IM Yearbook 2023

The completely new IM Yearbook 2023 is the 5th edition of what is now known as the most anticipated guide of the Investment Migration industry. The IM Yearbook is the essential global reference tool for the industry by the industry. Offering unrivaled valuable access to a prime targeted readership of your partners, clients and potential new business сontacts. Decision-makers in more than 54 countries trust the publication as a reputable source of information and guide. Readership includes: agents, law firms, advisory firms, banks, wealth managers, service providers, policy makers, government staffers, international organisations, and academics. Providing comprehensive, in-depth information about the global Investment Migration industry, the IM Yearbook 2023 will offer readers a practical A-Z guide to the current business operating environment while also highlighting the depth and breadth of practitioners, programmes, and their partners of all types.

The completely new IM Yearbook 2023 is the 5th edition of what is now known as the most anticipated guide of the Investment Migration industry.

The IM Yearbook is the essential global reference tool for the industry by the industry. Offering unrivaled valuable access to a prime targeted readership of your partners, clients and potential new business сontacts. Decision-makers in more than 54 countries trust the publication as a reputable source of information and guide. Readership includes: agents, law firms, advisory firms, banks, wealth managers, service providers, policy makers, government staffers, international organisations, and academics.

Providing comprehensive, in-depth information about the global Investment Migration industry, the IM Yearbook 2023 will offer readers a practical A-Z guide to the current business operating environment while also highlighting the depth and breadth of practitioners, programmes, and their partners of all types.


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<strong>IM</strong><br />



YEARBOOK <strong>2023</strong><br />

5 TH EDITION | €25<br />

Migration<br />

policy<br />

Accelerating the global recovery?<br />


• €530T: Global Wealth record<br />

• 281M: Global Migrants<br />

• 35-45yrs: Avg. Client Age<br />


• Engine of Change<br />

• Its all about EU Blood!<br />

• Must Peter Pay for Putin?<br />


• Real-Time DD<br />

• Women, Wealth, <strong>IM</strong><br />

• The Race is on!

Global Enhanced<br />

Due Diligence<br />

Established in 1961, Globe Detective Agency (P) Limited is the pioneer and leader in private<br />

Investigations in India with global expertise. Headquartered in New Delhi with a network of 20 branch<br />

offices, GDA specializes in Enhanced Due Diligence for the CBI/RBI industry and for Governments<br />

in 48 countries. This “deep dive” involves an in-depth background verification, extensive data<br />

acquisition and the use of established field resources. GDA‘s service offering also includes the<br />

authentication of documents and global security checks related to sanctions, enforcements, watch<br />

lists and identification of politically exposed persons.<br />

GDA’s highly-skilled, professional approach is personalized and rigorous. This is valued by<br />

Governments who regularly base their key Due Diligence decisions on information provided by GDA.<br />


601-603, Eros Apartments,<br />

56, Nehru Place, New Delhi 110019 • India<br />

T: (+91) 9311042007<br />

E: sachitkumar@globedetective.com<br />

www.globedetective.com<br />

Sachit Kumar - Managing Director<br />

Trusted<br />

Since 1961<br />

Global<br />

Network<br />

20<br />

Offices<br />

100,000+<br />

Cases &<br />


<strong>IM</strong> YEARBOOK<br />

Contents<br />

Facts & Figures<br />

The Numbers that Matter 4<br />

Editorial, Bruno L’ecuyer, CEO and Co-Founder of the Investment Migration Council<br />

An Engine of Change, Evolution and Growth 11<br />

In Conversation with Dimitry V. Kochenov and Elena Basheska<br />

It’s all about European Blood 16<br />

The <strong>IM</strong> Long Read<br />

A Fragile World Economy and New<br />

Opportunities for Investment Migration 20<br />

Eric Major, CEO of Latitude and Patricia Casaburi,<br />

Managing Director of Global Citizen Solutions<br />

What’s Ahead for Citizenship by Investment? 22<br />

From Refugee Past to EB-5 Professional:<br />

One Man’s Perspective on Migration 25<br />

The Big Picture<br />

The <strong>IM</strong> <strong>Yearbook</strong> Travels with<br />

Fragomen around the World 29<br />

Geoffrey DuBoulay and Keith Issac of Polaris Citizenship &<br />

Investment Consultancy Services<br />

Must Peter Pay for Putin? 32<br />

Trends and Topics<br />

Six Thoughts on Investment Migration<br />

in a Changing Landscape 34<br />

Dr Juerg Steffen, CEO of Henley & Partners<br />

Navigating a New Level of Volatility 42<br />

Anatomy of a Source Market:<br />

India 44<br />

Karen Kelly, Director of Strategy and Development at Exiger<br />

Looking Forward: Using Real-Time<br />

Monitoring to make Risk-Based Decisions 48<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 1

<strong>IM</strong> YEARBOOK<br />

Ronit Sharma, Founder & Managing Director of Immigrant Investor Group<br />

What HNWIs Need to Know about<br />

Canada’s Start-up Visa 50<br />

Charles Mizzi, CEO of the Residency Malta Agency<br />

From Permanent Residence to the Nomad<br />

Residence Permit:Malta Keeps on Innovating 52<br />

Frederico Seixas, Sales Director of Investaureum<br />

Portugal: Europe’s New “California” 54<br />

Interview with Austin T. Fragomen Jr, Chairman Emeritus at Fragomen<br />

The Global Race for High-Potential<br />

Migrants is Heating up 56<br />

Women, Wealth and Investment Migration 60<br />

How Migration Policy can Accelerate Recovery<br />

from the Global Economic Downturn 62<br />

Who’s Who<br />

Directory of People You Need to Know 66<br />

A Guide to the Investment Migration Council 73<br />

<strong>IM</strong>C Qualifications and Training 82<br />

The Investment Migration Forum Partnership<br />

Opportunities 87<br />

Visibility Opportunities for Your Business 102<br />

YEARBOOK <strong>2023</strong><br />

All rights reserved. Reproduction in whole or part is strictly prohibited without the written permission of<br />

the publisher. Opinions expressed in the <strong>IM</strong> <strong>Yearbook</strong> are not necessarily those of the editor, publisher<br />

or contributors. All reasonable care is taken to ensure truth and accuracy, but the editor and publisher<br />

cannot be held responsible for errors or omissions in articles, advertising, photographs, or illustrations.<br />

Publication Date: January <strong>2023</strong> • Printing: Gutenberg Press<br />

Publisher: Investment Migration Council - media@investmentmigration.org<br />

Editor: Bruno L’ecuyer - bruno.lecuyer@investmentmigration.org • Sonja Lindenberg - sonja@storycom.net<br />

Design: Ramon Micallef - ram@box-design.net • ISBN N°: 978-2-8399-3429-9<br />

2 - Investment Migration <strong>Yearbook</strong> 2O23

The Investment Migration Forum<br />

Advancing Residence and Citizenship by Investment<br />

15 th - 18 th May <strong>2023</strong>, London , United Kingdom<br />

350+<br />

Delegates<br />

50+<br />

Speakers<br />

55+<br />

Countries<br />

25+<br />

Partners<br />

The Investment Migration Forum will be hosting its 8 th edition in London! Renowned academics, government officials and<br />

representatives of international organisations - as well as the world's leading professionals dealing with investor migration<br />

and citizenship by investment - now have the London gathering entrenched on their annual calendar.<br />

13%<br />

60%<br />

8%<br />

10%<br />

7%<br />

Europe<br />

Asia<br />

USA & Canada<br />

Middle East<br />

<strong>IM</strong> YEARBOOK<br />

Facts & Figures 2022/23<br />

The Numbers that<br />

Headline Figures<br />

Investment migration has gone through<br />

enormous change since it started in<br />

the 1980s. It is today more diverse than<br />

ever as illustrated by the figures below.<br />

1984<br />

The year when St. Kitts<br />

and Nevis introduced<br />

the first modern<br />

CBI programme.<br />

150-170<br />

countries<br />

An EU passport typically allows<br />

visa-free travel to between 150<br />

and 170 countries, following<br />

multi-tiered due diligence.<br />

$100,00 to<br />

more than<br />

$5 million<br />

Investment requirements vary<br />

greatly across countries. While<br />

the minimum investment<br />

can be as low as $100,000,<br />

some countries require<br />

multi-million investments.<br />

400+<br />

The <strong>IM</strong>C has more than<br />

400 members coming from<br />

45 different countries.<br />

€20 billion<br />

Investment migration is<br />

estimated to be a €20-billionindustry.<br />

It generates significant<br />

societal and economic benefits,<br />

including job creation and<br />

notable contributions to GDP.<br />

90%<br />

of investment migration<br />

pathways are offered in<br />

so-called rich nations. Highincome<br />

countries as defined<br />

by the World Bank with a<br />

gross national income (GNI)<br />

per capita of US$12,696<br />

or higher account for 63%<br />

and upper middle-income<br />

countries with a GNI per<br />

capita between $4,046 $12,535<br />

$12,535 account for 30%.<br />

550+<br />

Small businesses and<br />

consultancies drive<br />

investment migration<br />

forward. There are some<br />

550+ agents licensed<br />

across the world.<br />

35-45<br />

years old<br />

Service providers report<br />

that in emerging market<br />

economies the average age<br />

of applicants is between<br />

35 and 45 years old.<br />

Countries with<br />

investor pathways<br />

for citizenship 2022:<br />

Antigua & Barbuda<br />

Dominica<br />

Grenada<br />

Jordan<br />

Malta<br />

St. Kitts & Nevis<br />

St. Lucia<br />

Turkey<br />

Popular countries<br />

with investor<br />

pathways for<br />

residence 2022<br />

Australia<br />

Canada (Quebec)<br />

Cayman Islands<br />

France<br />

Greece<br />

Hong Kong<br />

Ireland<br />

Italy<br />

Jersey<br />

Latvia<br />

Malta<br />

Monaco<br />

New Zealand<br />

Singapore<br />

Spain<br />

Thailand<br />

UAE<br />

UK<br />

USA<br />

Several other countries<br />

had investment migration<br />

programmes in place at<br />

different times in the past.<br />

In addition, around 10% of<br />

all established programmes<br />

have been replaced with<br />

revised versions between<br />

the years 2000 and 2015.<br />

98% of the world population<br />

acquired citizenship at<br />

birth, while naturalisations<br />

account for 2% of<br />

citizenship acquisitions<br />

around the world, according<br />

to citizenship expert<br />

Dimitry Kochenov.<br />

Migration<br />

Trends<br />

281 million<br />

international<br />

migrants<br />

The World Migration Report 2022<br />

published by the International<br />

Organization for Migration (IOM)<br />

estimates that 281 million people<br />

are living in a country other than<br />

their country of birth. Most people<br />

though continue to live in the<br />

countries in which they were born<br />

—only one in 30 are migrants.<br />

88,000<br />

millionaires<br />

The world’s rich are on the move<br />

again after a pandemic-induced<br />

dip: 88,000 millionaires are<br />

expected to move by the end of<br />

2022, according to the Henley<br />

Global Citizens Report.<br />

Global wealth will<br />

shrink in 2022<br />

While 2021 was a strong year<br />

for wealth growth, 2022 turned<br />

out to be significantly different.<br />

High inflation and interest rate<br />

hikes spurred stock market<br />

corrections. By end of April 2022,<br />

Capgemini estimated that global<br />

HNWI wealth had declined by<br />

4% compared to December 2021.<br />

+10%<br />

Knight Frank’s Wealth Report<br />

stated that globally the number<br />

of people with net wealth of<br />

US$30 million or more increased<br />

by almost 10% in 2021.<br />

This growth was evenly spread,<br />

with North America (up 12.2%)<br />

just ahead of the regional pack.<br />

Only Africa saw a decline in<br />

wealth, according to the report.<br />

4 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Matter<br />

25<br />

20<br />

Numbers and quoted percentages<br />

may not add up due to rounding.<br />

Wealth Growth Trends<br />

$530 trillion<br />

Global wealth reached a record high of $530 trillion in 2021, fuelled by strong<br />

equity markets and a surge in demand for real assets, according to the 2022<br />

edition of the Global Wealth report by the Boston Consulting Group (BCG).<br />

The report finds that despite geopolitical and economic destabilizers<br />

such as inflation and Russia’s invasion of Ukraine, approximately $80<br />

trillion in new wealth will likely be created over the next five years.<br />

In a notable industry shift, BCG predicts that Hong Kong will probably<br />

overtake Switzerland in <strong>2023</strong> as the domicile managing the largest amount<br />

of private cross-border wealth, ending a run of more than 200 years of Swiss<br />

dominance. The report points out that wealth assets will continue to rise in<br />

value in all regions. But Asia-Pacific will maintain the fastest rates of wealth<br />

growth, with asset values poised to increase by a compound annual growth<br />

rate (CAGR) of 8.4% through 2026. If that rate holds, the region could be home<br />

to nearly one-quarter of the world’s wealth by 2026, according to BCG.<br />

Switching to other parts of the world, BCG finds that wealth in the<br />

Middle East and Africa is on track to rise by a CAGR of 5.4% over the<br />

next five years, the biggest overall leap in regional wealth growth. In the<br />

US, wealth growth will be slower than in past years, with an estimated<br />

CAGR of 4.7% through 2026, down from a prior five-year average of 9.1%.<br />

Likewise, in Western Europe, wealth growth is likely to slow from roughly<br />

4.5% over the past five years to less than 4% annually until 2026.<br />

7.8%<br />

According to Capgemini’s World Wealth Report 2022, the global<br />

HNWI population expanded by 7.8% in 2021, with 1.7million new<br />

HNWI. While wealth swelled by 8%, or US$6.4 trillion.<br />

While multiple factors contributed to the growth of<br />

wealth, bull markets around the world were a primary driver.<br />

Globally, stock markets generated healthy returns.<br />

HNWI Population Growth in Millions<br />

Economic Forecast<br />

An uncertain<br />

economic<br />

outlook<br />

The World Economic Forum, the <strong>IM</strong>F, the WTO and<br />

the OECD – all international institutions have slashed<br />

their growth outlook for <strong>2023</strong>. Several shocks have hit<br />

a world economy already weakened by the pandemic:<br />

higher-than-expected inflation worldwide – especially in<br />

the US and major European economies – triggering tighter<br />

financial conditions; a worse-than-anticipated slowdown<br />

in China, reflecting Covid-19 outbreaks and lockdowns;<br />

and further negative spillovers from the war in Ukraine.<br />

Even wealthy countries are struggling with multiple costof-living<br />

pressures, while higher food and fuel prices are<br />

raising the prospect of unrest in poorer countries. Analysts<br />

expect further changes in the global economic and<br />

geopolitical order should energy trade shift, supply chains<br />

reconfigure, and nations rethink reserve currency holdings.<br />

The risks to the outlook are overwhelmingly tilted to the<br />

downside, the <strong>IM</strong>F noted. Global growth will likely decline to<br />

about 2.6% in 2022 and 2% in <strong>2023</strong>, which would put growth<br />

in the bottom 10% of outcomes since 1970. Meanwhile, the<br />

World Economic Forum expects global growth to slow<br />

from 6.1% to 3.2% in 2022, and the WTO revised down its<br />

forecast for global trade growth this year to 3% from 4.7%.<br />

A further tightening of global financial conditions will be<br />

felt disproportionately strong in emerging and developing<br />

economies, which are already facing elevated debt levels<br />

following the pandemic. Projections by the UN Conference<br />

on Trade and Development (UNCTAD) estimate that<br />

developing countries will need $310 billion to meet their<br />

external public debt service requirements in 2022.<br />

Meanwhile, the Economist Intelligence Unit reported<br />

that Saudi Arabia will be the world’s fastest-growing major<br />

economy in 2022, outperforming the dynamic Asian giants<br />

of China, India, Indonesia and South Korea, as well as<br />

the struggling G7 and other major emerging economies.<br />

Real GDP growth is expected to reach 7.5% in 2022. The<br />

kingdom has recovered quickly from a pandemic-induced<br />

recession in 2020 and is reaping the rewards of high<br />

global energy prices and increased energy production.<br />

15<br />

10<br />

5<br />

0<br />

2014 2015 2016 2017 2018 2019 2020 2021<br />

The US retained its lead for HNWI growth (13.2%) and wealth (13.8%) in 2021.<br />

The region accounted for more than half of the 1.7million new HNWIs.<br />

The US, Japan, Germany and China retained their top<br />

four positions in HNWI population markets in 2021. They<br />

comprised 63.6% of the global HNWI population.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 5

<strong>IM</strong> YEARBOOK<br />

Country<br />

Attraction<br />

The UAE,<br />

Australia and<br />

Singapore have<br />

been ranked<br />

the top three<br />

countries in terms<br />

of net inflows of<br />

HNWIs for 2022,<br />

according to<br />

figures provided<br />

by the Henley<br />

Global Citizens<br />

Report (Q2).<br />

The top three<br />

countries with<br />

the highest<br />

net outflows<br />

of HNWIs are<br />

Russia, China<br />

and India.<br />

Projected net inflows<br />

of HNWIs in 2022<br />

UAE 4,000<br />

Australia 3,500<br />

Singapore 2,800<br />

Israel 2,500<br />

Switzerland 2,200<br />

USA 1,500<br />

Portugal 1,300<br />

Greece 1,200<br />

Canada 1,000<br />

New Zealand 800<br />

Projected net outflows<br />

of HNWIs in 2022<br />

Russian Federation -15,000<br />

China -10,000<br />

India -8,000<br />

Hong Kong (SAR China) -3,000<br />

Ukraine -2,800<br />

Brazil -2,500<br />

UK -1,500<br />

Mexico -800<br />

Saudi Arabia -600<br />

Indonesia -600<br />


Russia<br />

Unsurprisingly, Russia has<br />

suffered the biggest emigration<br />

of millionaires in the first six<br />

months of 2022. Henley &<br />

Partners forecast net outflows<br />

of 15,000 by the end of 2022 —<br />

15% of its HNWI population<br />

and 9,500 more than in 2019.<br />

However, soon after the invasion<br />

of Ukraine, most countries said<br />

they would no longer accept<br />

or process applications from<br />

Russian citizens. Meanwhile,<br />

Russia advanced plans to<br />

launch its own golden visa<br />

in January <strong>2023</strong> and expects<br />

primarily Chinese to take<br />

advantage of the programme.<br />

China<br />

Chinese nationals have long<br />

accounted for approximately<br />

80% of applicants to any<br />

residence programme in the<br />

world. However, international<br />

travel bans due to Covid-19 and<br />

currency control mechanisms<br />

have made it increasingly<br />

difficult for Chinese nationals<br />

to use investment migration<br />

pathways. Nonetheless, around<br />

10,000 HNWIs in China planned<br />

in 2020, taking $48 billion in<br />

wealth with them, according<br />

to Henley and Partners.<br />

India<br />

Wealthy Indians are investing<br />

abroad at record rates, data<br />

from the country’s central<br />

bank revealed. In the 2021-22<br />

financial year, Indians ploughed<br />

$1.69bn directly into foreign<br />

bank deposits, equity and debt<br />

instruments, as well as into<br />

property outside the country,<br />

according to the Reserve Bank<br />

of India. That is almost 40%<br />

higher than the figure for 2020-21<br />

and nearly six times the $292m<br />

that Indians invested abroad in<br />

real estate, deposits, debt and<br />

equity in 2014/15. Rich Indians<br />

are not just sending their money<br />

abroad. Henley & Partners<br />

projected that around 8,000<br />

millionaires will have left the<br />

country by the end of 2022.<br />

6 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Investment<br />

Trends<br />

71%<br />

Emerging asset classes, including ESG,<br />

cryptocurrencies and NFTs, are high<br />

on the agenda of HNWIs. According to<br />

Capgemini’s Wealth Report 2022, 71% of<br />

HNWIs have invested in digital assets.<br />

Elsewhere, Knight Frank’s Wealth Report<br />

pointed out that 18% of UHNWIs now<br />

own cryptocurrencies, while 11% have<br />

invested in non-fungible tokens (NFTs).<br />

15%<br />

Around 15% of UHNWIs plan to<br />

apply for a second passport or new<br />

citizenship and 36% of those are<br />

planning to do so for a better quality<br />

of life, according to Knight Frank.<br />

80%<br />

Some 80% of wealthy investors want<br />

more ESG-compliant assets to futureproof<br />

their portfolios, Knight Frank said.<br />

The Attraction of<br />

Big City Life<br />

While many predicted that cities would<br />

lose their appeal as a result of the ‘race for<br />

space’ in the Covid-19-era, Knight Frank’s<br />

Global Buyer Survey 2021 indicate that<br />

the city is far from down and out. The<br />

survey found out that 38% of respondents<br />

that are inclined to move within the next<br />

12 months were looking at a city location,<br />

while 33% were considering the suburbs.<br />

US$53 trillion<br />

Investments that consider ESG<br />

criteria may exceed US$53 trillion<br />

by 2025, according to Capgemini.<br />

21%<br />

Knight Frank recorded an intention from<br />

21% of global UHWNIs to purchase new<br />

property somewhere in the world in 2022,<br />

up from the 19% who did so in 2021.<br />

Moreover, Knight Frank stated that<br />

the average value of luxury residential<br />

property increased by 8.4% in 2021,<br />

the highest annual increase since the<br />

firm launched its Prime International<br />

Residential Index in 2008.<br />

Top1O Passports<br />

Source: Henley & Partners Passport<br />

Index September 2022<br />

Rank<br />

Passport<br />

Visa-free score<br />

1 Japan 193<br />

2 Singapore 192<br />

South Korea<br />

3 Germany 190<br />

Spain<br />

4 Finland 189<br />

Italy<br />

Luxembourg<br />

5 Austria 188<br />

Denmark<br />

Netherlands<br />

Sweden<br />

6 France 187<br />

Ireland<br />

Portugal<br />

UK<br />

7 Belgium 186<br />

New Zealand<br />

Norway<br />

Switzerland<br />

US<br />

8 Australia 185<br />

Canada<br />

Czech Republic<br />

Greece<br />

Malta<br />

9 Hungary 183<br />

10 Lithuania 182<br />

Poland<br />

Slovakia<br />

Source: Arton’s Passport Index<br />

November 2022<br />

Rank<br />

Mobility<br />

score<br />

1 United Arab Emirates 177<br />

2 Germany, Sweden 173<br />

Finland, Luxembourg<br />

Spain, France, Italy<br />

Netherlands, Austria<br />

Switzerland, South Korea<br />

3 Denmark, Belgium 172<br />

Portugal, Norway<br />

Poland, Ireland<br />

United States of America<br />

New Zealand<br />

4 Czech Republic, Greece 171<br />

Hungary, Japan,<br />

United Kingdom, Australia<br />

5 Singapore 170<br />

Malta<br />

Lithuania<br />

Slovakia<br />

Canada<br />

6 Estonia 169<br />

Latvia<br />

Slovenia<br />

7 Liechtenstein 168<br />

Iceland<br />

8 Cyprus 167<br />

Croatia<br />

Romania<br />

Bulgaria<br />

9 Malaysia 165<br />

10 Monaco 163<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 7


111 Immigration Services<br />

360 Advisory & Management GmbH<br />

Academy Finance<br />

Adamjee Global Solutions<br />

Adrestia Legal<br />

Afi Ventour & Co.<br />

AIT Accounting & Management Services Ltd<br />

Alam Nam<br />

Alta Invest RCBI Solutions<br />

Andorra Guides<br />

Anna Grigorieva & Co. LLC<br />

Appleby<br />

Arden Leigh LLP<br />

Areti Charidemou & Associates LLC<br />

Asia Outbound Group<br />

Atlantic Bridge<br />

Austral Migration Consultancy P/L<br />

BDO<br />

Bedell Cristin<br />

Beshara Global Migration Law Firm<br />

BEYOND Residence and Citizenship<br />

BIZ Consult Ltd<br />

BLVUE Zürich Advisory AG (Ltd.)<br />

Bond University<br />

Bridge Partners<br />

Budget & Migration Consultants<br />

Bulgarian Citizenship Ltd.<br />

Century Capital Inc.<br />

Chetcuti Cauchi Advocates<br />

Citizenship By Investment Unit - Antigua & Barbuda<br />

Citizenship Invest<br />

Citizenship Solutions<br />

CJ International Group<br />

CLD Legal<br />

Dalmore Group, LLC<br />

Davidson immigration<br />

Davison & Davison Associates Limited<br />

Deloitte Malta<br />

Dentons<br />

Discus Holdings<br />

Dual Luxury World<br />

Energopiisi<br />

Erg, Family Office<br />

Exclusive Migration<br />

Exiger LLC<br />

Eximius Life<br />

FACT Due Diligence<br />

Filimon Consulting<br />

First Advisory Trust reg.<br />

Fragomen Worldwide<br />

Free Mobility Leaders<br />

Frendo Advisory<br />

Fresh Global Alliance Ltd<br />

Frontgate Global Concepts<br />

Ganado & Associates<br />

GICG Global Information Consulting Group<br />

GLI General Lines of Immigration Corporation<br />

Global Citizen Solutions Limited<br />

Global Nomad Consulting<br />

Global Residence and Citizenship Ltd.<br />

Globe Detective Agency (P) Ltd.<br />

Globevisa<br />

Go2Europe<br />

Golden Visa Consultancy<br />

Golden Visa Experts<br />

Grant, Joseph & Co<br />

Green Light Management Consultancy JLT<br />

Grosvenor Partners<br />

Guardian Corporate Services Ltd<br />

Guide Consultants<br />

Henley & Partners Montenegro<br />

Henley & Partners Australia<br />

Henley & Partners Austria<br />

Henley & Partners Canada (Quebec)<br />

Henley & Partners HKG<br />

Henley & Partners Jersey<br />

Henley & Partners Malta<br />

Henley & Partners Middle East DMCC<br />

Henley & Partners Portugal<br />

Henley & Partners Singapore Pte. Ltd.<br />

Henley & Partners South Africa (Pty) Ltd.<br />

Henley & Partners Spain<br />

Henley & Partners Switzerland<br />

Henley & Partners UK<br />


Hilton Global Associates<br />


<strong>IM</strong>M GROUP Co. Ltd.<br />

Immigrant Invest<br />

Immigrant Investor Group Inc (IIG)<br />

immVest International Limited<br />

Impart Immigration Consulting<br />

Integritas Group<br />

Intercorp International LTD<br />

International Center for Globalization and Development<br />

Inter-Tax Consultants<br />

Invest & Settle<br />

Invest in the USA (IIUSA)<br />

Investaureum Lda<br />

Island Living Investment Services Ltd<br />

J and Rays Ltd<br />

Joel Stewart PA<br />

8 - Investment Migration <strong>Yearbook</strong> 2O23

400+ MEMBERS FROM<br />

55+ COUNTRIES<br />

Joseph Rowe Attorneys-at-Law and Notaries Public<br />

Ketenci&Ketenci ILP<br />

Khalil Masri et Fils Sarl<br />

Klasko Immigration Law Partners, LLP<br />


KPMG Intl Malta<br />

KSi Malta<br />

La Vida Golden Visas<br />

Laferla Insurance Agency Limited<br />

Lamares, Capela & Associados<br />

Latitude Consultancy Limited<br />

Leary Global, Investment Migration Advisors<br />

Lecanda Immigration and Nationality Law<br />

Leisure World Properties Ltd<br />

Lincoln Global Partners UK Limited<br />

Magellan Champlain<br />

Maisto & Associati<br />

Mc Namara & Company - Barristors, Solicitors & Notaries Royal<br />

Michael Kyprianou & Co. LLC<br />

MICS Global<br />

Mifsud&Mifsud Advocates<br />

Migronis Ltd<br />

Mintz Group LLC<br />

Mirabello Consultancy AG<br />

M-J Global<br />

Moonline Immigration<br />

Motcomb<br />


My Global Citizenship<br />

Neity Lloyd Maddock<br />

New Balkans Law Office<br />

NEXT - Gali Macedo Lawyers<br />

Next Generation Equity<br />

NG Global Citizens Limited<br />

Nila Global<br />

Nomad Gate<br />

Novafirm SA<br />

NSM - Nuno Sousa Moniz, Sociedade de Advogados SP RL<br />

Optylon Krea LDA<br />

Orience International SL<br />

Passport Gates<br />

PassPro Immigration Services<br />

Paton & Mayr SLU<br />

PDE Consulting Ltd<br />

Polaris Citizenship & Investment Consultancy Services Limited<br />

Prime Synergy<br />

Professionals Ltd.<br />

ProPanama<br />

PT. Anugraha Askara Paramitra<br />

QuazarHouses LLC<br />

R P Merriman<br />

Range Developments Ltd.<br />

RC International<br />

Reef View Enterprises Ltd<br />

Residency Malta Agency<br />

Resolute Group<br />

RIF Trust Investments LLC<br />

RK Global Fortune Consulting<br />

ROC Citizenship<br />

Roseveare Group<br />

Rute Immigration.<br />

Sable International Limited<br />

Saeima (National Parliament) of Latvia<br />

Saratoga Capital<br />

SG - Secondpass Global<br />

Shard Capital Investor Visa<br />

Shirazi Immigration Law, Inc.<br />

S-RM Intelligence and Risk Consulting<br />

Startup Business Bureau<br />

Steptoe & Johnson LLP<br />

Sterling Migration<br />

Sunrise International Legal Services<br />

SwissTaxGroup<br />

The Address Consulting Group<br />

The Sovereign Group<br />

Thomas John & Co<br />

Trafalgar Properties LLC CBI / RBI Unit<br />

University of Vienna<br />

Valadas Coriel & Associados<br />

Vanuatu Life Style Ltd<br />

Vardikos & Vardikos<br />

Varnavas & Varnavas<br />

Vertex Advisory Ltd<br />

Visa World Wide Admission<br />

Visadoro<br />

Visas Consulting Group Inc<br />

Viya Global Vatandaşlık Ve Göç Hizmetleri<br />

Danışmanlık Ticaret Limited<br />

Vostok Consulting LLC<br />

WDM Lex Advisory Ltd<br />

WOLF THEISS Attorneys-at-Law<br />

World Grenada Inc.<br />

Xenoom Immigration Inc.<br />

XIPHIAS Immigration Pvt Ltd.<br />

Xumit Capital<br />

Neda Azarmehr<br />

Hudda Elmira Chehadé Cert (<strong>IM</strong>)<br />

Walid Nadar<br />

Adewale Dosunmu<br />

Imran Mirani<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 9


<strong>IM</strong> YEARBOOK<br />


An Engine of<br />

Change,<br />

Evolution and<br />

Growth<br />

World events over the last two years resulted<br />

into the perfect storm for the global economy.<br />

International migration and investment will<br />

play a key role as countries brace for impact.<br />

Bruno L’ecuyer, CEO &<br />

Co-Founder of the<br />

Investment Migration Council<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 11

<strong>IM</strong> YEARBOOK<br />

Change is not the right term to<br />

describe what the world economy<br />

and world politics are experiencing<br />

currently. It is too small a word to capture<br />

the essence of what is happening. The<br />

ongoing pandemic, the war in Ukraine,<br />

the effects of climate change, supply chain<br />

disruption, energy crisis, inflation, higher<br />

interest rates and potentially a coming<br />

recession have created an unprecedented<br />

scenario for global migration.<br />

Even wealthy countries are struggling<br />

with multiple cost-of-living pressures,<br />

while higher food and fuel prices are<br />

raising the prospect of unrest in poorer<br />

countries. Meanwhile, shifting alliances<br />

and value systems are creating a new global<br />

map of political and economic relations.<br />

While it is still too early to say how all this<br />

will play out, it looks certain that trends<br />

which started to unfold throughout the<br />

past two years will only intensify. Topics<br />

such as diversification, regionalisation<br />

and the protection of national borders<br />

will continue to dominate the investment<br />

migration agenda in <strong>2023</strong> and beyond.<br />

It seems more than likely that investment<br />

migration will continue to play an important<br />

role in attracting foreign investment<br />

and funding key government activities<br />

in several countries. After having to<br />

deal with the Covid-19 pandemic, many<br />

countries have little, or no reserves left<br />

to cushion the effects of the new crises.<br />

The opportunity to raise revenue from<br />

investment migration – given that there is<br />

also limited room to increase taxes – will<br />

remain a major motivation for countries to<br />

retain or introduce investment migration<br />

pathways. However, at the same time,<br />

support for investment migration pathways<br />

by supra-national entities, including the<br />

European Union, is at its lowest level.<br />

Reinventing an old concept<br />

Investment migration is not a new<br />

phenomenon. Some industry experts point<br />

out that it was common in the Roman<br />

Empire to grant citizenship in exchange for<br />

money, while others say that in 17 th -century<br />

France, under Louis the Great, it became<br />

a widespread practice to sell noble titles<br />

to affluent commoners to finance wars.<br />

Investment migration today is understood<br />

to have its origins in the Caribbean when St.<br />

Kitts and Nevis launched the first modern<br />

citizenship-by-investment pathway in<br />

1984 as a tool for economic development.<br />

Since then, the business model has<br />

quickly evolved and was developed further<br />

with Portugal’s introduction of residency<br />

by investment. In 2010, four EU member<br />

states hosted residency pathways, just<br />

seven years later, nearly half of all member<br />

states established them. Today, investment<br />

migration is featured in immigration<br />

law in most UN recognised countries,<br />

albeit in different forms and shapes.<br />

Globally, some 60 countries are actively<br />

promoting their pathways, with 30 of them<br />

being the most relevant and attracting the<br />

largest share of applicants. Countries such<br />

as the US, Canada, Australia, and the UK<br />

– all offering paths for immigrant investors<br />

– have long been among the favourite<br />

destinations for high-net-worth individuals.<br />

Citizenship-by-investment pathways<br />

usually receive less than 1,000 applications<br />

per year. However, Turkey seems to be<br />

the exception, with around 7,300 new<br />

citizenship investors between 2017 and<br />

2020. Residency by investment is the more<br />

popular choice. All pathways together are<br />

receiving tens of thousands of applications<br />

per year, generating billions in investments<br />

that are being mobilised to create jobs<br />

and encourage economic activity.<br />

Revenue generator<br />

Investment migration is estimated to<br />

generate €20 billion annually, and income<br />

from investment migration represents<br />

anything between 2% and 30% of GDP<br />

in some countries. While the economic<br />

impact of investment migration is marginal,<br />

investment migration income is a lifeline<br />

for smaller countries and microstates.<br />

Countries typically offer not just one<br />

way to invest, but also a range of qualifying<br />

options, which can include investments<br />

in real estate, businesses, government<br />

bonds, stocks and investment funds, as<br />

well as deposits in a bank and donations<br />

to the government or to the public good.<br />

Across the world investment migration<br />

has the catalyst for major infrastructural<br />

improvements, including resorts, harbours,<br />

airports, hospitals, office buildings,<br />

luxury residential developments and<br />

even an airline, which in turn have had a<br />

massive multiplier effect on the respective<br />

economies. Investment migration is not<br />

only influential in delivering cuttingedge<br />

infrastructure, investments<br />

into companies, start-ups and R&D<br />

programmes; it is also having the effect<br />

12 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

of generating whole new economic sectors<br />

that did not exist before their introduction.<br />

While the macroeconomic impact<br />

of investment migration cannot be<br />

underestimated, international organisations<br />

such as the <strong>IM</strong>F urge governments to ensure<br />

that the funds are channelled towards<br />

productive investments that will pay dividends<br />

in the future and not be tempted to finance<br />

day-to-day expenses. The policymakers<br />

equally acknowledge that income from<br />

investment migration provides a vital source<br />

of funding for economically weaker countries.<br />

Market pressure<br />

As climate change displaces more people,<br />

many argue we need a new mechanism<br />

to manage global labour mobility, the<br />

world’s biggest economic resource,<br />

more effectively and efficiently.<br />

While trends in global mobility have<br />

noticeably changed since the Covid-19<br />

pandemic, they continue to be interrupted<br />

by the war in Ukraine. The market is feeling<br />

the absence of Russian citizens, with most<br />

countries suspending applications from<br />

Russian and Belarussian nationals when Russia<br />

invaded Ukraine, stating that the necessary<br />

due diligence checks cannot be carried out.<br />

Turkey’s path to citizenship for investors is<br />

the exception and has therefore seen a wave<br />

of Russian applicants in 2022 after initially<br />

catering primarily to Middle Eastern investors,<br />

including Iranians, Iraqis and Afghans.<br />

To add a twist to the story, Russia<br />

pushed forward with plans to launch its<br />

own investment migration pathway and<br />

will accept applicants from January <strong>2023</strong>.<br />

Some analysts expect that primarily Chinese<br />

investors will take advantage of it. One<br />

reason is that Beijing is making it harder for<br />

its wealthy citizens to apply for investment<br />

migration visas in Europe and the US<br />

in a bid to head off potential capital<br />

outflows via residents looking to escape<br />

the country’s zero-Covid policy. Chinese<br />

nationals, which long accounted for the<br />

majority of applicants to any pathway, have<br />

not disappeared. However, many agents<br />

report that their number has decreased.<br />

Meanwhile, India, along with other<br />

countries in South-East Asia, is rising to the<br />

fore as an important source market. Some<br />

media outlets already called it “the Great<br />

Indian Investment Migration”. Although<br />

India is experiencing strong economic and<br />

population growth, the country’s infrastructure<br />

has not kept up with this expansion. The<br />

result is that air, water and noise pollution<br />

are part of everyday life in India’s megacities<br />

and are often cited as reasons why Indians<br />

consider investment migration pathways.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 13

