IM Yearbook 2024

IM 

INVESTMENT 

MIGRATION 

THE 

6th EDITION 

THE 

6th 

EDITION 

THE THE NUMBERS NUMBERS 

184m 184m global global migrants migrants 

IMC members IMC members = 200+ = spoken 200+ spoken languages languages 

100+ 100+ IM pathways IM pathways globally globally 

GLOBAL GLOBAL VIEWS VIEWS 

Long-term Long-term future future of immigration of immigration 

Portugal Portugal in the in spotlight the spotlight 

YEARBOOK 2024 

OECD OECD Report Report under under scrutiny scrutiny 

FORESIGHT 

NEW NEW IMC Business IMC Business memberships memberships 

The mindset The mindset of an investor of an investor 

Quest Quest for certainty for certainty and stability and stability 

Behavioural Behavioural 

Economics Economics 

& Migration Migration 

Trust-based immigration 

policies 

Trust-based 

are the 

immigration 

key to 

unlocking 

policies 

economic 

are the key 

prosperity 

to 

unlocking economic prosperity 

in our interconnected world 

in our interconnected world

Specializing in citizenship and residency by investment, our team are 

committed to offering clients unique experience. We offer free 

consultations to evaluate clients, answer questions your clients may have, 

and provide them with valuable recommendations and programs to meet 

their goals. 

We promise never to make direct contact with our partners' clients, 

which is guaranteed by the terms of our agreement. We welcome all 

sorts of companies and individual worldwide. Considerable commissions 

will be granted to celebrate the success of our joint effort. 

Siren Chen 

Chief Operating Officer 

Project R&D, B2B Division 

Email: 

Sirenchen@globevisa.com 

CONTACT US 

Website: 

www.globevisa.com

IM YEARBOOK 

Contents 

Key Insights at a Glance 4 

Facts & Figures 5 

IMC Members 2023 8 

Redefining Narratives and 

Remodelling Pathways 11 

Bruno L’Ecuyer, CEO Investment Migration Council 

In the Headlines 14 

Navigating Changes in 

Portugal’s Residency Pathway 17 

Interview with Jerome Morgan, Founder, 

President & CEO of the Mercan Group 

The Good, the Bad and the Ugly 18 

The FATF/OECD Report on Investment Migration 

What is the Data Showing Us 

about the New Era of EB-5? 20 

Lee Y. Li, Director of Policy 

Research and Data Analytics at IIUSA 

How the War in Israel and 

Gaza is Impacting IM 22 

From 2024 to the Future 24 

A Candid Conversation with Dr Juerg Steffen, 

CEO of Henley & Partners 

CBI: A Year of Transformation 

in the Caribbean 28 

3 Questions for 2024 33 

Six Things You Did Not Know 

about Due Diligence 37 

Kieron Sharp, CEO of FACT 

The Canadian Start-up Visa Journey 38 

Interview with Slava Apel, CEO of Startup Visa Services 

New IMC Membership Tiers Foster 

Inclusivity and Collaboration 41 

Interview with Jacqueline Gauci, 

Head of Membership Services at the IMC 

The Quest for Certainty 

and Stability 44 

Interview with Ron Klasko, 

Chairman of Klasko Immigration Law 

CBI Interviews Offer In-Depth 

Information & Reveal Disparities 46 

Interview with Sachit Kumar, Managing 

Director of Globe Detective Agency 

The Mindset of an Investor 47 

Dariush Soudi, CEO of Arena Capital and Consultancy 

Unpacking Policy 

Intentions: A Closer Look at 

UK Immigration Changes 48 

Interview with Nadine Goldfoot, Managing Partner of Fragomen UK 

Look for a Partner, 

not a Service Provider 50 

Interview with Karen Kelly, 

Vice President Commercial Markets at Exiger 

Rising Opportunities in 

Emerging Markets 53 

Interview with Michael Waechter, Director of Abode Options 

Navigating Austria’s 

Merit-Based Citizenship 54 

Stefan Pacher, Associate at Wolf Theiss 

Discovering the Hidden 

Charms of the Cayman Islands 56 

Kristy Rivers, Vice President of Business Development and Leasing at Dart 

Investment Migration Yearbook 2O24 - 1


St. Kitts and Nevis: 

A Trusted Innovator 59 

Country Spotlight 

Dominica: The Country 

that Bounces Back 60 


Unlocking Prosperity: Why 

Behavioural Sciences Matter in 

Investment Migration 63 

Solutions for Global Migrants Sibylla Verdi and Davide Petroni 

Solutions for Global Migrants 66 

Malta’s Residency Options at a Glance 

What is the Long-term Future 

of the Immigration Industry? 67 

Henry Fan, CEO and Co-Founder of Globevisa Group 

Amendments to the Portuguese 

Nationality Law: A NewParadigm 

for Residence Permit Applicants 71 

Diogo Capela, Founding Partner of Lamares, 

Capela & Associados 

Unveiling Grenada’s Global 

Citizenship Oasis: The Synergy of 

Luxury, Sustainability, and Progress 72 

Galli Khurelee, Vice President of Global 

Markets at Hengsheng Group 

Empowering Investment Migration 

Professionals: IMC Launches New 

Executive Master’s Programme amid 

Unprecedented Global Changes 74 

Dr Dee Allen and Philip Allen 

YEARBOOK 2024 

All rights reserved. Reproduction in whole or part is strictly 

prohibited without the written permission of the publisher. 

Opinions expressed in the IM Yearbook are not necessarily 

those of the editor, publisher or contributors. All reasonable 

care is taken to ensure truth and accuracy, but the editor and 

publisher cannot be held responsible for errors or omissions 

in articles, advertising, photographs, or illustrations. 

Publication Date: January 2024 

Printing: Gutenberg Press 

Publisher: Investment Migration Council - media@investmentmigration.org 

Editor: Bruno L’ecuyer - bruno.lecuyer@investmentmigration.org 

Sonja Lindenberg - sonja@storycom.net 

Cover Design: Ray Debono 

Layout: Ramon Micallef - ram@box-design.net 

ISBN N°: 978-2-8399-4156-3 

2 - Investment Migration Yearbook 2O24

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Antigua · Australia · Austria · Canada · China · Cyprus · Grenada · Hong Kong · India · Indonesia · Israel · Latvia · Malaysia · Malta · Montenegro · Nigeria · Pakistan 

Philippines · Portugal · Qatar · Singapore · South Africa · South Korea · Spain · St. Kitts · St. Lucia · Switzerland · Thailand · Türkiye · UAE · UK · USA · Uzbekistan · Vietnam


Facts & Figures 

Key Insights 

at a Glance 

Numbers and quoted percentages may not add up due to rounding. 

Investment Migration 

Market Expansion: 

Travel Freedom: 

Industry Players: 

Global Network: 

• Over the years, investment 

migration has undergone 

significant growth and 

transformation. 

• While numerous pathways 

have undergone changes 

or been terminated in 

2023, new avenues have 

emerged, with Namibia 

unveiling its residency 

pathway as the most 

recent addition last year. 

Global Reach: 

Approximate number of 

countries offering investment 

migration pathways: 

1OO 

Jurisdictions actively 

promoting their pathways: 

60 

Top destinations attracting 

the majority of applicants: 

3O 

Historical Milestone: 

The year 1984 marked a 

significant milestone in 

investment migration with the 

introduction of the first modern 

Citizenship by Investment (CBI) 

pathway by St. Kitts and Nevis. 

• An EU passport typically 

allows visa-free travel to 

an impressive range of 

15O-17O 

countries 

• Visa-free access is subject 

to comprehensive due 

diligence procedures. 

Diverse Investment 

Requirements: 

• Investment thresholds 

vary significantly 

across countries. 

• Minimum investment 

range: 

$100,000 

to over 

$5 million 

Geographical 

Distribution: 

• Rich nations dominate 

investment migration 

pathways, accounting for 

9O% 

• High-income countries 

(GNI per capita of 

$12,696 or higher): 63%. 

• Upper middle-income 

countries (GNI per 

capita between $4,046 

and $12,535): 30%. 

• Number of licensed 

agents driving 

investment migration: 

550+ 

• These agents primarily 

consist of small businesses 

and consultancies. 

Leading Residency Pathways (.) : 

Australia Austria Canada Cyprus 

Greece Hong Kong Ireland Italy 

Jersey Latvia Luxembourg Malaysia 

Malta Mauritius Monaco Montenegro 

Namibia Netherlands New Zealand Panama 

Portugal Singapore Spain Switzerland 

Thailand UAE UK US 

Citizenship Pathways (.) : 

The Investment Migration 

Council (IMC) unites over 

450 members from 

45+ different countries. 

Economic Impact: 

• Estimated value of the 


industry: €20 billion. 

• The industry generates 

substantial socioeconomic 

benefits, including job 

creation and notable 

contributions to GDP. 

Antigua & Barbuda Austria Dominica 

Egypt Grenada Jordan 

Malta Montenegro North Macedonia 

St. Kitts & Nevis St. Lucia Turkey 



Worldwide Migration Figures 

The global migrant population comprises 

approximately 184 million individuals, including 

37 million refugees. Among them, 43 percent 

reside in low- and middle-income countries. 

Around 40 percent, consisting of 64 million economic 

migrants and 10 million refugees, live in high-income 

countries that are members of the Organisation for 

Economic Co-operation and Development (OECD). 

This diverse group encompasses both highly skilled 

and low-skilled workers, along with their families. 

It also includes individuals with settlement intentions, 

temporary migrants, students, undocumented 

migrants, and those seeking international protection. 

This figure also includes 11 million EU citizens residing in 

other member states, enjoying extensive residency rights. 

Approximately 17 percent, comprising 31 million 

economic migrants, reside in the Gulf Cooperation 

Council (GCC) countries. These migrants 

predominantly hold temporary work visas and 

contribute to the labour force. On average, they make 

up about half of the population in GCC countries. 

Approximately 43 percent, encompassing 52 million 

economic migrants and 27 million refugees, reside in lowand 

middle-income countries. Their primary motivations 

for migration include employment opportunities, family 

reunification, and the pursuit of international protection. 

World’s 

Wealthiest 

Cities 

st New York City 

1 

nd Tokyo 

2 

rd San Francisco 

3 

4th: London 

5th: Singapore 

6th: Los Angeles & Malibu 

7th: Chicago 

8th: Houston 

9th: Beijing 

10th: Shanghai 

11th: Sydney 

12th: Hong Kong SAR 

13th: Frankfurt 

14th: Toronto 

15th: Zurich 

16th: Seoul 

17th: Melbourne 

18th: Dallas & Fort Worth 

19th: Geneva 

20th: Paris 

Source: Henley Global Citizens Report 

(all figures are of 30 June 2022) 

Source: World Development Report 2023, The World Bank Group 

Migration of Dollar Millionaires: Trends and Forecasts 

The provided data illustrates the annual count of dollar millionaires who have relocated 

and established residency in a new country for more than six months since 2013. 

Number of HNWIs Migrated 

51,000 

57,000 

64,000 

82,000 

95,000 

108,000 

110,000 

12,000 

Coronavirus 

impact 

25,000 

Coronavirus 

impact 

84,000 

122,000 

128,000 

2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 (F) 2024 (F) 

Source: New World Wealth 



Regional Spotlight 

The IM Yearbook delves into pivotal 

regions, explored the dynamic 

landscape of investment migration, 

and summarised the factors that 

drove demand and supply in 2023. 

Forecast Net Outflows 

n 2023 n 2022 

-13,500 

-10,800 

-6,500 

-7,500 

-3,200 

-1,600 

-3,000 

-8,500 

-1,200 

-1,800 

-1,000 

-2,400 

-800 

-400 

-700 

-800 

-500 

-400 

-300 

-100 

600 

300 

-300 

-200 

-300 

-200 

-200 

-400 

-200 

-200 

-100 

-600 

-100 

-100 

-100 

-100 

-100 

-100 

-100 

-100 

China 

India 

UK 

Russian 

Federation 

Brazil 

Hong Kong 

SAR 

South 

Korea 

Mexico 

South 

Africa 

Japan 

Vietnam 

Nigeria 

Indonesia 

Argentina 

Egypt 

Saudi 

Arabia 

Colombia 

Chile 

Kenya 

Ghana 

Source: Henley & Partners 2023 

Forecast Net HNWI Inflows 2023 

Actual Net HNWI Inflows 2023 

Australia 

UAE 

Singapore 

USA 

Switzerland 

Canada 

Greece 

France 

Portugal 

New 

Zealand 

Italy 

Israel 

Germany 

Spain 

Monaco 

Netherlands 

Malta 

Mauritius 

Luxembourg 

Morocco 

5,200 

3,800 

4,500 

5,200 

3,200 

2,900 

2,100 

1,500 

1,800 

2,200 

1,600 

1,200 

1,200 

1,000 

1,000 

500 

800 

1,400 

700 

800 

600 

300 

600 

1,100 

400 

200 

400 

200 

400 

300 

200 

200 

200 

200 

200 

200 

100 

100 

100 

100 

South Africa 

The demand for residence and 

citizenship by investment in South 

Africa has surged due to concerns 

over energy crisis, currency 

volatility, crime, corruption, 

unemployment, and a failing 

education system. The country’s 

grey listing by the Financial Action 

Task Force in February 2023 and 

changes in tax clearance processes 

have further fuelled this trend. 

South Africans are increasingly 

exploring options for alternative 

residence or citizenship, with 

Portugal being a popular choice. 

Namibia has also emerged as an 

attractive prospect, offering a 

stable democracy, favourable tax 

system, and cultural similarities. 

Europe 

Agents report that the most soughtafter 

residency pathways are those 

of Portugal, Spain and Greece. 

However, changes are imminent, 

such as the end of Portugal’s 

real estate investment route and 

increased real estate investment 

requirements in Greece. Despite 

these changes, there has been 

a consistent rise in enquiries, 

particularly from the UK and 

Turkey. In 2023, Italy’s residency 

pathway also garnered attention 

for its favourable tax regulations. 

Individuals who establish Italy 

as their tax domicile are required 

to pay an annual lump sum of 

€100,000 on any foreign-sourced 

income under the flat tax regime. 

US & Canada 

High-net-worth individuals in 

North America are increasingly 

aware of the benefits of investment 

migration. While the USA and 

Canada have long been attractive 

for inbound economic migration, 

wealthy investors are increasingly 

exploring outbound options. 

Factors such as political and 

economic changes, tax policy 

shifts, and global events fuel 

demand for stability and security. 

Agents report that EU countries 

like Greece, Italy, Portugal, and 

Spain are popular destinations, 

offering flexible residence options 

and access to desirable lifestyles 

and education. Caribbean 

countries with established 

citizenship by investment pathways 

have also garnered attention. 

Middle East 

The Middle East is experiencing 

significant growth in the investment 

migration sector, with high-networth 

individuals showing increased 

interest in European residence 

and citizenship pathways. Stable 

economies, high standards of living, 

and access to quality education 

and healthcare make countries 

like Malta, Portugal, and Spain 

popular choices. Impact investing, 

which combines financial returns 

with social and environmental 

benefits, is gaining traction in the 

region. Some investment migration 

pathways now require sustainable 

and socially responsible investments. 

China & Hong Kong 

In April 2023, Hong Kong lifted all 

Covid-19 restrictions, sparking a 

desire among wealthy families to 

secure alternative residence options 

abroad. After a slowdown during the 

pandemic, demand for investment 

migration in East Asia has rebounded 

significantly. High-net-worth 

investors seek alternative residence 

or citizenship for various reasons, 

including better education, improved 

living conditions, mobility, healthcare 

access, political stability, employment 

opportunities, and wealth 

diversification. According to service 

providers, changes in Portugal’s 

residency pathway led to increased 

interest in Greece, Italy, and Spain. 

Moreover, applicants from the region 

are increasingly considering multiple 

pathways to meet their family’s 

unique requirements and build a 

portfolio of residence and citizenship 

options, ensuring future-proof 

wealth and personal access rights. 

Southeast Asia 

The investment migration sector 

is thriving in Southeast Asia and 

Oceania, with growing interest 

from Malaysian citizens, as well as 

residents of Australia, the Philippines, 

and Singapore. Singapore has 

emerged as Asia’s top wealth hub, 

despite recent changes in investment 

migration pathways, such as increased 

investment requirements for the 

Singapore Global Investor Program. 

Developed countries like Australia 

and New Zealand are popular choices 

among Asian investor migrants, 

while 2023 also saw a significant 

increase in enquiries for Portugal’s 

and Spain’s residency pathways. 


LIST OF MEMBERS 2023 

111 Immigration Services 

360 Advisory & Management GmbH 

Abode Options Management consultants 

Academy Finance 

Afi Ventour & Co. 

AIT Accounting & Management Services Ltd 

Alpha Immigration Associates 

Alta Invest RCBI Solutions 

American Pathways Consulting LLC 

Andorra Guides 

Appleby 

Arden Leigh LLP 

Asia Outbound Group 

Attorney at Law Office Mia Jug Dujaković 

Austral Migration Consultancy P/L 

BDO 

Bedell Cristin 

Bellevue Zürich Advisory AG (Ltd.) 

Beshara Global Migration Law Firm 

BEYOND Residence and Citizenship 

BIZ Consult Ltd 

Bluewater Immigration 

Bond University 

Brenci. Lawyer – Advice – Negotiation 

Budget & Migration Consultants 

CANAfect Immigration & Citizenship Solutions Ltd. 

Caribbean Legal and Project Advisory Limited 

CBIM Solutions 

Century Capital Inc. 

Chetcuti Cauchi Advocates 

Cinvest Migration 

Citizenship By Investment Unit - Antigua & Barbuda 

Citizenship by Investment Unit - Saint Lucia 

CJ International Group 

CLD Legal 

CSB International Ltd. 

Dalmore Group, LLC 

Davison & Davison Associates Limited 

Discus Holdings 

Dual Luxury World 

EB5 Coast to Coast 

Energopiisi 

Erg, Family Office 

Exclusive Migration 

Exiger LLC 

FACT Due Diligence 

Filimon Consulting 

First Advisory Trust reg. 

Fragomen Worldwide 

Free Mobility Leaders 

Frendo Advisory 

Frontgate Global Concepts 

Ganado & Associates 

GICG Global Information Consulting Group 

GLI General Lines of Immigration Corporation 

Global Citizen Solutions Limited 

Global Migration Investment Services 

Global Nomad Consulting 

Global Pass SAL Offshore 

Global Residence and Citizenship Ltd. 

Global Residence Index 

Globe Detective Agency (P) Ltd. 

Globevisa 

Golden Visa Consultancy 

Green Card Fund 

Green Light Management Consultancy JLT 

Grenada Citizenship by Investment 

Guide Consultants 

Hawryluk Legal Advisors 

Hengsheng global commercial broker llc 

Henley & Partners Austria 

Henley & Partners Canada (Quebec) 

Henley & Partners HKG 

Henley & Partners Malta 

Henley & Partners Private Clients DMCC 

Henley & Partners Singapore Pte. Ltd. 

Henley & Partners South Africa (Pty) Ltd. 

Henley & Partners Switzerland 

Henley & Partners UK 

Hilton Global Associates 

Holistic Financial Group/Retirement Wealth Advisors 

IAS – INTERNATIONAL ATLANTIC SERVICES 

Immigrant Invest 

Immigrant Investor Group Inc (IIG) 

immVest International Limited 

INGWE Canada 

Integritas Ltd 

Intercorp International LTD 

International Center for Globalization and Development 

Inter-Tax Consultants 

Invest & Settle 

Invest Citizenship 

Invest in the USA (IIUSA) 

Investaureum Lda 

Island Living Investment Services Ltd 

Joseph Rowe Attorneys-at-Law and Notaries Public 

Ketenci&Ketenci ILP 

Khalil Masri et Fils Sarl 


450+ MEMBERS FROM 

55+ COUNTRIES 

Klasko Immigration Law Partners, LLP 

KLD LLP 

La Vida Golden Visas 

Laferla Insurance Agency Limited 

Lamares, Capela & Associados 

Latitude Consultancy Limited 

Lecanda Immigration and Nationality Law 

Lincoln Global Partners UK Limited 

Magellan Champlain 

Maisto & Associati 

Mc Namara & Company - Barristors, Solicitors & Notaries Royal 

MIBS GROUP 

Michael Kyprianou & Co. LLC 

MICS Global 

M-J Global 

Mona Shah & Associates 

Montsa Immigration Law & Global Mobility 

MOVEANYWHERE LTD 

Muscat Azzopardi & Associates 

My Global Citizenship 

My Grenada Solutions Inc. 

Neity Lloyd Maddock 

New Balkans Law Office 

New Beginnings Legal Services 

NEXT - Gali Macedo Lawyers 

Next Generation Equity 

NG Global Citizens Limited 

Nila Global 

Novafirm SA 

One world migration 

Ora Caribbean 

Orience International SL 

Origin BG OOD, BG 205479154 

Passport Gates 

PassPro Immigration Services 

Passworld Limited 

Paton & Mayr SLU 

Pen Students 

Penn State University 

Penvista Limited 

Polaris Citizenship & Investment Consultancy Services Limited 

Prime Properties 

Prime Synergy 

Promethean 

ProPanama 

PRO-Relocation 

Provenance Properties of Cayman Ltd. 

PT. Anugraha Askara Paramitra 

QuazarHouses LLC 

Reef View Enterprises Ltd 

Residency Malta Agency 

RFF Lawyers 

RIF Trust Investments LLC 

Roseveare Group 

Russian Residency 

Saad Ahsan Immigration Law Firm 

Sable International Limited 

Saeima (National Parliament) of Latvia 

Saratoga Capital 

Seed Consultancy 

Seven Continents LDA 

SG - Secondpass Global 

Shard Capital Investor Visa 

Sharif Star Real Estate Broker LLC 

Signia Legal & Consulting Services 

Smart Citizenship 

Sotheby’s International Realty Canada 

S-RM Intelligence and Risk Consulting 

Startup Visa Services 

Steptoe & Johnson LLP 

Sterling Migration 

Sunrise International Legal Services 

SwissTaxGroup 

The Address Consulting Group 

The Sovereign Group 

Thomas John & Co 

Trinity Corporate Services 

USA EB5 Immigration LLC 

Valadas Coriel & Associados 

Vanuatu Life Style Ltd 

Vardanyan & Partners 

Varnavas Law Firm 

Vertex Advisory Ltd 

Visa World Wide Admission 

Visadoro 

Visas Consulting Group Inc 

Vision & Law Immigration Co. Ltd 

Vision Immigration 

Viya Global Vatandaşlık Ve Göç Hizmetleri 

Danışmanlık Ticaret Limited 

White bird Group 

Windsor Capital Management Ltd 

WOLF THEISS Attorneys-at-Law 

World Grenada Inc. 

XIPHIAS Immigration Pvt Ltd. 

Xumit Capital 

ZINA P. ANTONIOU & CO. LLC 

Adewale Dosunmu 


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Overview 

Reimagining Investment Migration: 

Redefining Narratives and 

Remodelling Pathways 

Investment 

migration has been 

put on the fast-track 

for reinvention, 

propelled in no 

small part by 

the increased 

pressure of 

international bodies 

to reform many 

of its practices. 

Bruno L’ecuyer, CEO 

& Co-Founder of 

the Investment 

Migration Council 

In 2023, investment migration found 

itself at a crossroads, teetering on the 

precipice of profound transformation. 

Last year, the traditional practices of 

investment migration faced unprecedented 

scrutiny and pressure from international 

organisations. The European Union, which 

has long been a vocal critic, repeatedly 

called on its member states to abandon 

investment migration pathways, even 

wielding the threat of revoking visa-free 

travel for third countries. Elsewhere, the 

OECD and the Financial Action Task 

Force (FATF) argued that investment 

migration is prone to corruption and 

misuse if it is not properly managed. 

As the year unfolded, many wondered 

if this marked the end of investment 

migration as we knew it. Change came 

swift and at times, bewildering, with 

policy announcements oscillating 

between implementation and reversal. 

However, beneath the tumultuous 

surface, 2023 emerged as a pivotal year, 

prompting a critical re-evaluation of 

long-established norms in the thrilling 

world of investment migration. 

A Look Back 

For context, policy changes are somewhat 

inherent to investment migration. 

Throughout the years, various pathways 

opened, closed, and some even reopened. 

Investment migration traces its roots to St. 

Kitts and Nevis in the Caribbean, where 

the first modern citizenship-by-investment 

pathway was introduced in 1984 as a tool 

for economic advancement. The Republic 

of Ireland followed four years later, 

establishing a naturalisation programme, 

which was terminated the following decade. 

The introduction of residence-byinvestment 

started in 1986, when Canada 

introduced its Federal Immigrant Investor 

Programme, followed by the US’ EB-5 visa 

in 1990. However, residence by investment 

became extremely popular after Portugal 

introduced its residency pathway in 2012. 

Five years later, nearly half of all EU member 

states offered similar routes to residency. 

Today, investment migration is featured in 

immigration law in most UN recognised 

countries, albeit in different forms and shapes. 

2023 Policy Changes 

However, there’s no denying that we have 

seen some important shifts and changes 

in 2023. The year was marked by the everevolving 

narrative that the days of investment 

migration as it was long known are counted. 

The United States called for reform from 

Caribbean nations, while the European 

Union urged its member states to phase 

out existing pathways and even threatened 



to revoke visa-free travel for countries 

providing citizenship through investment. 

Malta now stands out as the sole 

EU country offering a direct path to 

citizenship in exchange for qualifying 

investment, but it’s under EU pressure, 

leading to uncertainty about its future. 

Ireland closed its residency pathway 

in 2023, and the Netherlands announced 

the discontinuation of its residence permit 

for foreign investors starting from 2024. 

Portugal initially proposed ending its 

residency pathway in February last year 

but later reversed its decision, opting to 

eliminate the real estate option instead. 

Interestingly, the likelihood that 

residence pathways would become 

obsolete sparked a surge in applications. 

Spain and Italy, among other countries, 

witnessed unprecedented levels of 

applications, a trend largely attributed 

by many service providers to the 

Fear of Missing Out (FOMO). 

Simultaneously, new residency 

pathways have emerged. Namibia has 

stepped into the residency arena, offering 

investors the opportunity to live, conduct 

business, and study in the African 

nation in exchange for a minimum real 

estate investment of $316,000 USD. 

Meanwhile, the UK has introduced the 

Innovator Founder visa, and Canada 

has reopened the Quebec investor 

programme. In addition, Hong Kong is 

poised for a revival in investment-based 

immigration after a hiatus since 2015. 

Too Big to Fail? 

Some analysts describe investment 

migration as too big to fail. It is estimated 

to generate approximately €20 billion 

annually. In certain microstates and 

island economies, revenue from foreign 

investment and government gains 

through investment migration accounts 

for a substantial 10% to 40% of GDP. 

These injections of revenue play a crucial 

role, frequently offsetting deficiencies 

experienced in other economic sectors. 

Globally, investment migration has acted 

as a catalyst for substantial infrastructural 

enhancements, spanning resorts, 

harbours, airports, hospitals, office 

spaces, luxury residential developments, 

and even entire airlines. International 

bodies like the IMF, OECD, and FATF 

have acknowledged this economic impact. 

Over the years, investment migration 

has had its fair share of scandals, 

mishaps, and controversies, which have 

made it a controversial topic. As early 

as 2018, Transparency International 

urged governments to implement robust 

governance and oversight mechanisms 

in their pathways. Since then, the 

sector has seen notable progress. 

Caribbean Reform 

In numerous nations, we observed the 

adoption of stricter regulations, enhanced 

transparency, and the establishment of a 

more rigorous due diligence procedure. 

These measures have notably bolstered 

the credibility of investment migration, 

mitigating the risks associated with money 

laundering and illicit activities. This 

shift aims to ensure that only genuine 

investors are eligible for residency and 

citizenship. For instance, the Caribbean’s 

investor citizenship routes have long 

faced scrutiny due to lax due diligence 

and transparency. However, in 2023, most 

Caribbean nations have taken proactive 

measures. These initiatives involved 

the restructuring of government units 

and a comprehensive overhaul of due 

diligence processes, aiming to significantly 

enhance transparency and credibility. 

Corruption and Misuse 

Undoubtedly, this evolution wasn’t solely 

driven by voluntary decisions within 

nations; external pressure played a pivotal 

role, particularly when the visa-free 

travel privileges to the EU and UK were 

jeopardised. Moreover, in November, the 

FATF and the OECD unveiled findings 

from a joint report investigating the threats 

of money laundering and financial crimes 

associated with citizenship and residency 

by investment. The report argues that 

if appropriately managed, investment 

migration holds potential benefits for 

both host nations and individuals in 

theory. Yet, the practical implementation 

of such initiatives harbours substantial 

risks, encompassing money laundering, 

fraud, and various forms of misuse. 

The report also provides a long list 

of recommendations to aid decisionmakers 

and administrators in mitigating 

these risks. The IMC, along with other 

professionals, commended the report, 

highlighting that any measures leading 

to more robust standards are beneficial. 

However, several professionals in the 

investment migration sphere emphasised 

significant shortcomings. They 

underscored how certain recommendations 

mirror existing practices while 

simultaneously condemning the report 

for oversimplifying and generalising. 

A Focus on Emerging Markets 

Meanwhile, new investment migration 

pathways are emerging in rapidly 

developing economies. Countries like 

Egypt, UAE, Jordan, Qatar, Bahrain, and 

Saudi Arabia have initiated pathways aimed 

at attracting foreign investment. These 

avenues have effectively engaged Middle 

Eastern investors, especially from nations 

like Saudi Arabia, Kuwait, and the UAE. 

With investment migration becoming more 



However, beneath 

the tumultuous 

surface, 2023 emerged 

as a pivotal year, 

prompting a critical 

re-evaluation of 

long-established 

norms in the world of 

investment migration. 

accessible and economic conditions in 

many countries growing more challenging, 

there’s anticipation that these options might 

attract interest from a broader demographic 

beyond just millionaires. Furthermore, 

there’s a growing demand for similar 

pathways in Latin America and Africa. 

While expectations abound for 

the emergence of more pathways, 

there’s also an anticipation of increased 

scrutiny. Crucial factors like compliance, 

trust in the process, and stringent 

regulation will significantly determine 

the sustainability and success of these 

initiatives. Additionally, concerns regarding 

democracy, governance, and how these 

states manage and oversee their pathways 

could potentially impact their longevity. 

From Mobility to Relocation 

In recent years, investment migration has 

seen tremendous growth. Various global 

upheavals like Covid-19, the Russia-Ukraine 

conflict, and escalating conflicts in places 

like the Gaza Strip have caused widespread 

social, political, and economic strains, 

prompting people to migrate across borders 

and relocate businesses and assets swiftly. 

What’s increasingly evident is that 

investor migrants aren’t merely seeking 

backup plans for increased mobility; they’re 

looking for pathways ensuring a stable 

future for their children, even if it entails 

relocation. This shift signifies a positive 

evolution for an industry that has been 

under scrutiny due to the perceived 

weak connections between investors 

and their adopted countries. Countless 

discussions have revolved around the 

issue of physical presence requirements. 

Experts argue that obtaining a 

residence permit through investment 

migration is often just the initial step for 

investors in a new country. The real value 

lies in subsequent investments, taxes 

contributed, economic spending, and job 

creation. Yet, the industry still grapples 

with fully demonstrating how these 

factors can thrive without relying solely 

on physical presence as a benchmark. 

Retirees, Start-up 

Entrepreneurs and 

Digital Nomads 

Amid an uncertain economic outlook, 

the demand for migration persists, 

leading to a surge in interest surrounding 

entrepreneur and start-up visas. These 

initiatives focus on attracting active 

investment and highly skilled individuals, 

steering away from negative sentiments 

often associated with passive investment 

migration policies. There is a clear trend 

that traditional investment migration is 

following suit, with Portugal abolishing 

real estate investments after locals were 

priced out of the housing market. 

Additionally, a multitude of countries 

has embraced the trend of introducing 

Global Nomad visas, allowing individuals 

to work remotely while residing in 

different countries. However, these 

programmes have faced significant 

criticism due to poorly designed legislation 

and open questions about tax liability, 

and experts have long highlighted the 

need for improvement in this domain. 

Retirement migration has caught the 

attention of migration professionals, with 

numerous countries that have existing 

residency pathways, or operated them 

in the past, also starting to introduce 

dedicated retirement visas. While retirees 

might not be investing directly in these 

jurisdictions, their spending on housing, 

services and other necessities generates 

positive net benefits for the local economy. 

Economists also anticipate that 

countries dealing with high debt, slow 

growth, and ambitious net-zero climate 

goals will continue to actively seek foreign 

capital. If conventional investment 

migration routes undergo reform or 

closure, alternative tax incentives may 

emerge in their stead. An example is Spain, 

which passed a law in January enabling 

non-residents, including digital nomad 

visa holders, to pay a flat 24% tax rate on 

income up to €600,000 over six years— 

contrasting sharply with the 47% rate for 

residents in higher income brackets. 

Stigma and Sustainability 

Investment migration has long grappled 

with a persistent stigma that hinders its 

evolution. The term “golden visas” has 

inadvertently led to misconceptions, 

painting investment migration as 

exclusive enclaves solely for the wealthy 

elite. Yet, the reality is quite different. 

These initiatives, aimed at attracting 

foreign investment, serve as drivers 

for economic growth and are vital for 

many nations’ development agendas. 

Unfortunately, this terminology 

has fuelled misunderstandings, 

overshadowing the broader advantages 

investment migrations offers. 

Public opinion has undeniably 

influenced investment migration 

development, sparking worries about 

the impact of foreign investment on 

local economies and societies. Countries 

have responded by instituting measures 

mandating investments in sustainable 

projects or contributions to social causes 

in exchange for residency. These actions 

not only enhance the reputation of these 

pathways but also ensure their positive 

impact on local economies and societies. 

Nothing to Hide 

However, the transformation of 

investment migration goes beyond 

reforming pathways; it involves 

reshaping mindsets, dispelling 

myths, and fostering a collaborative 

environment where investment 

becomes a conduit for progress, 

inclusivity, and shared prosperity. 

Conceptually, many people still 

struggle with investment migration. 

The idea that citizenship or residency 

can be granted in return for investment 

raises concerns about favouritism and 

unequal access to privileges. However, 

the industry must illustrate the tangible 

economic and social contributions 

facilitated by these investments. 

Crucially, the industry must pivot 

towards heightened transparency in 

fund allocation, stricter compliance 

measures, rigorous due diligence, 

and standardised best practices 

across the ecosystem. Variations in 

adherence to these standards have 

tarnished investment migration’s 

image, creating a negative perception 

that affects all players within it. 

Contrarily, a level playing field fosters 

openness where transparency acts as 

the cornerstone. As transparency gains 

prominence, it paves the path toward a 

fairer and more dependable landscape. 

After a series of surprises in 2023, there is 

hope that 2024 will bring greater clarity 

about the future of investment migration. 



In the HEADLI 

The past year witnessed a plethora of attention-grabbing headlines in the 

realm of investment migration. However, major media outlets also curated an 

array of insightful reads that delve deeper into the subject matter. From the 

bustling streets of Singapore to the tranquil shores of New Zealand, and the 

historic streets of Europe, the IM Yearbook has summarised migration news 

stories that offer a nuanced perspective that transcends sensationalism. 

The Singapore Surge 

The Financial Times Big Read kicked off the year by 

uncovering the burgeoning allure of Singapore. Against 

the backdrop of geopolitical tensions, Chinese individuals, 

families, and companies flocked to the city-state. According 

to Drew Thompson, a Visiting Fellow at the Lee Kuan Yew 

School of Public Policy in Singapore, this influx represents 

a “dramatic, epochal realignment of wealth in Asia,” as 

capital seeks the safest and most profitable destinations, 

with Singapore increasingly being seen as such. 

According to the FT, the growing Chinese presence is evident 

in various sectors, including luxury car purchases, property 

deals, and the establishment of family offices and businesses. 

Kia Meng Loh, Co-head of Private Wealth and Family Office 

Practices at Dentons Rodyk, noted that many mainland Chinese 

clients view Singapore as a “safer long-term bet than Hong Kong” 

due to political and economic stability and its rising status as 

Asia’s financial hub. 

However, the article also highlighted potential vulnerabilities 

in Singapore’s newfound appeal. Concerns were raised about 

the risk of China’s tolerance reaching a breaking point, societal 

pushback due to rising costs and perceived enclaves, and the 

possibility of Singapore becoming overly Sinicized, prompting 

identity and geopolitical concerns. An unnamed real estate agent 

emphasised the impact on local rents, attributing the rise to 

Chinese buyers willing to pay significantly above asking prices. 

Simon Tay, Chair of the Singapore Institute of International 

Affairs, acknowledged Singapore’s favourable position as a global 

financial hub amid slowing globalisation. He remarked: “In a 

world where China is looking for friends, it gets a warm reception 

in Singapore. At the same time, Wall Street and US companies 

increasingly see us as a premium alternative to other hubs.” 

The Economist’s Thesis on 

Global Migration Waves 

The Economist, in its May edition, argued that a new wave 

of mass migration was sweeping across the globe. The article 

identified several factors contributing to this migration boom. 

The post-pandemic economy, with low unemployment rates 

and high job vacancies, attracts people from abroad. Currency 

movements, such as the depreciation of emerging-market 

currencies against the dollar, make it financially advantageous 

for migrants. In addition, many governments are actively seeking 

to attract immigrants, with explicit targets and agreements to 

allow more people to work and study in certain countries. Even 

nations traditionally resistant to migration, like Japan and South 

Korea, are reconsidering their stance. Why? Economies that 

embrace migration tend to benefit in the long run, bringing new 

ideas, entrepreneurship, and fostering economic connections. 

“Over the next year or so migration may come down a bit. 

The post-pandemic ‘catch-up’ will end; rich-world labour markets 

are slowly loosening,” the writer noted. “Yet there is reason to 

believe that historically high levels of new arrivals will remain 

raised for some time. More welcoming government policy is 

one factor. More important, migration today begets migration 

tomorrow, as new arrivals bring over children and partners.” 



NES 

Southern Europe 

Beckons American Dreams 

February was also dominated by Portugal’s initial proposal to 

terminate its residency pathway as part of a comprehensive set 

of measures aimed at addressing the nation’s housing crisis. 

Although the government eventually reconsidered 

this decision, the New York Times decided to explore 

the life of Americans relocating to Southern European 

countries such as Portugal, Spain and Greece. 

The article shared stories of families finding solace and 

satisfaction in European living, contrasting it with the frenetic 

pace of major US cities. The spotlight fell on the Mitas family, 

who relocated from Florida to Portugal in 2019, narrating their 

experience of living in Lisbon and acquiring a historic house. In 

Greece, the Mallios family, originally from the US, highlighted 

their newfound sense of freedom and enjoyment on the island 

of Evia, purchased as part of Greece’s residency pathway. 

Lifestyle migration emerged as the primary motivation. 

While celebrating these stories, the article didn’t shy away 

from shedding light on challenges faced by locals in Southern 

European cities. The influx of foreign investment, heightened 

housing competition, leading to increased property prices and 

making it challenging for locals to find affordable housing. 

New Zealand’s Investment 

Migration Quandary 

In April, The Guardian directed its lens towards New 

Zealand, examining its appeal in the investment migration 

arena. The country, known for its geographic isolation and 

political stability, had been a sought-after destination for the 

super-rich applying for visas or citizenship. However, the 

preceding six months witnessed a dramatic decline, with 

only 15 applications for the country’s new foreign investor 

visa compared to 492 in 2021 under the previous criteria. 

Under the new criteria, applicants are required to invest 

at least NZ$15 million over three years, with only half of that 

allowed in passive investments, or $5 million if the funds directly 

supported a New Zealand business. The Guardian reported that 

this drop in visa applications garnered international attention, 

with rival media outlets suggesting that “rich foreigners 

spurn New Zealand.” The change was part of a broader 

“immigration reset” by the New Zealand government that was 

criticised for its “open door policy for the super wealthy.” 

The drop in applications was linked to the delayed release 

of approved investment options necessary for the visa. The 

updated criteria also imposed stricter requirements on investors, 

nudging them toward riskier investments. The government 

stood by the new category, highlighting its priority on attracting 

investors based on value rather than sheer quantity. 

Europe’s Investment Migration Pathways 

- A Resilient Tapestry 

Bloomberg, in its August analysis, turned its attention to the investment migration pathways in Europe. Despite political calls to end these 

programmes, the media house found that pathways in Greece and Portugal remained active and popular. Moreover, the journalists added 

that uncertainty around the future of the residency pathways led to a surge in interest, with immigration consultancies reporting a significant 

increase in enquiries and applications. 

The economic need for foreign capital and the substantial financial benefits for the countries involved suggest that these programmes 

are likely to endure despite ongoing discussions about their regulation and potential termination. Moreover, Bloomberg noted that among 

countries that have done away with their programmes, other options are on offer. “While there’s no exact equivalent to a golden visa, 

alternatives like digital nomad visas, designed for remote workers seeking to live abroad, are increasingly popular. Founders interested in 

setting up a business in the UK, France, Ireland, or Germany can also apply for special investor visas, which grant temporary residency and 

a path to a permanent stay.” 



Sam Altman’s Golden 

Visa - A Milestone in 

Indonesian Attraction 

September brought a landmark moment as Sam Altman, 

the CEO of OpenAI, became the inaugural recipient of an 

Indonesian golden visa. This ground-breaking development 

received extensive coverage in mainstream media outlets, from 

Bloomberg to Time Magazine. Altman’s 10-year visa was granted 

by Indonesia’s immigration authority, citing his international 

renown and potential contributions to the country’s growth. 

Introduced as part of Indonesia’s broader strategy to boost 

economic development, this new pathway allows foreign investors 

making substantial financial commitments to stay in Indonesia 

for durations ranging from five to ten years. It also entitles Altman 

to several advantages, including priority security screening at 

airports, extended residency periods, and streamlined entry and 

exit processes. It remained unclear whether Altman, who visited 

Jakarta in June to deliver a keynote on artificial intelligence (AI), 

applied for this visa or intends to make investments in Indonesia. 

Climate Change and 

Asylum Laws 

In November, the New York Times took us to Honduras, 

where two hurricanes in 2020 wreaked havoc on the villages 

of the Indigenous Miskito people. The aftermath led to a 

vacuum in governance, exploited by drug cartels, resulting in 

violence and insecurity. This forced individuals like Cosmi, 

a 36-year-old father, to flee to the US-Mexico border seeking 

asylum due to threats and dangers in their homeland. 

Alongside hundreds of others, Cosmi hoped to test 

a new legal argument: that the climate crisis-induced 

extreme weather qualifies as a basis for asylum, akin to 

the protection established after World War II and the 

Holocaust. Lawyers, however, stress that asylum laws 

were written well before the climate crisis. Asylum 

seekers typically must prove past persecution or a wellfounded 

fear of future persecution based on specific 

grounds like race, religion, nationality, political opinion, 

or group membership. For the Miskito, gaining asylum 

based solely on climate change poses difficulties. 

While acknowledging the role of global warming in 

displacement, the White House released a report in late 

2021. However, two years on, the administration has yet to 

implement its recommendation of forming an interagency 

working group to coordinate the US response to climateinduced 

migration, according to the New York Times. Kevin 

R. Johnson, the dean of the University of California, Davis, 

School of Law, notes that reforming asylum policies requires 

congressional action.“That is unlikely to happen when 

immigration is such a wedge issue on which compromise 

is viewed as weakness,” he is quoted in the article. 

The Truth behind UK’s Record Levels of Migration 

The Guardian turned its attention to the “record levels” of net migration in the UK. In an opinion piece, Nesrine Malik challenges the 

sensationalised headlines that portray immigration as an impending crisis, emphasising that the true narrative is far more nuanced. She 

points out that the focus on immigration numbers oversimplifies the complex roots of this phenomenon. Rather than an uncontrollable surge, 

Malik argues that these figures stem from deliberate economic and political choices. 

Factors such as workforce shortages across industries, reduced investment in training, and policy decisions post-Brexit have collectively 

contributed to the reliance on immigrants to fill crucial gaps in the labour market that “policymakers either did not anticipate, or ignored 

warnings about.” 

The crux of her argument lies in debunking the myth that immigrants are the cause of societal woes. Instead, she illustrates that they are 

an indispensable part of the solution. The issue, she contends, lies in the failure to invest in domestic training and a refusal to acknowledge 

the indispensable role immigrants play in a country’s workforce. “All while refusing to acknowledge that demographics mean that immigrants 

will always be essential, and so must be treated not as precarious bussed-in labourers, but with humanity, welcome and dignity,” she writes. 

“That really is the sum of it all. Doesn’t make a good headline though, does it?” 



Navigating Changes 

in Portugal’s Residency Pathway 

While the termination of Portugal’s real estate investment option may 

have disappointed some investors, the country’s residency pathway 

remains open for those willing to explore alternative options, says 

Jerome Morgan, Founder, President & CEO of the Mercan Group. 

Could you provide a 

brief overview of Mercan 

Properties? What would 

you highlight as your most 

important milestones 

and achievements? 

Mercan Properties specialises in the 

development and management of hotel 

assets within Portugal’s tourism sector. 

Presently, Mercan boasts a diverse portfolio 

of 30 projects spanning key regions such 

as Porto, Vila Nova de Gaia, Matosinhos, 

Lisbon, Amarante, Santiago do Cacém, 

Évora, Beja, the Algarve, and Madeira 

Island, collectively valued at €1.2 billion. 

Mercan Properties has significantly 

contributed to Portugal’s economy by not 

only attracting foreign investment but 

also by establishing high-quality tourism 

assets that drive employment, elevate local 

potential, and fortify Portugal’s reputation 

as a premier global tourist destination. 

Acquiring real estate to 

obtain residency is no longer 

possible in Portugal. How 

does this development impact 

your business operations 

and the investors associated 

with the company? 

It is important for investors and potential 

investors to understand that Portugal’s 

residency pathway has changed, but it 

hasn’t been terminated. While direct real 

estate investment is no longer possible, 

the government has recognised the vital 

role of foreign investment to advance 

the country’s strategic priorities. 

We will continue our operations in 

Portugal, focusing on the management 

of hotel assets and hospitality within the 

tourism sector. Our strategies will focus 

on future investments aimed at fostering 

growth in tourism and the Portuguese 

economy. This is what we have been doing 

since 2015. With plans to inaugurate three 

additional hotels in 2024, our commitment 

to Portugal remains unwavering. 

In this new reality, what 

unique offerings do you 

provide to potential investors? 

We have adapted our business model to 

align with the new legislative landscape. 

One avenue offered under the revised law 

involves investment in venture capital 

funds to gain residency. We perceive 

this avenue as compelling for investors. 

Specifically, investors can engage with 

Mercan’s venture capital fund. This 

fund will encompass a diverse portfolio 

of assets and channel investments into 

companies managing hospitality and 

tourism services in Portugal. We aim to 

differentiate ourselves from other funds 

by prioritising investment security and 

predictability. Our focus remains on 

the hospitality and management sector, 

solidifying our standing as a key player 

in Portugal’s vibrant tourism industry. 

What specific factors or 

attributes attract investors 

to Mercan Properties 

in comparison to other 

investment opportunities? 

Our business strategy has always been 

aligned with hospitality and tourism 

activities in Portugal, and now, we are 

advancing through the establishment 

of a dedicated venture capital fund. 

We believe our strength lies in our 

sector experience and extensive knowledge 

of various residence-by-investment models 

worldwide, making us a prominent player 

in the field. Our successful track record 

and established international partnerships 

over three decades have empowered us 

to offer secure and distinctive investment 

opportunities in promising markets and 

services. Furthermore, our portfolio 

places us among the top 10 players in 

terms of the largest number of fully 

operational hotels in the country. This 

achievement is a result of our promotion of 

internationally renowned brands within 

the hospitality and tourism sector. 

Our strategies will focus on future investments aimed at 

fostering growth in tourism and the Portuguese economy. 

How do you foresee the 

evolution of residency by 

investment over the next two to 

three years? Is there a risk that 

Portugal might permanently 

close its residency pathway? 

Portugal is set to hold elections in March 2024, 

which will bring forth a new government 

and parliament. It’s challenging to predict 

the future strategic priorities of the incoming 

executive. However, one certainty remains: 

Foreign investment has significantly 

contributed to Portugal’s development, 

particularly in the realm of tourism. We are 

confident that key policymakers will continue 

to acknowledge this reality. We maintain 

the belief that residency investment models, 

which positively impact Portuguese society 

through affordable projects, cultural and 

heritage promotion, tourism, and hospitality 

activities, will continue to be considered 

by the relevant authorities. These models 

create a high economic impact and add 

substantial value to the country. As such, 

we do not foresee the extinction of these 

foreign investment avenues in Portugal. 

Jerome Morgan, Founder, 

BIO President & CEO of the Mercan 

Group, has spearheaded the company’s 

rise as a leading Canadian immigration 

consulting entity since its establishment 

in 1989. Under his stewardship, 

Mercan has emerged as a trailblazer 

in the investment, employment, and 

immigration sectors. Additionally, 

he holds pivotal roles as the Co- 

Managing Partner of AII Funds and 

Managing Partner at Mercan Properties, 

significantly influencing Portugal’s 

residency-by-investment sector. 



The FATF/OECD Report on Investment Migration: 

The Good, the Bad and 

In November 2023, the Financial Action Task Force (FATF) and the Organisation 

for Economic Co-Operation and Development (OECD) released a joint 

report on investment migration. Dive into the IM Yearbook’s breakdown of 

its key takeaways, exploring the good, the bad, and the downright ugly. 

Investment migration is no stranger to 

outside scrutiny. From the International 

Monetary Fund and the World Economic 

Forum to Transparency International 

and the European Parliament, several 

international bodies have undertaken 

comprehensive assessments, often 

with a negative viewpoint, ignoring the 

numerous benefits. The joint report of 

the OECD and the FATF on “Misuse of 

Citizenship and Residency by Investment 

Programmes” aims to examine the 

financial crime and money laundering risks 

associated with investment migration. 

It presents a mixed picture. While 

acknowledging that investment migration 

“can potentially lead to economic growth,” 

the report also argues that citizenship 

and residency by investment are prone 

to corruption and misuse. Criminals 

have exploited a range of vulnerabilities 

in CBI/RBI programmes “to perpetrate 

massive frauds and launder proceeds 

of crime and corruption reaching into 

the billions of dollars, while also hiding 

assets in less compliant or effective 

jurisdictions, facilitating organised 

crime and evading law enforcement.” 

According to the report, CBI pathways 

are particularly vulnerable because they 

allow illicit actors more global mobility, 

the ability to open bank accounts and 

establish shell companies in other 

jurisdictions, and to disguise their identity 

or conceal where they may owe taxes or 

other liabilities from financial institutions 

by using new identification documents. 

The Findings 

The report suggests that both CBI and 

RBI can provide the criminally wealthy 

with a range of opportunities, such as the 

ability to place assets and family members 

overseas to prevent or hinder asset recovery 

efforts, explain suspicious high-value 

transactions, and enable the movement 

of significant sums of illicit funds across 

borders. Investment migration pathways 

can act as a gateway for their recipients to 

the financial systems of both small and large 

countries, as well as regional markets. They 

also provide the new citizens or residents 

with access they might not have enjoyed 

by virtue of their original citizenship or 

country of origin, and the likely lesser 

scrutiny that comes with being a domestic 

(as opposed to foreign) actor within their 

new financial system, the report claims. 

Moreover, the report emphasises that 

the elevated risks of money laundering 

and financial crime in investment 

migration pathways relates not only to 

the applicant, but also to the professional 

enablers and intermediaries involved in 

the process. It states that the high level of 

involvement by intermediaries in their 

design and development, and the necessary 

involvement of multiple agencies across 

a government, can provide challenges 

in coordination, implementation, and 

regulation. In addition, the report claims 

that criminal, negligent, or complicit 

property agents, wealth managers, 

immigration agents, marketing agents and 

concierge firms can assist in the abuse. 

“Opportunities for abuse tend to arise 

especially when governments struggle to 

govern their programmes effectively. Malign 

interests can infiltrate programmes when 

there is a lack of clarity around the roles of 

public and private actors involved, where 

conflicts of interest are not adequately 

managed, and where resources are lacking 

to ensure proper oversight. These challenges 

are compounded where there is a lack of 

internal control and audit measures to 

ensure that programmes are operating 

as intended, as well as the difficulties 

government agencies face in coordinating 

across public authorities and borders to 

manage risks,” the report highlights. 

The Recommendations 

The report proposes a long list of measures 

and cites examples of good practice 

that can help policy makers and those 

responsible for managing investment 

migration pathways to address these risks. 

These include an in-depth analysis and 

understanding of how criminals can exploit 

CBI or RBI pathways. It also highlights how 

governments can incorporate risk mitigation 

measures, such as multi-layered due 

diligence, in the design of their pathways. 

The FATF argues that financial 

transparency and oversight within 

citizenship and residency pathways 

are critical for ensuring accountability 

and preventing potential misuse. One 

pivotal aspect is the public availability 

of information. Clear frameworks 

should mandate the disclosure of 

pathway details and financial audits, 

establishing transparency. Moreover, 

considering making information public 

about individuals granted citizenship 

or residency could aid in due diligence 

processes, the report states. 

Efficient fiscal revenue handling is 

another crucial facet. The FATF and the 

OECD stressed the need for transparent 

reporting on investments. Likewise, 

responsibility and oversight measures play 

a significant role in ensuring the integrity 

of investment migration. Establishing 

a specialised agency, devoid of political 

influence and possessing regulatory 

authority, can oversee a pathway’s end-toend 

operation, the report stated. Moreover, 

only qualified personnel should handle 

customer due diligence minimize risks 

and errors. The authors also argue that 

regulating third-party providers and having 

the authority to remove those engaged 

in inappropriate conduct adds layers of 

protection against potential malpractice. 

The report also touches upon the 

need to license and regulate agents and 

employ only qualified service providers. 

Transparency and reporting mechanisms, 

such as publishing annual reports and 

considering application caps to manage 

caseloads, are highlighted as crucial steps 

toward greater accountability. In addition, 

the authors suggest implementing a multitier 

vetting process involving independent 

layers for due diligence and comprehensive 

checks, including interviews for verification. 



the Ugly 

Disclosing additional identities, 

conducting law enforcement checks, 

and continuously monitoring for risks, 

particularly concerning politically exposed 

persons (PEPs) and sanction screenings, 

are vital steps in maintaining integrity. 

Moreover, the report recommends 

establishing stringent measures for 

vetting and decision-making, including 

ongoing monitoring, transparent 

communication, and continuous corruption 

risk assessment, to ensure pathways 

operate ethically and transparently. 

Lastly, the report finds that evaluating 

the economic costs and benefits, 

establishing genuine connections between 

recipients and the jurisdiction, and 

continuous transparent communication 

domestically and internationally are key to 

fostering trust and accountability within 

citizenship and residency pathways. 

The IM Yearbook has spoken to 

several investment migration practitioners 

to gather their opinions on the report, 

and here’s what we discovered. 

The Good 

The report notably refrains from 

recommending the termination of 

investment migration pathways, differing 

from the European Economic and Social 

Committee’s proposal to phase out such 

schemes in the EU. The Investment 

Migration Council (IMC), engaged with 

the FATF since May 2023, emphasises 

the report’s acknowledgment of the 

benefits of well-managed pathways. It 

views it as a step forward, contributing 

constructively to the industry’s evolution. 

Others have observed that the report 

recognises countries’ sovereign rights to 

admit, provide residence to, and naturalise 

foreigners as they deem appropriate. 

Additionally, the report acknowledges 

the complexity of investment migration 

and highlights that properly managed 

Citizenship by Investment (CBI) or 

Residency by Investment (RBI) pathways 

can be beneficial for both host nations 

and individuals. It also recognises that 

these pathways attract a diverse clientele, 

many of whom have legitimate assets and 

benign intentions. Moreover, the report 

is seen as a guide for setting industry 

standards, regulations, and due diligence 

practices. Recommendations aimed at 

enhancing transparency, security, and 

abuse prevention align with established 

industry values and standards. 

The Bad 

However, the report also exhibits 

shortcomings. Some recommendations 

replicate existing practices, particularly 

in Caribbean jurisdictions that recently 

implemented similar changes. Specific 

suggestions, like distinguishing passports 

based on birth or ancestry versus economic 

citizenship, are considered challenging 

and likely to create new hurdles for issuing 

governments. Moreover, criticism has 

been voiced regarding the comprehensive 

nature of the recommendations, pointing 

out that the FATF and the OECD did not 

thoroughly assess the practical feasibility 

of implementing them. Questions linger 

about whether these recommendations, 

with potential increased fees, longer 

processing times, and resource demands, 

might make certain pathways unprofitable 

or unappealing for genuine applicants. 

The Ugly 

The report takes a strong stance, 

highlighting the susceptibility of citizenship 

and residency by investment to corruption 

and misuse. It outlines how criminals 

exploit vulnerabilities in CBI/RBI pathways 

to perpetrate “massive frauds and launder 

proceeds of crime and corruption reaching 

into the billions of dollars, while also 

hiding assets in less compliant or effective 

jurisdictions, facilitating organised 

crime and evading law enforcement.” 

Though recognising genuine applicants 

with good intentions, the report strongly 

leans towards portraying investment 

migration as primarily exploited by 

malicious actors. This viewpoint has 

sparked concerns about the report’s 

narrative. The foundational assumption 

that investment migration primarily 

serves nefarious ends and is exploited by 

malicious actors for ulterior motives poses 

a significant challenge. This inherent bias 

has raised concerns about the report’s 

narrative, indicating an immediate 

influence on its overall perspective. 

Additionally, criticism surrounds the 

report’s generalisation, with concerns that 

it fails to differentiate between countries 

and their specific pathways. It doesn’t 

specify which pathway could benefit from 

recommendations and enhancements. This 

omission gives readers the impression that 

regulation and due diligence measures of 

all pathways are of a substandard quality, 

which many view as disappointing. 

A Final Thought 

Over the past years, the IMC has 

emphasised the critical role of stringent 

due diligence measures in shaping the 

future of investment migration. The 

organisation has actively contributed to 

this field by establishing common due 

diligence standards and an anti-bribery 

code. Firm regulations, emphasising public 

integrity, tax compliance, and migration 

policy considerations, will persist as the 

foundational pillars of investment migration. 

Simultaneously, the IMC advocates 

for seamless collaboration among law 

enforcement authorities, immigration 

agencies, and financial intelligence 

units. As investment migration pathways 

often transcend individual jurisdictions, 

inter-country cooperation becomes 

imperative. The IMC endorses the call 

for jurisdictions to unite in addressing 

common challenges, sharing best 

practices, and collectively bolstering the 

resilience of investment migration against 

potential misuse. Continued efforts toward 

unified standards remain a paramount 

interest for all stakeholders involved. 



One Year After the Enactment of 

the EB-5 Reform and Integrity Act: 

What is the Data Showing Us 

about the New Era of EB-5? 

Lee Y. Li, Director of Policy Research and Data Analytics at 

Invest in the USA (IIUSA), delves into the statistics. 

In March 2022, the EB-5 Reform and Integrity Act (RIA) was passed in the US Congress 

and subsequently signed into law by President Biden. Several months later, in July 

2022, the US Citizenship and Immigration Services (USCIS) released new forms - 

Form I-526 (Standalone Investor Petition) and Form I-526E (Regional Centre Investor 

Petition) - as part of the RIA implementation, discontinuing the old Form I-526 (Alien 

Entrepreneurs Petition). A year later, in July 2023, USCIS began reporting data on three 

types of Form I-526 petitions: legacy I-526 petitions predating the RIA, new direct EB-5 

investment Form I-526 (direct I-526), and the Form I-526E for Regional Centre EB-5 

investment. Here are four key data points that we learned from the most recent statistics. 

1. OVER $1.5 BILLION IN CAPITAL INVESTMENT 

HAS BEEN RAISED THROUGH EB-5 SINCE 

THE INCEPTION OF THE RIA 

Based on our calculations, over $1.5 billion has been raised through the EB-5 

programme since the inception of the RIA, and nearly $1.4 billion in capital investment 

has been generated through the programme in FY2023 alone. The amount of EB-5 

investment generated in the first three quarters of FY2023 already represents a 

190% increase from the amount of EB-5 investment raised in the entire FY2022. 

Over $1.5 Billion Raised through EB-5 since RIA 

Figure 1: Estimted Amount of EB-5 Investment Inflows by Fiscal Year 

2. DEMAND FOR 

EB-5 CONTINUES TO 

GROW SINCE RIA 

During the first three quarters of FY2023, 

USCIS received 1,558 I-526E petitions and 

129 I-526 (direct EB-5) filings. The volume 

of I-526 filings, including both I-526 (direct 

EB-5) and I-526E, in the current fiscal year 

has already represented a 103% growth 

compared to the total number of I-526 

petitions filed throughout all FY2022. In 

addition, 649 I-526E petitions were filed 

in Q3, FY2023, representing a 31% growth 

from the previous quarter. The number of 

I-526E filings has increased consecutively in 

each quarter since the inception of the form 

in Q4 FY2022, indicating the continuing 

growth in demand for EB-5 Regional Centre 

projects among investors across the globe. 

Continued Growth of 

the Demand for EB-5 

Figure 2: Number of Form I-526E and 

I-526 (Direct) Filed by Quarter 

$7,000 

700 

1-526 

Amount of Funds Raised through EB-5 Financing 

$6,000 

$5,000 

$4,000 

$3,000 

$2,000 

$1,000 

Number of I-526 (Direct) & I-526E Petitions 

600 

500 

400 

300 

200 

100 

1-526 (direct) 

$0 

FY2008 FY2011 FY2015 FY2020 FY2023* 

Note: EB-5 capital investment inflow is estimated by the number of Form I-526 

and Form I-526E filed to USCIS. *2023 data for Q1, Q2 and Q3 only. 

Source: U.S. Citizenship and Immigration Services (USCIS) • Prepared by: IIUSA 

0 

FY2022 

Q4 

FY2023 

Q1 

FY2023 

Q2 

Source: U.S. Citizenship and Immigration 

Services (USCIS). Prepared by: IIUSA. 

FY2023 

Q3 



3. HIGHER CASE 

ADJUDICATION 

VOLUME IN FY2023 

Higher Case Filing and Adjudication Volume in FY2023 

Figure 3: YOY Data Comparison for Form I-526s Filed, Adjudicated & Pending 

USCIS processed 1,930 legacy I-526 

cases in the first three quarters of 

FY2023, marking a 60% increase from 

the total I-526 adjudication volume 

in FY2022. Although USCIS did not 

disclose any data on the number of 

I-526 (direct) and I-526E cases that have 

been adjudicated, we believe that the 

agency has already started approving 

I-526E cases that are associated with 

investment in an EB-5 project located 

within a rural area. Overall, the 

increase of case adjudication should 

translate into the improvement of case 

processing time for I-526 petitions. 

As USCIS continues to process a 

relatively large number of legacy I-526 

cases in FY2023, the number of pending 

legacy I-526 petitions continues to 

decline. As of the end of Q3, FY2023, 

there were 10,802 pending legacy I-526 

cases, which represents a 7% decrease 

from the previous quarter. The backlog 

of legacy I-526 cases has been reduced 

by 16% since the beginning of FY2023. 

Number of I-526 (Legacy), I-526 (Direct) & I-526E Petitions 

14,000 

12,000 

10,000 

8,000 

6,000 

4,000 

2,000 

0 

FY2002 Total 

FY2023 Q1-Q3 

829 

1,687 

1,203 

1,930 

13,062 

Filed Adjudicated Pending 

Note: Data in the chart above includes I-526 (legacy), I-526 (direct) and I-526E cases. 

Adjudication data for FY2023 Q1-Q3 only includes Form I-526 (legacy) statistics. 

Source: U.S. Citizenship and Immigration Services (USCIS) • Prepared by: IIUSA 

12,700 

4. APPROVAL RATE OF PRE-RIA I-526 CASES DROPPED 

SIGNIFICANTLY IN THE LAST TWO FISCAL YEARS 

Since FY2022, the average approval rate of legacy I-526 cases has seen a significant decline. 

Particularly, less than half of the I-526 cases that were adjudicated in FY2022 received 

an approval from USCIS, marking the lowest approval level in the 32-year history of the 

EB-5 programme. In the first three quarters of FY2023, the average approval rate of pre- 

RIA I-526 petitions was 68%, bouncing back from the historical low but remaining at the 

second-lowest level observed in the last 10 years. USCIS has not released any information 

shedding light on the reasons behind the recent surge in legacy I-526 case denials. 

Approval Rate of Pre-RIA I-526 Cases Remain at a Historical Low 

Figure 4: Average Approval Rate of Form I-526 (Legacy) by Fiscal Year 

Average Approval Rate of I-526 (Legacy) Petitions 

100% 

90% 

80% 

70% 

60% 

50% 

92% 

89% 

90% 

79% 

81% 

80% 

78% 

75% 

68% 

49% 

Lee Y. Li joined IIUSA in 

BIO 2014 as a Policy Analyst. He 

leads the association’s research and 

data analytic initiatives, providing 

regular reports on USCIS processing 

trends, EB-5 visa usage, waiting line 

forecast, investor markets analyses, 

and more. In addition, he manages 

IIUSA’s extensive industry data library 

and develops a variety of interactive 

maps as well as data dashboards to 

inform EB-5 policy discussions. 

40% 

FY’14 FY’15 FY’16 FY’17 FY’18 FY’19 FY’20 FY’21 FY’22 FY’23* 

*2023 data for Q1, Q2 and Q3 only 

Source: U.S. Citizenship and Immigration Services (USCIS). Prepared by: IIUSA. 



How the 

War in Israel 

and Gaza is 

Impacting 

Investment 

Migration 

After a long period of 

relative calm, the oldest 

conflict in the Middle 

East surged back into 

prominence. The IM 

Yearbook asked what 

impact the Israel- 

Hamas conflict has on 

investment migration. 

In 2023, the Israel-Hamas conflict 

reverberated across the Middle East. 

Despite the grim toll of lives lost, some 

commentators argue that this moment 

marks the region’s best opportunity for 

peace in decades. Yet, paradoxically, it also 

presents the highest risk of the conflict 

escalating uncontrollably. While it is unclear 

which path it will take, the IM Yearbook 

has gathered diverse perspectives on how 

this conflict impacts investment migration. 

Conflict and Migration 

Geopolitical instability and conflict 

have historically triggered migration 

and stand as fundamental catalysts for 

investment migration. This time is no 

exception, asserts Manpreet Kataria, 

Managing Partner of Alpha Immigration 

Associates, situated in the UAE. 

“We haven’t experienced an 

immediate impact – positive or negative 

– from the Israel-Hamas conflict 

but we expect increased numbers of 

Palestinian applications over the long 

term. As of now, the immediate focus of 

Palestinians is on survival and helping 

their family back home,” he says. 

“With the preference given to Dual 

nationals for evacuation during the 

conflict, a major awareness is expected to 

arise in the Middle East. Anyone living 

in the conflict zone or in a place where 

a conflict is anticipated would definitely 

take this into account and get a second 

residency or citizenship to safeguard 

themselves and their families,” he adds. 

No Safe Place 

Meanwhile, the conflict’s ripple effects 

have reached neighbouring countries. For 

instance, it prompted Iran-aligned armed 

groups to terminate a nearly year-long 

unilateral truce with US forces in Iraq and 

Syria. Rawa Kamal Ahmed, Immigration 

Department Manager of Moonline 

Travel and Trade in Iraq, describes the 

population in the region as “more stressed 

than anywhere else in the world.” 

Ahmed notes a surge in requests 

for citizenship and residency through 

investment, a trend expected to persist 

in the foreseeable future as the conflict 

has instilled a new level of fear among 

the young. “Sadly, the new generation 

believes, like previous generations, that 

Iraq will never be a safe place,” he adds. 

Business Relocation 

Elsewhere, immigration specialists have 

observed a surge in interest for residency 

options from Israelis. Cyprus has 

become a key destination as the island’s 

proximity, with just under an hour of 

flight time from Israel, has historically 

attracted a sizable Israeli community. 

Chriso Savva, Director of Chriso Savva 

LLC, underscores that not only are many 

Israelis pursuing residency permits in 

Cyprus, but they are also increasingly 

moving their businesses to the island. 

Amid an already tense global landscape, 

the war’s impact has extended to far-off 

continents, fostering divisive rifts that 

transcend mere pro-Israel or pro-Palestinian 

sentiments. Antisemitism is resurging, and cities 

spanning from London to Kuala Lumpur have 

witnessed pro-Palestinian demonstrations. 

Ron Klasko, Managing Partner of Klasko 

Immigration Law, stresses that the recent 

political shifts and responses to conflicts in 

the Middle East have influenced investment 

migration trends in the US. “Unfortunately, 

many American citizens, especially Jewish 

people, have safety and security concerns. 

This has led to increasing interest for 

third country citizenship or residence,” 

Klasko says. In response to this demand, 

Klasko co-founded Exodus Migration LLC, 

dedicated to guiding individuals and families 

in identifying suitable destinations for 

temporary or permanent relocation based 

on their specific needs and circumstances. 

Uncertain Future 

Towards the close of 2023, no one knew when 

or how the war will end, and it is impossible to 

predict. What seemed certain though is that 

the longer the war plays out, the greater the 

potential for wider consequences well beyond 

the Israeli or Palestinian borders. Optimists 

hoped that the Palestinian Authority – seen as 

more moderate than Hamas – could emerge 

strengthened, and Israel could re-commit 

itself to peace talks. But these days optimism 

is in short supply. The toll it has exacted is 

stark: thousands of lives lost, hundreds of 

thousands displaced, with many lacking a 

place to call home once the conflict ceases. 

These consequences will leave profound 

wounds etched into the fabric of 2024. 



Interview with Dr Juerg Steffen, CEO of Henley & Partners 

From 2024 

to the Future 

A Candid Conversation with Dr Juerg Steffen 

Dr Juerg Steffen, CEO of Henley & Partners, offers insights into 

the present landscape of investment migration, and discusses the 

evolving trends and strategies that will define the path forward. 

As investment migration 

pathways continue to 

rapidly evolve, could you 

share with us the top three 

trends that have significantly 

impacted the industry 

over the past 12 months? 

There are several converging global 

trends that are having a notable impact 

on the investment migration sector. The 

seismic geopolitical shifts that are creating 

a more multipolar world, along with the 

rise of wealth in the global south, have 

seen interest and uptake surge in certain 

countries, such as India, South Africa, 

and Turkey. The BRICS group of Brazil, 

Russia, India, China, and South Africa 

has emerged as an economic force that 

can no longer be overlooked. With its 

recent expansion to include six additional 

countries, including the UAE and Saudi 

Arabia, the BRICS +6 grouping constitutes 

36% of global GDP and 46% of the world 

population. And while there are many 

affluent individuals in these countries, 

they do not enjoy a great deal of travel 

freedom or economic mobility, hence their 

growing interest in investment migration. 

Another trend driving our sector is 

the relentless and ongoing volatility we 

have experienced since we entered the 

2020s, and this is exacerbated by a range of 

factors including unprecedented levels of 

violence and conflict in the Middle East, the 

war in Ukraine, and the mounting climate 

emergency. This is amplifying security, 

political, and economic risks, prompting 

affluent families globally to diversify their 

citizenship and residency and create a 

portfolio of domicile options through 

investment migration to extend their personal 

access rights to different jurisdictions to 

protect their lifestyles, wealth, and legacies. 

Even in highly developed countries with 

strong passports such as the UK and the USA, 

we are seeing sustained high interest in and 

demand for investment migration programs. 



And finally, overburdened 

governments struggling to mitigate the 

relentless economic pressures caused 

by global phenomena such as Covid-19, 

climate change, and aging populations, 

have driven up the supply side of our 

industry. The competition to attract 

capital and talent has never been 

fiercer, and we have seen a significant 

increase in interest from governments 

across the world in either introducing 

new or reviving existing investment 

migration legislation and options. 

Could you provide examples 

of countries that have 

developed new pathways 

or revitalised existing ones 

to entice foreign investors? 

And most importantly, 

what strategies have proven 

effective in this regard? 

The UAE has been immensely successful 

in enhancing its liveability and drawing the 

talented and the wealthy to its shores. This is 

in part due to its business-friendly policies, 

but it has also launched and expanded its 

residence by investment offering to retain 

and expand its population of affluent 

residents, so qualifying applicants can 

invest in a licensed company, an accredited 

local fund, or real estate to secure a UAE 

golden visa. Last year, the UAE had the 

highest net inflow of HNWIs globally, so 

clearly this was a successful strategy. 

The Antigua and Barbuda Citizenship 

by Investment pathway has also grown 

in popularity after it introduced a family 

option: the University of the West 

Indies Fund, contributing a minimum 

of $150,000 to the university for a 

family of a minimum of six persons. 

Moreover, nations as varied as Canada, 

the UK, Portugal, and St. Lucia all offer 

a business option. Such investment 

pathways are often industrially specific, 

with residence or citizenship granted to 

participants who invest in commercial 

enterprises and industries to create 

jobs. Industrially specific investment 

migration tends to launch new projects 

that benefit all levels of society. 

If we look back over the past few 

decades, St. Kitts and Nevis is another 

example of a small island nation using 

investment migration to restructure its 

economy and raise hundreds of millions 

of dollars in foreign direct investment 

geared towards laying the foundations for 

future growth and development. The St. 

Kitts and Nevis Citizenship by Investment 

Program has brought great value — at 

times estimated at 36% of its total revenue. 

Like several other countries, St. Kitts had a 

time limited offering that enabled investors 

to make a non-refundable contribution 

to its Sustainable Growth Fund (SGF). 

In response to international 

criticism, we’ve observed 

certain countries, especially 

in the Caribbean region, 

enhancing the security, 

management, and economic 

aspects of their investment 

migration pathways. Do 

you believe these changes 

have effectively addressed 

the concerns raised? 

My understanding is that the concerns were 

around issues of security and the potential 

abuse of investment migration pathways, 

and steps have been taken to strengthen due 

diligence, introduce mandatory interviews, 

and in the case of St. Kitts and Nevis, the 

minimum investment amounts have been 

increased. Due diligence is a fundamental 

aspect of every investment migration 

solution as it acts as a gatekeeper, not only 

protecting host nations from personae non 

gratae, but also safeguarding the integrity 

of the sector itself, so any steps to increase 

compliance are steps in the right direction. 

As demand for investment migration 

continues to grow, especially now as 

political strife, societal breakdowns, and 

climate and financial crises proliferate 

across the world, the sector must rise to the 

challenge and work even harder to improve 

its governance and due diligence standards. 

Some countries, like the 

UK, Portugal, and Ireland, 

have closed some of their 


pathways to new applicants. 

What do you think are the 

primary reasons behind such 

closures, and do you anticipate 

more countries following suit? 

Different countries have their own reasons 

for making such decisions. The most 

successful investment migration pathways 

are designed to serve a certain purpose, 

and once that has been achieved, or if it 

is not being achieved, it is best practice 

to reassess and adjust the investment 

options. Since Brexit, the UK has been 

making changes to its immigration 

policies across the board, from refugees, 

to students, to workers, and high-networth 

individuals have been no exception 

to this change. The country is, however, 

encouraging innovation with the launch 

of the Innovator Founder visa in 2023. 

Ireland established its pathway 

to stimulate investment, which it has 

achieved, and it will also continue its 

Start-up Entrepreneur Programme. The 

door has not been completely closed to 

innovative, business-minded investors. 

Portugal’s parliament has reapproved 

the bill to now end its real estate investment 

migration option, with the programme 

generating nearly €500 million between 

January and August 2023. Other investment 

pathways remain, and Portugal is still 

issuing golden residence permits. So yes, 

certainly in time, other pathways will make 

changes or end certain options, but we 

will also see new options emerge in other 

countries. Both the supply and demand 

side of the sector continues to grow. 

From your perspective, what 

additional innovations or 

improvements do you believe 

should be introduced to 

enhance the global landscape 

of investment migration? 

The great wealth transfer has been a talking 

point for several years now and is truly 

underway. To enhance the investment 

migration sector and keep ahead, we need to 

be mindful of and take seriously the needs 

and aspirations of the next generation and 

be proactive to ensure that we remain as 

relevant to them as we currently are to their 

parents and grandparents. No matter where 

we are in the world today, we can all see and 

feel the very real effects of climate change, 

which Gen Z and Gen Alpha children are 

growing up with as part of their daily lives. 

Sustainability and the climate emergency 

are urgent issues for them to address. 

It would be valuable to see more ESG 

investment migration options being offered 

by governments that address these concerns 

and would benefit both host countries 

societies and the future of our planet. 

Remote work and global 

nomad visas have become 

increasingly popular. What 

challenges and criticisms have 

these programmes faced, and 

how can they be improved? 

Digital nomad visas have certainly gained 

in popularity, and although the nomads 

themselves are expected to bring economic 

benefits to the host country, it is not clear 

to what extent, and there are also tax 

The shift towards e-citizenship could be transformative 

for investment migration, but as with digital nomad visas, 

they will require careful consideration on thorny issues 

such as tax — where do you pay it if you are a dual citizen 

and resident of both virtual and physical nations? 



implications to consider. They are still 

in their infancy, and over time it should 

become clearer how best to proceed to 

ensure that these visas are beneficial for all. 

For instance, red tape should be minimised, 

countries could consider offering tax 

incentives, and they need to ensure that 

it is relatively uncomplicated to obtain a 

work permit, open a bank account, set up 

a business, and of course, ensure that the 

tech infrastructure is efficient. Perhaps 

there could be project-specific nomad visas 

to address certain skills gaps, which would 

benefit the host country and nomads alike. 

Given the rapid changes 

in the industry, what role 

do you see technology and 

digital solutions playing in 

the future of investment 

migration? Are there any 

emerging tech trends that you 

find particularly intriguing? 

It is fascinating to observe in real time how 

the metaverse is reshaping many aspects 

of our society, even how sovereign states 

conceptualise and manage citizenship. 

We are now seeing the whole concept of 

sovereignty coming into question as the 

virtual frontier continues to expand. More 

possibilities are emerging, and nation 

states are beginning to explore how they 

can use the virtual world to grow their 

political capital and sovereign equity. 

One way they are doing so is by offering 

virtual citizenship, with Barbados being 

the pioneer and first to launch a virtual 

diplomatic embassy in Decentraland. Such 

initiatives also provide nation states with 

new possibilities for diversifying the type 

of capital they attract. The metaverse is 

built on blockchain, so perhaps in future 

digital assets, cryptocurrencies, and NFTs 

will become accepted forms of investment. 

The shift towards e-citizenship could be 

transformative for investment migration, 

but as with digital nomad visas, they will 

require careful consideration on thorny 

issues such as tax — where do you pay 

it if you are a dual citizen and resident 

of both virtual and physical nations? 

The concept of domicile 

diversification and building 

up a portfolio of alternative 

residence and citizenship 

options that gives you 

and your family personal 

access rights to multiple 

jurisdictions has really 

taken off with investors 

all over the world. 

Looking beyond traditional 

investment migration, what 

innovative approaches or 

unconventional ideas do 

you think have the potential 

to disrupt or reshape the 

industry in the years to come? 

As mentioned previously, seemingly 

futuristic ideas such as citizenship in the 

metaverse are now very real, and a KPMG 

report is predicting that eventually, digital 

citizenship could even replace passports 

and residence cards for the physical world. 

We already see Singapore using biometric 

technology and facial recognition to allow 

passengers to fly without passports or 

boarding passes. If they are successful in 

attracting wealthy and talented individuals, 

virtual nations could gain sufficient 

power, influence, and to rival real-world 

nation states. And then of course, if 

certain key regions move towards being 

almost borderless, such as has been on the 

cards in Africa for some time, this would 

disrupt the global mobility hierarchy. 

On a more personal note, as 

you reflect on your five-year 

tenure as CEO of Henley, can 

you share with us the key 

milestones and challenges 

you’ve encountered along the 

way? What stands out as the 

most memorable highlight, 

and conversely, what was 

the most significant hurdle 

you’ve had to overcome? 

The first six months or so of the Covid 

pandemic was certainly a very challenging 

and demanding period for our sector and 

our firm as many governments closed their 

immigration offices, and we were unable to 

submit residence and citizenship applications 

on behalf of our clients. It was a time of 

great uncertainty and anxiety as nobody 

knew what was going to happen next and 

how things would turn out. Clients had to 

wait extended periods of time to begin and 

complete their application process which 

impacted heavily on our business. However, 

it also underscored the importance of having 

a portfolio of resident and citizenship options 

that provides you with personal access rights 

to different jurisdictions around the world 

in times of crisis. This led to a significant 

spike in interest and applications, and 

this is a trend that continues to this day. 

One of our biggest achievements was 

the recent opening of our 40 th office, with 

many more planned and in the pipeline 

due to the unprecedented global demand 

for residence and citizenship by investment 

by investors and governments alike. Our 

sector and the positive value we create for 

both global citizens and sovereign states is 

certainly going from strength to strength. 

As one of the biggest players 

in the investment migration 

industry, Henley & Partners 

has landed in the hot seat 

more than once in recent 

years. Is there a thoughtprovoking 

question that you’ve 

always hoped a journalist 

would ask you, yet it has never 

come up in an interview? 

Generally, I wish journalists would ask me 

more about who is applying for the different 

residence and citizenship pathways and 

why they are interested in it. It offers a 

fascinating reflection of our world today that 

provides valuable insights into a country’s 

economic outlook and future trends. For 

instance, prior to Covid, a high percentage 

of our applicants came from emerging 

markets with relatively weak passports 

that limited their global mobility and 

aspirations. They were interested in either 

moving to a more developed economy or at 

least have the option to move or travel there 

without restrictions if they needed too. 

During and after Covid, a new trend 

emerged that expanded our client base 

into highly developed and relatively stable 

nations in Europe and the US who woke up 

to the importance of having options in terms 

of where in the world they could live, work, 

invest and retire. The concept of domicile 

diversification and building up a portfolio of 

alternative residence and citizenship options 

that gives you and your family personal 

access rights to multiple jurisdictions has 

really taken off with investors all over the 

world. In this transitional period that is 

plagued by heightened security, political, 

and economic risks, wealthy families 

regardless of what citizenship they hold 

are revisiting their priorities to ensure 

their legacies, wealth, and lifestyles are 

protected, and that they don’t just have 

Plan B in place, but also a Plan C and D. 

Dr Juerg Steffen is the CEO 

BIO of Henley & Partners. He has 

more than 30 years’ experience 

in the financial services industry and 

is widely regarded as a leader in the 

field of investment migration. He first 

joined Henley & Partners in 2013 to 

set up the firm’s Singapore office and 

was latter appointed COO of the group. 

Before joining Henley & