 10% discount on the above mentioned packages.
Kindly contact events@investmentmigration.org for further information.
Prices exclude UK VAT charged at 20%.
Investment Migration Yearbook 2O23 16 - 99

IM YEARBOOK
Forum Partnership Opportunities
Delegate Tote Bag Partner
EUR 2,000
USB Charging Cables Partner
EUR 2,000
Branded tote bag to be co branded with the IMC
40 word company profile on website & delegate book
Logo to appear on all campaigns related to the event
Branded USB Charging Cables to be co branded with
the IMC
40 word company profile on website & delegate book
Logo to appear on all campaigns related to the event
Branded Coaster Partner
EUR 2,000
Coasters that are distributed at coffee breaks to be
branded with company logo
40 word company profile on website & delegate book
Logo to appear on all campaigns related to the event
Branded A5 Notebook Partner
EUR 2,500
Branded desktop delegate notebook to be co branded with
the IMC
40 word company profile on website & delegate book
Logo to appear on all campaigns related to the event
Corporate / Corporate PLUS Members with the IMC are eligible for a 5% / 10% discount on the above mentioned packages.
Kindly contact events@investmentmigration.org for further information.
Prices exclude UK VAT charged at 20%.
100 17 - Investment Migration Yearbook 2O23

IM YEARBOOK
Forum Partnership Opportunities
Speaker Gift Partner
EUR 5,000
Speaker Gift to be co branded with the IMC
40 word company profile on website & delegate book
Logo to appear on all campaigns related to the event
Juice Bar Partner
EUR 5,000
Juice Bar to be co branded with the IMC
40 word company profile on website & delegate book
Logo to appear on all campaigns related to the event
‘Sweet Shop’ Partner
EUR 5,000
Powerbank Partner
EUR 6,000
Sweet shop to be co branded with the IMC
40 word company profile on website & delegate book
Logo to appear on all campaigns related to the event
Powerbanks to be branded with company logo
40 word company profile on website & delegate book
Logo to appear on all campaigns related to the event
Corporate / Corporate PLUS Members with the IMC are eligible for a 5% / 10% discount on the above mentioned packages.
Kindly contact events@investmentmigration.org for further information.
Prices exclude UK VAT charged at 20%.
Investment Migration Yearbook 2O23 - 10118

IM YEARBOOK
Visibility Opportunities for Your Business
The Investment Migration Council provides numerous opportunities to increase
your corporate visibility and to enhance your Business Growth
investmentmigration.org/partner-with-us/
102 - Investment Migration Yearbook 2O23

Introduction
IM YEARBOOK
The IMC provides a range of high-quality and specifically targeted
promotional channels; these include the IMC website (which benefits from a
sustainable subscriber growth), as well as Email Newsletter software which is
Introduction
targeted towards specialised niche segments of the market.
Introduction
The IMC Media Channels provide cost-effective, measurable and
results-oriented The IMC provides means a range of enhancing of high-quality your and business specifically development. targeted
promotional channels; these include the IMC website (which benefits from a
This sustainable document subscriber is designed growth), to provide as well a as deeper Email Newsletter knowledge software about the which IMC is
Visibilty targeted Opportunities.
towards specialised niche segments of the market.
Please The IMC contact Media us Channels on info@investmentmigration.org provide cost-effective, measurable for more details. and
results-oriented means of enhancing your business development.
This document is designed to provide a deeper knowledge about the IMC
Visibilty Opportunities.
Please contact us on info@investmentmigration.org for more details.
Reasons to partner with us
Reasons to partner with us
Precise Audience Targeting
When partnering with the IMC, you
know that your message will reach
Reasons a specialised to target partner audience which with us
suits your business interests.
High-Quality Precise Audience Content Targeting
Both When the partnering IMC website with and the e-Newsletters,
IMC, you
offer know high-quality that your content message that will attracts reach
industry a specialised professionals, target audience thus giving which your
advertising suits your more business opportunities interests. to be
seen by the right audience.
High-Quality Content
Both the IMC website and e-Newsletters,
offer high-quality content that attracts
industry professionals, thus giving your
advertising more opportunities to be
seen by the right audience.
Exclusivity of one advertiser
per opportunity
All IMC Visibility Opportunities are limited
to one partner per medium/package.
Extensive Exclusivity post-campaign
of one advertiser
reporting per opportunity
Each All partner IMC Visibility will be Opportunities provided with are limited
a detailed to one partner post-campaign per medium/package.
report which
will be compiled for you by the
IMC team.
Extensive post-campaign
reporting
Each partner will be provided with
a detailed post-campaign report which
will be compiled for you by the
IMC team.
Investment Migration Yearbook 2O23 - 103

IM YEARBOOK
Membership Facts
Membership Facts
IMC Members represent companies and are industry professionals with proven expertise
IMC and Members a good reputation represent within companies the field and around are industry the globe. professionals with proven expertise
and a good reputation within the field around the globe.
e. 7 %
e. 7 %
f. 2 %
f. 2 %
g. 1 %
g. 1 %
h. 1 %
h. 1 %
a Europe
a Europe
b Middle East
d. 11 %
b Middle East
d. 11 %
c Asia
c Asia
d USA & Canada
c. 11
% a. 53%
d USA & Canada
c. 11
% a. 53%
e Caribbean
e Caribbean
f Africa
f Africa
g South America
g South America
b. 14 %
b. 14 % h Oceana
h Oceana
Our Members - Your Audience
Our Members - Your Audience
Our Members Your Audience
(July 2022)
Our Members include the world’s leading industry professionals, service
providers, Our Members academics include and the world’s government leading officials industry who professionals, are dealing with service investor migration
providers, and representing academics the following and government sectors: officials who are dealing with investor migration
and representing the following sectors:
- Citizenship-by-investment Consultancy
-
Citizenship-by-investment Consultancy
Immigration Law
-
Immigration Law
Wealth Management
-
Wealth Management
Financial Advisory
-
Financial Advisory
Private Banking
-
Private Banking
Government and Academia
- Government and Academia
(July 2022)
104 - Investment Migration Yearbook 2O23

IM YEARBOOK
Website Facts
Website Facts
Key traffic channels:
d. 8 %
e. 1 %
c. 15 % a. 48 %
a Direct Traffic
b Organic Search
c Social Media
d Referral from partner sites
e Email Marketing
(July 2022)
Here are our top 5 visited pages on IMC’s official website:
1. Home Page: a lively hub of activity
2. Membership: dedicated information about membership
3. News: latest News, Articles and Reports, all industry focussed
4. About: a comprehensive breakdown of insider’s information
5. Contact Us: popular page about the IMC and its global locations
Investment Migration Yearbook 2O23 - 105

IM YEARBOOK
Visibility Opportunities
Visibility Opportunities
The IMC Website
Our website is an informational platform for industry stakeholders who are exploring
latest updates within the RCBI Industry. The website is regularly updated with the latest
industry-related news, articles, academic papers and the latest overview
of residency- and citizenship-by-investment programmes from around the world.
IMC website Key Performance Indicators:
7.800 sessions
Average visits per month
+85% new users annually
Constantly growing audience
Accessed from 150+ countries
Global Reach
2 pages per session
Average page views
65% desktop
35% mobile & tablets
Technology
Top 25 Geo-locations
4
18
17
7 11 25 8
21 22
13 12
9
10 15 23
24
2
5
1
3
14
6
20
19
16
(July 2022)
106 - Investment Migration Yearbook 2O23

IM YEARBOOK
1. Horizontal Banner on top visited pages
1. Horizontal Banner on top visited pages
This opportunity offers a hyper-linked horizontal banner at the base of the page of the
most This opportunity visited sections offers of a hyper-linked IMC website, horizontal such as banner the Homepage, at the base “About of the Us” page section and
“Membership”
of the most visited
page
sections
and limited
of IMC
to
website,
one banner
such as
per
the
page.
Homepage, “About Us”
section and “Membership” page and limited to one banner per page.
Your Brand Here!
Size: 728px x 90 px
In partnership with
Your Brand Here!
Size: 728px x 90 px
Size: 728px x 90 px
Page / location
6 months
Homepage €3,500
Membership €3,000
About Us €2,500
The Governing Board €2,500
The Advisory Committee €2,500
Investment Migration Yearbook 2O23 - 107

IM YEARBOOK
2. Standard Horizontal Banner on Knowledge pages
2. Standard Horizontal Banner on Knowledge pages
The IMC website is regularly updated with industry-related news and articles.
This The information IMC website is published is regularly under updated the “Knowledge” with industry-related section and news consists and of articles. news,
thought This information leadership, is reports published & papers under and the newsletter-related “Knowledge” section pages. and consists of news,
thought leadership, reports & papers and newsletter-related pages.
Your Brand Here!
Size: 728px x 96 px
Your Brand Here!
Size: 728px x 96 px
Your Brand Here!
Size: 728px x 96 px
Page / location
6 months
Contact Us €2,500
News €2,000
Thought Leadership €2,000
Reports & Papers €1,500
108 - Investment Migration Yearbook 2O23

IM YEARBOOK
e-Newsletter Overview
We issue regular email newsletters that are sent to senior and influential stakeholders
of the industry. Each of our email newsletters feature high-quality content. This medium
offers a deep insight into readers’ behaviours, covering aspects such as open rates and
links clicked, amongst other metrics.
There are three types of Newsletters that are issued by the IMC:
• News Round-up – issued once a month (12 per year)
• IMC Bulletin – issued every quarter (4 per year)
• Corporate Announcements - exclusive dedicated messaging to deliver a specific,
important message to a selected audience (more details on page 14)
Email marketing communications issued by the
IMC have a proven track record:
Average open rate of 45%
Low unsubscribe rate
Consistent increase in the
subscribing audience
Investment Migration Yearbook 2O23 - 109

IM YEARBOOK
3. News Round-Up
3. News Round-Up
The
The
“News
“News
Round-up”
Round-up”
is
is
a regular
a regular
e-Newsletter
e-Newsletter
issue
issue
that
that
provides
provides readers with a
readers selection with of a the selection latest news of the and latest developments news and developments within the within industry. the All articles are
industry. objective All and articles industry-related are objective only. and industry-related only.
Description
1 month
(2 mail-shots)
3 months
(6 mail-shots)
One banner located at the very top of the newsletter template
which is the prime spot visibility-wise
One industry-related press release
Press release to be published on the website
€1,000 €2,500
Banner Specifications:
Target Audience:
IMC Members
File type:
.jpg, .jpeg, 72 dpi
Frequency:
Banner Position:
Every month
Prime position at the top
Reports:
2 reports per mail-shot
(1 and 2 weeks after email is sent out)
Size:
600px x 200 px
110 - Investment Migration Yearbook 2O23

IM YEARBOOK
4. IMC Bulletin e-Newsletter
The IMC Bulletin is a quarterly email newsletter with valuable interesting industry-related
content. Each issue of the IMC Bulletin, which begins with a welcome note by the CEO or a
guest editor, features articles that are contributed by IMC Members as well as by members
of the Advisory Committee, academics and prominent contributors. A list of recently
joined
members joined members is also included. is also included. The Bulletin The Bulletin is sent, is personally sent, personally addressed addressed (Dear Dr (Dear Smith, Dr Smith, etc.),
to etc.), more to than more 1,600 than 1,600 recipients, recipients, and enjoys and enjoys a sustainable a sustainable opening opening rate of rate 20%. of 20%.
Description 1 issue 2 issues
Two hyperlinked banners (details below)
One paid industry-related article
One featured event to be displayed at the top of the events section
Banner to be placed in the News Section on the IMC Website
(only if two issues are purchased)
€5,000 €9,000
Banner Specifications:
Target Audience:
Frequency:
Position:
IMC Members, IMC Subscribers, IMC
Contacts
4 issues per year
1 banner after editorial
and 1 after articles
Size:
File type:
Reports:
600px x 200px
.jpg, .jpeg, 72 dpi
2 reports per main-shot
(1 and 2 weeks after email is sent out)
Investment Migration Yearbook 2O23 - 111

IM YEARBOOK
5. Corporate Announcements via Dedicated Email Shots
5. Corporate Announcements via Dedicated Email Shots
The IMC Corporate Announcement provides a unique opportunity to deliver a message
to all
The
IMC
IMC
Members,
Corporate
with
Announcement
a possibility of
provides
selection
a unique
by line of
opportunity
business or
to
by
deliver
country
a message
of citizenship/business.
to all IMC Members,
This
with
message
a possibility
can contain
of selection
an important
by line of
Press
business
Release,
or by country
Call
of
for
citizenship/business.
a Collaboration or any
This
other
message
objective
can contain
and industry-related
an important
update.
Press Release,
Call for a Collaboration or any other objective and industry-related update.
Description
Format:
Dedicated email template containing two hyperlinked banners, text
(up to 200 words) and a ‘Read More’ link to only one website
1 mailshot
€6,000
The Announcement includes the following:
One banner at the top of the page
One Face photo with name and title on the left (will appear as
paragraph breakdown on device version)
One banner under “read more” button
One article up to 200 words
Target Audience:
Can be pre-identified according to the country, membership status
(members, leads, etc.) and line of business.
Service includes:
Creation of a newsletter using IMC template & content provided
Provision of a newsletter preview for approval
Sending of a newsletter to agreed Target Group (contact lists)
2 post-campaign reports will be provided (1 and 2 weeks after email is sent out)
Creation of customised template or campaign design is available on request at an
additional cost. Contact us on info@investmentmigration.org for more details.
112 - Investment Migration Yearbook 2O23

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Save the Date
The Investment
Migration Forum
15 th -18 th May 2023
London
investmentmigration.org
Organisation in special consultative status with the Economic
and Social Council of the United Nations since 2019.
€25
European Commission Joint Transparency
Register Secretariat ID: 337639131420-09