<strong>IM</strong> YEARBOOK<br />

EU challenges<br />

Meanwhile, investment migration is facing<br />

a barrage of criticism from policymakers<br />

in the European Union. One reason for the<br />

opposition is that citizenship and residency<br />

pathways in one EU country automatically<br />

confer rights concerning all EU member<br />

states. These rights include free movement,<br />

the right to vote, consular protection, and<br />

access to the internal market. In addition,<br />

EU policymakers argue investment<br />

migration poses risks of money laundering,<br />

security, tax evasion and corruption.<br />

The perceived lack of transparency<br />

and non-established harmonised<br />

governance practices across member states<br />

operating exacerbate such concerns.<br />

In 2020, the European Parliament has<br />

called on EU member states to phase out<br />

their schemes, while in March 2022, the<br />

European Commission recommended<br />

that member states operating investor<br />

citizenship pathways should terminate<br />

them immediately, while it looks to regulate<br />

residency pathways in a stricter way.<br />

Moreover, two years after it first initiated<br />

infringement procedures against Malta<br />

over its investor citizenship, the European<br />

Commission referred the case to the<br />

Court of Justice of the European Union<br />

(CJEU). Many industry professionals<br />

welcome the fact that the CJEU has now<br />

been called to rule as this would provide<br />

much needed clarity on the matter. Sector<br />

experts say an EU legislative framework<br />

on investment migration is inevitable.<br />

However, the process of adoption<br />

of any additional legislation could take<br />

several months if not years. Thus far,<br />

there has been no official communication;<br />

however, the European Parliament had<br />

already made a few suggestions. These<br />

included phasing-out of investor citizenship,<br />

introducing comprehensive regulation for<br />

residency pathways, and possibly creating<br />

an adjustment mechanism that would<br />

require member states operating residency<br />

pathways to compensate other member<br />

states for the “negative consequences”<br />

through a contribution to the EU budget.<br />

While the EU’s primary focus is<br />

member states operating such pathways,<br />

non-EU countries with visa-free access<br />

to the European Schengen area have also<br />

been put under the microscope. Countries<br />

in the Caribbean operating investment<br />

migration pathways should ensure they<br />

apply the highest level of due diligence and<br />

best-practice industry standards should<br />

they wish to maintain visa-free access to the<br />

EU. Vanuatu has already lost its visa-free<br />

access to the EU due to the inadequate<br />

procedure of vetting its applicants.<br />

More to do<br />

Boston Consulting Group predicts<br />

that the world will continue to open to<br />

global migrants despite considerable<br />

political polarisation in some countries.<br />

Investment migration is not without its risks,<br />

but it’s also an important economic tool for<br />

many countries. The Investment Migration<br />

Council shares a strong responsibility<br />

about what the future should bring<br />

Initiatives of the Investment Migration<br />

Council, such as the development of<br />

common due diligence standards and an<br />

anti-bribery code, show that the industry is<br />

recognising the need to either self-regulate<br />

effectively or accept that rules will be<br />

imposed on it. In the presence of so much<br />

pressure, the industry can only survive if<br />

every party involved acts in a transparent<br />

manner. It’s unfortunate that the sector<br />

remains largely unregulated, with only a<br />

handful of countries having established<br />

an independent regulator to oversee the<br />

operation of their programmes. Moreover,<br />

to this date, there are no harmonised<br />

procedures on how these pathways operate.<br />

The immediate challenge for the<br />

industry is to get all industry stakeholders<br />

to commit to the highest standards of<br />

transparency and good governance. It is<br />

crucial that countries communicate how<br />

application decisions are made and share<br />

more information with other countries,<br />

players in the financial services industry<br />

and policymakers, including those in the<br />

EU. As a democratic body with complex<br />

bureaucratic procedures in place, the EU<br />

relies on constructive dialogue with all<br />

concerned partners to develop its policies.<br />

A regular information exchange is therefore<br />

in the best interest of all stakeholders.<br />

14 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

New mobility regimes<br />

The investment migration landscape is<br />

rapidly changing. Globally, a whole range<br />

of mobility regimes are available in the<br />

marketplace. A by-product of Covid-19, the<br />

number of digital nomad visas available<br />

has increased steadily, while most nations<br />

today offer either entrepreneur- or startup<br />

visas, which can also deliver real<br />

economic benefits in terms of job creation,<br />

new services and supporting a sustained<br />

culture of innovation, to the host country.<br />

As a customer-oriented sector,<br />

investment migration is also gearing up to<br />

service new client segments. The average<br />

age of multi-millionaires in the world has<br />

decreased over the last two decades. Service<br />

providers report that in emerging market<br />

economies the average age of applicants is<br />

between 35 and 45 years old, and many of<br />

them are young entrepreneurs spurring<br />

demand for active investment options<br />

as opposed to the traditional passive<br />

alternatives. A closer look at the new<br />

generation of mobility regimes can offer<br />

powerful reflections to those countries<br />

who wish to ensure their pathways<br />

will enjoy support in years to come.<br />

Meanwhile, around the world,<br />

powerful demographic, economic and<br />

technological changes are increasing<br />

women’s financial strength and<br />

independence. Investment migration, like<br />

much of the wealth management industry,<br />

has been primarily geared towards a<br />

male clientele; however, attracting and<br />

retaining female customers will be a critical<br />

growth factor for agents and advisors.<br />

A virtual future<br />

If there was one headline that dominated<br />

business publications this past year, it was<br />

the arrival of the metaverse. Metaverse<br />

technology is now a major part of<br />

discussions on the internet, and many<br />

believe that it will – much like the internet<br />

did – redefine how people interact with<br />

their environment and with each other.<br />

In this context, virtual citizenship seems<br />

to be a very real possibility. A properly<br />

functioning metaverse needs several<br />

building blocks to function, and many<br />

believe extended reality will uplift the<br />

user experience in the metaverse through<br />

devices such as AR smart glasses, haptics,<br />

hologram displays, and VR headsets.<br />

Currently, VR is used mostly for gaming.<br />

But in the future of the metaverse it will<br />

be used for almost anything, including<br />

work, education and socialising, which<br />

would reduce the need for physical travel.<br />

You believe the idea is far-fetched? Just<br />

think of Estonia’s successful e-residency<br />

programme. While e-residents are<br />

permitted to open bank accounts, start<br />

companies, sign documents, and pay tax<br />

under Estonian jurisdiction and law, they<br />

gain no rights to live in Estonia, nor do they<br />

accrue any other kind of physical benefit.<br />

Necessity versus nationalism<br />

Geopolitical tensions, volatile markets, and<br />

the threat of climate change: the diverse<br />

and partly overlapping crises are creating<br />

a new desire for security, and thus demand<br />

for investment migration is not expected<br />

to fall. Boston Consulting Group (BCG)<br />

expects migration to exceed 4% of the<br />

global population by 2030, or more than 350<br />

million people, up from 280 million in 2022.<br />

“Rather than moving toward a less globalised,<br />

more nationalistic future where migrants are<br />

viewed as a harbinger of unwelcome change,<br />

we predict that the world will continue to<br />

open to global migrants despite considerable<br />

political polarisation in some countries,”<br />

BCG predict. Why? Because “necessity will<br />

trump nationalism” as cities and countries<br />

compete for talent, residents and investment.<br />

For many sector experts, investment<br />

migration should not be discussed separately<br />

from other forms of legal migration. As<br />

climate change displaces more people,<br />

many argue we need a new mechanism to<br />

manage global labour mobility, the world’s<br />

biggest economic resource, more effectively<br />

and efficiently. There has already been a<br />

shift in public opinion in many countries.<br />

In the UK and the US, the tendency to see<br />

immigration as a problem to be controlled<br />

is in decline, while Canada says higher<br />

immigration is necessary to fuel economic<br />

growth. Properly managed, immigration,<br />

including investment-based forms, is a<br />

resource that can deliver gains for all.<br />

Bruno L’ecuyer is Chief<br />

BIO Executive of the Investment<br />

Migration Council. Bruno leads the<br />

Secretariat and is responsible for all<br />

<strong>IM</strong>C operations. A regular contributor<br />

to international publications and<br />

conferences in Europe, North America,<br />

Caribbean, Middle East and Asia, he<br />

has held positions in London, Paris<br />

and Hong Kong. Bruno was previously<br />

head at a national financial services<br />

association, acting as a bridge<br />

between government, industry and<br />

international policy institutions. He has<br />

extensive expertise and experience<br />

in the management and expansion of<br />

a professional services association.<br />

A member of the Governing Board,<br />

Bruno acts as its Secretary and<br />

chairs the Advisory Committee.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 15

<strong>IM</strong> YEARBOOK<br />

In conversation with Dimitry V. Kochenov and Elena Basheska<br />

“It is all about<br />

European<br />

blood”<br />

The <strong>IM</strong> <strong>Yearbook</strong> sits down with Dimitry V. Kochenov<br />

and Elena Basheska to discuss the European<br />

Commission’s views on investment migration.<br />

“It Is All About European<br />

Blood, Baby!” This is the<br />

attention-grabbing and<br />

thought-provoking title of a<br />

new report you just wrote.<br />

Why did you choose this title?<br />

Dimitry Kochenov (DK): It is just a<br />

reflection of reality: The European<br />

Commission makes a clear distinction<br />

between those who acquire European<br />

‘citizenship by blood’ and all others. When<br />

‘blood’ is there, nothing else – such as<br />

residence, place of birth or income – usually<br />

matters, so the links to Europe are presumed<br />

to be there when one can trace the right<br />

ancestry. This means that the whole concept<br />

of citizenship as promoted by the European<br />

Commission is a blood-based status.<br />

I’ll give you an example of citizenship by<br />

decent, which makes the absurdity of this<br />

quite obvious. So, if someone who has lived<br />

in Australia for many generations, suddenly<br />

finds a Greek ancestor, then this is the ‘blood<br />

link’ that counts and that automatically<br />

enables this person to get a Greek passport<br />

and all the rights in the European Union.<br />

Of course, no due diligence and no other<br />

checks other than those about the blood<br />

connection are carried out. However, make<br />

sure all the line is male. Any grandmother<br />

would ruin the construct and you will<br />

need to spend years and/ or a lot of money<br />

to acquire European documents.<br />

Be it as it may, it’s clear that the only<br />

thing that counts is the blood line. This<br />

explains the title, and there is nothing<br />

exaggerated about it. The blood paradigm<br />

is only broken by naturalisations, which<br />

amount to less than 2% of citizenship<br />

acquisitions around the world.<br />

Over the past eight years,<br />

EU institutions have turned<br />

to investment on numerous<br />

occasions. For those who are<br />

not familiar with the issue,<br />

can you briefly summarise the<br />

EU’s actions and initiatives?<br />

DK: It all started with a debate in the<br />

European Parliament (EP) when Malta<br />

was about to introduce its CBI in 2014. It’s<br />

interesting to note that back then there<br />

was already a programme in Ireland,<br />

which didn’t raise any red flags and was<br />

operating in a similar way to the one<br />

that Malta planned to introduce. And<br />

Cyprus did not interest the EP either:<br />

context did not seem to matter.<br />

In other parts of the world such<br />

as the US and Canada, programmes<br />

were operating, too. But the European<br />

Commission did not think critically of<br />

these programmes. They only started<br />

exercising pressure on Malta as a result<br />

of the commotion in the European<br />

Parliament, which claimed that European<br />

citizenship should not be for sale. So,<br />

one part of the dispute revolves around<br />

the question whether the EU only<br />

wants to accept the blood connection<br />

or whether the EU wants to consider a<br />

more open version on the modalities of<br />

citizenship acquisition. The essence of<br />

EU citizenship is essentially at stake.<br />

“No sane academic voice would argue that the EU has<br />

competence to legislate here, which is why all the documents<br />

that the Commission released so far with the aim of attacking<br />

the investment migration industry are not legislative<br />

proposals, even if they attempt to push the member states,<br />

purely politically, to alter their regulation in a certain way.”<br />

16 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

The other part of the dispute concerns<br />

the EU’s competence. When the European<br />

Parliament released its resolution in<br />

2014, it underlined that the EU doesn’t<br />

have competence on the matter. Viviane<br />

Reding, Vice President of the European<br />

Commission, said the same earlier when<br />

asked about Cyprus, only to change<br />

her mind concerning the scope of EU<br />

law when Malta entered the picture.<br />

Knowing that the EU has no competence,<br />

the Commission pushed Malta, simply<br />

by exercising political pressure, to<br />

introduce a legal residency requirement.<br />

In the years that followed, the<br />

position and the tone of the EU changed<br />

gradually as if the Union law about the<br />

separation of competences between the<br />

member states and the EU had changed,<br />

which was, of course, not the case. So,<br />

in the more recent reports of both the<br />

European Parliament and the European<br />

Commission, we already see that somehow<br />

the EU institutions think they should<br />

have a say in citizenship questions.<br />

Elena Basheska (EB): Then, at the<br />

end of September 2022, the Commission<br />

announced that it would refer Malta<br />

to the Court of Justice of the European<br />

Union (CJEU). The Commission insists<br />

that CBI programmes are a violation<br />

of the principle of ‘sincere cooperation’<br />

enshrined in Article 4(3) of the Treaty of<br />

the EU (TEU) because it confers citizenship<br />

in the absence of a ‘genuine link’.<br />

To date, Malta operates<br />

the only active formal CBI<br />

programme in the EU;<br />

however, you argue that<br />

investment migration is<br />

legally practised by the<br />

absolute majority of the EU’s<br />

member states. Can you<br />

give us a few examples?<br />

DK: Yes, in fact the backdrop to all the<br />

above is that today almost 20 member<br />

states offer residency by investment.<br />

And, of course, we know very well that<br />

accumulating residency is the easiest<br />

path to EU citizenship, if you cannot find<br />

blood. Moreover, most EU countries –<br />

although they do not operate formal CBI<br />

programmes – allow for discretionary<br />

naturalisation on the grounds of ‘special<br />

achievements’, which often includes<br />

economic achievements. The difference<br />

between the two approaches is formal<br />

rather than substantial: CBI programmes<br />

are specifically designed to attract foreign<br />

investors, set clear criteria for applicants<br />

and are marketed by service providers,<br />

while naturalisation on the grounds of<br />

‘special achievements’ is traditionally<br />

less transparent in terms of qualifying<br />

criteria and not marketed by agents.<br />

You claim that the EU lacks<br />

legislative competence in the<br />

area of citizenship while the<br />

principles of international<br />

law also do not back the<br />

Commission’s position. Can<br />

you outline your reasoning?<br />

DK: The ABC of global citizenship law is<br />

that states are free to confer citizenship on<br />

those whom they consider qualified under<br />

the Hague Convention of Nationality and,<br />

unquestionably, under EU law. No sane<br />

academic voice would argue that the EU<br />

has competence to legislate here, which is<br />

why all the documents that the Commission<br />

released so far with the aim of attacking<br />

the investment migration industry are not<br />

legislative proposals, even if they attempt to<br />

push the member states, purely politically,<br />

to alter their regulation in a certain way.<br />

France still decides on who is French and<br />

retains all the rights to do so, just as Malta<br />

decides on who is Maltese and Finland on<br />

who is Finnish. The law is crystal clear.<br />

You argue that the European<br />

Commission is abusing its<br />

power and has concerted<br />

a “large-scale political<br />

campaign to mislead the<br />

public”. What other elements<br />

in the Commission’s narrative<br />

led you to this conclusion?<br />

DK: The Commission is routinely<br />

demonising investment migrants – an<br />

approach, which is questionable at best.<br />

Its core argument in numerous documents<br />

could be boiled to the following: thirdcountry<br />

nationals who invest in member<br />

states may be criminals and, therefore,<br />

investment migration programmes create<br />

security risks; the fact that EU citizenship<br />

provides for cross-border rights increases<br />

such risks further. The Commission seems<br />

to make assumptions about investors largely<br />

on the basis of their status as beneficiaries of<br />

RBI and CBI programmes. The presumption<br />

of innocence, apparently, does not enter<br />

the picture. This is contrary to the EU<br />

Charter and wider EU law, especially given<br />

that discrimination based on the mode<br />

of citizenship acquisition is prohibited.<br />

In fact, the Commission’s attack against<br />

investment migration assumes that it is<br />

acceptable to target groups of EU citizens<br />

and single them out for differentiated<br />

treatment based on the ground on which<br />

nationality of an EU member state and,<br />

thus, EU citizenship had been acquired.<br />

This type of discrimination is squarely<br />

prohibited in EU law. Treating Europeans<br />

differently based on the rule which made<br />

them EU citizens is not what EU law<br />

allows and most national constitutions<br />

would prohibit it too. The crusade against<br />

CBI is an assault on this principle.<br />

What, in your opinion,<br />

are other problematic<br />

aspects in the European<br />

Commission’s approach?<br />

DK: Another critical aspect is the whole<br />

assumption that there needs to be<br />

some sort of link that should underpin<br />

a person’s citizenship when we have<br />

already seen that blood is the only one<br />

that the European Commission and the<br />

European Parliament are interested<br />

in. Furthermore, it goes directly<br />

against the EU’s internal market and<br />

the principle of non-discrimination<br />

on the basis of nationality – the very<br />

core of what the EU is all about.<br />

In fact, concrete member state<br />

nationality is made irrelevant by the<br />

successful operation of EU law. So, for<br />

a child born in Luxembourg with a<br />

Danish passport, who lives his or her<br />

whole life there and has no connection<br />

to Danish society, the principle of nondiscrimination<br />

holds. Luxembourg<br />

will not be legally allowed to mistreat<br />

this child. The CJEU has already<br />

ruled that member states of residence<br />

are not entitled to question lawfully<br />

acquired citizenship of the EU.<br />

What other comments would<br />

you like to make about the<br />

European Commission’s<br />

attitude towards<br />

investment migration?<br />

EB: The Commission makes frequent<br />

references to genuine links and the<br />

principle of sincere cooperation.<br />

These are somewhat misplaced.<br />

The Commission’s argument is that<br />

a lack of genuine link undermines<br />

the status of EU citizenship in<br />

accordance with Art 20 TFEU and<br />

is incompatible with the principle<br />

of sincere cooperation enshrined in<br />

Article 4(3) TEU. This argument of the<br />

European Commission is very weak.<br />

Furthermore, infringement of<br />

the principle of sincere cooperation,<br />

without violation of a more specific<br />

Treaty obligation, cannot be successfully<br />

invoked, and Article 20 TFEU which<br />

is often put by the Commission in the<br />

same context with the principle of<br />

sincere cooperation does not impose<br />

such specific obligation on member<br />

states. It, therefore, remains unclear<br />

how investment programmes infringe<br />

Article 4(3) TEU. It is difficult to imagine<br />

that the principle of sincere cooperation<br />

could be successfully invoked in the<br />

context of investment migration. Article<br />

4(3) TEU concerns the achievement of<br />

EU objectives and genuine compliance<br />

with EU law, none of which seems<br />

to relate to investment migration.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 17

<strong>IM</strong> YEARBOOK<br />

You mention that the<br />

European institutions<br />

used the war in Ukraine<br />

as an opportunity to again<br />

voice its opinion about<br />

investment migration. What<br />

thoughts would you like<br />

to share about this issue?<br />

EB: In March 2022, the EP called on<br />

the member states with residence<br />

by investment schemes to review all<br />

beneficiaries of such residence status<br />

and to revoke those attributed to Russian<br />

high-net-worth individuals and their<br />

families, in particular those linked to<br />

sanctioned individuals and companies.<br />

The Commission equally regarded the<br />

start of the war as a pretext to voice its<br />

opinion on investment migration, calling<br />

for the immediate termination of existing<br />

CBI programmes and stricter checks of<br />

RBI in respect of Russian and Belarusian<br />

citizens who naturalised or obtained<br />

their residence through investment.<br />

However, the Commission did not<br />

make the same recommendation about<br />

Russians and Belarusians who obtained<br />

or are in a process of acquiring their EU<br />

citizenship for ‘special achievements’ or<br />

who claimed citizenship by decent. The<br />

Commission justified such a move with<br />

‘the difficulty to conduct the appropriate<br />

security checks and due diligence in<br />

these particular circumstances and in<br />

view of the gravity of the situation’. And<br />

again, the Commission did not express<br />

similar concerns about Russians and<br />

Belarusians who are acquiring their<br />

EU residence permits on the basis of<br />

grounds other than investment migration.<br />

This suggests that the Commission is<br />

fighting its own war against investment<br />

migration in this context rather than<br />

being genuinely concerned about security<br />

risks. Such policy is dangerous, especially<br />

if we know that nowadays Russian<br />

elites in the country are expected, if not<br />

forced, to support the war in Ukraine.<br />

Moreover, stripping Russians and<br />

Belarusians of their citizenship acquired<br />

through investment may be problematic<br />

even if that is conducted for justified<br />

security reasons. EU member states have<br />

conditions for withdrawal of citizenship,<br />

including for security reasons and<br />

such rules are equally applicable to<br />

naturalised citizens of all nationalities<br />

and notwithstanding the naturalisation<br />

grounds. Applying such rules to Russians<br />

and Belarussians specifically, as seemingly<br />

suggested by the European Commission, is<br />

arbitrary and discriminatory. Even<br />

more so, according to experts in the<br />

field, the deprivation of nationality of<br />

citizens on national security grounds<br />

is presumptively arbitrary and<br />

exceptions to that are very limited.<br />

In the report, you talk about<br />

the “failure of structures”<br />

and “abusive misuse of EU<br />

law”. What aspects of this<br />

development worry you<br />

the most and what change<br />

would you like to see?<br />

DK: What worries me the most is that EU<br />

citizenship, which was construed first to<br />

liberate us from the bonds of nationalism,<br />

is now being hijacked by some 19 th -century<br />

blood nationalists who happened to<br />

hold the upper hand in the European<br />

Commission. I can’t believe that the<br />

Commission’s Legal Service, which is the<br />

in-house legal counsel to the Commission,<br />

supported the decision to refer the matter<br />

to the CJEU. To me all this is a clear sign<br />

that basic checks and balances within the<br />

Commission are absolutely hijacked by<br />

politicians who have zero interest in citizens’<br />

rights and in the preservation of the main<br />

achievements of the European Union.<br />

What line of argument do you<br />

think the CJEU will adopt?<br />

DK: The CJEU is in a very difficult<br />

situation. Obviously, no one is interested<br />

in the European Commission losing its<br />

face. However, should the Commission<br />

win this case, it would destroy the main<br />

achievements of the EU. The court will<br />

have to be extremely careful in trying<br />

to preserve the internal market without<br />

being too harsh on the Commission.<br />

What I can predict is that the CJEU<br />

will focus on the problems, which the<br />

Commission tries to connect with<br />

investment migration, which would be<br />

money laundering, terrorist financing<br />

and tax evasion. Ironically, these are the<br />

fields in which the Commission already<br />

has competence to act. If the Commission<br />

thinks there is money laundering going<br />

on, it has the competence to legislate and<br />

should work with the member states to<br />

make sure that legislation is operational on<br />

the ground. So, then it would not be about<br />

the institution of citizenship but how to<br />

deal with the negative consequences of a<br />

particular way of acquiring citizenship.<br />

Do you think the case and,<br />

ultimately the CJEU’s decision,<br />

will have repercussions on the<br />

countries outside of the EU?<br />

EB: I think it depends on the outcome. If<br />

the CJEU disapproves the Commission’s<br />

arguments, it will probably stimulate<br />

other member states within the EU and<br />

even beyond to launch formal investment<br />

migration programmes. So, the court case<br />

will have the opposite effect of what the<br />

Commission wanted to achieve. And again,<br />

I don’t see how the CJEU can support the<br />

Commission’s argument that CBIs violate<br />

the principle of ‘sincere cooperation’ due<br />

to the absence of the ‘genuine link’.<br />

DK: We also need to keep in mind that the<br />

EU is not the top market for citizenship by<br />

investment, and we know that what the<br />

EU thinks about it has a very limited effect<br />

on what happens outside of the EU. And<br />

if we are honest, declaring a war against<br />

investment migration when you are not<br />

actually the market leader in investment<br />

migration is a very problematic start to<br />

begin with. But even if the CJEU will not<br />

uphold the current law, it will probably<br />

not destroy investment migration at<br />

all. Investment migration will simply<br />

move to other regions of the world.<br />

Professor Dimitry V.<br />

BIOS Kochenov leads the<br />

Rule of Law Workgroup at the Central<br />

European University (CEU) Democracy<br />

Institute and teaches at the Department<br />

of Legal Studies. His research focuses<br />

on the principles of law in the global<br />

context, with a special emphasis<br />

on the Rule of Law, citizenship, and<br />

the enforcement of EU values.<br />

Dr Elena Basheska is a Post-doctoral<br />

Research Fellow at CEU Democracy<br />

Institute. She combines this position<br />

with legal research and advisory<br />

practice in the United Kingdom.<br />

18 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

The <strong>IM</strong> Long Read<br />

A Fragile<br />

World Economy<br />

and New<br />

Opportunities<br />

for Investment<br />

Migration<br />

Andres Solimano, <strong>IM</strong>C Chair as well as founder and<br />

chair of the International Centre for Globalisation<br />

and Development, analyses the current economic<br />

climate and its effects on investment migration.<br />

The world economy is uncertain and<br />

experiencing a deterioration that is<br />

expected to continue in <strong>2023</strong> only<br />

to recover in 2024. Currently, the global<br />

economy is effected by an unpleasant<br />

combination of high inflation, higher<br />

interest rates and serious geopolitical risks.<br />

Moreover, there is the possibility of a new<br />

debt crisis in low-income countries and<br />

highly indebted emerging economies.<br />

In the last three years, the global<br />

economy has experienced the effects of the<br />

Covid-19 pandemic followed by a global<br />

recession. World GDP contracted in 2020<br />

due to forced lockdowns, which created a<br />

supply side shock as people could not go<br />

to work and supply chains broke down.<br />

While there was a rapid turnaround with<br />

a strong recovery in 2021, more structural<br />

challenges such as climate change,<br />

entrenched inequality, the replacement of<br />

fossil oil energy matrix to support green<br />

growth, and environmental fragility<br />

remained. Global institutions such as the<br />

International Monetary Fund, the World<br />

Bank and others still expect growth in 2022<br />

and <strong>2023</strong> for the world, although they have<br />

adjusted their projections downwards.<br />

Nonetheless, this uncertain economic<br />

environment may have positive effects on<br />

investment migration flows as the insurance<br />

value of programmes is rising. Investors will<br />

make an extra effort to find more secure<br />

locations where to invest their money and<br />

secure a better environment. Countries<br />

offering more stability, predictability<br />

and good investment opportunities<br />

will benefit from this development.<br />

The shift to high inflation<br />

After decades of 2% to 3% inflation per<br />

year in industrial economies, since the<br />

Covid-19 pandemic, and exacerbated<br />

by the war against Ukraine, inflation<br />

has accelerated and reached annualised<br />

levels of around 8% in 2022.<br />

Large economies such as the US, UK,<br />

Germany and Spain are experiencing<br />

annual inflation above 10%. Some countries,<br />

such as the Baltic ones, have an inflation<br />

rate hovering around 16% to 20%.<br />

Several demand and supply factors have<br />

contributed to the acceleration of inflation<br />

in the world economy since 2020-21. One<br />

reason is the accumulation of household<br />

liquidity due to a lack of consumption<br />

opportunities during the lockdown period.<br />

When mobility restrictions were lifted,<br />

this excess liquidity went directly to the<br />

market, pushed up prices in the process.<br />

Tied to this are also the fiscal transfers and<br />

subsidies granted by national governments to<br />

households in the Covid-crisis era. These have<br />

contributed to increase aggregate demand,<br />

leading to fiscal-led inflationary pressures.<br />

Moreover, cost-push effects associated<br />

with supply constraints due to strains<br />

on maritime transport facilities and the<br />

subsequent rise in freight rates along with<br />

other disruptions in supply chains increased<br />

prices, while the rise in food and energy prices,<br />

which started in 2020 but exacerbated after<br />

Russian’s invasion of Ukraine in February<br />

of 2022, added to “headline inflation”.<br />

A concern is that these inflationary<br />

pressures may become entrenched.<br />

Inflation dynamics over the next two<br />

20 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

years will also depend on second-round<br />

effects such as the response of wages<br />

to previous price hikes as well as price<br />

adjustment policies by governments.<br />

A key player in the future evolution<br />

of inflation are central banks. Nowadays,<br />

around the world, monetary authorities<br />

are tightening monetary policy through<br />

higher interest rates to reduce inflation.<br />

The sources of inflationary pressures<br />

vary across economies. While there is<br />

some consensus that inflation in the US<br />

is largely associated with an ‘overheated’<br />

economy’ due to exaggerated levels of<br />

demand in both the goods and the labour<br />

market relative to the potential supply,<br />

it is an open question whether this is an<br />

accurate description of the economic reality<br />

of America. Low unemployment is used<br />

as an argument to back the hypothesis<br />

of “excess demand in America”.<br />

For Europe, the diagnosis is different,<br />

and it focuses on the very sharp increases<br />

in the price of gas and oil, imported from<br />

abroad, mostly Russia. Thus, a supplyshock<br />

story describes the inflationary<br />

situation in Europe better while a demandside<br />

story is more plausible for America.<br />

Among emerging economies, inflation is<br />

closely related to the energy price and food<br />

price shocks coming from international<br />

markets, so we are dealing with a mix of<br />

supply-shock and imported inflation.<br />

An impending recession?<br />

As mentioned, the <strong>IM</strong>F, the World Bank,<br />

the OECD, and the European Central<br />

Bank have all adjusted downwards<br />

their GDP growth forecasts for 2022 and<br />

<strong>2023</strong>. In turn, recessions are anticipated<br />

in <strong>2023</strong> for Germany, Italy and Russia,<br />

while the two major powerhouse<br />

of the world economy – the US and<br />

China – will experience slowdowns.<br />

The causes of the global slowdown<br />

are related to the effects of higher interest<br />

rates to fight inflation, compounded by<br />

supply energy and food price shocks<br />

and the effects of increased uncertainty<br />

affecting private investment and<br />

consumption, two main drivers of aggregate<br />

spending and economic activity.<br />

In addition, world trade has<br />

declined due to supply disruptions<br />

and new geopolitical realities, shaped<br />

by embargoes and a shift to ‘secure<br />

sources’ of supply – a major change when<br />

compared to the previous rule of “cost<br />

minimisation” that governed globalisation<br />

in the last three decades. All these<br />

factors are affecting global growth.<br />

The risk of a debt crisis<br />

During the Covid-19 crisis of 2020-21 many<br />

governments were forced to increase<br />

their levels of foreign borrowing. They<br />

needed financing to fund Covid-related<br />

support programmes set up to protect<br />

the living standards of their people who<br />

could not go to work and generate the<br />

necessary income to sustain themselves.<br />

Importantly, this borrowing was<br />

contracted, mainly in US dollars and<br />

took place at generally low interest rates.<br />

However, during 2022, macroeconomic<br />

and financial conditions have<br />

changed dramatically. A sharp rise<br />

in interest rates, a very strong dollar<br />

and portfolio capital outflows from<br />

developing nations at the periphery to<br />

advanced economies at the centre may<br />

eventually trigger a new debt crisis.<br />

For context, in the early 1980s, a very<br />

similar combination of economic factors<br />

affected the world economy following<br />

inflation stabilisation policies in the US<br />

pursued by the Federal Reserve: interest<br />

rates increased, the dollar appreciated<br />

against main world currencies and<br />

currencies of the periphery. In addition,<br />

capital flight was the norm with money<br />

flowing from economies of the global<br />

south to the US and other advanced<br />

economies. The result was the onset of a<br />

debt crisis in several large economies of<br />

Latin America, Turkey and the Philippines<br />

including forced debt rescheduling, debt<br />

cancelations and debt defaults. These<br />

episodes were also accompanied by<br />

currency crashes, recessions, dwindling<br />

investment and portfolio capital outflows.<br />

We have seen several debt crises in<br />

the last three to four decades: the East<br />

Asian crisis in 1997-98, the convertibility<br />

crisis in Argentina in 2000-01, debt<br />

stresses in Brazil in the late 1990s and<br />

the global financial crisis of 2008-09.<br />

Yet, history does not need to repeat<br />

itself. After four decades of repeated debt<br />

crises around the world there are better<br />

mechanisms to anticipate them and cope<br />

with them if they take place. Exchange<br />

rates regimes in developing countries are<br />

more flexible now than then, international<br />

reserves in the hands of central banks are<br />

higher and fiscal policy has become more<br />

ordered and predictable. Moreover, today,<br />

the <strong>IM</strong>F has in place a set of new financing<br />

instruments, several of quick disbursement,<br />

that could help avert the repeat of debt<br />

crises. However, there is little space for<br />

complacency as financial conditions are<br />

fragile even in large mature economies. Just<br />

think of the sharp decline in the value of the<br />

pound and bond prices following the Truss-<br />

Kwarteng regressive tax cut and spending<br />

increase package of late September in the<br />

UK, a policy mix that was later reversed.<br />

Investment migration<br />

An important consequence of the current<br />

economic difficulties is that the global<br />

economy is becoming more fragmented,<br />

risky, and unpredictable. How can these<br />

developments affect investment migration?<br />

Two main channels are relevant: First, in a<br />

world of heightened economic, geopolitical<br />

and security risks, an increase in the<br />

demand for investment migration is likely<br />

to follow. Option theory predicts that a<br />

vehicle, programme, or policy – think of<br />

investment migration – that enhances<br />

opportunities in risky environments carry<br />

a positive price, or insurance value.<br />

Second, governments in tough times<br />

are in increased need of foreign capital,<br />

talent, entrepreneurial capacities, and<br />

cash, and therefore will view investment<br />

migration more favourably. This already<br />

happened after the 2008-09 global financial<br />

crisis and is bound to happen again in the<br />

current circumstances. Even though, the<br />

golden years for investment migration of<br />

the 2010s might be largely over for various<br />

reasons, the economic need of countries for<br />

foreign financing, along with a personal/<br />

household demand for geographic risk<br />

diversification, remains. Therefore, it is<br />

very likely that investment migration will<br />

continue to thrive for quite a while.<br />

Dr Andrés Solimano holds a<br />

BIO Ph.D. in Economics from the<br />

Massachusetts Institute of Technology<br />

(MIT). He is the chairperson of the<br />

Investment Migration Council, as<br />

well as founder and chair of the<br />

International Centre for Globalisation<br />

and Development (CIGLOB). Previously,<br />

he served as country director at<br />

the World Bank, executive director<br />

at the Inter‐American Development<br />

Bank and director of the project on<br />

International Mobility of Talent with<br />

the United Nations University ‐ World<br />

Institute of Economic Research.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 21

<strong>IM</strong> YEARBOOK<br />

What’s ahead for Citizenship by Investment?<br />

The idea of citizenship by investment has long provoked discussion<br />

and debate amongst critics and supporters. The <strong>IM</strong> <strong>Yearbook</strong> has<br />

invited Eric Major, CEO of Latitude and Patricia Casaburi, Managing<br />

Director of Global Citizen Solutions, to share their thoughts<br />

and opinions on the future of citizenship by investment.<br />

Pressure from the EU<br />

and the US is growing<br />

to end citizenship by<br />

investment (CBI) pathways<br />

in Europe and beyond.<br />

Are we seeing the end of<br />

citizenship by investment?<br />

Eric Major: Certainly not! Citizenship is a<br />

sovereign matter, which no supranational<br />

body can fully dismiss or carry off. The<br />

question is whether they can influence a<br />

country to cease it, to which the answer<br />

is Yes. Some nations will be influenced,<br />

possibly Malta and Montenegro, and<br />

others will not be. The Caribbean<br />

nations, I suspect fall in this category.<br />

However, in the end, CBI will be around<br />

for as long as independent states exist.<br />

Patricia Casaburi: I think we will see<br />

an evolution rather than the end of<br />

citizenship by investment. Most countries<br />

have a few different paths to temporary<br />

or permanent relocation, and we are<br />

seeing governments being creative in the<br />

development of visas for various market<br />

demands, hence the popularity of the<br />

digital nomad visas in EU and beyond.<br />

Investment migration<br />

professionals have adopted<br />

important self-regulatory<br />

mechanisms, while<br />

programmes insist that<br />

they apply the highest<br />

levels of due diligence. In<br />

your opinion, why have<br />

these initiatives failed to<br />

convince critics so far?<br />

Patricia Casaburi: Critics of CBI and<br />

RBI who are part of the EU or other<br />

governments would likely want to see<br />

more harmonisation on the due diligence<br />

checks, more cross-border reports and<br />

background checks on main applicants<br />

and family members regarding sources<br />

of wealth, corruption, and tax evasion.<br />

Of course, these are in place, but a lack of<br />

standardisation and transparency exists.<br />

Eric Major: The truthful answer is that our<br />

industry has experienced very damaging<br />

blemishes, even over the last three years,<br />

which brings fair doubt to the veracity<br />

of the industry’s claim to its high level of<br />

due diligence: Cyprus, Vanuatu and even<br />

Portugal quickly come to mind, let alone the<br />

early days of the Caribbean CBIs. It’s harder<br />

to build a reputation than it is to destroy it.<br />

There are concerns that if<br />

CIPs are phased out, the<br />

economies of some Caribbean<br />

countries will collapse. What<br />

comments would you like<br />

to make about this issue?<br />

Patricia Casaburi: Some countries in the<br />

Caribbean, like St Lucia, do not rely solely<br />

on CBI and have a diverse tourism industry.<br />

The population is often well-educated;<br />

however, the islands suffer from a lack of job<br />

opportunities and of course, are often hit by<br />

hurricanes. So, unless these governments<br />

propose ways of diversifying their economy<br />

with agriculture, for example, the downfall<br />

of CIPs would impact them hugely.<br />

Eric Major: As I already mentioned, I do<br />

not believe the Caribbean CIPs will be<br />

phased out. Yes, they could potentially<br />

loose visa-free travel privileges in the<br />

Schengen area, but I am 100% convinced<br />

they will continue to exist. Last I checked,<br />

there were more millionaires in the US<br />

than in any other country in the world,<br />

and Americans don’t apply for Caribbean<br />

CIPs because of Schengen access. They<br />

buy it because it is a safe destination<br />

that provides them a great lifestyle.<br />

In your opinion, how should<br />

CIP countries and the industry<br />

best respond to the situation?<br />

Eric Major: Let time show us how things<br />

will play out. At this point in time, there<br />

is nothing the industry can do to reverse<br />

the decisions that have already been made.<br />

However, we should encourage the CIUs<br />

to have a 10%-15% refusal rate. Too low a<br />

refusal rate isn’t credible in my mind.<br />

Patricia Casaburi: Four things come to<br />

my mind: Implementing the sought-after<br />

standardization of due diligence, improve<br />

communication between member states and<br />

third countries, continuous monitoring but<br />

also, investments that fit a bigger agenda.<br />

For example, investments in climate change<br />

and advancing energy targets, solutions that<br />

ensure the affordability of rent for locals,<br />

the creation of jobs, social programmes, and<br />

productive investments in the economy.<br />

What are your expectations<br />

for citizenship and residence<br />

by investment for the next<br />

three to five years?<br />

Patricia Casaburi: I predict that there<br />

will likely be more regulation, the<br />

introduction of an EU regulatory body<br />

that oversees programmes at the country<br />

level, productive investment, as well as<br />

full cross-border transparency. We may<br />

see the rise of programmes that cater to<br />

other parts of the world, like the Asian<br />

as well as the South and Latin American<br />

markets. Motivation is also ever evolving<br />

and geo-political events matter.<br />

Eric Major: Lots of changes<br />

coming, and I am still bullish!<br />

BIOS<br />

Patricia Casaburi is the<br />

Managing Director of<br />

Global Citizen Solutions. She previously<br />

worked for The Rezidor Hotel Group<br />

as a Corporate Account Director.<br />

Eric Major is one of the pioneers of<br />

the investment migration industry.<br />

A former CEO of Henley & Partners, he<br />

is now CEO and Chairman of Latitude<br />

– Residency & Citizenship Solutions.<br />

22 - Investment Migration <strong>Yearbook</strong> 2O23

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<strong>IM</strong> YEARBOOK<br />

From refugee past to EB-5 professional:<br />

One man’s perspective on<br />


At a time when Iran is rocked by the biggest wave of unrest and antiregime<br />

demonstrations it has seen in years, Abteen Vaziri recalls how he had<br />

fled the country more than three decades ago. Vaziri, who is today a key<br />

figure in the US EB-5 industry, says due to his refugee past he has a unique<br />

perspective on migration that many of his fellow practitioners lack.<br />

One evening in 1989, Abteen Vaziri’s mother<br />

told him that the family would flee Iran.<br />

He was nine years old and in the<br />

middle of school exams. He had studied<br />

a lot and didn’t want to leave his home<br />

in Tehran to not miss the test. But he<br />

didn’t have a choice, although he didn’t<br />

understand what was happening: “It was<br />

odd that while my parents feared for their<br />

lives, I worried about school,” he recalls.<br />

Today, Vaziri sits in an office in New<br />

York City. He is the Managing Director<br />

of Brevet Capital, an investment firm<br />

which has about $2billion of assets under<br />

management. In addition to overseeing<br />

the business operation, he manages one<br />

of Brevet’s five funds: the Brevet Capital<br />

Immigration Fund, an EB-5 compliant fund.<br />

Vaziri’s family first attempted to leave<br />

Iran in 1979 when the Islamic Revolution<br />

shook the world. The revolution turned<br />

Iranian society upside down and ended with<br />

the establishment of the world’s first Islamic<br />

state. Mohammad Reza Shah Pahlavi, the<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 25

<strong>IM</strong> YEARBOOK<br />

leader of Iran since 1941, left the country<br />

in January 1979 and Ayatollah Ruhollah<br />

Khomeini, a previously exiled opponent of<br />

the Shah, returned and took control of Iran.<br />

Prior to the revolution, Vaziri’s father<br />

was an officer in the Iranian air force.<br />

Expecting a brutal crackdown on opponents<br />

and weighing their options, his parents<br />

– like many others – wanted to get out<br />

of Iran. “We sold all our assets and paid<br />

$15,000 to a group of smugglers who were<br />

supposed to take us by horse back and<br />

camel to the border and into Pakistan.<br />

My aunt, my uncle and their son went<br />

first, but my aunt got malaria in Pakistan<br />

and died. My parents were so distraught<br />

and didn’t want to leave Iran anymore.<br />

So, the smugglers pocketed our money<br />

and passports while we stayed behind.”<br />

After the regime change, Vaziri’s father<br />

was court-martialed and sentenced to<br />

death. However, while he was in prison,<br />

Iraqi forces launched a full-scale invasion<br />

of Iran, beginning the Iran-Iraq War<br />

in September 1980. Suddenly, military<br />

personnel were needed. “My dad was given<br />

a pardon but in return he had to join the<br />

air force again. He was given back his job in<br />

military logistics, moving and coordinating<br />

equipment, supplies and troops.”<br />

In 1989, when the war ended, Vaziri’s<br />

father finally managed to obtain a fake<br />

passport. As a military officer, he wasn’t<br />

allowed to have a real passport. “He then<br />

escaped to Austria and later travelled<br />

to Germany. My mother, my sister and I<br />

also left Iran, but we first went to France.<br />

We then joined my father in Aachen,<br />

Germany, where we were accepted as<br />

political refugees,” Vaziri explained.<br />

Vaziri arrived in Germany in November<br />

1989, which at that time was experiencing<br />

its own watershed moment. “I remember<br />

that it was all over the news that the<br />

Berlin Wall had come down. Until today,<br />

every time I see pictures of the fall of<br />

the Berlin Wall, I equate that in my own<br />

mind to our own liberation from Iran.”<br />

However, at first, things didn’t get<br />

much easier for Vaziri. “I did not speak<br />

the language, and everything was new<br />

and different,” he said. Just when he had<br />

started to settle in, another move was on<br />

the cards: In 1991, the family relocated<br />

to the US after they had been granted<br />

a green card as political refugees.<br />

They lived in Los Angeles for the first<br />

four years, then they moved to Texas where<br />

Vaziri completed high school. University<br />

followed and after first obtaining a degree<br />

in computer sciences, he also obtained<br />

a Master of Business Administration in<br />

Finance and later a law degree in New York.<br />

Initially, Vaziri worked in the financial<br />

industry, but as often in life, a coincidence<br />

led him to his current career. He went for<br />

a job interview for a position as a portfolio<br />

manager, but during the interview, he<br />

was informed that he won’t be managing<br />

a portfolio of assets, but a portfolio of<br />

investors. “Back then, I was familiar with the<br />

programme because one of my cousin’s used<br />

the Canadian programme to emigrate from<br />

Iran to Canada. I got the job immediately.”<br />

Vaziri worked for the North Texas EB-5<br />

Regional Centre (NTRC) for just under<br />

four years. During this time, he managed<br />

the largest-ever EB-5 project in the state of<br />

Texas. He then got recruited by Greystone<br />

EB5 Holdings, a very large institutional<br />

lender, to help build their EB-5 practice, and<br />

in 2018, he joined Brevet to set up their EB-5<br />

practice, a position he holds until today.<br />

Although refugees leave in a situation<br />

of emergency with much less planning<br />

than EB-5 investors, he says he has a better<br />

understanding of his clients’ situation than<br />

many of his peers in the EB-5 industry.<br />

“It’s helpful to not only know the legal and<br />

the business side of the industry, but also<br />

to be able to relate to the human story.<br />

There are a lot of emotions involved when<br />

people are moving to another country.”<br />

“We sold all our assets and paid $15,000 to a group<br />

of smugglers who were supposed to take us by horse<br />

back and camel to the border and into Pakistan.<br />

26 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

be beneficial to the entire EB-5 industry<br />

and could be a “huge support in the next<br />

battle with Congress”. Vaziri concludes:<br />

“In our industry, we often get so bogged<br />

down with regulations, with fund raising<br />

and yes, also, with competing. We easily<br />

forget about the end users, but without the<br />

investors our industry wouldn’t exist.”<br />

Vaziri also sits on the board of<br />

directors of IIUSA, the trade association<br />

for the EB-5 regional centre programme.<br />

“When I ran for the board of directors at<br />

IIUSA in 2018, there wasn’t a single person<br />

on the board who was an immigrant,”<br />

he says. Today, the situation is different<br />

as he has been joined by another board<br />

member originally from Turkey.<br />

But Vaziri does not want to stop<br />

there. He wants more change and has<br />

fresh ideas: “In the US, there are about<br />

70.000 to 80.000 EB-5 investors, and<br />

they don’t really have a voice. While<br />

there are several investor associations,<br />

they are very fragmented. I think<br />

there’s a need for a membership-based<br />

investor organisation,” he explains.<br />

When the EB-5 progamme lapsed<br />

in 2021, there was a huge vacuum of<br />

information and a lot of uncertainty among<br />

investors. “But investors need a reliable<br />

source of information and an independent<br />

body they can turn to,” he says.<br />

Vaziri envisions a membershipbased<br />

investor organisation would also<br />

Abteen Vaziri currently<br />

BIO serves as a Managing<br />

Director at Brevet Capital<br />

Management, a position he has held<br />

since June 2018. He previously served<br />

as a director at Greystone & Co,<br />

an institutional real estate lender,<br />

and helped build Greystone’s EB-5<br />

real estate financing platform. He<br />

is also a board member of IIUSA.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 27

<strong>IM</strong> YEARBOOK<br />

2 22<br />


The <strong>IM</strong> <strong>Yearbook</strong> travels with Fragomen around the<br />

world to update you on policy changes and developments<br />

in the most important investment migration markets.<br />

Based in more than 50 offices worldwide, Fragomen’s<br />

team is well placed to share some key observations.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 29

<strong>IM</strong> YEARBOOK<br />

United States<br />

The EB-5 Immigrant Investor Visa Regional Centre<br />

Programme has returned, and for the first time in its<br />

history it has seen some form of longer-term authorisation. In<br />

March 2022, the US government re-authorised the popular<br />

programme until 2027, which allows prospective foreign<br />

investors to invest capital into a government-approved<br />

regional centre in order to receive permanent residency<br />

for themselves and any qualifying family members.<br />

The Regional Centre Programme has been increasingly<br />

popular since its inception in 1992; however, it had historically<br />

been authorised by Congress in short-term increments. The<br />

programme lapsed in June 2021 and was not immediately<br />

renewed by Congress. The entire programme was put on hold,<br />

bar investors who had already received their initial green card.<br />

The reauthorisation is important, especially for<br />

prospective investors in the APAC region, including<br />

China and India, who can take advantage of quicker<br />

green card processing times in comparison to other<br />

employment-based permanent residency options.<br />

Further, new investors are also able to invest in the<br />

programme, at a lower investment amount than the<br />

previous minimum, and with greater protections and<br />

benefits afforded to them. In addition, the reauthorisation<br />

of the programme enhances benefits for foreign investors;<br />

in certain cases, permitting investors and their family<br />

members to receive unrestricted work authorisation and<br />

international travel permission while waiting for their<br />

permanent residency to be granted, having a major positive<br />

practical benefit for investors and their families.<br />

While the Regional Centre Programme was on hold, many<br />

investors resorted to pursuing direct investment opportunities.<br />

But we now see a renewed trend toward passive investment<br />

through the quicker and cheaper Regional Centre option<br />

building up, which will likely yield a surge in investment<br />

migration into the US over the coming months and years.<br />

Investors from the APAC region interested in the<br />

US continue to take advantage of Caribbean citizenship<br />

programmes due to their quick and relatively low-cost options,<br />

with a focus on visa-free travel and access to the US and Canada.<br />

The most popular programmes in the Caribbean include<br />

Antigua, Dominica, St. Kitts and Nevis, Grenada, and St. Lucia.<br />

Meanwhile, investors from the US remain interested in many of<br />

the European options, with particular emphasis on Portugal’s<br />

Golden Visa Programme. Canada is also an attractive option.<br />

Future election will likely have a major role to play<br />

in shaping the landscape of investment migration – the<br />

popularity of residency and citizenship is often a result of<br />

the political landscape of the country. However, given the<br />

reauthorisation of the EB-5 Regional Centre Programme<br />

as well as continued interest in other investment options,<br />

including the E-Visa Treaty Investor and Treaty Trader<br />

non-immigrant visa options, the interest for investment<br />

migration in the United States has the foundation to<br />

continue to attract foreign investors in the coming years.<br />

EMEA<br />

In Europe, we are seeing a global big-picture trend of<br />

movement away from purely passive investment migration<br />

routes, towards residence programmes which require a<br />

tangible economic benefit to be generated by applicants.<br />

The conflict in Russia has also seen every jurisdiction in<br />

Europe exclude Russian and Belarussian applicants from their<br />

investment migration routes. The Turkish CBI programme is<br />

the outlier, continuing to accept Russian applicants, and seeing<br />

very large numbers of applicants since the start of the year.<br />

In the UK, the Tier 1 Investor visa closed to new<br />

applicants in February 2022. It seems certain that we will<br />

not see a like-for-like replacement for the investor visa.<br />

The first half of 2022 also saw the UK’s Global Talent visa<br />

for tech leaders receive its highest number of applicants and<br />

successful endorsements, illustrating the continued growth<br />

of the UK’s tech sector. The UK is likely to continue to heavily<br />

market its global talent visa to maintain the status of its tech<br />

sector, but there remains a critical need for a sector agnostic<br />

investment migration route to replace the existing restrictive<br />

innovator route, which we hope to see in the coming months.<br />

Meanwhile, Portugal’s Golden Visa saw some important<br />

changes in January 2022, prohibiting qualifying investments<br />

Given the<br />

European<br />

Commission’s<br />

approach, there<br />

is an opportunity<br />

now for EU<br />

countries to look<br />

at how they can<br />

use investment<br />

migration as part<br />

of their foreign<br />

direct investment<br />

policy and for<br />

this narrative to<br />

be re-aligned.<br />

30 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

APAC<br />

in property in the most popular areas – such as Lisbon, Porto<br />

and many coastal towns – with the Portuguese government<br />

aiming to drive investment in less affluent inland regions.<br />

While property investment remains an attractive option for<br />

many clients, we are increasingly seeing investors consider the<br />

other options under the programme – such as an investment<br />

in a Portuguese company or an approved investment fund.<br />

Elsewhere, the Montenegro citizenship by investment pathway,<br />

which has attracted a significant number of applicants given the<br />

country’s proposed accession to the EU by 2025, will close at the<br />

end of 2022. The programme was initially scheduled to terminate<br />

at the end of 2021, but the government made a last-minute U-turn.<br />

EU countries face a challenge in terms of the European<br />

Commission’s approach to citizenship and residence by<br />

investment pathways. In April 2022, the Commission issued<br />

a recommendation urging EU member states to repeal CBI<br />

programmes, with a specific reasoned opinion against Malta’s<br />

programme. In March 2022, Malta suspended its CBI programme<br />

for Russian and Belarusian nationals but continues to operate<br />

the programme for all other nationals and has not announced a<br />

formal suspension. In September 2022, the matter was referred to<br />

the EU Court of Justice over what Brussels says violates EU law.<br />

Both Australia and Singapore continue to attract large<br />

number of high-net-worth individuals, mainly from the<br />

rest of Asia. New World Wealth estimates that in 2022, the net<br />

inflow is expected to be 3,500 millionaires to Australia and<br />

approximately 2,800 individuals are expected in Singapore. The<br />

consistently high inflows are partly due to Australia’s pointsbased<br />

immigration system, which favours wealthy individuals,<br />

business owners and professionals. Notably, Singapore is<br />

emerging as Asia’s top wealth management centre, which should<br />

assist in attracting many more affluent individuals to relocate<br />

there in future through the Global Investor Programme (GIP).<br />

Meanwhile, China’s extremely strict Covid-19 travel<br />

restrictions are creating a new economic sphere tethered to<br />

the political landscape. High-net-worth individuals tired of<br />

lockdowns are leaving the country. These individuals, however,<br />

are generally seeking to move to countries that have remained<br />

on good terms with China, such as Singapore and Ireland, rather<br />

than traditionally popular destinations such as the US and<br />

Canada. The most popular programme Indian and Pakistani<br />

investors and entrepreneurs are enquiring about is the Portugal<br />

Golden Residence Permit Programme, followed by Canada.<br />

Throughout the past two to three years, we have seen<br />

a sharp increase in emigration from Hong Kong Chinese,<br />

mainly to traditional countries like Australia, Canada,<br />

the US and the UK. Due to the relaxation of the UK<br />

government’s policy on British National Overseas (BNO)<br />

passport holders, in terms of residency as well as a path to<br />

citizenship, we have seen a spike of BNO passport holders<br />

settling in the UK. It is estimated that more than three<br />

million Hong Kong Chinese are eligible for BNO passports.<br />

Restrictive health policies in Asia are waning, and most<br />

countries will have a new focus on economic sustainability<br />

and healthcare equality. The economic downturn and<br />

talent competition will also likely play a part in the way<br />

migration policy evolves in the next 12 to 19 months.<br />

There is often an unfair perception that investment<br />

migration sits outside the standard framework of investment<br />

and immigration policy. Given the European Commission’s<br />

approach, there is an opportunity now for EU countries to look<br />

at how they can use investment migration as part of their foreign<br />

direct investment policy and for this narrative to be re-aligned.<br />

Meanwhile, we are seeing increased prevalence of digital nomad<br />

visa options in Europe driven by the change in working patterns<br />

which emerged during the pandemic – with Italy and Spain the<br />

latest countries confirming they plan to introduce such a route.<br />

African countries also want to jump on the bandwagon of<br />

remote working and start-up visas. On the back of this trend,<br />

the investment migration landscape will grow but mainly in<br />

countries like Mauritius and South Africa. Other countries thus<br />

far fail to succeed due to poor marketing and delivery, and, lastly,<br />

due to a lack of appetite for these programmes in the region.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 31

<strong>IM</strong> YEARBOOK<br />

Must Peter Pay for Putin?<br />

A Case of Nationality Based<br />

Discrimination and Big Stick Diplomacy<br />

Geoffrey DuBoulay<br />

and Keith Issac of<br />

Polaris Citizenship<br />

& Investment<br />

Consultancy<br />

Services argue<br />

against a blanket<br />

ban of Russian and<br />

Belarusian nationals<br />

following Russia’s<br />

invasion of Ukraine.<br />

While citizenship by investment (CBI)<br />

started some 38 years ago in St.<br />

Kitts & Nevis, this industry first landed on<br />

the shores of Saint Lucia in 2015 through<br />

the Citizenship by Investment Act (No.14<br />

of 2015). As mandated by the Act, the<br />

CBI programme is administered by the<br />

Citizenship by Investment Unit (CIP Unit).<br />

Since officially accepting applicants in<br />

January 2016, St. Lucia has welcomed over<br />

one thousand persons as citizens via its CBI<br />

programme (CIP) and generated more than<br />

60 million Eastern Caribbean Dollars.<br />

Blanketban imposed<br />

Despite the substantial revenue generated,<br />

CBI remains a topic of contention both<br />

locally and on the global stage. The<br />

2022 invasion of Ukraine by Russia has<br />

placed a spotlight on CBI with most<br />

CIPs banning Russian and Belarusian<br />

nationals outright. Uniquely, while most<br />

islands began the suspension of the<br />

programme to Russians from as early<br />

as March 4th 2022, St. Lucia originally<br />

opted to take a different approach and<br />

kept the CIP open to Russian applicants<br />

even after all CBI offering islands had<br />

decided otherwise. Unfortunately, St.<br />

Lucia closed its doors on March 18th 2022<br />

due to growing external pressures.<br />

While, at the time of writing,<br />

Russian nationals may no longer apply<br />

to all but one Caribbean Island’s CIP, as<br />

practitioners in an industry which seeks to<br />

be a force for good by promoting freedom<br />

of mobility, we must ask whether such a<br />

blanket ban is necessary or justified. Initial<br />

comments from St. Lucia’s government<br />

and Unit officials painted a desire to<br />

refrain from discriminating against<br />

Russian applicants based on nationality.<br />

It was stated that mechanisms were in<br />

place to ensure that any individual with<br />

ties to Vladimir Putin’s regime, on a<br />

relevant sanction list or of general bad<br />

character, could not obtain citizenship.<br />

Noting that Russia has a population<br />

of approximately 150 million persons as<br />

well as a diaspora of over 20 million, it<br />

is likely that only a fractional percentile<br />

falls into the aforementioned categories.<br />

Mechanisms to ensure<br />

CIP integrity<br />

Section 36 of the Act mandates that<br />

the following persons may not be<br />

granted citizenship through the CIP:<br />

• Individuals who have been<br />

convicted of a criminal offence;<br />

• Individuals who are the subject<br />

of a criminal investigation;<br />

• Individuals who are considered to be<br />

a potential national security risk;<br />

• Individuals involved in any activity<br />

likely to cause disrepute to Saint Lucia;<br />

• Individuals who have been denied a visa<br />

to a country with which Saint Lucia has<br />

visa-free travel and has not subsequently<br />

obtained a visa to that country; and<br />

• Individuals who provide false<br />

information in their CBI application.<br />

These rules ensure that individuals of<br />

unscrupulous character do not tarnish<br />

the reputation of St. Lucia and its CIP.<br />

Provided that the legislation is properly<br />

administered, it is improbable that any<br />

“bad apples” would obtain citizenship.<br />

Compliance with the legislation is<br />

ensured through a rigorous enhanced<br />

due diligence process. This process is<br />

three phased with vetting of applicants<br />

undertaken by the Royal Saint Lucia<br />

Police Force, the CARICOM <strong>IM</strong>PACS-<br />

Joint Regional Communications<br />

Centre and international due diligence<br />

partners such as BDO, Exiger and<br />

Refinitiv. Once complete, vetting<br />

agencies provide comprehensive<br />

reports on every applicant so that an<br />

appropriate decision to either grant<br />

or deny citizenship is made. In fact,<br />

St. Lucia’s due diligence process has<br />

been praised internationally for its<br />

transparency, rigor and integrity. It is<br />

further noted that the decision to grant<br />

or deny citizenship is taken by a fiveperson<br />

board of skilled, independent,<br />

impartial non-executive directors.<br />

The implementation of the<br />

legislative framework through the<br />

due diligence process described above<br />

ensures that only individuals of good<br />

character and suitable background,<br />

regardless of nationality, may<br />

obtain citizenship. This alleviates<br />

any concerns related to sanctioned<br />

Russians and Russians associated with<br />

the current regime misusing CIPs.<br />

32 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Post citizenship safeguards<br />

From the inception of the CIP, dozens<br />

of reputable Russian nationals have<br />

become citizens with total contributions<br />

to St. Lucia’s economy exceeding<br />

US$2,000,000.00. Despite this financial<br />

impact, many commentators have raised<br />

concerned around their continued<br />

possession of Saint Lucian citizenship.<br />

These concerns are especially relevant<br />

as persons may be sanctioned post grant<br />

of citizenship and circumstances, such<br />

as ties to the Russian regime, which were<br />

once potentially acceptable, are now not.<br />

The St. Lucia government, through the<br />

Act, has put in place a revocation process<br />

which seeks to alleviate the abovementioned<br />

fears. Whilst international standards of due<br />

diligence ensure that only individuals who<br />

demonstrate sound character and can prove<br />

clean criminal and civil records may obtain<br />

citizenship, it does not prevent these persons<br />

from committing crimes or performing<br />

nefarious acts post citizenship. Further,<br />

misdeeds of now citizens are sometimes only<br />

brought to fore after the citizenship process<br />

has been concluded. To protect against<br />

these possibilities, Section 38 of the Act<br />

empowers the Minister with responsibility<br />

for the CIP to revoke citizenship where:<br />

• Citizenship was found to be obtained<br />

by false representation, fraud or<br />

intentional concealment of facts;<br />

• The citizen has been convicted<br />

of an offence; and<br />

• The citizen has performed an<br />

act which, in the opinion of the<br />

Minister responsible for the CBI<br />

programme, has the potential to<br />

bring disrepute to Saint Lucia.<br />

This revocation mechanism, whilst<br />

sparingly used, is an important tool which<br />

guarantees that any person, Russian or<br />

otherwise, who should no longer hold<br />

citizenship, is rightfully stripped of the<br />

privilege. Importantly, placing the power<br />

of revocation with the Minister responsible<br />

for the CIP allows action to be taken<br />

expediently where necessary with damage<br />

to the CIP’s reputation controlled. Do note<br />

that those who have lost citizenship have a<br />

right of appeal to the courts which serves as<br />

a check and balance against the potential<br />

misuse of the revocation provision.<br />

Final thoughts<br />

Through an analysis of the above, namely<br />

the legislative framework surrounding<br />

the grant of citizenship and the practical<br />

application of that framework through due<br />

diligence and the revocation procedure,<br />

it is evident that Saint Lucia’s CIP is well<br />

insulated against potential harm which may<br />

be caused by the accepting of nationals of<br />

any country. The original decision to not<br />

Discrimination of persons based on nationality<br />

only, whether in the CBI space or otherwise, has<br />

always been and will always be unjust.<br />

discriminate on the basis of nationality<br />

and to continue much needed revenue<br />

generation through the acceptance of<br />

Russian and Belorussian nationals was<br />

therefore an entirely sound one.<br />

While it is agreed that Saint Lucia<br />

should support its global partners, the<br />

acceptance of Russian nationals by the CIP,<br />

who are not sanctioned and not associated<br />

with the current regime, does not in any<br />

way undermine these goals. In fact, one<br />

may argue that an increase in Russian<br />

nationals obtaining CBI can hurt the<br />

regime as high-net-worth individuals are<br />

now able to effectively withdraw from the<br />

Russian economy and migrate elsewhere;<br />

thereby creating the type of brain drain<br />

which has haunted the Caribbean region<br />

for decades. Further, by isolating Russian<br />

nationals from the rest of the world, are<br />

we not aiding and abetting the cause<br />

of the current regime? The lessons of<br />

World War I, a precursor to World War<br />

II, partially due to similar discrimination<br />

against a select group of people, should<br />

not be lost on the Western Front.<br />

Discrimination of persons based on<br />

nationality only, whether in the CBI space<br />

or otherwise, has always been and will<br />

always be unjust. A most recent example<br />

of this was the “Muslim Travel Ban” which<br />

was widely critiqued in 2017 for being a<br />

near blanket ban of travel to the US by<br />

nationals of Iran, Iraq, Libya, Somalia,<br />

Sudan, Syria and Yemen. Article 2 of the<br />

United Nations International Convention<br />

on the Elimination of All Forms of Racial<br />

Discrimination expressly condemns<br />

racial discrimination and obliges parties<br />

to “pursue by all appropriate means and<br />

without delay a policy of eliminating racial<br />

discrimination in all its forms”. It should be<br />

noted that the convention expressly includes<br />

discrimination based on nationality as<br />

a form of racial discrimination and has<br />

eighty-eight signatories including the<br />

United States, the United Kingdom and<br />

all EU member states. With this context<br />

in mind, the decision taken by the Elite<br />

West to exclude Russian nationals, solely<br />

on account of that fact, from the global<br />

marketplace, and attempts to pressure<br />

Caribbean CBI offering states to do the same<br />

is equal parts astonishing and amusing.<br />

Role of the <strong>IM</strong>C<br />

The Investment Migration Council, which<br />

seeks to promote ethical standards in the<br />

CBI space globally and lobby on behalf<br />

of CIPs, has a vital role to play in righting<br />

current wrongs. The situation at the time<br />

of writing unjustly disenfranchises a select<br />

group of persons by stripping them of equal<br />

access to investment migration, damages<br />

the reputation of our industry by making<br />

us co-conspirators to a segregationist<br />

status quo and reduces financial viability<br />

by excluding over one hundred million<br />

potential CBI participants. Of equally great<br />

concern is the continued influence of global<br />

superpowers on the decisions of supposedly<br />

sovereign Caribbean states. The continued<br />

meddling in the affairs of these jurisdictions<br />

by the “First World” has led to disastrous<br />

results such as the destruction of the banana<br />

industry in the eastern Caribbean, and<br />

the decline of its financial services sector.<br />

We must ensure that CBI is not another<br />

casualty to the Big Stick Diplomacy which<br />

has been extended to the region time and<br />

time again. The <strong>IM</strong>C therefore is implored<br />

to fulfil a lobbying mandate on behalf of<br />

CBI offering states and by extension, the<br />

now marginalised national groups, in<br />

both Brussels and the global arena.<br />

Geoffrey DuBoulay is<br />

BIOS Managing Director of<br />

Polaris Citizenship & Investment<br />

Consultancy Services and the Managing<br />

Partner of the firm Floissac, DuBoulay<br />

& Thomas in Saint Lucia. He possesses<br />

a master’s degree in Commercial<br />

and Corporate Law and has over 20<br />

years’ experience as an attorney.<br />

Keith Isaac is the Chief Operating<br />

Officer of Polaris Citizenship &<br />

Investment Consultancy Services<br />

and an attorney-at-law at the firm<br />

Floissac, DuBoulay & Thomas in<br />

Saint Lucia. He holds a master’s<br />

degree in Law and a Certification in<br />

Investment Migration. He is a fivetime<br />

former St. Lucia National Youth<br />

Parliamentarian and a former St.<br />

Lucia Junior Minister for Tourism.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 33

<strong>IM</strong> YEARBOOK<br />

Trends and Topics<br />

Six Thoughts<br />

on Investment Migration<br />

in a Changing Landscape<br />

While it is impossible to predict the future, it is possible<br />

to consider how current megatrends and potential future<br />

disruptions might affect investment migration in the years to<br />

come. We look at the global shifts reshaping the world and<br />

ask what are the implications for investment migration?<br />

34 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

1. Welcome to the metaverse<br />

The idea of virtual citizenship isn’t new. In fact, it has been debated ever since<br />

Linden Lab launched its online platform Second Life in 2003. At its peak, Second<br />

Life reported millions of active users in self-made virtual worlds complete with<br />

property sales, a market of virtual goods, and a functioning economy that was<br />

worth around US$500 million in GDP around 2007, according to Time magazine.<br />

While Second Life might not represent<br />

the broader vision of the modern<br />

metaverse, it can certainly be called a<br />

metaverse pioneer. Interest in the metaverse<br />

spiked in recent months amid a rise in sales<br />

of non-fungible tokens (NFTs) as well as<br />

investment from big tech companies in the<br />

space. In fact, the metaverse has become a<br />

mainstream topic since the day Facebook<br />

changed its name to Meta in October 2021.<br />

But what exactly is the metaverse?<br />

The word itself means “beyond the<br />

universe”. One way to describe it is the<br />

convergence of digital and physical lives,<br />

making the metaverse a space where<br />

you can interact with virtual objects in<br />

real life and with real-time information.<br />

Philip Rosedale, Founder of Second<br />

Life, told the World Economic Forum in<br />

2022: “The most important meaning of<br />

‘metaverse’ is the mission to make the<br />

internet a live experience with other<br />

people always there, as opposed to the<br />

largely individual experience it is today.”<br />

Bloomberg Intelligence expects the<br />

market opportunity for the metaverse to<br />

reach US$800 billion by 2024. According<br />

to a report published by Citi Research,<br />

the metaverse represents a potential US$8<br />

trillion to US$13 trillion opportunity by<br />

2030, that could boast as many as five<br />

billion users. Likewise, Goldman Sachs<br />

arrived at a US$12.5 trillion opportunity<br />

if one-third of the digital economy shifts<br />

into virtual worlds and then expands by<br />

25%. “We believe the metaverse is the next<br />

generation of the internet — combining the<br />

physical and digital world in a persistent<br />

and immersive manner — and not purely<br />

a virtual reality world,” their report reads.<br />

More importantly in an investment<br />

migration context, KPMG predicts that<br />

by 2040 the concept of digital citizenship<br />

is thriving, and many people have<br />

done away with their passports and<br />

residency cards for the physical world.<br />

The consulting firm further forecasts:<br />

“There are at least 11 virtual nations<br />

now with a combined population of 200<br />

million ‘citizens’ and a GDP above US$100<br />

billion each. Their citizens enjoy higher<br />

incomes and live in ‘gated communities’<br />

that have their own security. Benefits like<br />

virtual welfare, employment, and other<br />

amenities are vastly superior to those<br />

provided by physical nations, creating a<br />

substantial lifestyle gap between citizens<br />

of physical nations and those in virtual<br />

nations, who are dual citizens of the<br />

physical country they reside in.”<br />

The future of the metaverse is far<br />

from certain, and many say the metaverse<br />

is still several years away. However, a<br />

likely scenario is that individuals are<br />

physical residents of one country but meta<br />

citizens of another because they connect<br />

with the values, ideologies, and laws of<br />

the meta state more than with those of<br />

their base in the real world. Moreover,<br />

they conduct business with like-minded<br />

forward-thinkers in the metaverse,<br />

attend the best universities online, and<br />

invest in digital real estate using crypto.<br />

It’s time to start thinking about<br />

the metaverse because some of<br />

investment migration’s selling points<br />

and experiences are fast becoming<br />

metaverse elements. Much like the<br />

entertainment industry must decide if<br />

it is sticking to a shrinking market for<br />

traditional forms of amusement, or start<br />

bringing their characters and brands into<br />

metaverse platforms, the big question<br />

for investment migration is: how can<br />

it capitalise on the metaverse? Now is<br />

the time to experiment and invest and<br />

innovate in metaverse-based use cases.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 35

<strong>IM</strong> YEARBOOK<br />

2. Cryptocurrencies and investment<br />

migration – a match made in heaven?<br />

Cryptocurrencies hit a rough patch in 2022. Since November 2021, the crypto<br />

market has dropped 60% - drastically falling from a market cap of $3 trillion<br />

to less than $1 trillion in October 2022. The collapse of Sam Bankman-Fried’s<br />

FTX exchange in November 2022 served as just another example of the<br />

unpredictable nature of the industry. However, the onset of the so-called crypto<br />

winter as this period of market cooling has become known is one reason why<br />

cryptos are playing an increasingly important role in investment migration.<br />

Given the volatility of the market, many<br />

crypto millionaires are diversifying<br />

part of their net worth into other hard<br />

assets such as real estate. Both agents<br />

and pathways report that they have seen<br />

a surge in enquires from those who have<br />

made a fortune from cryptocurrency<br />

investments, as well as from those who<br />

want to invest in digital currencies and<br />

are looking for a crypto-friendly base.<br />

In the past few years crypto assets<br />

have moved from being niche products<br />

to having a more mainstream presence.<br />

In June 2021, the UK Financial Conduct<br />

Authority published its fourth consumer<br />

research publication on crypto-assets<br />

ownership, which found heightened<br />

public interest in, and media coverage of,<br />

cryptos, with 78% of adults now having<br />

heard of cryptocurrencies. Around<br />

2.3 million now own crypto assets, up<br />

from around 1.9 million in 2020.<br />

In the US, Pew Research, a nonpartisan<br />

think tank in Washington, reported that<br />

16% of survey participants indicated<br />

they had personally invested in, traded<br />

or otherwise used cryptocurrencies.<br />

Elsewhere, Newsweek Magazine cited<br />

a survey from January 2022 by crypto<br />

firm New York Digital Investment<br />

Group, estimating the total number of<br />

Americans who own cryptos at 46 million,<br />

which is about 14% of the population.<br />

It comes as no surprise that the<br />

investment immigration industry is<br />

gearing up to the use of cryptos. Portugal,<br />

which is generally regarded a crypto<br />

hub, and St. Kitts and Nevis, as well as<br />

Antigua and Barbuda have emerged<br />

as the leading investment migration<br />

countries with crypto-friendly policies.<br />

One key advantage of cryptocurrencies<br />

is they do not rely on intermediaries such<br />

as commercial banks and credit card<br />

companies to conduct transactions, which<br />

cuts out the inefficiencies and added costs<br />

of these intermediaries. In the Caribbean,<br />

it also addresses correspondent banking<br />

issues that have long plagued the region.<br />

Portugal is accepting bitcoin and other<br />

cryptocurrencies for real estate investment in<br />

its golden visa programme. While the country<br />

had been notable for having no crypto taxes on<br />

individuals, in October 2022 the government<br />

proposed to impose a 28% income tax on<br />

cryptocurrencies held for less than a one-year<br />

period. Meanwhile, Antigua and Barbuda, as<br />

well as St, Kitts and Nevis are members of the<br />

Eastern Caribbean Currency Union, which<br />

developed its own digital currency called<br />

DCash. While it remains to be seen if DCash<br />

will elicit the same level of enthusiasm as<br />

bitcoin and other cryptocurrencies, it is another<br />

example that shows that crypto assets as well as<br />

its associated products and services have grown<br />

rapidly in recent years and are here to stay.<br />

36 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

3. Sustainability: True impact or green washing?<br />

The world is more than ever under pressure to channel money into<br />

curbing climate change – and yet fighting climate change seems to<br />

have slipped down on many nations’ agenda as the Ukraine war, high<br />

energy prices and geopolitical tensions took precedence in 2022.<br />

hardest work is still to come.<br />

“TThe reality is that not enough has<br />

been done in the last 12 months – some<br />

would argue we have moved backwards,”<br />

Hortense Bioy, Global Director of<br />

Sustainability Research at Morningstar,<br />

told Reuters in November 2022.<br />

Moreover, sustainable investing<br />

has come in for a great deal of criticism<br />

since the turn of the year with the list<br />

of companies and countries that have<br />

been accused of not being as ESGfriendly<br />

as promoted getting longer by<br />

the day. Case in point: Human rights<br />

advocates pointed out concerns about<br />

Egypt’s human rights record ahead of<br />

Cop27, the UN climate summit that took<br />

place in the Egyptian resort town of<br />

Sharm el-Sheikh in November 2022.<br />

In 2020, the Investment Migration<br />

Council highlighted that investment<br />

migration has the potential to advance the<br />

2030 Sustainable Development Agenda<br />

(SDG). Investment migration brings in fresh<br />

capital, human skills, and entrepreneurial<br />

capacity for the receiving nation.<br />

Some of this money contributes, often<br />

unintendedly, towards meeting the SDGs.<br />

For example, investment migration<br />

income made important contributions<br />

to the funding of physical and social<br />

infrastructure, particularly to finance the<br />

reconstruction of infrastructure damaged<br />

by hurricanes that have hit the Caribbean.<br />

Elsewhere, investments migration is<br />

directed to business investment that create<br />

jobs and therefore reduces poverty.<br />

However, to ensure that investment<br />

migration income is not overlooked<br />

as a factor within a country’s overall<br />

sustainability and development strategy,<br />

countries should apply ESG criteria<br />

to investment which form part of an<br />

investment migration pathway. There<br />

is a strong need for a more streamlined<br />

and systematic approach and to better<br />

integrate ESG factors so that investment<br />

migration can positively impact the world.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 37

<strong>IM</strong> YEARBOOK<br />

4. Are you ready for the next generation of clients?<br />

Generation Alpha, the children of Millennials born between 2010 and<br />

2024, promises to play a key role in shaping our society within the next<br />

couple of decades and is expected to be the generation with the largest<br />

spending power yet. While, for the time being, investment migration<br />

is largely driven by Gen X and Millennials customers, we ask what are<br />

some of the typical traits we can expect from the next generations?<br />

Generation Z, those between 1995 and<br />

2009, are the first digital natives. They<br />

have grown up with smartphones and<br />

tablets and since an early age had internet<br />

access at home. They consume mainly<br />

digital media and are used to watch a video<br />

summarising an issue rather than read an<br />

article covering the topic. Due to social<br />

media platforms such as Facebook and<br />

Instagram, Gen Zs are constantly connected<br />

to and influenced by their peers. Moreover,<br />

Gen Zs tend to be highly educated,<br />

environmentally conscious and longing to<br />

leave a positive impact within communities.<br />

The 2022 edition of the Wealth report<br />

predicts that between 2021 to 2026 the<br />

global UHNWI population will grow<br />

by a further 28%, more than a doubling<br />

in numbers over a 10-year period. This<br />

growth will consist mainly of Millennials<br />

and Gen Zs as they inherit assets and<br />

companies from their parents or else as<br />

innovators and successful start-up owners<br />

particularly in the technology field.<br />

Generation Alpha, or Gen Alpha,<br />

is the demographic cohort succeeding<br />

Generation Z and is made up of mostly the<br />

children of Millennials. The name derives<br />

from the first letter of the Greek alphabet.<br />

Mark McCrindle, a demographer who<br />

rose to fame for analysing and naming<br />

generations, says members of Gen Alpha<br />

are the first generation to have been<br />

born and fully shaped in the 21 st century.<br />

They are also expected to be the largest<br />

generation ever. By 2025, they will number<br />

two billion globally and most of them will<br />

live in Asia – mainly in China and India.<br />

By 2030, the first members of Gen<br />

Alpha will be young adults, and they<br />

are the next generation of customers<br />

that will benefit from the largest<br />

intergenerational wealth transfer in<br />

history. Much like Gen Zs, Gen alpha will<br />

be digital. They are growing up in a world<br />

where TikTok, Roblox and Instagram<br />

are not disruptors but the established<br />

incumbents, McCrindle emphasizes.<br />

While sustainability is already<br />

important to Millennials and Gen Z<br />

consumers, it is expected that Gen Alpha<br />

will resonate especially strongly with<br />

sustainability, given that they will be growing<br />

up entirely under the threat of climate change.<br />

There is also consensus among researchers<br />

that Covid-19 will have a lasting impact on<br />

this cohort since their formative years have<br />

been shaped by a global pandemic. So, it’s<br />

perhaps unsurprising that many believe<br />

that Gen Alpha can be defined by their<br />

worries towards becoming ill and not being<br />

able to see their families for a long period.<br />

Although the demographic transition<br />

is still a few years away, the investment<br />

migration community needs to start<br />

catering for these new realities. For Gen<br />

Z and Gen Alpha themes such as the<br />

environment, general wellbeing, and<br />

technology ought to be more central, while<br />

those who wish to win them as clients need<br />

to adapt their communication methods.<br />

Bureaucracy, antiquated portals and slow<br />

processes will not attract the upcoming<br />

generations. What started with Gen Z<br />

will continue with Gen Alpha. Those<br />

born after 2010, McCrindle summarises,<br />

will be more digital, global, social and<br />

visual than any generation before them.<br />

38 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

5. The new reality: remote working and nomad visas<br />

Estonia gave rise to successful companies like Skype, Wise, Bolt and<br />

Playtech, and it was the first country to launch a digital nomad visa in 2020,<br />

which fast became the ultimate concept for countries to attract remote<br />

workers. Just two years later, in 2022, more than 25 countries run similar<br />

programmes, according to a Migration Policy Institute report, making it one<br />

of the most important trends in the immigration space in recent years.<br />

Sparked by the pandemic, remote work<br />

has become an integrated part of today’s<br />

work fabric. Even as companies such as<br />

Uber and Tesla try to reign in personnel<br />

back to their brick-and-mortar offices, there<br />

is consensus that remote work will remain<br />

mainstream and an important tool for<br />

companies to recruit and retain employees.<br />

Concurrently, freelancing is on the<br />

rise. In 2021, according to the US Bureau<br />

of Labour Statistics, over 47 million<br />

Americans voluntary quit their jobs and<br />

trends predict that by 2027 50% of the<br />

workforce will be freelancing in the country.<br />

While people’s reasons for quitting their<br />

jobs vary, of course, the inclination is that<br />

those with a high level of education and in<br />

possession of sought-after specialised skills,<br />

are opting for flexible projects with several<br />

companies instead of a stable contract<br />

with a single business. This trend has<br />

reduced the need of one to be permanently<br />

based in one location to be close to his/<br />

her place of work or business. Instead,<br />

tech-savvy individuals are moving to far<br />

flung exotic nations to strike a better worklife<br />

balance, explore new places without<br />

the need of taking a career break and, at<br />

the same time, escape crowded cities.<br />

This has markedly created a new niche<br />

for countries to cater for this increased<br />

demand of individuals wanting to work<br />

remotely from outside their home country.<br />

What has been termed as a ‘digital nomad<br />

visa’ is fundamentally a programme<br />

that gives an individual the legal right to<br />

work remotely while residing away from<br />

their country of permanent residence.<br />

Some programmes have been specifically<br />

designed for remote workers while others<br />

have been adapted from earlier work visas.<br />

While some variations exist among<br />

them, they generally follow the same<br />

idea: granting a temporary hassle-free<br />

residency permit that allows foreigners<br />

to stay from six months to five years. The<br />

onset of these programmes addressed a<br />

legal vacuum for remote workers wanting to<br />

spend an extended period abroad working<br />

independently, although there are still some<br />

unanswered questions about tax liability.<br />

Applying for a digital nomad visa<br />

generally involves an application fee<br />

together with proof of a certain level of<br />

income to sustain oneself. The fees vary<br />

from being at no cost when applying for<br />

a visa in Georgia to US$2,000 for the<br />

Barbados ‘Welcome Stamp’ programme.<br />

Income requirements range from<br />

US$1,275 per month under Ecuador’s<br />

visa programme to US$100,000 per<br />

year under the Cayman Islands ‘Global<br />

Citizen Concierge Programme’. Average<br />

rates hover around €3,000 per month<br />

as per Malta’s ‘Nomad Residency<br />

Permit’, and the Cypriot, Panama, and<br />

Romanian nomad visa programmes.<br />

With an estimated 35 million digital<br />

nomads worldwide contributing to a global<br />

economic value of US$787 billion per year,<br />

it’s no surprise that countries around the<br />

world are launching their own digital<br />

nomad visa programmes. This new visa<br />

trend has generally been positively received<br />

by local communities and has spurred<br />

several developments. Co-working and<br />

co-living spaces have boomed, and in some<br />

places, entire areas have been built to cater<br />

for the influx of these new communities.<br />

The concept of digital nomad visas<br />

is only a few years old and essentially<br />

still an experiment. However, judging<br />

from the increasing number of countries<br />

coming up with their own programmes<br />

and the growing number of digital<br />

nomads worldwide, it’s likely that<br />

digital nomad visas are here to stay.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 39

<strong>IM</strong> YEARBOOK<br />

6. Start-ups going global<br />

For centuries, some of the biggest companies in the US have been founded by<br />

immigrants – just think of Levi Strauss from Germany or Elon Musk from South<br />

Africa. An analysis by the National Foundation for American Policy from May<br />

2022 found that immigrants have started more than half of America’s start-up<br />

companies valued at US$1 billion or more. Attracting a start-up before it grows big<br />

can have a huge impact on a country’s economy. For instance, Berlin-based fashion<br />

e-commerce company Zalando grew to become the<br />

10th biggest employer in the city over the last 12 years.<br />

While it’s incredibly difficult for smaller countries<br />

to attract investment from established companies<br />

such as Google, chances are they will succeed in<br />

attracting the founders of the ‘next Google’ to start<br />

up in their location. This is the rationale driving<br />

the rapid expansion of start-up visa programmes.<br />

In 2022, around 40 nations, including<br />

most OECD countries, had some<br />

form of start-up-related programme<br />

in place. In fact, migration policies in<br />

many countries are moving away from<br />

being focused on traditional family or<br />

employment-related immigration and<br />

crafted more around entrepreneurial<br />

and highly skilled individuals. This<br />

‘merit based’ approach is proving<br />

popular. A growing global nationalistic<br />

environment driven mainly by populist<br />

ideologies is not leaving much space for<br />

the ‘traditional’ immigration policies.<br />

Start-up related visas attract fewer<br />

negative sentiments, do not generally<br />

spur contentious opinions, and garner<br />

wider partisan support. Secondly,<br />

if managed properly, start-up visa<br />

programmes can potentially leave<br />

substantial economic multiplier outcomes<br />

on a nation’s economy creating growth<br />

opportunities in new innovative areas.<br />

Contrary to entrepreneur-related<br />

visas which have been around for a while,<br />

start-up visa programmes focus on the<br />

potential of a business, rather than the<br />

actual capital invested. The main goal is<br />

that of augmenting the national start-up<br />

ecosystem by attracting talent and ideas<br />

from abroad. Differences exist between<br />

various programmes, including whether<br />

they offer temporary or permanent status,<br />

how they are assessed and monitored,<br />

the sectors targeted, and the investment<br />

requirements and commitments. In<br />

most cases only temporary renewable<br />

residence permits are offered.<br />

Canada is one of a handful of countries<br />

that through its Start-up Visa (SUV)<br />

programme offers permanent residency to<br />

successful applicants. Most programmes<br />

offer family members temporary residency<br />

with working rights. Japan and Korea<br />

conversely do not admit family members<br />

via their start-up programmes.<br />

There is no single method on how startup<br />

programmes are evaluated and selected.<br />

Unlike other immigration programmes<br />

based on investment, net worth or skill<br />

set, most start-up visas are about enticing<br />

and supporting business owners before<br />

they succeed and leave a positive impact<br />

on the local community. Start-ups are in<br />

essence high risk with many failing after few<br />

years operating. Managing the associated<br />

risks is key for these programmes.<br />

A balance needs to be struck between<br />

venturing on a great entrepreneurial<br />

potential but mitigating the associated<br />

risks through selection, monitoring and<br />

support structures. Most governments<br />

involve players from the local business<br />

community and expert panels to assist<br />

and guide immigration personnel who do<br />

not possess the ability to assess promising<br />

business plans. Lithuania for example has<br />

a panel of experts, the majority of which<br />

come from the private sector assessing<br />

applications. The UK involves universities,<br />

while Finland, the Netherlands, and<br />

Malta allot their innovation and business<br />

agencies to select applications. Some<br />

programmes, such as those offered in<br />

Poland, France and Spain even offer<br />

some limited form of capital assistance<br />

via grants and business incubators.<br />

Attracting the right start-ups from<br />

around the globe can reap tangible<br />

economic benefits for countries. Replicating<br />

the Silicon Valley success story is an end<br />

target for many programmes. Apart from<br />

job creation, successful start-ups sustain<br />

and spread a culture of innovation and<br />

entrepreneurship. They can also boost<br />

the marque of countries, both regionally<br />

and globally. For instance, entrepreneurs<br />

who have followed Chile’s ‘Start up Chile’<br />

programme over the last decade or so<br />

have generated sales of more than one<br />

billion dollars worldwide. Chile, which<br />

was a pioneer in devising international<br />

start-up programmes more than ten<br />

years ago, has become a hub for startups<br />

in Latam attracting in the process<br />

international highly skilled talent.<br />

Start-up visas are by design low-volume.<br />

A well planned and successful start-up<br />

visa programme needs to be supplemented<br />

by wider policies such as incubators,<br />

business networking avenues and tangible<br />

investment incentives. With more countries<br />

coming up with start-up related visa<br />

programmes, having the right ecosystem<br />

is what will differentiate one programme<br />

from the other. If successful, a start-up<br />

visa programme can enhance a country’s<br />

standing on the global scene, create new<br />

high growth sectors, attract talent, and<br />

assert a government’s commitment to<br />

entrepreneurship and innovation.<br />

40 - Investment Migration <strong>Yearbook</strong> 2O23

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<strong>IM</strong> YEARBOOK<br />

Navigating a<br />

new level of<br />

volatility<br />

Dr Juerg Steffen,<br />

CEO of Henley &<br />

Partners, writes<br />

that turmoil<br />

and instability<br />

have become<br />

the common<br />

denominators of<br />

the 21st century,<br />

which have<br />

accelerated demand<br />

for investment<br />

migration pathways.<br />

A<br />

twin dynamic is at play in the<br />

investment migration arena<br />

as investors pursue sovereign<br />

diversification at the same time as nation<br />

states seek to boost their sovereign<br />

equity – in both cases, residence and<br />

citizenship by investment provides the<br />

optimal solution. Relentless volatility and<br />

uncertainty continue to drive wealthy<br />

individuals across the world to explore<br />

the most suitable investment migration<br />

solutions to manage the risks of abrupt<br />

changes in policy or legislation that could<br />

threaten their capital and lifestyles.<br />

Sovereign diversity<br />

Although historically investment migration<br />

programmes might have been considered<br />

a convenient add-on for globally minded<br />

investors and entrepreneurs, today, faced<br />

with so many ever-fluxing dynamics on<br />

the global stage, sovereign diversity has<br />

risen to the fore, and this asset class is now<br />

deemed a necessity. Investors are looking to<br />

protect themselves and their families from<br />

ongoing political insecurity and economic<br />

instability by having the option to live,<br />

work, and conduct business in an array of<br />

different jurisdictions across the world.<br />

Another paradigm shift is taking<br />

place at the sovereign level with more<br />

governments increasingly keen to engage<br />

with the global community of high-networth<br />

investors and talented individuals,<br />

encouraging them to their shores by<br />

introducing new immigration pathways,<br />

including residence and citizenship by<br />

investment programmes. Nation states can<br />

use these programmes as an innovative<br />

financing tool by allocating inflows to<br />

social, infrastructure, and development<br />

projects that benefit their citizens. In so<br />

doing, they also boost public finances, foster<br />

economic growth, and create employment<br />

opportunities without increasing debt.<br />

Crisis after crisis<br />

The 21 st century certainly began as it meant<br />

to go on. Merely a year into this millennium,<br />

the world was upended in 2001 by the<br />

9/11 attacks, a single event that catapulted<br />

humanity into an ideological tug-of-war,<br />

deepening fissures between sovereign states<br />

and shaking the geopolitical scales of power.<br />

War and volatility have also fuelled<br />

the mass migration of people looking to<br />

escape hardship and authoritarian rule and<br />

added pressure to the seemingly irresoluble<br />

refugee crisis the world confronts. The<br />

ongoing conflict in Ukraine has become<br />

the current centre of global political<br />

instability as Europe responds to warfare<br />

on its own turf. The conflict has also<br />

awoken the sleeping dragon of ideological,<br />

political, and economic warfare between<br />

East and West, taking us back to an era<br />

reminiscent of the Cold War. It has also<br />

driven wealthy individuals, entrepreneurs,<br />

42 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

the Great Lockdown, albeit to varying<br />

extents. It highlighted the immeasurable<br />

value of freedoms once taken for granted,<br />

emphasised the importance of robust<br />

healthcare access, and prompted many to<br />

explore truly effective ways of safeguarding<br />

their wealth and lifestyles. It is now of<br />

paramount importance to high-net-worth<br />

individuals to mitigate exposure to volatility<br />

at home and protect against the barrage<br />

of multi-faceted crises that the world is<br />

enduring by accessing a greater number<br />

of jurisdictions through a diversified<br />

portfolio of residences and citizenships.<br />

The way we interact and the way we<br />

work have changed thanks to technological<br />

advancements and, with this digital<br />

transformation, the world has become truly<br />

interconnected. Many who have explored<br />

new locations from which to work or run<br />

their businesses during the pandemic<br />

have started examining more permanent<br />

options available to secure additional<br />

passports and the rights to live in attractive,<br />

stable, and cosmopolitan locations. And<br />

now, more than ever, countries need<br />

their talent and their investment to boost<br />

their own resilience to future shocks. It’s<br />

a win-win situation. Nation states can<br />

leverage their sovereign equity to provide<br />

investors with the sovereign diversity they<br />

are looking for, to the benefit of both.<br />

and business owners to invest in<br />

residence and citizenship by investment<br />

programmes in countries that offer more<br />

stable socio-political environments<br />

that grant them peace of mind.<br />

Asset devaluation<br />

Less than a decade after 9/11, international<br />

markets suffered the global financial<br />

crisis of 2007–2008, with the collapse of<br />

the American housing market having<br />

a dramatic domino effect the world<br />

over. Now, 15 years later, on the back of<br />

a devastating global pandemic, we are<br />

staring yet another economic emergency<br />

in the face, with inflation rates soaring<br />

and a painful global cost-of-living crisis<br />

further widening the wealth gap. The<br />

World Economic Forum’s Chief Economists<br />

Outlook for September 2022 was grim,<br />

warning that a global recession is possible<br />

in <strong>2023</strong>, with growth stifled by “once-in-a-<br />

generation inflation” in the US and Europe.<br />

Economic volatility of this scale<br />

heightens risk, and risk prompts affluent<br />

individuals to look for ways to protect their<br />

wealth, their capital, and their families, and<br />

future-proof their investments. Demand<br />

for investment migration pathways has<br />

accelerated in recent years as wealthy<br />

families seek to safeguard their legacies<br />

and retain the optionality to move to, or<br />

invest in, more secure jurisdictions. The<br />

record inflation we are experiencing across<br />

the world is devaluing liquid assets with<br />

each passing day, making residence and<br />

citizenship programmes linked to real estate<br />

investments in budding property markets,<br />

or those tied to funds in lucrative financial<br />

hubs, very attractive to astute investors.<br />

The conscientious investor<br />

When borders shut in 2020, humankind<br />

shared the life-changing experience of<br />

Dr Juerg Steffen is the CEO<br />

BIO of Henley & Partners. He<br />

has more than 30 years’ experience<br />

in the financial services industry and<br />

is widely regarded as a leader in the<br />

field of investment migration. He first<br />

joined Henley & Partners in 2013 to<br />

set up the firm’s Singapore office and<br />

was latter appointed COO of the group.<br />

Before joining Henley & Partners, he<br />

was a personal advisor in the family<br />

office of one of Europe’s wealthiest<br />

families. He also served as a member<br />

of the management board and as head<br />

of the Wealth Planning department of a<br />

leading private bank in Austria and was<br />

a director in the Cross-Border Wealth<br />

Planning department of UBS in Zurich.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 43

<strong>IM</strong> YEARBOOK<br />

Anatomy of a Source Market:<br />

INDIA<br />

India is on track to become an economic superpower and is<br />

one of the hottest growth markets for investment migration.<br />

Immigration firms and consultants report record enquiries<br />

from the South Asian country, and according to Henley &<br />

Partners, around 8,000 millionaires left the country last year.<br />

Wealth diversification, access to markets, along with better<br />

education opportunities and greater mobility, are key motivators<br />

for Indians to invest in foreign countries. While India’s migration<br />

market had long been focused on the US, today’s investors<br />

are showing interest in a greater number of destinations.<br />

Growth story<br />

A country with 1.42 billion inhabitants, India’s story is one of growth<br />

and expansion. After decades of socialism, India implemented<br />

wide-ranging economic reforms in the early 1990s that had a<br />

positive impact on growth, consumption, urbanisation as well as<br />

wealth creation. At the start of the 21st century, India recorded an<br />

annual GDP growth of 6% to 7%, and from 2013 to 2018, India was<br />

the world’s fastest growing major economy, surpassing China.<br />

In 2022, despite a slew of challenges including macroeconomic<br />

headwinds stemming from Russia’s war in Ukraine, elevated<br />

crude oil prices and tightening liquidity globally, India’s economy<br />

continued to outperform most of its global peers. The <strong>IM</strong>F expects<br />

growth of 6.8% for the 2022/23 period – in the G20 only Saudi<br />

Arabia will grow faster. A recent Morgan Stanley report finds that<br />

the country has the conditions in place for an economic boom<br />

by 2030. Fuelled by investments in manufacturing, the energy<br />

transition, and the country’s advanced digital infrastructure, India<br />

will likely grow into the world’s third-largest economy by the end<br />

of the decade as its GDP is going to double to US$7.5 trillion.<br />

India’s rich<br />

In <strong>2023</strong>, India will likely surpass China as the most populated<br />

country, and by 2030, it will be home to 1.5 billion people – a market<br />

full of potential and too big to be ignored. More importantly, the<br />

number of wealthy individuals in India is on a steady rise. According<br />

to Knight Frank India, ultra-high-net-worth individuals increased<br />

by 11% in 2021 to more than 13,600. This was the highest percentage<br />

growth of any country in the Asia-Pacific region, with Knight<br />

Frank citing “equity markets and digital adoption as factors<br />

driving growth in the super rich category of India”. By 2026,<br />

some 19,000 Indians are projected to have net assets of $30<br />

million, while the number of individuals with more than US$1<br />

million is expected to surge by 77% between 2021 and 2026.<br />

Why invest abroad?<br />

With so much growth at home, it begs the question why are<br />

Indians interested in investing and moving abroad? Ravi Kanth<br />

Gangishetty, CEO and founder of RK Global Fortune Consulting,<br />

says India’s wealthy elite “thinks indeed twice today to move<br />

out of India”. While India has grown by leaps and bounds in<br />

the last 25 to 30 years, and “there are lots of new business and<br />

investment opportunities available,” he says, environmental<br />

concerns, low quality of life, corruption issues and weak<br />

regulation are major factors in people’s decision to emigrate.<br />

Varun Singh, managing director of Xiphias Immigration,<br />

also admits that “India’s growth story remains strong”, and<br />

in-country consumption holds great promise for businesses<br />

seeking high-yielding investments. “However, the aspiration of<br />

families to become cosmopolitan and transnational, as well as<br />

their desire to diversify their financial assets globally, is driving<br />

families to migrate internationally through investment,” he says.<br />

Client profile and motives<br />

Investor migrants from India are a diverse mix of business<br />

owners, new-age entrepreneurs, corporate executives, and<br />

skilled professionals. As diverse as their background, so too are<br />

their motives. A top priority of Asian parents is the desire to<br />

give their children the best education possible. Many of India’s<br />

second and third-generation business owners send their children<br />

abroad to study and to gain valuable work experience before<br />

asking them to return home and join their parents’ companies.<br />

“Diversification of geographical risks, in terms of wealth<br />

portfolios and access to developed nations” is another driving<br />

force for well-established businesspeople and corporate<br />

executives, according to Sumit Singh, Managing Director of<br />

44 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Indian families are becoming<br />

increasingly globalised and<br />

have shown a great appetite<br />

for investment migration in<br />

recent years. Three Indian<br />

immigration experts share<br />

essential insight into the<br />

Indian investment migration<br />

market and explain what<br />

Indian clients really want.<br />

Xumit Capital. He also mentions proper retirement planning with<br />

enhanced quality of life and access to good health care, as well as<br />

the prospect of easier travel. An Indian passport provides visa-free<br />

access to only 60 nations, mostly in Asia, Africa, and the Caribbean.<br />

Investor migrants under the age of 35, meanwhile, are<br />

predominantly start-up entrepreneurs who want to scale their<br />

companies. They are driven by the desire to relocate or set up<br />

their businesses in the most conducive start-up ecosystem. Indian<br />

start-ups often have foreign investors, and for many it is a logical<br />

choice to move their business closer to investors and venture<br />

capital. Besides, in India, the ease of doing business hasn’t improved<br />

much despite various initiatives by the Modi government.<br />

Destination appeal<br />

English-speaking nations are the first choice of Indian<br />

investors, and the US has long been the dream destination of<br />

many Indians. The UK, Canada, Australia, and New Zealand<br />

are equally sought-after destinations, while Singapore<br />

and Dubai are also on the radar of investor migrants.<br />

Meanwhile, families are becoming more open to relocating<br />

to Europe, and European nations such as Portugal and Greece,<br />

where English is still widely spoken, are actively considered.<br />

In addition to the language factor, the size of the Indian<br />

diaspora in the destination country is also playing a role in<br />

Indian’s investment migration decisions. According to a UN<br />

report, 18 million people from the country lived outside their<br />

homeland in 2020 - almost half of them in the US or the Gulf<br />

region. All experts feel this is an important factor that should not<br />

be underestimated. For example, says Gangishetty, many Indians<br />

are aware that the CEOs of several top US IT companies are from<br />

India, so they send their children, especially those studying IT<br />

and software development, to the US for their higher education.<br />

Preferred investment routes<br />

Traditionally, Indians relied on student or employmentbased<br />

visas if they wanted to spend extended periods<br />

abroad. However, as a result of changing migration policies,<br />

in combination with the Covid-19 pandemic, India’s upper<br />

class has come to appreciate the more predictable and<br />

permanent nature of investment migration programmes.<br />

From all the options, residency pathways are often more<br />

popular among Indian investors as India does not allow dual<br />

citizenship, unless investors opt for the Overseas Citizenship of<br />

India (OCI) option, an immigration status permitting a foreign<br />

citizen of Indian origin to live and work in India indefinitely.<br />

The EB-5 visa to the US is still the most sought-after<br />

programme by the Indian HNI community, but other pathways<br />

are actively considered. “For Indians with entrepreneurial<br />

bent, Canada is the best destination for migration. Federal<br />

and provincial programmes have different dynamics and<br />

different level of engagements, which suit many businesspeople<br />

in India,” says Sumit Singh. However, he highlights most<br />

Indian investor migrants want to “avoid business risks<br />

and thus prefer to be a sleeping-partner in a venture”.<br />

He has also noticed a spike of interest from Indians<br />

in the residency programmes of Portugal and Greece,<br />

mostly due to “the ease of investment” as real estate<br />

is the favourite asset-class of Indian families.<br />

Attracting Indian HNWIs<br />

Asked about cultural differences, Varun Singh comments:<br />

“Indian investor migrants are a tad different than investors<br />

from other countries.” Since they are not yet very familiar<br />

with the concept of investment migration, they take a<br />

little longer to decide, he explains. Moreover, Sumit<br />

Singh says, Indian investors are “risk-averse by nature”.<br />

He feels more awareness campaigns and roadshows<br />

in India would help in winning investor trust.<br />

Varun Singh, meanwhile, points out that foreign<br />

immigration consultants who want to attract Indian<br />

high-net-worth clients need to promote the destination<br />

country first, as this is still the primary factor driving the<br />

migration decision. To many, the investment route and<br />

the project are of secondary importance, while success<br />

stories of other Indians and the presence of Indian culture<br />

are elements that leave a mark on Indian investors and<br />

have the power to influence an investor’s decision.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 45

<strong>IM</strong> YEARBOOK<br />

Overcoming challenges<br />

Once a decision has been taken, Indian investor migrants must<br />

overcome several obstacles in order to start their migration<br />

journey. Before 2004, transferring money overseas was a<br />

cumbersome procedure involving numerous approvals from the<br />

Reserve Bank of India. Although India has liberalised foreign<br />

exchange transactions, Indian residents are only allowed to<br />

remit $250,000 per year. “This means investors take two to<br />

three years to deploy their capital overseas. Furthermore, not<br />

many Indian banks are supportive of such large transactions<br />

for migration purposes,” Sumit Singh explains.<br />

Another challenge revolves around the source of funds<br />

requirements. India is still a cash-rich country and proving the<br />

source of funds is quite often a problem for investors who either own<br />

property or inherited large sums of money. Moreover, the experts<br />

point out, with so many hurdles in the way, even genuine Indian<br />

investors are sometimes not willing to wait and invest in a process,<br />

which can take years depending on the destination country.<br />

Future attraction<br />

Looking to the future, all experts believe demand for investment<br />

migration from Indian nationals will remain high. There is also<br />

the expectation that the new generation of start-up programmes<br />

in developed countries such as Canada, the United Kingdom,<br />

Australia, and others will appeal to Indian entrepreneurs. “Although<br />

India has been a great haven for new startups, new entrepreneurs<br />

and innovators are looking to launch their start-ups in developed<br />

markets not only for the environment and infrastructure they<br />

provide, but also for market access,” says Varun Singh. Gangishetty,<br />

meanwhile, noticed also the “reverse trend” of US Green Card<br />

holders of Indian origin migrating back to India. India’s economic<br />

growth has created a lot more opportunities in recent years,<br />

making moving back a much more attractive option today.<br />

Sumit Singh is the Managing Director<br />

BIOS of Xumit Capital, an India-based global<br />

investment & migration advisory firm. He has more than<br />

15 years of experience in assisting high-net-worth clients<br />

with capital management and resettlement solutions.<br />

He is also a SEBI Registered Investment Advisor and an<br />

Associate Member of the Investment Migration Council.<br />

Ravi Kanth Gangishetty is founder and CEO of RK<br />

Global Fortune Consulting, a boutique Indian investment<br />

migration firm. He has worked for more than 11 years<br />

in the immigration consulting services sector.<br />

46 - Investment Migration <strong>Yearbook</strong> 2O23


Address: Quadrant Row, 9-11 Brazil Street, Castries, St. Lucia<br />

Email: info@polariscitizenship.com<br />

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<strong>IM</strong> YEARBOOK<br />

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Looking forward:<br />

Using real-time monitoring to make risk-based decisions<br />

Exiger’s Karen Kelly says Russia’s invasion of Ukraine<br />

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In the weeks and months since the<br />

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Residency and citizenship by investment<br />

(RCBI) pathways have of course been<br />

impacted, with increased scrutiny on<br />

their due diligence standards and overall<br />

compliance programmes for the assessment<br />

of individuals seeking a foothold in those<br />

jurisdictions. The impact has not been<br />

limited to the investment migration<br />

industry, however. Any organisation doing<br />

business with those connected to high-risk<br />

jurisdictions such as Russia, including<br />

large and small financial institutions and<br />

corporations, has had to re-evaluate those<br />

relationships and reassess the effectiveness<br />

of their compliance programmes.<br />

Monitoring works<br />

In the immediate aftermath of Russia’s<br />

invasion and the first of many waves of<br />

sanctions targeting Russia and Belarus,<br />

Exiger worked closely with partners<br />

across all industries. This included those<br />

in the investment migration industry,<br />

looking back at their existing and previous<br />

relationships; and in the context of RCBI<br />

programmes, at previously approved<br />

applicants. This covered targeted sanctions<br />

and adverse media searches of previously<br />

screened individuals and companies,<br />

and often their close associates, for<br />

any new and elevated risk arising from<br />

direct or indirect sanctions exposure.<br />

For our partners in the investment<br />

migration industry, this exercise served<br />

to validate and reinforce the necessity<br />

and effectiveness of technology-enabled<br />

monitoring of previously approved<br />

applicants. Over the last five years, we have<br />

seen ongoing, real-time monitoring, after<br />

the initial due diligence report has been<br />

delivered, go from a ‘nice-to-have’ to a<br />

necessary component for programmes with<br />

which we work. We strongly recommend it<br />

as a best practice for all programmes and<br />

due diligence providers working with them.<br />

It was rewarding to confirm that,<br />

while conducting re-screening exercises<br />

for our clients, we did not uncover any<br />

adverse information or risks not already<br />

unearthed through our regular monitoring<br />

of applicants. Notably, through the use of<br />

an effective monitoring programme, our<br />

clients learned of new adverse information<br />

or risks in near real time, rather than at<br />

the time of the re-screening exercise. Done<br />

right, monitoring can and does alert a<br />

programme to serious findings that come<br />

up after an applicant is approved, putting<br />

the programme in a position to proactively<br />

address these issues rather than scrambling<br />

to react after it has become a problem.<br />

A necessary shift<br />

Investment migration pathways are<br />

playing catch-up when they rush to<br />

re-check and re-screen previously<br />

approved applicants when a new risk<br />

or threat comes to the surface, like the<br />

Russian sanctions risk. What the industry<br />

demands, and what the new standard for<br />

best practices requires, is a shift from a<br />

“look back” mindset to “look forward”.<br />

Today’s monitoring technology<br />

offers RCBI pathways the opportunity<br />

to avail themselves of the right real-time<br />

information, putting them in a position<br />

to identify individual applicants with<br />

new and serious red flags. Moreover,<br />

a monitoring programme centralises<br />

volumes of information across complete<br />

applicant populations into a single data<br />

set, allowing programmes to identify<br />

patterns of risk and changing trends in<br />

risk exposure over time. Armed with<br />

good data sooner, programmes can make<br />

good decisions, and can look forward.<br />

In the case of Russia in 2022, a<br />

centralised view and analysis of Russian<br />

applicants could identify almost<br />

immediately what percentage of a pathway’s<br />

48 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Over the last five years, we have seen ongoing, real-time<br />

monitoring, after the initial due diligence report has<br />

been delivered, go from a ‘nice-to-have’ to a necessary<br />

component for programmes with which we work.”<br />

total applicant population was impacted<br />

by sanctions, and at what level (and the<br />

likely percentage of new applicants who<br />

would present this risk). This is the type<br />

of critical data point to have in hand when<br />

weighing decisions about imposing or<br />

lifting restrictions on those applying to<br />

investment migration programmes.<br />

The recent concerns over Russian<br />

applicants are just one example, and not<br />

the first, of how risk and risk appetites can<br />

change quickly. Other sanctions regimes<br />

will inevitably come about and may shift<br />

the focus to other jurisdiction or groups.<br />

New and different risks may surface raising<br />

greater concern for investment migration<br />

pathways due to changing attitudes.<br />

We see rising awareness around<br />

Environmental, Social, and Governance<br />

(ESG) risks across other industries, and<br />

now in investment migration as well.<br />

With a whole-population approach<br />

toward monitoring and analysis, adverse<br />

media and enforcement actions could<br />

identify rising risk in a particular region<br />

related to violations such as forced labor<br />

or unsafe working conditions. If an<br />

RCBI programme is aware of this risk<br />

early, they can not only develop targeted<br />

strategies to reassess previously approved<br />

applicants with such red flags or in that<br />

particular region, but also incorporate<br />

those strategies into the risk framework<br />

going forward for new applicants.<br />

Monitoring is now widely embraced<br />

by investment migration pathways. The<br />

next big step is consolidating that data<br />

and analysis for all applicants centrally,<br />

allowing programmes to take a holistic view,<br />

looking forward to continuously improve<br />

and refine their compliance programmes.<br />

Doing so will demonstrate to the industry,<br />

and to the general public, that they are<br />

prepared to address the changing risk<br />

landscape and committed to accepting<br />

only the highest quality applicants.<br />

BIO<br />

Karen Kelly is Director of<br />

Strategy & Development for<br />

Exiger’s Immigration, Citizenship, and<br />

Visa (ICV) Practice. She has 14 years<br />

of experience managing due diligence<br />

solutions for residence- and citizenshipby-investment<br />

(RCBI) programs,<br />

financial institutions, and corporations,<br />

as well as developing specialized<br />

due diligence training programs.<br />

She also helped lead a large-scale RCBI<br />

program review focusing on policies<br />

and procedures, workflow, operational<br />

support, and system implementation.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 49

<strong>IM</strong> YEARBOOK<br />

What HNWIs need to know about<br />

Canada’s Start-Up Visa<br />

Ronit Sharma, Founder & Managing<br />

Director of Immigrant Investor<br />

Group, outlines the key advantages of<br />

Canada’s Start-Up Visa Programme.<br />

Canada is a G7 country with one of the<br />

world’s best performing economies<br />

over the past decade. It offers a<br />

cosmopolitan, family friendly lifestyle<br />

with several world-class cities that provide<br />

well diversified business environments,<br />

excellent education institutions, vibrant<br />

social scenes, and a wealth of cultural<br />

events. These are some of the reasons<br />

why Canada is a popular place for startups,<br />

entrepreneurs and innovators.<br />

The Start-Up Visa Programme<br />

(SUVP) to Canada is the premier investor<br />

immigration programme to Canada, which<br />

is currently being used by high-net-worth<br />

Individuals (HNWIs) seeking a long-term<br />

residency / citizenship plan for their family.<br />

From pilot to permanent<br />

In 2013, the Government of Canada<br />

launched the SUVP to Canada as a pilot<br />

programme and in 2018, the programme<br />

was made permanent. The objective<br />

of the programme is to attract talented<br />

entrepreneurs to Canada who have<br />

innovative and technology-related ideas<br />

which may be successfully launched in<br />

Canada. The SUVP is sector agnostic as<br />

long as the start-up is innovative, unique<br />

and disruptive, thereby qualifying and<br />

meeting the government’s guidelines.<br />

The government has trusted various<br />

Designated Organizations (DOs) such<br />

as incubators, angel groups and venture<br />

capital groups to administer and mandate<br />

the programme. The role of the DO is to<br />

ensure that start-ups meet the government’s<br />

criteria and make a minimum investment.<br />

They also need to issue a letter of support,<br />

which will then be submitted with the<br />

applicant’s immigration application. The<br />

investment requirements with the DO’s<br />

are limited to the angel group stream<br />

and venture capital group stream and are<br />

CA$75,000 and CA$200,000 respectively.<br />

Co-investment and<br />

co-partnership<br />

What is unique about the SUVP to<br />

Canada is that the government allows<br />

for co-investment and co-partnership<br />

structures with a maximum of five<br />

individuals per startup. Most applicants<br />

in the queue applied for the incubator<br />

stream, which is the easiest and least<br />

expensive route to apply as no investment<br />

capital is required. This, however, allows<br />

for low quality start-ups in the system, and<br />

unfortunately, there is a greater chance<br />

of being rejected. Immigrant applicants<br />

should be cognizant of the offerings in<br />

the marketplace and should not focus<br />

on the price. Instead, the focus should<br />

be on the genuineness and viability of<br />

the start-up and ensure that the required<br />

early-stage capital is being raised.<br />

Over the past decade, second<br />

residency and second citizenship<br />

programmes have expanded globally.<br />

However, investor immigration to Canada<br />

has been in existence for approximately<br />

30 years and has always been a top<br />

choice among HNWIs. Canada does<br />

not offer immediate global mobility<br />

but a medium to long term second<br />

residency solution so the children<br />

can study, real estate investments<br />

can be made, business opportunities<br />

can be explored and eventually a<br />

retirement plan can be crafted.<br />

From a North American standpoint,<br />

the SUVP competes directly with the US<br />

EB 5 Immigrant Investor Programme<br />

which is currently priced at US$800,000.<br />

In this regard, the SUVP to Canada is<br />

priced quite competitively in the range of<br />

CA$250,000 to CA$350,000. Immigrant<br />

Investor Group Inc. works with a few<br />

select angel groups and venture capital<br />

groups who have real start-ups that<br />

require early-stage capital to launch.<br />

Increased quota allocation<br />

The current official government processing<br />

time to obtain Canadian permanent residency<br />

under the SUVP to Canada is 32 months.<br />

However, in October 2022, the government<br />

aggressively increased the quota allocation<br />

for applications under the SUVP over the<br />

next three years, and it is anticipated that the<br />

processing times will come down again to<br />

18 to 24 months. One major advantage of the<br />

SUVP to Canada is that once an applicant<br />

receives Canadian permanent residency, it is<br />

unconditional from the first day. Therefore,<br />

even if the start-up fails, the applicant will<br />

retain their Canadian permanent residency.<br />

The SUVP to Canada has essentially<br />

replaced the Quebec Immigrant Investor<br />

Programme where immigrant applicants had to<br />

invest CA$1,200,000 to the government for five<br />

years at zero percent interest which was funded<br />

via a one-time finance payment of CA$360,000.<br />

The last intake period of the Quebec Immigrant<br />

Investor Programme was August 2019.<br />

In conclusion, the SUVP to Canada is<br />

a win-win programme. Canada’s start-up<br />

ecosystem can develop the next unicorns<br />

and high-net-worth families can obtain<br />

Canadian permanent residency which will<br />

eventually lead to Canadian citizenship.<br />

Ronit Sharma is the Founder<br />

BIO & Managing Director of<br />

Immigrant Investor Group Inc. Ronit<br />

Sharma also serves as a Global<br />

Director for Immigration Solutions<br />

Law Group, Global Partner for JTH<br />

Lawyers Inc. and Strategic Partner of<br />

Latitude Residency & Citizenship.<br />

50 - Investment Migration <strong>Yearbook</strong> 2O23

INVESTOR <strong>IM</strong>MIGRATION<br />


START UP<br />


to Canada<br />

Angel Stream<br />

Incubator Stream<br />

Venture Capital Stream<br />

Ronit Sharma<br />

Founder & Managing Director<br />

Immigrant Investor Group Inc.<br />

Canada Mobile / WhatsApp: +1.647.295.7664<br />

ronitsharma@immigrantinvestorgroup.com<br />

www.immigrantinvestorgroup.com<br />

*please get in touch to review B2B collaboration opportunities*<br />





<strong>IM</strong> YEARBOOK<br />

From Permanent Residence to the Nomad Residence Permit:<br />

Malta keeps on innovating<br />

Malta is one of the most popular destinations and jurisdictions for second<br />

residency, and the country’s appeal as a place to relocate to remains high. The<br />

<strong>IM</strong> <strong>Yearbook</strong> catches up with Charles Mizzi, CEO of the Residency Malta Agency,<br />

to understand how the agency has established itself as a leader in the industry.<br />

like charity, begins at<br />

home,” says Charles Mizzi, “and<br />

“Success,<br />

this is one of the principles<br />

on which Residency Malta is built. The<br />

Agency actively invests in the people who<br />

make it what it is, and this holistic view<br />

of development has helped propel the<br />

Malta Permanent Residence Programme<br />

(MPRP) towards its continued success.”<br />

With the firm belief in people<br />

development as an important business<br />

driver, over the past year, Residency Malta<br />

has continued training its staff and investing<br />

in its HR, as a way of refining its work and<br />

delivering output of the highest standards.<br />

“Whether it’s customer service, investigative<br />

analysis or technical skills, our people<br />

need to be at the forefront of their area of<br />

expertise, so that we can add value to every<br />

stage in the application process,” says Mizzi.<br />

The Agency simultaneously invested in<br />

its IT systems, enabling more streamlined<br />

and efficient operations and an overall<br />

improvement in processing time. “We<br />

are now promising a four- to six-month<br />

processing time for the MPRP without<br />

compromising on due diligence,” he<br />

adds. “This brand promise has become<br />

an important feature of our programme<br />

and an effective selling point.”<br />

Service to agents<br />

MPRP applications may only be submitted<br />

to Residency Malta via licensed agents.<br />

“Our relationship with agents is crucial<br />

to the management of the MPRP,”<br />

highlights Mizzi. The agency continues<br />

to strive towards more communication<br />

with agents to keep them updated, while<br />

listening to their feedback, exchanging<br />

ideas and working towards a better<br />

product for everyone involved.<br />

Towards this end, Residency Malta<br />

recently launched an Agents’ Portal, a<br />

useful tool which allows agents to securely<br />

check the status of their applications, while<br />

also giving them access to other data and<br />

reports that help them organise their work.<br />

“This aspect of our digitalisation has also<br />

added value both to agents and their clients<br />

and has allowed us to keep our promise<br />

of quality and value for anyone who gets<br />

in touch with Residency Malta,” he says.<br />

Product diversification<br />

Malta is a treasure trove of opportunities,<br />

and Residency Malta has taken upon itself<br />

the role of making sure this is properly<br />

marketed and availed of. Staying in touch<br />

with the dynamic market is one of the ways<br />

in which the agency diversifies its product<br />

and makes sure to unlock the full potential<br />

Malta has to offer to the right applicants.<br />

The launch of the Nomad Residence<br />

Permit is one such example of this. In<br />

2021, Residency Malta began offering<br />

a one-year residence permit for digital<br />

nomads from non-EU countries. This<br />

product was successful not only in terms<br />

of numbers, but also in its ranking on<br />

international sites. The agency – in<br />

collaboration with the country’s business<br />

promotion body, Malta Enterprise – also<br />

launched a Startup Residence Programme,<br />

for individuals from third countries who<br />

would like to use Malta as a launch pad<br />

for their innovative startup and scale up.<br />

Malta’s attractions<br />

“All our programmes offer a strong<br />

proposal with added value,” says Mizzi.<br />

“But a contributor to our success is<br />

Malta itself. We are offering residency<br />

on an island that builds a balanced bridge<br />

between Mediterranean island life and a<br />

metropolitan lifestyle. English is a national<br />

language making communication between<br />

locals and expats easy. Our history and<br />

heritage have given the island its character,<br />

and this has continued to evolve with<br />

the times. Our local infrastructure is<br />

constantly improving, and the digital<br />

infrastructure is ideal for those wishing<br />

to work remotely from our shores.”<br />

Malta is also ideal for family relocation.<br />

The island is safe and family-oriented,<br />

boasts one of the best healthcare systems in<br />

the world and offers a variety of educational<br />

institutions in addition to easy flight<br />

connections and access to the rest of the EU.<br />

Meanwhile, Malta has reaped great<br />

benefits from the agency’s success, with<br />

revenue invested in the Consolidated Fund<br />

and the National Development Social Fund,<br />

which in turn provide important financing<br />

for Malta’s infrastructure, health, education,<br />

heritage, and philanthropic projects.<br />

“Residency Malta has one mission<br />

– unlocking Malta’s potential as a home<br />

away from home while adding value to our<br />

country. We will continue to push towards<br />

efficiency, transparency and integrity, while<br />

keeping our solutions fresh in a highly<br />

dynamic market,” Mizzi concludes.<br />

52 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Portugal:<br />

Europe’s New “California”<br />

American interest in Portugal is at an all-time high.<br />

Frederico Seixas, Sales Director of Investaureum, explains why.<br />

The Portuguese Golden Visa has<br />

never been as popular as it is<br />

now. According to the Portuguese<br />

Immigration and Border Service (SEF),<br />

in the first eight months of 2022, US<br />

citizens accounted for 17.5% of all golden<br />

visa applications. They consider the<br />

programme an easy route to establish<br />

residency in Europe as it offers them<br />

mobility in Europe, a solid plan B, and<br />

possibly a profitable investment. In fact, the<br />

Alentejo region in Portugal has recently<br />

been dubbed the Portuguese “Napa<br />

Valley”, and we have seen huge interest<br />

from the US in our two Alentejo projects.<br />

There are, of course, various reasons<br />

why Americans are leaving their country.<br />

Here is an excerpt from an article in the<br />

New Yorker: “Our democracy is in crisis.<br />

Many institutions of our government are<br />

dysfunctional and getting worse. Our<br />

electoral system has produced, in a single<br />

generation, two Presidents who received<br />

fewer votes than their opponents. A changed<br />

media landscape has – with the shrewd<br />

assistance of malicious actors at home and<br />

abroad – loosened our collective grasp on<br />

reality. Our politics have become alarmingly<br />

acrimonious. … Technology is enriching<br />

some and leaving many others behind.”<br />

Residence Permits (ARI) US Applicants - Years 2021 & 2022<br />

30<br />

20<br />

10<br />

0<br />

N/A<br />

N/A<br />

N/A<br />


54 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

US applicants’ share of overall Portugal<br />

golden visas (approved applications)<br />

20<br />

5,2% 6,3% 11,6% 17,5%<br />

15<br />

10<br />

5<br />

0<br />

JUN 2020 2021 2022 (Jan-Aug)<br />

US investors in Portugal<br />

fall typically into five<br />

main categories:<br />

• Retirees<br />

• Plan B seekers<br />

• Digital nomads<br />

• Parents of children<br />

living in Europe<br />

• Crypto investors<br />

RETIREES. The Annual Global<br />

Retirement Index 2022 has named Portugal<br />

the fourth best country for retirement.<br />

Portugal has great weather, a central<br />

location, good connections to the rest of<br />

Europe, a safe society, great health and<br />

education, as well as a relatively affordable<br />

cost of living. Many Americans dream of<br />

spending their retirement years travelling<br />

within Europe. Portugal’s Golden Visa<br />

ensures seamless travel on the continent.<br />

PLAN B SEEKERS. In today’s world,<br />

having a plan B is no longer an option.<br />

It is a requirement. Considering the<br />

current political and social atmosphere,<br />

having a plan B in a calm and stable<br />

country has become more important<br />

than ever. According to the Global<br />

Peace Index 2021, Portugal is the fourth<br />

safest country in the world. This is a<br />

huge motivation for investors who want<br />

to secure their family’s future in a safe<br />

country. Apart from security, the quality<br />

of life, education, and health care in<br />

Portugal are among the best in Western<br />

Europe, accompanied by a nice and mild<br />

climate and many world-class beaches.<br />


STUDYING IN EUROPE. The pandemic<br />

has brought about travel and visa<br />

limitations for many wealthy American<br />

parents, who were suddenly not allowed<br />

to make short trips to visit their children<br />

working or studying in Europe. It turns<br />

out that this temporary confinement<br />

has triggered demand among affluent<br />

parents for more permanent solutions<br />

that allow unrestricted travel to Europe.<br />

DIGITAL NOMADS. In addition to the<br />

Golden Visa, Portugal recently launched<br />

a one-year digital nomad visa. Remote<br />

workers are now able to live and work<br />

in the country for up to 12 months. To<br />

qualify, applicants must earn at least<br />

€2,800 per month – roughly four times<br />

Portugal’s minimum wage. Of course,<br />

the Portuguese Golden Visa continues to<br />

be attractive for US-born digital nomads<br />

who want to establish a base in Europe.<br />

CRYPTO INVESTORS. Investors who<br />

want to secure their crypto earnings<br />

through a tangible asset, should consider<br />

the real estate option under Portugal’s<br />

Golden Visa. Investors can also opt<br />

for Portugal Golden Visa investment<br />

funds if they are already familiar with<br />

non-traditional investments. There are<br />

funds that focus on crypto investments.<br />

In Portugal, traders and investors aren’t<br />

subject to certain taxes on their crypto<br />

earnings. Also, the crypto community in<br />

the country is growing, which means that<br />

investing in the country opens the door to<br />

all kinds of networking opportunities.<br />

The Bottom Line<br />

The Portugal Golden Visa stands<br />

out because of its flexibility. It allows<br />

for various investment methods that<br />

cater to different styles of investment.<br />

Moreover, Portugal is calm, safe,<br />

welcoming, and generally a pleasant<br />

place to live. Welcome to Portugal!<br />

Frederico Seixas is the<br />

BIO Sales & Marketing Director<br />

of Investaureum. He has 25 years<br />

of experience in the real estate<br />

sector, of which seven are directly<br />

with the investment migration<br />

industry. The Investaureum Group is<br />

a Portuguese Real Estate Investment<br />

Group, specialised in Prime/Unique<br />

Real Estate Chartered/Heritage<br />

investments that are eligible for the<br />

Portugal Golden Visa programme.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 55

<strong>IM</strong> YEARBOOK<br />

Interview with Austin T. Fragomen Jr, Chairman Emeritus at Fragomen<br />

The global race for<br />

high-potential migrants<br />

is heating up<br />

Austin Fragomen shaped modern immigration<br />

practice like no other and built the largest migration<br />

focused legal firm in the world. In January <strong>2023</strong>, he<br />

has passedon the leadership of the firm to Lance<br />

Kaplan and Enrique Gonzalez. The <strong>IM</strong> <strong>Yearbook</strong><br />

caught up with Austin Fragomen to relive some<br />

of his career highlights and gain his thoughts on<br />

the current trends influencing global migration.<br />

What memories or<br />

recollections do you<br />

have of your entry into<br />

immigration law?<br />

As a law student I was very interested<br />

in international law, and I took as many<br />

international law courses as I could.<br />

When I graduated from law school, I<br />

went to work for the house judiciary<br />

committee, the US house representatives,<br />

and I became the staff council to the<br />

immigration subcommittee. Back then,<br />

the US immigration system was very<br />

much focused on family reunification<br />

and humanitarian immigration, and<br />

although it had some allowance for<br />

business immigration, this was limited.<br />

56 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

When I arrived at the Committee in the<br />

1970s, the big issue was how corporations<br />

could move people around the world. It<br />

was very laborious because there was no<br />

non-immigrant category that allowed<br />

for work on a temporary basis. I got<br />

involved in making changes to certain<br />

visa categories to ease the process.<br />

I thought this was a big growth<br />

opportunity, which turned out to be<br />

accurate. In the years that followed,<br />

companies really embraced these new<br />

methods and opportunities to move people<br />

around the world. We then decided to<br />

build an immigration practice, which had<br />

two prongs to it: the private client and the<br />

corporate practice. And we maintained<br />

this dual approach throughout the years.<br />

Fragomen was founded<br />

in 1951 as Elmer Fried.<br />

Looking back, during which<br />

period did you experience<br />

the greatest growth?<br />

In 1990, there was a major reform of the<br />

immigration Act, which greatly increased<br />

the number of visas allotted to business<br />

immigration and created the EB-5<br />

category in the US. That provided a lot<br />

of additional opportunities. Previously,<br />

the US didn’t really have a programme<br />

for investment migration. Back then that<br />

space was dominated by some Caribbean<br />

countries, South American countries, and<br />

some other obscure places that I found<br />

most of the investors didn’t know where<br />

they were. I remember someone in Hong<br />

Kong once asked whether world maps<br />

are handed out along with the visas so<br />

that the investors knew where to go.<br />

Meanwhile, we saw big demand<br />

for global representation from major<br />

corporations. They, of course, had<br />

operations around the world and asked us to<br />

represent them. We did that first through cocouncel<br />

in places like Canada, the UK and<br />

Brazil. Then, in 1999, we opened our first<br />

foreign office in Belgium and subsequently<br />

got more involved in global emigration and<br />

represented people moving out of the US.<br />

The private client side only got<br />

international following the introduction<br />

of the US EB-5 regional centre programme<br />

in 2005. Before that, the EB-5 system in the<br />

US was not very popular, it just had around<br />

1,000 applicants per year. It simply was too<br />

complicated since investors had to have an<br />

active business with at least 10 employees<br />

What strategy did you<br />

apply to scale the firm and<br />

transform it from being a<br />

small boutique law firm<br />

into a global organisation?<br />

In most countries, we were co-counseling<br />

with another law firm initially. We only<br />

opened our own office when we had<br />

enough critical mass. Frequently, the<br />

co-counsel would merge into our firm.<br />

Of course, the situation was a little bit<br />

different in each country. For instance,<br />

after PwC in Australia decided to<br />

divest themselves of their consulting<br />

businesses in the early 2000s, we bought<br />

the immigration business from them.<br />

We never opened an office and then<br />

tried to get clients. We always made sure<br />

we had clients first. Our clients were<br />

mainly the global operations of US-based<br />

companies that we represented, so this<br />

made it easy to expand. Once the US<br />

regional centre system was established,<br />

we were able to look at US immigration.<br />

The first country – besides the Caribbean<br />

islands – which had a robust and active<br />

immigration system was Canada. We used<br />

that particularly for Asian and South African<br />

clients. As the residency and citizenship by<br />

investment sector really took off, it became<br />

a large part of our private client business.<br />

What can you tell us about<br />

Fragomen’s footprint today?<br />

We now have a staff count of some 6,000<br />

people. The important thing is that through<br />

various layers of subsidiaries, we own all<br />

the offices that we have throughout the<br />

world, except for a few locations in Latin<br />

America where we have a network of<br />

providers with whom we have a different<br />

economic arrangement. Ultimately, we’d<br />

like to have offices in all the principal<br />

countries where there is enough activity<br />

and that warrant to have an office.<br />

We have a handful of locations where<br />

we are going to be opening offices. We<br />

were a little bit late in South-East Asia, so<br />

we recently opened an office in Thailand,<br />

and will probably be opening offices in the<br />

Philippines and in Japan next. We didn’t<br />

have a good coverage there before. We<br />

had offices in Singapore, Malaysia, and<br />

China. We thought at some point we will<br />

have offices across China, but right now the<br />

business in China is impacted due to all<br />

the Covid-19 the restrictions. Importantly,<br />

however, in many countries we managed<br />

to build up local business, even in China<br />

we represent several Chinese companies<br />

for immigration purposes around the<br />

world. We are competing with the Big Four<br />

primarily, not with other law firms. They<br />

have offices everywhere, so it’s important<br />

for us to have offices in major locations<br />

that offer a certain volume of work too.<br />

2022 marked the year where<br />

geopolitical tensions moved<br />

centre-stage again, and the<br />

economic outlook for <strong>2023</strong><br />

has turned sour. How do you<br />

think this climate will affect<br />

investment migration?<br />

The prospect of a recession hasn’t<br />

really impacted employment so far,<br />

but it will to a degree. We can expect<br />

that to happen, but it is not going to be<br />

anywhere near the impact that Covid-19<br />

or the 2008/2009 financial crisis had.<br />

More importantly, labour migration is a<br />

growing business, regardless of what’s going<br />

to happen to the economy. As long as we have<br />

population growth, labour migration will<br />

grow too. In fact, if you track the number of<br />

labour migrants against population growth,<br />

the growth line is pretty much the same.<br />

I think countries will really start<br />

focusing on the skill gap problem that<br />

they have. Many countries need people<br />

with specific skills. However, their<br />

educational and training systems lag<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 57

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<strong>IM</strong> YEARBOOK<br />

behind and countries are not able<br />

to fill those needs domestically. On<br />

top of it, there is the demographic<br />

problem, with several countries just<br />

not having enough workers. On the<br />

other hand, many developing countries<br />

are experiencing strong population<br />

growth. Therefore, migration will be a<br />

major factor moving into the future.<br />

How can host countries best<br />

try to attract skilled workers?<br />

I think countries need to and will start<br />

institutionalising their need for migrants,<br />

and they will further decouple work visas<br />

from employment. Some countries have<br />

already launched programmes to attract<br />

high-potential migrants. An example<br />

is the UK’s ‘High Potential Individual<br />

Visa’, through which graduates of the<br />

world’s top universities can get a work<br />

permit in the UK without having a job<br />

offer. Elsewhere, in 2021, Canada allowed<br />

about 50,000 foreign students to stay<br />

for 18 months after graduation to seek<br />

employment, during a time when the<br />

economy was reopening from Covid<br />

shutdowns and companies needed to hire.<br />

I am certain we are going to see<br />

a lot more international cooperation.<br />

Countries will work closely together to<br />

place job seekers across borders. The<br />

Global Compact for Migration, which has<br />

been adopted by most of the countries in<br />

the world, sets up best practices for every<br />

aspect of migration. For the first time<br />

countries are really coming together and<br />

talking about how they can use migration<br />

as a tool for development. Moreover,<br />

there’s a parallel UN Organisation called<br />

the Global Forum on Migration and<br />

Development. I am the chairman of the<br />

private sector group in the Global Forum<br />

on Migration and Development, so I do<br />

a lot of work with different countries<br />

around the world on migration policy.<br />

We see a lot more coordination and<br />

transparency, as well as sharing of best<br />

practices. This is very different compared<br />

to the situation a few years ago.<br />

Yet immigration remains<br />

one of the most controversial<br />

policy issues in many parts of<br />

the world, including the US<br />

and Europe. What thoughts<br />

would you like to share about<br />

migration, public opinion,<br />

and political support?<br />

I think that the general attitude<br />

towards immigration is becoming more<br />

positive in the sense that people are<br />

realising that countries require some<br />

level of immigration. I think Covid-19<br />

helped in a weird way because in<br />

many developed countries, immigrants<br />

made up a large part of the ‘essential<br />

workers’ that kept everything moving.<br />

Moreover, countries are making<br />

statements about their need for<br />

immigration. For instance, Japan just said<br />

they need more people because they have<br />

a massive shortage of workers. Of course,<br />

what’s negative is irregular immigration.<br />

Since Donald Trump has announced<br />

that he wants to run for president again,<br />

I think we will have several more years<br />

of intense analysis of immigration<br />

in the US. Europe has substantial<br />

problems with irregular immigration<br />

too, but I think overall the attitude<br />

towards immigrants is slightly better.<br />

In a previous interview<br />

with the <strong>IM</strong> <strong>Yearbook</strong>, you<br />

were not very convinced<br />

that start-up, entrepeneur<br />

or innovator visas would be<br />

economically successful.<br />

Today, almost every country<br />

runs these programmes.<br />

Have you noticed any<br />

significant improvements?<br />

There’s a renewed interest in these<br />

programmes as countries are trying to<br />

attract innovators and entrepreneurs to<br />

create jobs. But I am still of the opinion<br />

that no one has figured out how to run<br />

them. How do you identify people who<br />

are the process of being successful?<br />

Some programmes look at how much<br />

money a start-up has attracted from<br />

angel investors. However, the presence<br />

of venture capital doesn’t mean that you<br />

are going to have a successful company.<br />

However, I think we are going to<br />

see more digital nomad programmes,<br />

which are going to allow people to live<br />

somewhere and not have to make an<br />

investment. I think that offering will<br />

compete to some extent with traditional<br />

investment migration programmes.<br />

India is currently one of<br />

the hottest markets for<br />

investment migration.<br />

Yes, what’s interesting about India is that<br />

there’s a lot of circular migration. We<br />

see a lot of Indians coming to the US to<br />

study because they think they have more<br />

opportunities here and it’s a good career<br />

steppingstone for them, but many of them<br />

are returning to India, where they set up<br />

their own companies or take up senior<br />

positions in large Indian companies.<br />

It’s one of the big success stories in the<br />

migration field: People leaving a country,<br />

acquiring a higher level of education,<br />

and then returning and applying<br />

those skills in their home country.<br />

What key lessons have<br />

learned along the way that<br />

would you like to share with<br />

practitioners across the world?<br />

From my experience, and in retrospect, I can<br />

say that recessions or other forms of turmoil<br />

only have a minimal impact on migration.<br />

The one thing that we really need to be<br />

aware of are politicians who can be harmful<br />

to the migration system due to their general<br />

xenophobia. They are the people that as an<br />

industry we really must be concerned about.<br />

What are your plans for your<br />

retirement? I find it hard to<br />

believe that someone like<br />

you will just sit back and<br />

enjoy the Florida sunset.<br />

I will certainly keep my affiliation with my<br />

firm as chairman emeritus. My plan is to<br />

continue being involved in migration policy.<br />

I will be somewhat less involved with clients,<br />

but I will offer advice at the policy level and<br />

support organisations such as the <strong>IM</strong>C.<br />

BIO<br />

Austin Fragomen is Founder<br />

and Chairman of the<br />

Executive Committee for Fragomen,<br />

one of the world’s leading law firms<br />

dedicated exclusively to immigration<br />

services worldwide. Established in<br />

1951, Fragomen has grown from a<br />

respected domestic US immigration law<br />

practice to a truly global organisation.<br />

Austin has served as staff counsel<br />

to the US House of Representatives<br />

subcommittee on immigration,<br />

citizenship and international law and<br />

as an adjunct professor of law at<br />

New York University School of Law.<br />

Also, he has testified before Congress<br />

on a range of immigration issues<br />

and before the immigration subcommittees<br />

of the House and Senate<br />

to share his knowledge on a variety<br />

of business immigration issues.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 59

<strong>IM</strong> YEARBOOK<br />

Women, Wealth and<br />

Investment Migration<br />

Women’s economic power and financial independence<br />

are growing rapidly around the world, yet they are often<br />

overlooked by the financial and wealth management industry.<br />

The <strong>IM</strong> <strong>Yearbook</strong> asked four experts: how well are<br />

women served in an investment migration context?<br />

Investment migration – much like the<br />

entire wealth management industry<br />

– is geared towards a predominantly<br />

male clientele. Since, historically, men<br />

were the main income earners and<br />

entrepreneurs, they were also making<br />

most investment and financial decisions.<br />

However, women’s wealth is growing.<br />

McKinsey found out that women already<br />

control more than a third of total US<br />

household assets, and their portion is<br />

expected to grow throughout the coming<br />

generational wealth transfer. In the UK,<br />

60% of wealth will be in female hands by<br />

2025, according to a forecast by the Centre<br />

for Business and Economic Research.<br />

In recent years, financial service firms<br />

and wealth advisors have made a concerted<br />

effort to attract more women investors,<br />

who today are assuming more powerful<br />

roles in personal and family investing and<br />

decision making. This raises the question:<br />

have investment migration consultancies<br />

also noticed a rise in female clients?<br />

On the rise<br />

Alexander Varnavas, managing<br />

partner at Varnavas law firm in<br />

Greece, comments: “For the past two<br />

years, women have formed 40% of our<br />

clientele, which is an increase from the<br />

first years operating in the investment<br />

migration industry in Greece. Even<br />

though the rest of the 60% is technically<br />

male-dominant, this does not imply that<br />

their significant others had no major role<br />

in the planning and execution of their<br />

investment plans through our services.”<br />

He adds that his firm had<br />

“executive-level men entrusting<br />

their sisters, spouses or daughters to<br />

manage million-dollar investments<br />

on their behalf, or more accurately,<br />

with minimum involvement from<br />

them, as they entrust women in their<br />

lives to manage the whole process”.<br />

Paul Williams, CEO of La Vida, said<br />

he hasn’t noticed a particular shift.<br />

“We treat everyone the same and<br />

find their needs are similar,” he said. In<br />

family applications, “the main applicant<br />

is sometimes the husband, sometimes<br />

the wife”. However, in terms of single<br />

applications, women are in the minority. “I<br />

would say far less than men, possibly 10%.”<br />

Jennifer Lai, Wealth & Residency<br />

Planning Managing Director at DL<br />

Holdings Group, says that around half<br />

of her clients are women. She adds that<br />

traditionally Asian culture considers ‘men as<br />

breadwinners’ and ‘women as homemaker’.<br />

However, migration is seen as a family<br />

matter, and she has had many cases where<br />

the husband started the initial conversation<br />

and then leaving it to his wife to follow up.<br />

In addition, she says that among her<br />

clients she has had many successful female<br />

entrepreneurs, professionals and executives<br />

in senior management, either married<br />

or single. “They are the decision-makers<br />

on many aspects, including investment<br />

migration.” Lai concludes that women are<br />

60 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

playing a more important role in investment<br />

migration, not only as a result of the gender<br />

equality debate, but also because they have<br />

become more successful in business, which,<br />

in turn, has strengthened their position<br />

when it comes to family decision making.<br />

Different attitudes<br />

In the US, Edward Beshara, Managing<br />

Partner of Beshara Global Migration Law<br />

Firm, also saw the percentage of female<br />

clientele growing from around 25% a few<br />

years ago to 35% today. But the change is<br />

not just in the numbers: “While female and<br />

male clients usually have the same business<br />

and immigration goals, women are detail<br />

oriented in regard to the particulars of<br />

the investment and will always use dual<br />

diligence to the extreme by reviewing<br />

the details and processes of investment<br />

migration,” he said. Lai also perceives<br />

women as detail-oriented, assessing and<br />

analysing every step of the process. Male<br />

clients, she says, do not focus so much on the<br />

process but look more into the end results.<br />

Analysing women’s relationship and<br />

attitudes towards the wealth management<br />

sector, EY pointed out that many women<br />

view the industry as male-oriented and<br />

unwelcoming. Meanwhile, a research<br />

study commissioned by Merrill, “Seeing<br />

the Unseen: The Role Gender Plays in<br />

Wealth Management,” took an expansive<br />

view of the subject, delving into the stories<br />

of women investors and their financial<br />

advisors. Among the study’s findings are<br />

that only 8% of women investors have<br />

experienced negative gender assumptions<br />

from their financial advisors and that<br />

such incidences of bias are usually subtle.<br />

But, as the research emphasises, there<br />

are multiple areas of unconscious bias,<br />

underscoring the need for advisors and<br />

executives to evaluate their own behaviors.<br />

The status quo<br />

Varnavas says “a lack of accommodation for<br />

women” in an investment migration context<br />

would not surprise him. “Unfortunately,<br />

women still have to deal with misogynistic<br />

practices. For centuries it had become<br />

normalised to underestimate them,<br />

and many professionals up to now have<br />

not adapted and openly accepted that<br />

businesswomen have a profound position<br />

in every industry,” he adds. He believes his<br />

firm is on a solid path. “Even though it was<br />

not deliberate, our establishment is made<br />

mostly of female professionals,” he adds.<br />

While most women do not explicitly<br />

look for female advisers, many place a<br />

high value on establishing a personal<br />

connection with their adviser. Varnavas’<br />

firm contracted 80% of the businesswoman<br />

who approached the firm in 2022. “Our<br />

corporate strategy is about taking every<br />

inquiry seriously. We communicate with all<br />

of our clients promptly, we do put the time<br />

to answer thoroughly, and we ensure that<br />

we respect the intelligence and boundaries<br />

of clients in our follow-up routines.”<br />

Lai also said her firm has “successfully<br />

connected with women on the personal<br />

level and on the coroproate level”. However,<br />

she does not think she needs to change<br />

her service provision to “serve by gender”.<br />

For her, it’s always about providing<br />

quality and professional services that<br />

are in tune with the client’s demands<br />

and interests, irrespective of gender.<br />

A long list of male-focused industries,<br />

such as automobiles and real estate, have<br />

revamped their product and service models<br />

to meet women’s needs in recent years. As<br />

unprecedented sums of assets shift into<br />

the hands of women over the next decade,<br />

consultancy firms in the investment<br />

migration space have no choice but to ensure<br />

they attract and retain women investors.<br />

BIOS<br />

Edward Beshara is the Managing<br />

Partner of Beshara Global Migration<br />

Law Firm. He represents corporate<br />

and individual clients from all<br />

countries worldwide in regard to their<br />

business and family US visa goals.<br />

Jennifer Lai is the Managing Director<br />

of Wealth and Residency Planning<br />

at DL Holdings in Hong Kong. She<br />

previously worked for more than 10<br />

years at Henley & Partners and held<br />

various roles during that time.<br />

Alexander Varnavas is the Managing<br />

Partner of Varnavas Law Firm 1978<br />

and a leading lawyer in real estate<br />

and investment migration law. He<br />

has introduced the private client<br />

practice of the firm, representing<br />

HNWI and UHNWI to invest in Greece.<br />

Paul Williams is founder and CEO of<br />

La Vida. He qualified as a Chartered<br />

Accountant and held several senior<br />

positions at multi-national companies<br />

before forming La Vida in 2002.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 61

<strong>IM</strong> YEARBOOK<br />

How migration policy<br />

can accelerate recovery from<br />

the global economic downturn<br />

Dr Khalid Koser, Executive Director of the Global Community Engagement<br />

and Resilience Fund, says migration is critical for growth while the economic<br />

importance of highly skilled migrants far outweighs their numerical significance.<br />

The Covid-19 pandemic and the<br />

conflict in Ukraine have distracted<br />

and distorted global migration<br />

policy and diverted resources away<br />

from it; with lasting implications which<br />

will become exposed during the global<br />

economic downturn and slow its recovery.<br />

Globally, migration came to a<br />

standstill during the pandemic; by<br />

April 2020 more than half the world’s<br />

population was under some form of<br />

lockdown. Continuing restrictions<br />

on entry and exit in some parts of the<br />

world (especially China), social and<br />

economic impacts of the pandemic<br />

which have exacerbated poverty,<br />

changes in work patterns and lifestyle<br />

choices, and continuing disruption<br />

to airline schedules and pricing, are<br />

all factors why migration has not yet<br />

recovered to its pre-pandemic rates.<br />

Focus on Ukraine<br />

The conflict in Ukraine has had significant<br />

migration impacts, particularly on<br />

mobility in and out of Russia, but almost<br />

the entire policy focus has been on the<br />

forced migration of about seven million<br />

people displaced internally, and a further<br />

approximately seven million refugees mainly<br />

to other European countries, many of whom<br />

have started to return. Ukrainians are not<br />

the majority of the world’s refugees, and<br />

globally the number of refugees is far fewer<br />

than the number of voluntary migrants.<br />

Migration is critical for global<br />

economic growth, providing labour,<br />

skills, and money. The failure to recover<br />

migration rates more quickly, as well as<br />

an understandable emphasis on refugees,<br />

will exacerbate the global economic<br />

downturn, and slow its recovery.<br />

Three Goals<br />

In the short term, global migration policy<br />

should have three goals. One is to ensure<br />

that workers can continue to migrate, inside<br />

but especially outside their countries.<br />

But this is challenging because during<br />

recessions, historically, migrants have<br />

tended to be scapegoated, with politics<br />

demanding that restrictions are increased<br />

while economics demands that they be<br />

lowered. A partial solution is to enable<br />

the many millions of migrant workers<br />

who lost their jobs during the pandemic,<br />

but mostly were unable to return home,<br />

to re-enter the labour market. As the<br />

furor over the Qatar World Cup reminds<br />

us, however, it is also essential that<br />

migrant workers’ rights are respected.<br />

The economic significance of highly<br />

skilled migrants far outweighs their<br />

62 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

The failure to recover migration rates more quickly, as well<br />

as an understandable emphasis on refugees, will exacerbate<br />

the global economic downturn, and slow its recovery.<br />

rarely fosters the serendipity required<br />

for innovation. Particularly important is<br />

to promote the migration of students, for<br />

example through expanded scholarship<br />

schemes, and to ease employment and<br />

residence requirements that often mean<br />

they cannot remain after their studies.<br />

US$500 billion<br />

numerical significance; and a second<br />

priority should be to ensure that talent can<br />

flow freely, accepting for the moment that<br />

the significant pools of talent in Russia and<br />

China currently remain largely inaccessible<br />

to the global economy. In certain sectors, for<br />

example financial services, the acceleration<br />

of online work because of the pandemic<br />

can resolve this challenge. But in others,<br />

like healthcare and education, people<br />

need to be present. One of the lessons of<br />

the pandemic is also that remote work<br />

One of the lessons of<br />

the pandemic is also<br />

that remote work rarely<br />

fosters the serendipity<br />

required for innovation.<br />

The pandemic and the wider implications<br />

of the Ukraine crisis, for example on<br />

global food supplies, have made more<br />

people more reliant on money traditionally<br />

remitted by migrants to their families at<br />

home. The World Bank estimates that in<br />

2021 over US$500 billion was remitted<br />

globally, and that remittances were<br />

recovering quickly following their collapse<br />

during the pandemic. A third target<br />

should be policies geared to maintaining<br />

the recovery of remittances, including<br />

increasing competition within the sector<br />

to drive down commission rates.<br />

Achieving these goals requires a<br />

re-allocation of financial and human<br />

resources to migration at the national,<br />

regional, and global levels. The return on<br />

investment will make that worthwhile: It<br />

will accelerate the recovery from the global<br />

economic downturn, but also promote the<br />

diversity of social and cultural exchanges<br />

that were lost to the pandemic and are at<br />

risk because of political extremism.<br />

Dr Khalid Koser is founding<br />

BIO Executive Director of the<br />

Global Community Engagement &<br />

Resilience Fund (GCERF). An academic<br />

by training, Khalid is Professor of<br />

Conflict, Peace and Security at<br />

the University of Maastricht. As a<br />

global advocate for migrants and<br />

refugees, he chaired the World<br />

Economic Forum Global Future<br />

Council on Migration for six years,<br />

edits the Journal of Refugee Studies,<br />

and was appointed MBE for services<br />

to asylum seekers and refugees.<br />

He chairs the Board of Trustees<br />

for the sustainable development<br />

charity Raleigh International.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 63

<strong>IM</strong> YEARBOOK<br />



PART OF THE <strong>IM</strong>CET<br />



SUCCESS!<br />

Below Is The Official List Of<br />

<strong>IM</strong> Certified Practitioners<br />

Adewole Adenle<br />

Darien Ellul<br />

Jude Clemoes<br />

Nevnihal El Afifi<br />

Stefanie Fetzer<br />

Aggelos Nizamis<br />

David Adeola Olabode<br />

Jusztina Rebeka Juhasz<br />

Nguyen Hai Yen<br />

Stewart Koesten<br />

Agnes Varga<br />

David Paillé<br />

Katarzyna Aldycka<br />

Nguyen Minh Tri<br />

Sue Nickason<br />

Aimee Lisle<br />

Dishita Sheth<br />

Kathy Rivera<br />

Nguyen Thi Lan Phuong<br />

Sylvania Tobierre<br />

Alan Huether<br />

Dmitry Dudarev<br />

Keith Isaac<br />

Nguyen Thi Minh Thu<br />

Sylwia Wolos<br />

Aleksandra Smolen<br />

Dmitry Shishkin<br />

Keni Ma<br />

Nguyen Thi Minh Trang<br />

Tajma Brown<br />

Alexander Zvarkovskiy<br />

Dom Barnes<br />

Kenny Arevalo-Lebrun<br />

Nikisha Delabanque<br />

Tertius Relihan<br />

Alexei Sakharov<br />

Eddy Leviten<br />

Kervin Leonice<br />

Nikkita Nair<br />

Tessy Ekpunobi<br />

Aliza Thompson-Nurse<br />

Edwina Keyser<br />

Khanh Do<br />

Nora Gomori<br />

Theodore Prillaman<br />

Analida Vallarino<br />

Eleni Acquarone<br />

Laila Alrasheed<br />

Olakitan Arogundade<br />

Theresa Okeke<br />

Anastasiia Chekina<br />

Eliot Brendon Mc Gillivary<br />

Laila El Orfi<br />

Opinder pal Singh<br />

Tishanna Higgins<br />

Anca Patrascu<br />

Elizabeth Davison<br />

Laura Austin<br />

Pablo Ostrick<br />

Trafford Busuttil<br />

Andres Gutierrez<br />

Elmarie Theron<br />

Lesikel Ali<br />

Patrick Ansah<br />

Tran Thi Truc Linh<br />

Andrew Hesner<br />

Erica Lake<br />

Lilla Krifaton<br />

Pelin Güngör<br />

Tran Tuan Anh<br />

Andria Petrou<br />

Evelyne Hantig<br />

Linda Boiteau<br />

Philip Paschalides<br />

Vadym Shevchenko<br />

Anna Ponte<br />

Fabia Francis<br />

Lisa McShine<br />

Pierre-Étienne<br />

Valentina Alekseyevna Sammut<br />

Asim Mahmood<br />

Gabriele Avellino<br />

Lucy Mckenzie<br />

Balthazar-Lacasse<br />

Valeriano Anibarro<br />

Audra DeFalco<br />

Gianella Farrugia<br />

Ludovic Mapessa<br />

Rachel Micallef<br />

Vanda Marlok<br />

Bobbi Jo Kutch<br />

Hangama Wanner<br />

Lukas Harries<br />

Rebecca Williams<br />

Vanessa Lima<br />

Bojana Minic<br />

Hanna-Liina Linnasmäe<br />

Madalena Monteiro<br />

Renee Pindar<br />

Varun Singh<br />

Bruno L’ecuyer<br />

Hassan Sattar<br />

Marcus Lionel<br />

Richard Jacks<br />

Veronica Bulat<br />

Caterina Assunta Passini<br />

Hudda Elmira Chehadé<br />

Maria Grech<br />

Roddy Denness<br />

Victor Lawson<br />

Cedric Leblanc<br />

Ibifuro Sekibo<br />

Maria Kouri<br />

Roderick Cutajar<br />

Victoria Atanasova<br />

Chameil Neecola Joseph<br />

Irene Davidson<br />

Marie Lou Cutajar<br />

Rohit Kapur<br />

Viviana Echeverria Pascual<br />

Chelita Virdee<br />

Irina Walsh<br />

Matteo Cicero<br />

Roleece Brookes<br />

Yanica Woods<br />

Cheryl Francis<br />

Jacques Plante<br />

Michael Martin<br />

Rosendo Guimaraes da Costa<br />

Yuan-Yu Hung<br />

Chris Siwei Chen<br />

James Muscat Azzopardi<br />

Michel Soler<br />

Samantha Julien-Fontaine<br />

Zachary Busuttil<br />

Christian Wayne<br />

James Swenson<br />

Mohamed Isaydou<br />

Samuel Morrell<br />

Zain Ahmad Butt<br />

Christina Georgaki<br />

Jamie Alleyne<br />

Mohammad Asghar Ali<br />

Sara Rebolo<br />

Zamaris Saxon<br />

Christopher Clowes<br />

Jaynelle Lake<br />

Mounir Bendaoud<br />

Sarah Young<br />

Zarah Gaba<br />

Claire Joseph<br />

Jennifer-Lynn Kent<br />

Mphuthumi Soga<br />

Sasha L’ecuyer<br />

Zeleka Peters<br />

Clare Monique Aquilina<br />

Jessica Debono<br />

Mtonya A. G. Deterville<br />

Sebastien Pham<br />

Zoe Dowe<br />

Dalia Akl<br />

Johannes du Toit<br />

Muhammed Yusuf Coban<br />

Seethalakshmi Ramanathan<br />

Community Malta Agency<br />

Daniel Ohana<br />

John Richardson<br />

Nani Yuningsih<br />

Shanda Toussaint<br />

Staff Members<br />

Daniel Saint-Davis<br />

Jose Luis Garcia Reyna<br />

Natalia Fridlender<br />

Shane Qu<br />

Residency Malta Agency<br />

Daniel Twomey<br />

Joshua Lake<br />

Neil O’Leary<br />

Sharlene Isaac-Louison<br />

Staff Members<br />

64 - Investment Migration <strong>Yearbook</strong> 2O23




“I’m excited about this new partnership with<br />

RIF Trust and Latitude as we’ve enjoyed a<br />

mutually beneficial relationship for some<br />

time. The new agreement will see both<br />

sides collaborate on the planning and<br />

implementing marketing strategies across<br />

key areas, leveraging our programme’s<br />

strong brand and RIF Trust and Latitude’s<br />

experience to make St Lucia a number<br />

1 option.”<br />

– Mr Mc Claude Emmanuel, the Chief Executive<br />

Officer of the Citizenship by Investment Unit<br />

of St Lucia<br />


North & South America, Europe & Asia: info@latitudeworld.com<br />

Middle East and Africa: contact@riftrust.com

<strong>IM</strong> YEARBOOK<br />

Fellow Member Certified <strong>IM</strong>CET Professional<br />

Certified <strong>IM</strong>CET Professional<br />

Certified <strong>IM</strong>CET Professional<br />

Theresa Okeke <strong>IM</strong>CM<br />

Managing Director<br />

CBI Agent | Luxury<br />

Resort & Second-<br />

Home Realtor®<br />

Valentina Sammut<br />

<strong>IM</strong>CM<br />

Founder and Chief<br />

Executive Officer<br />

Varun Singh<br />

<strong>IM</strong>CM<br />

Managing Director<br />

Paul Williams<br />

<strong>IM</strong>CM<br />

CEO<br />

Alexander Varnavas<br />

F<strong>IM</strong>C<br />

Managing Partner<br />


Theresa Okeke is the Managing Director of Frontgate Global Concepts,<br />

a bespoke Investment Migration consultancy firm specializing in the<br />

Grenada CBI program. Based in Atlanta, GA., with offices in West Africa<br />

and Canada, Frontgate Global collaborates with the most trustworthy<br />

local partners to ensure a successful compliance process. Our investor<br />

representation services are highly personalized, and we serve as a trusted<br />

resource for the E2- Visa & Canadian Start-up Visa program. Theresa<br />

has <strong>IM</strong>C certification in Investment Migration and is a licensed resort<br />

& luxury second home realtor with Berkshire Hathaway. With diverse<br />

backgrounds in international business and public service, helping<br />

our clients successfully navigate the application process to achieve<br />

mobility & their second-home goals is what motivates our team.<br />

BIZ CONSULT L<strong>IM</strong>ITED<br />

BIZ Consult Limited is the leading exclusive provider of customer oriented<br />

immigration services with the focus on the residency and citizenship by<br />

investments, due diligence, compliance. BIZ Consult offers its clients and<br />

their family members — which include high net worth individuals from<br />

the Commonwealth of Independent States, Asia and Middle East — the<br />

full support with documents, translations, legalisation, and real estate<br />

since 2014. The company provides its services with the highest professional<br />

standards. BIZ Consult founder Valentina Sammut is an <strong>IM</strong>C certified<br />

professional. Our team of legal professionals provides sound advice with<br />

respect and diligence with strict confidentiality and data security. The<br />

company is an approved accredited agent by the Malta Community Agency.<br />

XIPHIAS <strong>IM</strong>MIGRATION<br />

XIPHIAS Immigration is one of the leading Investment Migration<br />

firm in India. The organization has nurtured long-term client<br />

relationships by offering innovative ideas and developed associations<br />

with global powerhouses such as Europe ,Canada, UK, Australia,<br />

US and New Zealand. ICCRC, CANADA and MARA, AUSTRALIA<br />

officially recognize XIPHIAS Immigration through its certified<br />

consultants. The organization has collaborated with eminent<br />

attorneys and legislators for assistance with processes in their<br />

respective countries. The team is knowledgeable and experienced<br />

and provides services with honesty ,integrity and professionalism.<br />


Based in London, UK, La Vida Golden Visas facilitates the acquisition<br />

of residency, immigration and citizenship through investment. We<br />

make what looks like an expensive and difficult option, affordable<br />

and complex free. With clients covering more than 60 countries<br />

worldwide and over 15 programme options, we understand your<br />

reasons and we have the best solution for your needs. Today’s Golden<br />

Visa has become an essential requirement for many high-net-worth<br />

families. Let us help you achieve your goals. Visit our website at<br />

www.goldenvisas.com for full details on the investment and real<br />

estate options available in the Caribbean, USA and Europe.<br />


We are an awarded Law Firm based in Athens, with expertise in Real<br />

Estate Law and Investment Immigration. Our dedicated team consists of<br />

trustworthy and highly trained lawyers, notaries and financial advisors,<br />

who provide our domestic and international clientele with high-quality<br />

legal services. Experienced for over 40 years to support prestigious<br />

companies and high-net-worth individuals from all over the world, we<br />

have developed an entirely client-focused practice, fulfilling diversified<br />

objectives and expectations. Being the first ‘Greek’ <strong>IM</strong>C Members,<br />

since 2015, and believing in teamwork, we pursue the establishment of<br />

long-term collaborations with lawyers and professionals dealing with<br />

investor immigration programs worldwide, to provide global, multidimensional<br />

solutions related to the Golden Visa program in Greece.<br />

1201 W Peachtree St.Suite 2300<br />

Atlanta, GA 30309<br />

T: 1-800-425-9212<br />

M: 1-404-407-5555/ 1-404-910-8835<br />

W: www.frontgateglobalconcepts.com<br />

E: info@frontgateglobalconcepts.com<br />

146, Fl. 4, Constitution Street,<br />

Mosta, MST 9055, Malta<br />

W: https://bizconsultmalta.com/<br />

T: (+356) 99 020 654<br />

E: info@bizconsultmalta.com<br />

Contact: Valentina Sammut - Founder<br />

and Chief Executive Officer<br />

8th Floor BMTC Depot<br />

Koramangala 6th Block<br />

Bangalore 560095 KA INDIA<br />

www.xiphiasimmigration.com<br />

+91-9019 400 500<br />

Belmont House, Belmont Road,<br />

Uxbridge, UB8 1HE England<br />

W: https://www.goldenvisas.com/<br />

T: +44 207 060 1475<br />

E: info@goldenvisas.com<br />

Contact – Paul Williams – CEO<br />

6 Loukianou St. Kolonaki,<br />

10675, Athens, Greece<br />

T: +302106400300<br />

E: legal@varnavas.gr<br />

W: www.varnavas.gr<br />

66 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Charles Mizzi<br />

<strong>IM</strong>CM<br />

Chief Executive Officer<br />


Residency Malta Agency is the Government entity responsible for<br />

managing and promoting the Malta Permanent Residence Programme.<br />

The programme grants beneficiaries from third countries the right to settle<br />

permanently in Malta and travel visa-free across Schengen for 90 out of<br />

180 days. Beneficiaries can enjoy residency in a safe and stable country<br />

boasting excellent educational opportunities and economic prosperity.<br />

All applications submitted through licensed agents undergo a rigorous<br />

due diligence process to ensure that only fit-and-proper individuals are<br />

granted residency. The Agency also manages the Nomad Residence Permit<br />

– a one year residency permit for digital nomads and remote workers.<br />

Zentrum Business Centre, Level 2<br />

Mdina Road, Qormi QRM 9010, Malta<br />

T: [+356] 2203 4000<br />

e: customercare.residencymalta@gov.mt<br />

w: residencymalta.gov.mt<br />

Contact: Roberta Rodoligo – Senior Manager<br />

Hui Li (Eric)<br />

Managing Director<br />


Hellenic Investment Fund Co IKE, a real estate developer in Greece,<br />

serves the demand of income generating properties as well as high-end<br />

family residential properties by one-stop full package services including<br />

property management, relocation and family centered support. We<br />

strive to earn the deep and lasting trust from our clients consistently.<br />

Hellenic Investment Fund Co IKE<br />

78 Posidonos, Alimos, Athens, Greece 17455<br />

T: +30 2109848813<br />

M: +30 6949698967<br />

E: eric@hif.gr<br />

W: www.hif.gr<br />

Ricardo Cambra<br />

La Duke<br />

<strong>IM</strong>CM<br />

Managing Partner<br />


With more than15 years of experience and successful advice in immigration<br />

matters, real estate, tax and estate planning and corporate law, CLD<br />

Legal assist businesses, investors, families, and individuals to choose the<br />

right residency program in Panama, suited to their needs. Our highly<br />

experienced and knowledgeable professionals accompany our clients<br />

through all the stages. Contact and book a private meeting to evaluate<br />

your options: Friendly Countries Visa; residence as a retiree or pensioner;<br />

residence as a Foreign Professional; Permanent residence for Italian<br />

citizens; Visa for SEM Business workers; Work visa within 10%; Domestic<br />

workers; Reasons for family reunification; For economic solvency; among<br />

other visas of temporary, permanent residence or by special policies.<br />

Samuel Lewis Avenue & 55 East St.,<br />

Obarrio, Building SL 55, 21st Floor<br />

Panama City, Panama<br />

1. Headshot in CMYK –<br />

www.cldlegal.com<br />

Please use one of the below pictures.<br />

Marco Cerrato<br />

<strong>IM</strong>CM<br />

Partner<br />


Maisto e Associati is an independent Italian tax law firm, established in<br />

1991, with 60 professionals (including 11 partners) divided among its offices<br />

in Mian (main office), Rome and London, consistently ranked as tier 1 in<br />

the Italian tax scene. The Firm has developed a unique expertise in the<br />

private clients sector and in particular in advising over 100 families on<br />

their relocation to Italy under the Italian Forfait Tax Regime. Within this<br />

specific practice area, the Firm has acquired extensive knowledge and<br />

expertise on the immigration law aspects of the relocation, assisting clients<br />

throughout the entire procedure for the obtainment of the investor visa<br />

(the Italian visually elected HNWIs) and the related residence permit.<br />

Maisto e Associati<br />

Piazza Filippo Meda,<br />

5, 20121 Milan, Italy<br />

2. Full Name and Designation –<br />

+39 02776931<br />

Barr. Tessy Ekpunobi<br />

milano@maisto.it<br />

Investment Migration Attorney<br />

www.maisto.it<br />

3. Company Name and Logo in CMYK<br />

Fellow Member /<br />

Certified <strong>IM</strong>CET Professional<br />

Barr. Tessy Ekpunobi<br />

F<strong>IM</strong>C<br />

Investment Migration<br />

Attorney<br />


Global residence and Citizenship Ltd. (GRCL) is a full-service<br />

international Law Firm in Nigeria, with a sister company in Canada,<br />

specializing in international migration with a specialty in Second/<br />

Alternative Residency and Citizenship programs. With over 25 years of<br />

International Migration experience, we have successfully assisted over<br />

3000 clients to legally obtain citizenships and permanent residency<br />

through Investment Migration Programs including but not limited to:<br />

Start -Ups, Provincial Nominee, Real-Estate/Donation options, and<br />

significant investments option of some EU, North America and the<br />

Caribbean that offer alternative residency/citizenship programs. Our<br />

global team of legal professionals and affiliates ensure that all clients<br />

are treated with respect and confidentiality, all files handled with<br />

competence and efficiency geared towards a successful outcome.<br />



N0. 20, 641 Rd. Off 64 Road. Off 6 th Avenue.<br />

Gwarimpa. FCT. Abuja. Nigeria<br />

Tel: +234.805.897.3551. +1.513.729.7703<br />

Nº 20, 641 Email: Rd. globalresidences@gmail.com<br />

Off 64 RoadOff 6th Avenue.<br />

Gwarimpa. URL: FCT. https://global-residence-and-citizenship.business.site/<br />

Abuja. Nigeria<br />

T: +234.805.897.3551 Contact: Tessy Ekpunobi • +1.513.729.7703<br />

Esq. – Investment Migration Attorney<br />

E: globalresidences@gmail.com<br />

W:<br />

4.<br />

https://global-residence-andcitizenship.business.site/<br />

A 120-word write-up describing the main activities of the organisation<br />

Contact: Global Tessy residence Ekpunobi and Citizenship Esq. Ltd. – (GRCL) is a full-service international Law Fir<br />

Canada, specializing in international migration with a specialty in Second/Alterna<br />

Investment Migration Attorney<br />

With over 25 years of International Migration experience, we have successfully a<br />

citizenships and permanent residency through Investment Migration Programs in<br />

Provincial Nominee, Real-Estate/Donation options, and significant investments o<br />

Caribbean that offer alternative residency/citizenship programs.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 67<br />

Our global team of legal professionals and affiliates ensure that all clients are tre<br />

files handled with competence and efficiency geared towards a successful outco

<strong>IM</strong> YEARBOOK<br />

Anubhuti David<br />

Global Proposition<br />

Director, Customer<br />

Risk Intelligence<br />


For over a decade Refinitiv, an LSEG business, have been a trusted due<br />

diligence provider supporting governments, regulators, civil society, as<br />

well as agents and law firms in mitigating risks related to Citizenship by<br />

Investment (CBI) and Residency by Investment (RBI) programmes.<br />

Being the only due diligence provider in the market leveraging our<br />

World-Check Risk Intelligence proprietary data, our Investment<br />

Migration reports offer accurate, quality insights, ratings and analysis<br />

into the potential risks associated with applicants and co-applicants,<br />

no matter where they are located. Our thorough research and<br />

background checks covers areas of core identity and integrity risks<br />

as well as emerging risks, safeguarding your programme from illicit<br />

money flows, sanctions, and related reputational vulnerabilities.<br />

5 Canada Square,<br />

Canary Wharf, London, E14 5AQ<br />

Contact: Anubhuti David – Global Proposition<br />

Director, Customer Risk Intelligence<br />

E: Anubhuti.David@lseg.com<br />

T: +44 (0)20 7542 3881<br />

W: https://www.refinitiv.com<br />

Karen Kelly<br />

<strong>IM</strong>CM<br />

Director, Strategy<br />

& Development<br />

EXIGER<br />

Exiger has been a pioneer, innovator, and leading provider of due diligence<br />

and advisory services to the investment migration industry since 2006.<br />

As a trusted partner to the largest and fastest growing Residency and<br />

Citizenship by Investment (RCBI) programmes operating today, we<br />

bring cost-effective and efficient, technology-enabled solutions to the<br />

industry. Exiger has developed specialized methodology and reporting<br />

for the investment migration industry, including a one-of-a-kind risk<br />

assessment. Our award-winning AI technology platform, DDIQ, is<br />

also changing the way programmes manage applicants and agents<br />

by anticipating their most pressing needs. With over 200 full-time<br />

research staff speaking 35 languages in research centers around the<br />

globe, we empower you to make the world a safer place to do business.<br />

1675 Broadway, Floor 15, New York, NY 10019<br />

www.exiger.com<br />

Contact: Karen Kelly – Director,<br />

Strategy & Development -<br />

kakelly@exiger.com,<br />

+1 778 945 7318<br />

Jennifer Lai<br />

Wealth & Residency<br />

Planning Managing<br />

Director<br />


Headquartered in Hong Kong, DL Holdings has offices in Shanghai, San<br />

Francisco, Singapore and Tokyo. We provide customized global family<br />

office, private banking, investment banking, and residency planning services<br />

to the clients. We currently have assets under management and investment<br />

over US$3 billion, of which nearly US$2.1 billion is under DL Family Office.<br />

The group holds Type 1, 4, 6 and 9 licenses issued by HKSFC, as well as<br />

Singapore RFMC fund management license, Cayman Islands SIBL fund<br />

management license and more than 18 HK Limited Partnership Funds (LPF).<br />

Unit 2801, 28/F, Vertical Square 28<br />

Heung Yip Road, Wong Chuk Hung, Hong Kong<br />

Contact: Jennifer Lai - Wealth & Residency<br />

Planning Managing Director<br />

Certified <strong>IM</strong>CET Professional<br />

Laura Austin<br />

<strong>IM</strong>CM<br />

Managing Director<br />


Mintz Group is the partner of choice for due diligence, investigations, and<br />

background screening, anywhere in the world. Since 1994, Mintz Group has<br />

worked with governments, corporations, investors, and the legal, financial,<br />

and talent advisors who need actionable facts to assess risks, protect<br />

reputations, and win disputes. Mintz Group has employed a uniquely<br />

transparent and practical approach to fact gathering and has provided<br />

impartial facts that are comprehensively researched, properly sourced, and<br />

stand up to the toughest scrutiny. Headquartered in New York City, Mintz<br />

Group has offices in 18 countries across nine time zones, with a team that<br />

speaks more than 35 languages, and has successfully conducted over 40,000<br />

investigations in 100+ countries. To learn more, please visit mintzgroup.com<br />

110 Fifth Avenue, New York, NY 10011<br />

T: +1 646.713.4121<br />

M: +1 612.618.1222<br />

E: laustin@mintzgroup.com<br />

W: www.mintzgroup.com<br />

Patricia Casaburi<br />

<strong>IM</strong>CM<br />

Managing Director<br />


Global Citizen Solutions is a boutique consultancy firm focused on<br />

residency, citizenship programs, investment and global mobility. With<br />

offices in Portugal, the United Kingdom, Hong Kong and Brazil, our<br />

multicultural and multilingual team will guide individuals and families<br />

from start to finish, providing expert advice considering freedom, mobility,<br />

taxation, and security. Our international team is devoted to fulfilling our<br />

client’s personal and financial needs, knowing that each situation is unique.<br />

Av 24 de Julho 4,<br />

3 Esquerdo, 1200-161 - Lisboa - Portugal<br />

E: patricia@globalcitizensolutions.com<br />

T: +351 936 122 186<br />

W: https://www.globalcitizensolutions.com<br />

68 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Fellow Member Certified <strong>IM</strong>CET Professional<br />

Fellow Member<br />

Fellow Member /<br />

Certified <strong>IM</strong>CET Professional<br />

H. Ronald Klasko<br />

F<strong>IM</strong>C<br />

Managing Partner<br />

Andres Solimano<br />

<strong>IM</strong>CM<br />

Chairperson<br />

Bruno L’ecuyer<br />

F<strong>IM</strong>C<br />

Chief Executive<br />

& Co-Founder<br />

Dario Aquilina<br />

<strong>IM</strong>CM<br />

Digital Channels Officer<br />

David Chen<br />

F<strong>IM</strong>C<br />

Executive Director &<br />

Managing Partner<br />


H. Ronald Klasko is a leading U.S. lawyer representing treaty investors<br />

(E-2) and green card investors (EB-5). Ron was the lead attorney on Matters<br />

of Walsh and Pollard, the key precedent for E-2 visas and co-counsel<br />

on a 2022 lawsuit reopening the EB-5 regional center program. His firm<br />

is the North America Regional Representative office of the Investment<br />

Migration Council, of which Ron also serves on the Governing Board.<br />

Ron regularly speaks on investment migration globally and is known for<br />

pioneering innovative immigration solutions. Under Ron’s leadership,<br />

Klasko Immigration Law Partners is regularly recognized by Chambers<br />

Global and U.S. News and World Report. Ron was President and General<br />

Counsel of AILA and served five terms as Chair of the EB-5 Committee.<br />


The Investment Migration Council (<strong>IM</strong>C) is the worldwide forum for<br />

investment migration, bringing together the leading stakeholders in<br />

the field. The <strong>IM</strong>C sets global standards, provides qualifications and<br />

publishes indemand research in the field of investment migration aimed<br />

at governments, policy-makers, international organisations, and the<br />

public. It is an impact focused Swiss-based membership organisation in<br />

special consultative status with the Economic and Social Council of the<br />

United Nations since 2019 and registered with the European Commission<br />

Joint Transparency Register Secretariat (ID: 337639131420-09).<br />


The Investment Migration Council (<strong>IM</strong>C) is the worldwide forum for<br />

investment migration, bringing together the leading stakeholders in<br />

the field. The <strong>IM</strong>C sets global standards, provides qualifications and<br />

publishes indemand research in the field of investment migration aimed<br />

at governments, policy-makers, international organisations, and the<br />

public. It is an impact focused Swiss-based membership organisation in<br />

special consultative status with the Economic and Social Council of the<br />

United Nations since 2019 and registered with the European Commission<br />

Joint Transparency Register Secretariat (ID: 337639131420-09).<br />


The Investment Migration Council (<strong>IM</strong>C) is the worldwide forum for<br />

investment migration, bringing together the leading stakeholders in<br />

the field. The <strong>IM</strong>C sets global standards, provides qualifications and<br />

publishes indemand research in the field of investment migration aimed<br />

at governments, policy-makers, international organisations, and the<br />

public. It is an impact focused Swiss-based membership organisation in<br />

special consultative status with the Economic and Social Council of the<br />

United Nations since 2019 and registered with the European Commission<br />

Joint Transparency Register Secretariat (ID: 337639131420-09).<br />


As one of the most prestigious immigration firms in China, VCG has<br />

been dedicated to the achievement of the immigration dream of the<br />

wealthy elites since 1997. With the assistance of VCG, thousands of<br />

families not only successfully acquire the residency in their desired<br />

destination but also swiftly fit into the new life. Visas Consulting Group<br />

perfectly understands the balance between the needs of the clients<br />

and the laws of immigration. To fulfill people’s pursuit for a better life<br />

is always at the heart of VCG’s philosophy: Visas to your future.<br />

1601 Market Street, Suite 2600<br />

Philadelphia, PA 19103<br />

T: 215.825.8600<br />

E: rklasko@klaskolaw.com<br />

W: www.KlaskoLaw.com<br />

Contact: H. Ronald Klasko – Managing Partner<br />

16 Rue Maunoir 1211 Geneva – Switzerland<br />

T: (+41) 22 533 1333<br />

E: info@investmentmigration.org<br />

W: investmentmigration.org<br />

Contact: Bruno L’ecuyer - Chief Executive<br />

16 Rue Maunoir 1211 Geneva – Switzerland<br />

T: (+41) 22 533 1333<br />

E: info@investmentmigration.org<br />

W: investmentmigration.org<br />

Contact: Bruno L’ecuyer - Chief Executive<br />

16 Rue Maunoir 1211 Geneva – Switzerland<br />

T: (+41) 22 533 1333<br />

E: dario.aquilina@investmentmigration.org<br />

W: investmentmigration.org<br />

Contact: Dario Aquilina – Digital Channels Officer<br />

29/F Huaihai Plaza, 1045 Huaihai Road,<br />

Central Shanghai, 200031 – China<br />

T: (+86) 21 6415 8666<br />

E: dchen@visas.to<br />

W: www.visas.to<br />

Contact: David Chen - Executive<br />

Director & Managing Partner<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 69

<strong>IM</strong> YEARBOOK<br />

Fellow Member Certified <strong>IM</strong>CET Professional<br />

Certified <strong>IM</strong>CET Professional<br />

Jacqueline Gauci<br />

<strong>IM</strong>CM<br />

Head of Membership<br />

Services<br />

Marie’ Lou Cutajar<br />

<strong>IM</strong>CM<br />

Head of Education<br />

& Training<br />

Nadine Goldfoot<br />

F<strong>IM</strong>C<br />

Managing Partner<br />


The Investment Migration Council (<strong>IM</strong>C) is the worldwide forum for<br />

investment migration, bringing together the leading stakeholders in<br />

the field. The <strong>IM</strong>C sets global standards, provides qualifications and<br />

publishes indemand research in the field of investment migration aimed<br />

at governments, policy-makers, international organisations, and the<br />

public. It is an impact focused Swiss-based membership organisation in<br />

special consultative status with the Economic and Social Council of the<br />

United Nations since 2019 and registered with the European Commission<br />

Joint Transparency Register Secretariat (ID: 337639131420-09).<br />


Marie’ Lou is the Head of Education and Training at the Investment<br />

Migration Council, where she acts as the point of contact for all training<br />

related enquiries. She is responsible for the day to day co-ordination<br />

and administration of the training programme, making sure that<br />

all those who enroll for the course get all the assistance that they<br />

require and experience a positive learning journey. Marie’ Lou is also<br />

leading several projects within the <strong>IM</strong>CET, focusing on the growth of<br />

the education and training portfolio – with the intention to enhance<br />

professionalism and setting standards of best practice in the <strong>IM</strong> industry.<br />


Fragomen is the world’s leading exclusive provider of immigration<br />

services. With more than 50 strategically located offices worldwide,<br />

we provide immigration services in more than 170 countries. Our<br />

Worldwide Private Client Practice helps individuals – from investors,<br />

high-net-worth individuals and entrepreneurs to executives,<br />

professionals, artists, athletes, students and their families – to<br />

navigate and plan for their long- and short-term movement around<br />

the world. Available in multiple countries, alternative citizenship and<br />

residency programmes promote economic growth through investment<br />

and offer immigration benefits to investors seeking to expand and<br />

secure their personal and financial security and stability, leverage<br />

global business opportunities and enhance their quality of life.<br />

16 Rue Maunoir 1211 Geneva – Switzerland<br />

T: (+41) 22 533 1333<br />

E: membership@investmentmigration.org<br />

W: investmentmigration.org<br />

Contact: Jacqueline Gauci –<br />

Head of Membership Services<br />

16 Rue Maunoir 1211 Geneva – Switzerland<br />

T: (+41) 22 533 1333<br />

E: imcet@investmentmigration.org<br />

W: investmentmigration.org<br />

Contact: Marie’ Lou Cutajar –<br />

Head of Education & Training<br />

1st Floor, 95 Gresham Street,<br />

London EC2V 7NA - United Kingdom<br />

T:(+44) 2070 909 156<br />

E: NGoldfoot@Fragomen.com<br />

W: www.fragomen.com<br />

Contact: Nadine Goldfoot – Managing Partner<br />

Fellow Member<br />

Dr. Christian H. Kaelin<br />

F<strong>IM</strong>C<br />

Chairman<br />

Geoffrey DuBoulay<br />

<strong>IM</strong>CM<br />

Managing Director<br />


With over 25 years of institutional experience and more than 35 offices<br />

worldwide, Henley & Partners is by far the largest globally integrated<br />

pure play residence and citizenship advisory firm in the world. Through<br />

the provision of bespoke residence and citizenship by investment<br />

solutions, we have helped thousands of individuals and families, their<br />

advisors, and many sovereign states to generate value. Our outstanding<br />

people and systems provide a world-class advisory service underpinned<br />

by strict confidentiality, data security, and limited transaction risk.<br />



Polaris is a licensed Authorised Agent for Citizenship by Investment in<br />

Saint Lucia. Built on the infrastructure, ethics and values of its sister firm,<br />

Floissac, DuBoulay & Thomas, a full service commercial and corporate law<br />

firm founded in 1960, Polaris takes a bespoke, hands-on and personalized<br />

approach to CBI which is client focused, solution oriented and regulatory<br />

compliant. Our advisors are all trained and qualified attorneys with over<br />

fifty years’ experience in the legal, investment and advisory sectors. All our<br />

processing officers have obtained certifications in investment migration<br />

and are <strong>IM</strong>C certified practitioners. Our competence, expertise and<br />

ethos have led to an over 98% success rate on submitted applications.<br />

20 Grosvenor Place<br />

London, SW1X7HN<br />

United Kingdom<br />

T: (+44) 207 823 1010<br />

E: uk@henleyglobal.com<br />

W: henleyglobal.com<br />

Contact: Dr Christian H. Kaelin - Chairman<br />



Quadrant Row, 9-11 Brazil Street<br />

P.O Box 722, Castries – St. Lucia<br />

T: (+1) 758 714 7373/ (+1) 758 452 2887<br />

E: info@polariscitizenship.com<br />

W: www.polariscitizenship.com<br />

Contact: Geoffrey DuBoulay – Managing Director<br />

70 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Sachit Kumar<br />

<strong>IM</strong>CM<br />

Managing Director<br />

GLOBE DETECTIVE AGENCY (P) L<strong>IM</strong>ITED<br />

Established in 1961, GDA is the pioneer and leader in private Investigations<br />

in India with Global expertise. Headquartered in New Delhi with a network<br />

of 20 branches, GDA specializes in Enhanced Due Diligence worldwide for<br />

the investment migration industry in 40 countries. This includes a “deep<br />

dive” into a subject’s background to verify information, acquire relevant<br />

inputs and fill gaps through field resources. It also includes authentication<br />

of documents and global security checks related to sanctions, enforcements,<br />

1,200 watchlists originating from more than 80 countries and identification<br />

of politically exposed persons. GDA’s highly skilled, professional approach<br />

is personalized and rigorous. GDA is aware that important decisions<br />

are made partly/wholly based on the information that we provide.<br />

601-603, Eros Apartments, 56, Nehru Place,<br />

New Delhi-110019, India<br />

T: (+91) 9311042007<br />

E: sachitkumar@globedetective.com<br />

W: www.globedetective.com<br />

Contact: Mr. Sachit Kumar – Managing Director<br />

Certified <strong>IM</strong>CET Professional Certified <strong>IM</strong>CET Professional<br />

Dr. Maria Grech<br />

Senior Associate<br />

Fabienne de Blois<br />

<strong>IM</strong>CM<br />

Associate Director<br />

Estelle Nogues<br />

<strong>IM</strong>CM<br />

Head Stakeholder<br />

Concierge<br />


Set up in 1971, Muscat Azzopardi & Associates (MA&A) are a team<br />

of multilingual advocates with an international outlook, advising<br />

private and corporate clients. MA&A has built up invaluable<br />

experience in advising on legal and practical issues that arise when<br />

considering a second citizenship or an alternative residence.<br />

Our global portfolio of high net worth and ultra-high net worth<br />

individuals are highly appreciative of our guidance. Our lawyers<br />

share a special work ethic and personally guide clients - not just<br />

by assisting our clients through every step of the process, from the<br />

first contact to the actual acquisition of a Maltese citizenship or of<br />

residence in Malta, but we continue to serve our clients beyond.<br />

S-RM<br />

S-RM helps many of the world’s leading organisations understand, manage,<br />

and mitigate reputational and regulatory risk. For over seven years, our<br />

dedicated 45+ practitioner team has been helping citizenship and residency<br />

by investment agencies make nuanced decisions. We work across all sectors<br />

and jurisdictions that form the focal points for the citizenship and residency<br />

by investment industry, including in fragile and informal economies, and in<br />

jurisdictions where information is hard to access and understand. Supported<br />

by a further 180+ practitioners across S-RM’s seven global offices, our teams<br />

are experts in civil and commercial registration processes and in navigating<br />

complex media landscapes. We pride ourselves in our ability to discreetly<br />

gather commentary through enquiries in the circles that Applicants operate in,<br />

helping you understand the warning signs of corruption, illicit financial flows<br />

and identity fraud, as well as the factors that may mitigate these concerns.<br />


The Investment Migration Council (<strong>IM</strong>C) is the worldwide forum for<br />

investment migration, bringing together the leading stakeholders in<br />

the field. The <strong>IM</strong>C sets global standards, provides qualifications and<br />

publishes indemand research in the field of investment migration aimed<br />

at governments, policy-makers, international organisations, and the<br />

public. It is an impact focused Swiss-based membership organisation in<br />

special consultative status with the Economic and Social Council of the<br />

United Nations since 2019 and registered with the European Commission<br />

Joint Transparency Register Secretariat (ID: 337639131420-09).<br />

40, Villa Fairholme, Sir Augustus Bartolo Street,<br />

Ta’ Xbiex XBX 1095, Malta<br />

Tel: (+356) 2133 6196<br />

Mob: (+356) 9993 0258<br />

4th Floor Beaufort House,<br />

15 St Botolph Street,<br />

London, Greater London, EC3A<br />

7DT, United Kingdom<br />

T: +44 (0)7393 010932<br />

E: F.deBlois@s-rminform.com<br />

W: www.s-rminform.com<br />

16 Rue Maunoir 1211 Geneva – Switzerland<br />

T: (+41) 22 533 1333<br />

E: estelle.nogues@investmentmigration.org<br />

W: investmentmigration.org<br />

Contact: Estelle Nogues –<br />

Head Stakeholder Concierge<br />

Mtonya A. G.<br />

Deterville<br />

Attorney-at-law /<br />

Notary Royal<br />


Global Migration and Investment Services (“GMIS”), is an Authorized Agent<br />

of Citizenship by Investment Saint Lucia. We support our clients as they<br />

navigate the Citizenship by Investment process. We assist in completing<br />

applications while providing timely, efficient and professional services in<br />

accordance with the CIP Legislation. Our team is led by a dynamic duo of<br />

lawyers, (sisters) who are <strong>IM</strong>C certified. They possess extensive diplomatic<br />

and immigration experience as they have lived in several countries<br />

throughout the world. Our goal is to ensure our clients’ success within the<br />

shortest possible timeframe. We are supported by and affiliated with the<br />

law firm of Deterville & Associates which is built on a legacy of providing<br />

exceptional legal services. A perfect cocktail to a seamless experience.<br />

Attorney-at-law | Notary Royal<br />

99 Chaussee Road | P.O. Box 835 |General Post<br />

Office | Castries | LC04 101 | Saint Lucia<br />

W: www.detervilleassociates.com<br />

E: lawyer@detervilleassociates.com<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 71

<strong>IM</strong> YEARBOOK<br />

In a bid to reduce our carbon<br />

footprint, we will no longer<br />

be printing mountains of<br />

material, therefore the<br />

following pages includes<br />

information about <strong>IM</strong>C<br />

initiatives in the coming year.<br />

72 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

A Guide to the Investment Migration Council<br />

investmentmigration.org<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 73

<strong>IM</strong> YEARBOOK<br />

Who’s Who<br />


Andrés Solimano<br />

(Chairperson)<br />

Bruno L’ecuyer<br />

Nadine Goldfoot<br />

David Chen Ronald H. Klasko Christian H. Kalin<br />

Geneva, Switzerland<br />

Head Quarters<br />

Investment Migration Council<br />

16 rue Maunoir<br />

1211 Geneva, Switzerland<br />

Office: +41 22 533 1333<br />

Email: info@investmentmigration.org<br />

<strong>IM</strong>C London Office<br />

Contact: Nadine Goldfoot<br />

1st Floor, 95 Gresham Street<br />

London EC2V 7NA,<br />

United Kingdom<br />

Office: +44 (0) 20 7090 9156<br />

Email: london@investmentmigration.org<br />

<strong>IM</strong>C New York Office<br />

Contact: H.Ronald Klasko<br />

54 W. 40th Street, Suite 516<br />

New York, NY 10018<br />

Office: +646 787 1371<br />

Email: newyork@investmentmigration.org<br />

<strong>IM</strong>C Hong Kong Office<br />

Contact: Denis NG<br />

Unit E, 29/F, Tower 1, Admiralty Centre,<br />

No,18 Harcourt Road, Admiralty, Hong Kong<br />

Office: +852 3101 4100<br />

Email: hongkong@investmentmigration.org<br />

<strong>IM</strong>C Caribbean Office<br />

Contact: Christopher Willis<br />

95 Solaris Avenue, 2nd Floor,<br />

Camana Bay, PO Box 30745,<br />

Grand Cayman,<br />

Cayman Islands, KY1-1203<br />

Office: +1 (345) 325 3030<br />

Email: caribbean@investmentmigration.org<br />

<strong>IM</strong>C Dubai Office<br />

Contact: David Regueiro Santalla<br />

Office No. 2804, U-Bora Tower,<br />

Business Bay, Dubai<br />

Office: +971 (0) 4 520 6775<br />

Email: dubai@investmentmigration.org<br />

74 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />


Bruno L’ecuyer <strong>IM</strong>CM<br />

(Committee Chairman)<br />

Prof. Dr. Andrés Solimano<br />

<strong>IM</strong>CM<br />

Prof. R. James Breiding<br />

Paul Williams<br />

ACA <strong>IM</strong>CM<br />

Peter Vincent Anastassis Yiasemides Edward Beshara<br />

<strong>IM</strong>CM<br />

Inigo Lecanda Crooke<br />

F<strong>IM</strong>C<br />

Alexander Varnavas<br />

<strong>IM</strong>CM<br />

Michael Frendo<br />

<strong>IM</strong>CM<br />

Jennifer Lai<br />

<strong>IM</strong>CM<br />

Tiago Gali Macedo<br />

<strong>IM</strong>CM<br />

Philippe Foret<br />

Eric G. Major<br />

<strong>IM</strong>CM<br />

Kieron Sharp<br />

<strong>IM</strong>CM<br />

Prof. Dr. Khalid Koser<br />

Prof. Dr. Christian Joppke Austin T. Fragomen Boriss Cilevics Ghada al Atrash<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 75

<strong>IM</strong> YEARBOOK<br />

About Us<br />

We are the worldwide<br />

association for<br />

Investment Migration,<br />

bringing together the<br />

leading stakeholders<br />

in the field and giving<br />

the industry a voice.<br />

Our Mission<br />

Our mission is simple<br />

and straightforward:<br />

it is about setting the<br />

global standards for<br />

others to follow and<br />

promoting competence<br />

and ethical behaviour.<br />

Additionally, we improve<br />

public understanding<br />

and transparency of the<br />

industry through various<br />

initiatives, including<br />

academic research.<br />

We are the leading<br />

platform for<br />

governments, academia<br />

and professionals.<br />

Structure of the <strong>IM</strong>C<br />

- Legal form: non-profit Swiss-based<br />

Association (Art 60 seq Swiss Civil Code)<br />

- A solidly funded association, through<br />

membership & donors<br />

- Professional, full-time secretariat headed by a CEO<br />

- The leading industry firms are already members<br />

- World’s most-respected experts on the<br />

governing board and advisory comittee<br />

The leading industry firms<br />

are already <strong>IM</strong>C members<br />

- Refinitiv<br />

- Henley & Partners<br />

- RIF Trust<br />

- Visas Consulting Group<br />

- Fragomen Worldwide<br />

- Exiger DD<br />

- Latitude<br />

- Polaris Citizenship & Investment<br />

…and many more<br />

76 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Three Essential<br />

Reasons to Join<br />

1. Achieve greater industry-wide<br />

visibility to grow your business<br />

2. Build and contribute to a worldclass<br />

network of contacts<br />

3. Learn about all the latest<br />

developments taking place<br />

Membership<br />

Criteria<br />

To become a member, one must<br />

have proven expertise within the<br />

sector, a good reputation, and a clean<br />

professional and personal record.<br />

The <strong>IM</strong>C has very strict membership<br />

admission criteria to ensure<br />

its members are of the highest<br />

professional standards.<br />

The <strong>IM</strong>C offers different levels of<br />

annual memberships for individual<br />

practitioners, academics, firms,<br />

associates, governments and<br />

affiliates. Membership packages<br />

include the below, each offering<br />

various levels of benefits.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 77

<strong>IM</strong> YEARBOOK<br />

Two Routes to Membership<br />

Two Routes to Membership<br />

1. Membership by Education<br />

1. Membership by Education<br />

The journey to membership via the education route is the<br />

recommended one since this strenghtens the skills and knowledge<br />

of members and by consequence the wider industry.<br />

The journey to membership via the education route is the recommended one since this<br />

strenghtens the skills and knowledge of members and by consequence the wider industry.<br />

2. Membership by Experience<br />

To 2. follow Membership suit with by Experience other professionals bodies, membership by<br />

experience is offered to those practitioners who meet the necessary<br />

criteria in any membership tier to be members of the <strong>IM</strong>C.<br />

To follow suit with other professionals bodies, membership by experience is offered<br />

to those practitioners who meet the necessary criteria in any membership tier to be<br />

members of the <strong>IM</strong>C.<br />

Application can filled online on www.investmentmigration.org/membership<br />

Application can filled online on www.investmentmigration.org/membership<br />

Membership Levels<br />

Membership Levels<br />

78 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Corporate Membership Benefits Benefits<br />

Corporate Membership Benefits<br />

Individual Membership Benefits<br />

Individual Membership Benefits Benefits<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 79

<strong>IM</strong> YEARBOOK<br />

Application Process Timeline<br />

Application Process Timeline<br />

Investigative Due Diligence<br />

Investigative Due Diligence<br />

Our Due Diligence checks on prospective members are carried out by a roster of Due<br />

Diligence firms. They apply a leading edge methodology to generate information from a<br />

broad range of sources, including on-the-ground, in-country investigative intelligence.<br />

Our Due Diligence checks on prospective members are carried<br />

out by a roster of Due Diligence firms. They apply a leading edge<br />

methodology to generate information from a broad range of sources,<br />

including on-the-ground, in-country investigative intelligence.<br />

Types of risks identified:<br />

- Criminal activity<br />

- Misrepresentations or factual omissions<br />

Types - Unreported of risks identified:<br />

financial issues<br />

- Criminal - Civil litigation activity<br />

- Misrepresentations - Character issues or factual omissions<br />

- Unreported - PEP checkfinancial issues<br />

- Civil litigation<br />

- Character issues<br />

- PEP check<br />

80 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

FAQ’s<br />

Why does the industry need the <strong>IM</strong>C?<br />

Until the <strong>IM</strong>C was established, there was no body to act as a bridge<br />

between governments, academia, and practitioners. The <strong>IM</strong>C brings<br />

all stakeholders together in an independent manner, and the interests<br />

of all stakeholders are considered for the benefit of the industry.<br />

How many members are participating?<br />

Today, there are nearly 500 members from over<br />

55+ different countries and territories.<br />

Can anyone join?<br />

To become an active member, you must be a practitioner with proven<br />

expertise and experience in investor immigration, have a good reputation<br />

and a clean professional and personal record. Each application is assessed<br />

on its individual merit and considered by the governing board.<br />

Contact Us<br />

Secretariat:<br />

London:<br />

New York:<br />

Grand Cayman:<br />

Hong Kong:<br />

Dubai:<br />

info@investmentmigration.org<br />

london@investmentmigration.org<br />

newyork@investmentmigration.org<br />

caribbean@investmentmigration.org<br />

hongkong@investmentmigration.org<br />

dubai@investmentmigration.org<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 81

<strong>IM</strong> YEARBOOK<br />

<strong>IM</strong>C Qualifications and Training<br />

<strong>IM</strong>C Qualifications and Training<br />

<strong>IM</strong>C Qualifications and Training<br />

82 - Investment Migration <strong>Yearbook</strong> 2O23<br />

investmentmigration.org/education<br />

Contact: imcet@investmentmigration.org<br />

investmentmigration.org/education<br />

Contact: imcet@investmentmigration.org<br />

Contact: imcet@investmentmigration.org

<strong>IM</strong> YEARBOOK<br />

Certification in Investment Migration ‐ Cert (<strong>IM</strong>)<br />

Overview and Objectives<br />

The Certification in Investment Migration is an intermediate<br />

level course designed to be studied over about 6 months.<br />

This practical introduction leads to a professional status<br />

with the <strong>IM</strong>C and is benchmarked at Associate level for those<br />

working in the <strong>IM</strong> industry. This is the first global Investment<br />

Migration course of its type - specially designed for those<br />

working in the industry. The course is taught online through<br />

our custom Learning Management System and includes<br />

5 compulsory modules.<br />

Target Audience<br />

All staff working in, allied to, or intending to work<br />

in the industry<br />

Advisors<br />

Agents<br />

Lawyers/paralegals<br />

CIP programme staff<br />

Regulators and government staff<br />

Compliance professionals<br />

Financial services practitioners<br />

Investment advisors<br />

Assessment<br />

The programme is assessed via:<br />

Two hour, online, multiple choice test<br />

100 multiple choice questions to be answered<br />

70% Pass mark<br />

Certification and Designation<br />

Individuals who successfully complete the programme will<br />

be awarded the '<strong>IM</strong>C Certification in Investment Migration'.<br />

The certificate carries with it the designation Cert (<strong>IM</strong>)<br />

and leads to membership of the <strong>IM</strong>C.<br />

Example designation - Carmen Swift Cert (<strong>IM</strong>); <strong>IM</strong>CM (Associate)<br />

Professional Status<br />

On successful completion of the Certification,<br />

Non-<strong>IM</strong>C Members will become eligible to apply for membership<br />

of the <strong>IM</strong>C at Associate level.<br />

Course Format<br />

Delivered online via an easy to use,<br />

comprehensive Learning Management System (LMS)<br />

Accessible by a range of mobile and laptop technologies<br />

Needs to be completed within 6 months, however actual<br />

study time is around 25 hours<br />

Comprehensive support materials including:<br />

— comprehensive module manuals<br />

— interactive e-learning modules<br />

— case studies and examples<br />

— specimen test questions<br />

Entrance Requirements<br />

Applicants should possess:<br />

Good educational background<br />

Ability to complete the readings and comprehend core<br />

principles in the English language<br />

How to Apply<br />

To apply for the Certification in Investment Migration course,<br />

please go to investmentmigration.org/education to enrol online.<br />

Rationale for Taking the Certification<br />

The <strong>IM</strong>C Certification is a groundbreaking initiative<br />

designed to prepare participants for work in a new<br />

and vibrant industry where high professional<br />

standards, values and enhanced competencies<br />

are required. This certification will:<br />

Provide verifiable evidence of competency<br />

(knowledge, skills and behaviours)<br />

Provide a practical focus and benchmarking of<br />

your work in the industry<br />

Help you to reduce risk in your firm and enhance<br />

the firm’s reputation<br />

Enhance your career prospects<br />

Keep you abreast of developments in the industry<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 83

<strong>IM</strong> YEARBOOK<br />

Programme Structure / Course Format<br />

Module 1<br />

Module 2<br />

Citizenship and Residence by Investment<br />

Industry Overview<br />

Understanding Citizenship and Residence<br />

Ways of Acquiring the Status of Citizenship<br />

The Concept of Residence<br />

Development and Characteristics<br />

of Investment Migration<br />

Citizenship and Residence by Investment:<br />

Assessing the Arguments<br />

Ethics, Conduct and Professional Standards in<br />

Investment Migration<br />

Ethics<br />

Codes of Conduct<br />

Corporate Culture and Values<br />

Integrity<br />

Competence<br />

Transparency<br />

Marketing of Citizenship & Residence by<br />

Investment Programmes<br />

Practical Application of the <strong>IM</strong>C Code<br />

Whistleblowing<br />

Module 3<br />

Module 4<br />

Anti-Money Laundering (AML)<br />

and Financial Crime Prevention (FCP)<br />

Nature of AML, Terrorist Financing (TF) and<br />

Sanctions<br />

Terrorist Financing<br />

Sanctions<br />

Key International AML and Sanctions Bodies<br />

Suspicious Activity Reporting<br />

Concept of Risk Management<br />

Bribery and Corruption<br />

Cybercrime<br />

Investor Migration — Know Your Customer (KYC)<br />

and Customer Due Diligence (CDD)<br />

Generic KYC and CDD<br />

Customer Due Diligence<br />

Types of Due Diligence<br />

Politically Exposed Persons<br />

Customer Risk Rating<br />

CDD Gone Wrong – Regulatory Action<br />

Citizenship by Investment and Residence by<br />

Investment – the need for CDD<br />

Minimum Standards for Agents<br />

Module 5<br />

Personal Data: Management and Protection<br />

What is Personal Data?<br />

Principles of Data Protection<br />

Risks Associated with Inappropriate Management of<br />

Personal Data<br />

84 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

New Modules Added to <strong>IM</strong>CET Portfolio<br />

Module 6<br />

Module 7<br />

Demand for Residence and Citizenship by Investment<br />

The expansion of dual citizenship provisions<br />

and their implications<br />

Key demographics of demand for CBI and RBI<br />

programmes<br />

People’s motives in participating in CBI and RBI<br />

programmes<br />

The differences in demand from different<br />

countries of origin<br />

Examine the impact of Covid-19 on demand<br />

General factors that determine patterns of<br />

demand<br />

Factors that lead to increased and decreased<br />

demand<br />

Common Reporting Standard and Mandatory Disclosure<br />

Rules<br />

The reporting framework established by the<br />

OECD Common Reporting Standard<br />

The different financial institutions involved in<br />

the domestic CRS reporting process<br />

CRS due diligence processes and procedures<br />

and its application to entity and individual<br />

account holders<br />

Contents of a CRS report and various financial<br />

account information reporting requirements<br />

Understand the contents of MDR disclosure<br />

Identify circumstances when a client will be<br />

required to file an MDR disclosure<br />

<strong>IM</strong>CET's training portfolio now consists of 7 specialised modules. Students can choose to create their own learning journey<br />

through a combination of 3 compulsory and 4 elective modules to convert successful completion into the renowned<br />

‘Certification in Investment Migration’ and hold the designation Cert (<strong>IM</strong>) and considered a certified <strong>IM</strong> practitioner.<br />

Students can now also choose to study modules individually at their own leisure in the bitesize option – no need to make an<br />

outright commitment to the entire course, but still with the option to graduate as a certified <strong>IM</strong> practitioner.<br />

Speak to us today for more information.<br />

3 Compulsory Modules<br />

+<br />

2 Elective Modules<br />

Ethics, Conduct and Professional Standards in<br />

<strong>IM</strong><br />

Anti-Money Laundering and Financial Crime<br />

Prevention<br />

Investor Migration – Know Your Customer and<br />

Customer Due Diligence<br />

Citizenship and Residence by Investment<br />

Personal Data: Management and Protection<br />

Demand for Residence and Citizenship by<br />

Investment<br />

Common Reporting Standard &<br />

Mandatory Disclosure Rules<br />

=<br />

Awarded the <strong>IM</strong>C Certification in Investment Migration, Cert (<strong>IM</strong>)<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 85


<strong>IM</strong>C Education & Training (<strong>IM</strong>CET)<br />

<strong>IM</strong>CET is the investment migration industry's only provider<br />

Education & Training (<strong>IM</strong>CET)<br />

of certificated professional education and training<br />

programmes for advisors, agents, lawyers, programme staff<br />

and others working in or associated with the industry.<br />

<strong>IM</strong>CET <strong>IM</strong>CET is is the a newly investment constituted migration division industry's of the only <strong>IM</strong>C provider whose<br />

of courses certificated and qualifications professional education are designed and to training enhance the<br />

programmes for advisors, agents, lawyers, programme staff<br />

and others working in or associated with the industry.<br />

<strong>IM</strong>CET is a newly constituted division of the <strong>IM</strong>C whose<br />

courses and qualifications are designed to enhance the<br />

technical knowledge, competencies and expertise of those<br />

working in or associated with the industry.<br />

The <strong>IM</strong>CET courses are delivered through a flexible range of<br />

learning methods to enable individuals to study in a way that<br />

technical suits them knowledge, at a time competencies and in a format and that expertise works for of those<br />

working their lifestyle. in or associated with the industry.<br />

The <strong>IM</strong>CET courses are delivered through a flexible range of<br />

learning methods to enable individuals to study in a way that<br />

suits them at a time and in a format that works for<br />

their lifestyle.<br />

All education enquiries to imcet@investmentmigration.org<br />

All education enquiries to imcet@investmentmigration.org<br />

investmentmigration.org/education<br />

investmentmigration.org/education<br />

86 - Investment Migration <strong>Yearbook</strong> 2O23

8<strong>IM</strong> YEARBOOK<br />

<strong>2023</strong><br />

15 th - 18 th May <strong>2023</strong><br />

investmentmigration.org/forum/<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 87

<strong>IM</strong> YEARBOOK<br />

About the Forum<br />

The Investment Migration Forum is the largest and most important residence &<br />

citizenship by investment event in the world. Renowned academics, government<br />

officials, representatives of international organisations, as well as the world’s<br />

leading professionals dealing with investment migration will be gathering in<br />

London for the 8 th edition of the Forum.<br />

The three day event will cover a variety of related subjects which are of interest<br />

to the academic, professional and government community. Expect 300+<br />

participants from over 40+ countries.<br />

A limited number of partnership opportunities are available for highly respected<br />

firms to participate in the success of the Forum and to improve their visibility.<br />

About Us<br />

The Investment Migration Council (<strong>IM</strong>C) is the worldwide forum for investment<br />

migration, bringing together the leading stakeholders in the field. The <strong>IM</strong>C sets<br />

global standards, provides qualifications, and publishes in-demand research in the<br />

field of investment migration aimed at governments, policy makers, international<br />

organisations, and the public. It is an impact focused Swiss based (non-profit)<br />

membership organisation in special consultative status with the Economic and<br />

Social Council of the United Nations since 2019 and registered with the European<br />

Commission Joint Transparency Register Secretariat<br />

(ID: 337639131420-09).<br />

Who will Attend<br />

88 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Why should you be part of our Forum?<br />

Why should you be part of our Forum?<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 89

<strong>IM</strong> YEARBOOK<br />

A Who’s Who from Government,<br />

Academia and Business<br />

Prof Dimitry Kochenov<br />

CEU<br />

Prof<br />

Democracy<br />

Dimitry<br />

Institute<br />

Kochenov<br />

Budapest & CEU Legal Studies<br />

CEU Democracy Institute<br />

Department, Vienna<br />

Budapest & CEU Legal Studies<br />

Department, Vienna<br />

Laura Austin <strong>IM</strong>CM<br />

Managing<br />

Laura<br />

Director,<br />

Austin <strong>IM</strong>CM<br />

Mintz Group, New York<br />

Managing Director,<br />

Mintz Group, New York<br />

Eric Major <strong>IM</strong>CM<br />

CEO, Eric Major <strong>IM</strong>CM<br />

Latitude, London<br />

CEO,<br />

Latitude, London<br />

Joe Lynam<br />

Former Disinformation<br />

Specialist, Joe Lynam Brussels<br />

Former Disinformation<br />

Specialist, Brussels<br />

Kieron Sharp <strong>IM</strong>CM<br />

CEO,<br />

FACT Due Kieron Diligence, Sharp London <strong>IM</strong>CM<br />

CEO,<br />

FACT Due Diligence, London<br />

Marina Brizar<br />

UK Director,<br />

Talent Beyond Marina Boundaries, Brizar<br />

London<br />

UK Director,<br />

Talent Beyond Boundaries,<br />

London<br />

Peter Vincent<br />

International Security<br />

Consultant, Virginia<br />

Peter Vincent<br />

International Security<br />

Consultant, Virginia<br />

David Regueiro <strong>IM</strong>CM<br />

COO,<br />

RIF Trust, Dubai<br />

David Regueiro <strong>IM</strong>CM<br />

COO,<br />

RIF Trust, Dubai<br />

Chairman,<br />

Henley & Partners, Zurich<br />

Chairman,<br />

Henley & Partners, Zurich<br />

Nadine Goldfoot <strong>IM</strong>CM<br />

Managing Partner,<br />

Fragomen, London<br />

Nadine Goldfoot <strong>IM</strong>CM<br />

Managing Partner,<br />

Fragomen, London<br />

Karen Kelly <strong>IM</strong>CM<br />

Director - Strategy &<br />

Development,<br />

Exiger, New York<br />

Karen Kelly <strong>IM</strong>CM<br />

Director - Strategy &<br />

Development,<br />

Exiger, New York<br />

Chairman,<br />

Fragomen, New York<br />

Chairman,<br />

Fragomen, New York<br />

90 - Investment Migration <strong>Yearbook</strong> 2O23<br />


<strong>IM</strong> YEARBOOK<br />

Expected Attendance<br />

Based on the success of the past Forum and high demand of the industry, we expect<br />

to have well Based over on the 300+ success delegates of the attending past Forum the and next high Forum demand in <strong>2023</strong>. of the industry, we expect<br />

to have well over 300+ delegates attending the next Forum in <strong>2023</strong>.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 91<br />


<strong>IM</strong> YEARBOOK<br />

Previous Forum Partners<br />

FACT<br />

D U E D I L I G E N C E<br />



FACT<br />

D U E D I L I G E N C E<br />



92 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />



Investment Migration <strong>Yearbook</strong> 2O23 - 93<br />


<strong>IM</strong> YEARBOOK<br />

Testimonials from Past Forums<br />

An excellent Investment Migration Forum<br />

after a 2 year absence due to the global<br />

pandemic.”<br />

Peter Vincent<br />

International Security Consultant, USA<br />

The Investment Migration Forum offers an unrivaled platform<br />

for industry discussion and participation. I have been involved<br />

with the Forum from the beginning, and I consider it an honor<br />

to be closely aligned with the Investment Migration Council.”<br />

Laura Austin<br />

Managing Director, Mintz Group, USA<br />

The team did a great job and hope to be a partner at next<br />

year’s Investment Migration Forum. Congratulations!”<br />

Steven Pepa<br />

Managing Director, Saratoga Capital, Cyprus<br />

Undoubtedly the most important annual meeting for<br />

RCBI professionals, service providers and<br />

governments. Connecting with like-minded delegates<br />

offers us all an opportunity to drive our visions<br />

forward to ensure the sustainability of the industry.”<br />

Charles Mizzi<br />

CEO, Residency Malta Agency, Malta<br />

94 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

We were delighted to be able to attend the 2019 Investment Migration Forum<br />

as a Silver Partner. This was a great event, which gave us the opportunity<br />

to connect with potential partners that have access to the High-Net-Worth<br />

Customer base that want our products, and that need International Medical<br />

Insurance as a part of the requirements for residency and/or citizenship<br />

by investment. It was also of great benefit for us to learn more about the<br />

current global investment migration trends.”<br />

Charles W. Nyren<br />

Head of Business Development, Cigna, UK<br />

The Forum provides an excellent platform for<br />

investment migration professionals from around the<br />

world to meet, exchange ideas and learn about the<br />

industry’s latest trends. As both a sponsor of this<br />

year’s event as welll as the President of the<br />

not-for-profit trade association for EB-5 Regional<br />

Center professionals (IIUSA), I fully encourage all EB-5<br />

professionals to participate in next year’s event.”<br />

Bob Kraft<br />

President, IIUSA; CEO, FirstPathway Partners, USA<br />

A truly excellent event - it goes from strength to strength<br />

each year! Thank you to you and the team for all your<br />

exceptional work.”<br />

Nadine Goldfoot <strong>IM</strong>CM<br />

Managing Partner, Fragomen, London<br />

This is where you want to be. Meet the core<br />

of global migration industry.”<br />

Richard Kurland<br />

Immigration Lawyer & Policy Analyst, Kurland Tobe, Canada<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 95

<strong>IM</strong> YEARBOOK<br />

Become our exclusive Gala Dinner Partner<br />

EUR 60,000<br />

Become our exclusive Gala Dinner Partner<br />

EUR 60,000<br />

Be recognised as the most important partner for our first London Investment Migration<br />

Forum.<br />

Be recognised as the most important partner for our first London Investment Migration<br />

We are organising a once in a lifetime opportunity to jointly host a spectacular evening in<br />

Forum.<br />

one of the worlds most recognisable historic buildings featured in many movies such as<br />

Harry Potter, Mission Impossible, Paddington, Sherlock Holmes, Lawrence of Arabia and<br />

We are organising a once in a lifetime opportunity to jointly host a spectacular evening in<br />

many more.<br />

one of the worlds most recognisable historic buildings featured in many movies such as<br />

Harry Potter, Mission Impossible, Paddington, Sherlock Holmes, Lawrence of Arabia and<br />

For one night only the cathedral will close its doors to the public and host our closing event<br />

many more.<br />

starting with a welcome choral concert under the dome, a welcome cocktail reception in<br />

Admiral Nelsons Chamber, followed by a gastronomic dinner in the Crypt with musical<br />

For one night only the cathedral will close its doors to the public and host our closing event<br />

entertainment. The event will include presentation of the <strong>IM</strong>C recognition awards with the<br />

starting with a welcome choral concert under the dome, a welcome cocktail reception in<br />

opportunity to make a welcome speech.<br />

Admiral Nelsons Chamber, followed by a gastronomic dinner in the Crypt with musical<br />

entertainment. The event will include presentation of the <strong>IM</strong>C recognition awards with the<br />

opportunity to make a welcome speech.<br />

*Sponsorship can be shared between up to 3 companies.<br />

Corporate / Corporate PLUS Members with the <strong>IM</strong>C are eligible for a 5% / 10% discount on the above mentioned packages.<br />

Kindly contact events@investmentmigration.org for further information.<br />

Prices exclude UK VAT charged at 20%.<br />

*Sponsorship can be shared between up to 3 companies.<br />

Corporate<br />

96 13- Investment<br />

/ Corporate<br />

Migration<br />

PLUS<br />

<strong>Yearbook</strong><br />

Members<br />

2O23<br />

with the <strong>IM</strong>C are eligible for a 5% / 10% discount on the above mentioned packages.<br />

Kindly contact events@investmentmigration.org for further information.<br />

Prices exclude UK VAT charged at 20%.

<strong>IM</strong> YEARBOOK<br />

We have worked hard with our partners to bring you an exhaustive list of terrific benefits<br />

as follows:<br />

5 Delegate passes including access to all social functions<br />

1 table of 10 delegates reserved at the Gala Dinner<br />

Company profile on forum webpage and forum delegate book<br />

Exhibitor display table at the forum<br />

Company logo to appear on forum holding slide in plenary room<br />

Keynote presentation during one of the plenary sessions<br />

Welcome signage at Gala Dinner venue<br />

Company logo in forum delegate book<br />

Full page advertisement to be included in forum delegate book<br />

Company logo to appear on general forum signage<br />

Social media coverage<br />

Company hyperlinked logo on forum webpage<br />

Company name on the cover of forum delegate book<br />

Web advertisement on <strong>IM</strong>C website for a period of 6 months<br />

Rotating advert (x2) to be shown during breaks on the<br />

main screen<br />

Private Meeting room to be reserved for 4hrs during the Forum<br />

Panel discussion participation with your company logo<br />

to be displayed on a screen<br />

To receive list of delegates 1 week prior of the forum<br />

(Includes: Name, Company & Country)<br />

Company logo & hyperlink to appear on all forum mailshots,<br />

both pre & post forum<br />

Working Lunch “case study” presentation<br />

(optional attendance by delegates)<br />

14<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 97

<strong>IM</strong> YEARBOOK<br />

Forum Partnership Opportunities<br />

Delegate passes including access to all social functions<br />

Delegate Company passes logo in including forum delegate access book to all social functions<br />

Company logo profile in on forum forum delegate webpage book and forum delegate book<br />

Company Full page advertisement profile on forum to webpage be included and in forum delegate book<br />

EUR 20,000 EUR 17,000 EUR 13,000 EUR 9,000 EUR 5,000<br />

EUR 20,000 4 EUR 17,000 3 EUR 13,000 2 EUR 9,000 1 EUR 5,000 1<br />

4 3 2 1 1<br />

100 words 80 words 60 words 50 words 40 words<br />

100 words 80 words 60 words 50 words 40 words<br />

Full Exhibitor page display advertisement table to be included in forum delegate book<br />

Exhibitor Company display logo to table appear on general forum signage<br />

Company logo to appear on general forum holding forum slide signage in plenary room<br />

Company Panel discussion logo to participation appear forum with holding your company slide in logo plenary room<br />

to be displayed on a screen<br />

Panel discussion participation with your company logo<br />

to Company be displayed logo & on hyperlink a screento appear on all forum mailshots,<br />

both pre & post forum<br />

Company logo & hyperlink to appear on all forum mailshots,<br />

both Social pre media & post coverage forum<br />

Social Keynote media presentation coverageduring one of the plenary sessions<br />

Keynote Company presentation hyperlinked during logo on one forum of the webpage plenary sessions<br />

Company hyperlinked name on the logo cover on of forum webpage delegate book<br />

Company To receive name list of on delegates the cover 1 of week forum prior delegate of the forum book<br />

(Includes: Name, Company & Country)<br />

To receive list of delegates 1 week prior of the forum<br />

(Includes: Web advertisement Name, Company on <strong>IM</strong>C & website Country) for a period of 6 months<br />

Web Rotating advertisement (x2) on to <strong>IM</strong>C be shown website during for a breaks period on of the 6 months main screen<br />

Rotating Private Meeting advert (x2) room to to be be shown reserved during for breaks 4hrs during on the the main Forum screen<br />

Private Working Meeting Lunch “case room study” to be reserved presentation for 4hrs during the Forum<br />

(optional attendance by delegates)- Reserved only for first 2 partners<br />

Working Lunch “case study” presentation<br />

(optional Full page advertisement attendance by on delegates)- outside back Reserved cover, inside only front for first cover 2 or partners other<br />

prominent position of forum delegate book (first come first served basis)<br />

Full page advertisement on outside back cover, inside front cover or other<br />

Mention prominent of position company of forum by Forum delegate Chair book in opening (first come speech first served basis)<br />

Choice Mention of of stand company location by Forum in exhibition Chair hall in opening (first come speech first served basis)<br />

Choice One mailshot of stand to location all delegates in exhibition one week hall before (first come the event first served basis)<br />

One Reserved mailshot delegate to all table delegates near one stageweek before the event<br />

Reserved delegate table near stage<br />

Partner delegate passes, included in partnership agreement, are not tranferable. The pass can only be used by a representative of the partnering<br />

company in their capacity as a delegate<br />

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<br />

company in their capacity as a delegate<br />

Speakers (panel/keynote) passes included as part of package<br />

Corporate / Corporate PLUS Members with the <strong>IM</strong>C are eligible for a 5% / 10% discount on the above mentioned packages.<br />

Kindly contact events@investmentmigration.org for further information.<br />

Corporate Prices exclude / Corporate UK VAT charged PLUS Members at 20%. with the <strong>IM</strong>C are eligible for a 5% / 10% discount on the above mentioned packages.<br />

Kindly contact events@investmentmigration.org for further information.<br />

Prices 15 exclude UK VAT charged at 20%.<br />

98 - Investment Migration <strong>Yearbook</strong> 2O23<br />


<strong>IM</strong> YEARBOOK<br />

Forum Partnership Opportunities<br />

Welcome Cocktail Reception / Networking Cocktail Reception Package<br />

A Welcome Cocktail Reception or Networking Cocktail will be held on the first or second day of the event to meet all the delegates.<br />

Delegate pass including access to all social functions*<br />

Company logo to appear inside Forum delegate book<br />

Company profile on Forum webiste and Forum delegate book<br />

Branded Tent Cards during reception<br />

EUR 15,000<br />

1<br />

50 words<br />

Web advertisement on <strong>IM</strong>C website for 4 months if package is booked by 31 March <strong>2023</strong><br />

Exhibitor display table<br />

Full page advertisement to be included in Forum delegate book<br />

Company logo to appear on general Forum signage<br />

Welcome Address at the Cocktail Reception**<br />

Lunch Break<br />

Gain more visibility during Lunch Break on 1 of the conference days. (1 per day)<br />

Benefits<br />

EUR 6,000<br />

Company logo on Forum webpage<br />

Company Logo in Forum delegate book<br />

Company Logo on signage at two Forum lunch breaks<br />

Delegate pass including access to all social functions* 1<br />

Networking Break<br />

Get additional light on your company during Networking Breaks on 1 of the conference days. (2 per day)<br />

Benefits<br />

Networking Break<br />

Partner<br />

EUR 5,000<br />

Company logo on Forum webpage<br />

Company Logo in Forum delegate book<br />

Company Logo on signage at four Forum networking breaks<br />

Delegate pass including access to all social functions* 1<br />

* Partner delegate passes, included in partnership agreement, are not transferable. The pass can only be used by a representative<br />

of the partnering company in their capacity as a delegate<br />

** To be co-ordinated with the programme committee.<br />

Corporate / Corporate PLUS Members with the <strong>IM</strong>C are eligible for a 5% / 10% discount on the above mentioned packages.<br />

Kindly contact events@investmentmigration.org for further information.<br />

Prices exclude UK VAT charged at 20%.<br />

Investment Migration <strong>Yearbook</strong> 2O23 16 - 99

<strong>IM</strong> YEARBOOK<br />

Forum Partnership Opportunities<br />

Delegate Tote Bag Partner<br />

EUR 2,000<br />

USB Charging Cables Partner<br />

EUR 2,000<br />

Branded tote bag to be co branded with the <strong>IM</strong>C<br />

40 word company profile on website & delegate book<br />

Logo to appear on all campaigns related to the event<br />

Branded USB Charging Cables to be co branded with<br />

the <strong>IM</strong>C<br />

40 word company profile on website & delegate book<br />

Logo to appear on all campaigns related to the event<br />

Branded Coaster Partner<br />

EUR 2,000<br />

Coasters that are distributed at coffee breaks to be<br />

branded with company logo<br />

40 word company profile on website & delegate book<br />

Logo to appear on all campaigns related to the event<br />

Branded A5 Notebook Partner<br />

EUR 2,500<br />

Branded desktop delegate notebook to be co branded with<br />

the <strong>IM</strong>C<br />

40 word company profile on website & delegate book<br />

Logo to appear on all campaigns related to the event<br />

Corporate / Corporate PLUS Members with the <strong>IM</strong>C are eligible for a 5% / 10% discount on the above mentioned packages.<br />

Kindly contact events@investmentmigration.org for further information.<br />

Prices exclude UK VAT charged at 20%.<br />

100 17 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Forum Partnership Opportunities<br />

Speaker Gift Partner<br />

EUR 5,000<br />

Speaker Gift to be co branded with the <strong>IM</strong>C<br />

40 word company profile on website & delegate book<br />

Logo to appear on all campaigns related to the event<br />

Juice Bar Partner<br />

EUR 5,000<br />

Juice Bar to be co branded with the <strong>IM</strong>C<br />

40 word company profile on website & delegate book<br />

Logo to appear on all campaigns related to the event<br />

‘Sweet Shop’ Partner<br />

EUR 5,000<br />

Powerbank Partner<br />

EUR 6,000<br />

Sweet shop to be co branded with the <strong>IM</strong>C<br />

40 word company profile on website & delegate book<br />

Logo to appear on all campaigns related to the event<br />

Powerbanks to be branded with company logo<br />

40 word company profile on website & delegate book<br />

Logo to appear on all campaigns related to the event<br />

Corporate / Corporate PLUS Members with the <strong>IM</strong>C are eligible for a 5% / 10% discount on the above mentioned packages.<br />

Kindly contact events@investmentmigration.org for further information.<br />

Prices exclude UK VAT charged at 20%.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 10118

<strong>IM</strong> YEARBOOK<br />

Visibility Opportunities for Your Business<br />

The Investment Migration Council provides numerous opportunities to increase<br />

your corporate visibility and to enhance your Business Growth<br />

investmentmigration.org/partner-with-us/<br />

102 - Investment Migration <strong>Yearbook</strong> 2O23

Introduction<br />

<strong>IM</strong> YEARBOOK<br />

The <strong>IM</strong>C provides a range of high-quality and specifically targeted<br />

promotional channels; these include the <strong>IM</strong>C website (which benefits from a<br />

sustainable subscriber growth), as well as Email Newsletter software which is<br />

Introduction<br />

targeted towards specialised niche segments of the market.<br />

Introduction<br />

The <strong>IM</strong>C Media Channels provide cost-effective, measurable and<br />

results-oriented The <strong>IM</strong>C provides means a range of enhancing of high-quality your and business specifically development. targeted<br />

promotional channels; these include the <strong>IM</strong>C website (which benefits from a<br />

This sustainable document subscriber is designed growth), to provide as well a as deeper Email Newsletter knowledge software about the which <strong>IM</strong>C is<br />

Visibilty targeted Opportunities.<br />

towards specialised niche segments of the market.<br />

Please The <strong>IM</strong>C contact Media us Channels on info@investmentmigration.org provide cost-effective, measurable for more details. and<br />

results-oriented means of enhancing your business development.<br />

This document is designed to provide a deeper knowledge about the <strong>IM</strong>C<br />

Visibilty Opportunities.<br />

Please contact us on info@investmentmigration.org for more details.<br />

Reasons to partner with us<br />

Reasons to partner with us<br />

Precise Audience Targeting<br />

When partnering with the <strong>IM</strong>C, you<br />

know that your message will reach<br />

Reasons a specialised to target partner audience which with us<br />

suits your business interests.<br />

High-Quality Precise Audience Content Targeting<br />

Both When the partnering <strong>IM</strong>C website with and the e-Newsletters,<br />

<strong>IM</strong>C, you<br />

offer know high-quality that your content message that will attracts reach<br />

industry a specialised professionals, target audience thus giving which your<br />

advertising suits your more business opportunities interests. to be<br />

seen by the right audience.<br />

High-Quality Content<br />

Both the <strong>IM</strong>C website and e-Newsletters,<br />

offer high-quality content that attracts<br />

industry professionals, thus giving your<br />

advertising more opportunities to be<br />

seen by the right audience.<br />

Exclusivity of one advertiser<br />

per opportunity<br />

All <strong>IM</strong>C Visibility Opportunities are limited<br />

to one partner per medium/package.<br />

Extensive Exclusivity post-campaign<br />

of one advertiser<br />

reporting per opportunity<br />

Each All partner <strong>IM</strong>C Visibility will be Opportunities provided with are limited<br />

a detailed to one partner post-campaign per medium/package.<br />

report which<br />

will be compiled for you by the<br />

<strong>IM</strong>C team.<br />

Extensive post-campaign<br />

reporting<br />

Each partner will be provided with<br />

a detailed post-campaign report which<br />

will be compiled for you by the<br />

<strong>IM</strong>C team.<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 103

<strong>IM</strong> YEARBOOK<br />

Membership Facts<br />

Membership Facts<br />

<strong>IM</strong>C Members represent companies and are industry professionals with proven expertise<br />

<strong>IM</strong>C and Members a good reputation represent within companies the field and around are industry the globe. professionals with proven expertise<br />

and a good reputation within the field around the globe.<br />

e. 7 %<br />

e. 7 %<br />

f. 2 %<br />

f. 2 %<br />

g. 1 %<br />

g. 1 %<br />

h. 1 %<br />

h. 1 %<br />

a Europe<br />

a Europe<br />

b Middle East<br />

d. 11 %<br />

b Middle East<br />

d. 11 %<br />

c Asia<br />

c Asia<br />

d USA & Canada<br />

c. 11<br />

% a. 53%<br />

d USA & Canada<br />

c. 11<br />

% a. 53%<br />

e Caribbean<br />

e Caribbean<br />

f Africa<br />

f Africa<br />

g South America<br />

g South America<br />

b. 14 %<br />

b. 14 % h Oceana<br />

h Oceana<br />

Our Members - Your Audience<br />

Our Members - Your Audience<br />

Our Members Your Audience<br />

(July 2022)<br />

Our Members include the world’s leading industry professionals, service<br />

providers, Our Members academics include and the world’s government leading officials industry who professionals, are dealing with service investor migration<br />

providers, and representing academics the following and government sectors: officials who are dealing with investor migration<br />

and representing the following sectors:<br />

- Citizenship-by-investment Consultancy<br />

-<br />

Citizenship-by-investment Consultancy<br />

Immigration Law<br />

-<br />

Immigration Law<br />

Wealth Management<br />

-<br />

Wealth Management<br />

Financial Advisory<br />

-<br />

Financial Advisory<br />

Private Banking<br />

-<br />

Private Banking<br />

Government and Academia<br />

- Government and Academia<br />

(July 2022)<br />

104 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

Website Facts<br />

Website Facts<br />

Key traffic channels:<br />

d. 8 %<br />

e. 1 %<br />

c. 15 % a. 48 %<br />

a Direct Traffic<br />

b Organic Search<br />

c Social Media<br />

d Referral from partner sites<br />

e Email Marketing<br />

(July 2022)<br />

Here are our top 5 visited pages on <strong>IM</strong>C’s official website:<br />

1. Home Page: a lively hub of activity<br />

2. Membership: dedicated information about membership<br />

3. News: latest News, Articles and Reports, all industry focussed<br />

4. About: a comprehensive breakdown of insider’s information<br />

5. Contact Us: popular page about the <strong>IM</strong>C and its global locations<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 105

<strong>IM</strong> YEARBOOK<br />

Visibility Opportunities<br />

Visibility Opportunities<br />

The <strong>IM</strong>C Website<br />

Our website is an informational platform for industry stakeholders who are exploring<br />

latest updates within the RCBI Industry. The website is regularly updated with the latest<br />

industry-related news, articles, academic papers and the latest overview<br />

of residency- and citizenship-by-investment programmes from around the world.<br />

<strong>IM</strong>C website Key Performance Indicators:<br />

7.800 sessions<br />

Average visits per month<br />

+85% new users annually<br />

Constantly growing audience<br />

Accessed from 150+ countries<br />

Global Reach<br />

2 pages per session<br />

Average page views<br />

65% desktop<br />

35% mobile & tablets<br />

Technology<br />

Top 25 Geo-locations<br />

4<br />

18<br />

17<br />

7 11 25 8<br />

21 22<br />

13 12<br />

9<br />

10 15 23<br />

24<br />

2<br />

5<br />

1<br />

3<br />

14<br />

6<br />

20<br />

19<br />

16<br />

(July 2022)<br />

106 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

1. Horizontal Banner on top visited pages<br />

1. Horizontal Banner on top visited pages<br />

This opportunity offers a hyper-linked horizontal banner at the base of the page of the<br />

most This opportunity visited sections offers of a hyper-linked <strong>IM</strong>C website, horizontal such as banner the Homepage, at the base “About of the Us” page section and<br />

“Membership”<br />

of the most visited<br />

page<br />

sections<br />

and limited<br />

of <strong>IM</strong>C<br />

to<br />

website,<br />

one banner<br />

such as<br />

per<br />

the<br />

page.<br />

Homepage, “About Us”<br />

section and “Membership” page and limited to one banner per page.<br />

Your Brand Here!<br />

Size: 728px x 90 px<br />

In partnership with<br />

Your Brand Here!<br />

Size: 728px x 90 px<br />

Size: 728px x 90 px<br />

Page / location<br />

6 months<br />

Homepage €3,500<br />

Membership €3,000<br />

About Us €2,500<br />

The Governing Board €2,500<br />

The Advisory Committee €2,500<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 107

<strong>IM</strong> YEARBOOK<br />

2. Standard Horizontal Banner on Knowledge pages<br />

2. Standard Horizontal Banner on Knowledge pages<br />

The <strong>IM</strong>C website is regularly updated with industry-related news and articles.<br />

This The information <strong>IM</strong>C website is published is regularly under updated the “Knowledge” with industry-related section and news consists and of articles. news,<br />

thought This information leadership, is reports published & papers under and the newsletter-related “Knowledge” section pages. and consists of news,<br />

thought leadership, reports & papers and newsletter-related pages.<br />

Your Brand Here!<br />

Size: 728px x 96 px<br />

Your Brand Here!<br />

Size: 728px x 96 px<br />

Your Brand Here!<br />

Size: 728px x 96 px<br />

Page / location<br />

6 months<br />

Contact Us €2,500<br />

News €2,000<br />

Thought Leadership €2,000<br />

Reports & Papers €1,500<br />

108 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

e-Newsletter Overview<br />

We issue regular email newsletters that are sent to senior and influential stakeholders<br />

of the industry. Each of our email newsletters feature high-quality content. This medium<br />

offers a deep insight into readers’ behaviours, covering aspects such as open rates and<br />

links clicked, amongst other metrics.<br />

There are three types of Newsletters that are issued by the <strong>IM</strong>C:<br />

• News Round-up – issued once a month (12 per year)<br />

• <strong>IM</strong>C Bulletin – issued every quarter (4 per year)<br />

• Corporate Announcements - exclusive dedicated messaging to deliver a specific,<br />

important message to a selected audience (more details on page 14)<br />

Email marketing communications issued by the<br />

<strong>IM</strong>C have a proven track record:<br />

Average open rate of 45%<br />

Low unsubscribe rate<br />

Consistent increase in the<br />

subscribing audience<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 109

<strong>IM</strong> YEARBOOK<br />

3. News Round-Up<br />

3. News Round-Up<br />

The<br />

The<br />

“News<br />

“News<br />

Round-up”<br />

Round-up”<br />

is<br />

is<br />

a regular<br />

a regular<br />

e-Newsletter<br />

e-Newsletter<br />

issue<br />

issue<br />

that<br />

that<br />

provides<br />

provides readers with a<br />

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<br />

industry. objective All and articles industry-related are objective only. and industry-related only.<br />

Description<br />

1 month<br />

(2 mail-shots)<br />

3 months<br />

(6 mail-shots)<br />

One banner located at the very top of the newsletter template<br />

which is the prime spot visibility-wise<br />

One industry-related press release<br />

Press release to be published on the website<br />

€1,000 €2,500<br />

Banner Specifications:<br />

Target Audience:<br />

<strong>IM</strong>C Members<br />

File type:<br />

.jpg, .jpeg, 72 dpi<br />

Frequency:<br />

Banner Position:<br />

Every month<br />

Prime position at the top<br />

Reports:<br />

2 reports per mail-shot<br />

(1 and 2 weeks after email is sent out)<br />

Size:<br />

600px x 200 px<br />

110 - Investment Migration <strong>Yearbook</strong> 2O23

<strong>IM</strong> YEARBOOK<br />

4. <strong>IM</strong>C Bulletin e-Newsletter<br />

The <strong>IM</strong>C Bulletin is a quarterly email newsletter with valuable interesting industry-related<br />

content. Each issue of the <strong>IM</strong>C Bulletin, which begins with a welcome note by the CEO or a<br />

guest editor, features articles that are contributed by <strong>IM</strong>C Members as well as by members<br />

of the Advisory Committee, academics and prominent contributors. A list of recently<br />

joined<br />

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.),<br />

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%.<br />

Description 1 issue 2 issues<br />

Two hyperlinked banners (details below)<br />

One paid industry-related article<br />

One featured event to be displayed at the top of the events section<br />

Banner to be placed in the News Section on the <strong>IM</strong>C Website<br />

(only if two issues are purchased)<br />

€5,000 €9,000<br />

Banner Specifications:<br />

Target Audience:<br />

Frequency:<br />

Position:<br />

<strong>IM</strong>C Members, <strong>IM</strong>C Subscribers, <strong>IM</strong>C<br />

Contacts<br />

4 issues per year<br />

1 banner after editorial<br />

and 1 after articles<br />

Size:<br />

File type:<br />

Reports:<br />

600px x 200px<br />

.jpg, .jpeg, 72 dpi<br />

2 reports per main-shot<br />

(1 and 2 weeks after email is sent out)<br />

Investment Migration <strong>Yearbook</strong> 2O23 - 111

<strong>IM</strong> YEARBOOK<br />

5. Corporate Announcements via Dedicated Email Shots<br />

5. Corporate Announcements via Dedicated Email Shots<br />

The <strong>IM</strong>C Corporate Announcement provides a unique opportunity to deliver a message<br />

to all<br />

The<br />

<strong>IM</strong>C<br />

<strong>IM</strong>C<br />

Members,<br />

Corporate<br />

with<br />

Announcement<br />

a possibility of<br />

provides<br />

selection<br />

a unique<br />

by line of<br />

opportunity<br />

business or<br />

to<br />

by<br />

deliver<br />

country<br />

a message<br />

of citizenship/business.<br />

to all <strong>IM</strong>C Members,<br />

This<br />

with<br />

message<br />

a possibility<br />

can contain<br />

of selection<br />

an important<br />

by line of<br />

Press<br />

business<br />

Release,<br />

or by country<br />

Call<br />

of<br />

for<br />

citizenship/business.<br />

a Collaboration or any<br />

This<br />

other<br />

message<br />

objective<br />

can contain<br />

and industry-related<br />

an important<br />

update.<br />

Press Release,<br />

Call for a Collaboration or any other objective and industry-related update.<br />

Description<br />

Format:<br />

Dedicated email template containing two hyperlinked banners, text<br />

(up to 200 words) and a ‘Read More’ link to only one website<br />

1 mailshot<br />

€6,000<br />

The Announcement includes the following:<br />

One banner at the top of the page<br />

One Face photo with name and title on the left (will appear as<br />

paragraph breakdown on device version)<br />

One banner under “read more” button<br />

One article up to 200 words<br />

Target Audience:<br />

Can be pre-identified according to the country, membership status<br />

(members, leads, etc.) and line of business.<br />

Service includes:<br />

Creation of a newsletter using <strong>IM</strong>C template & content provided<br />

Provision of a newsletter preview for approval<br />

Sending of a newsletter to agreed Target Group (contact lists)<br />

2 post-campaign reports will be provided (1 and 2 weeks after email is sent out)<br />

Creation of customised template or campaign design is available on request at an<br />

additional cost. Contact us on info@investmentmigration.org for more details.<br />

112 - Investment Migration <strong>Yearbook</strong> 2O23

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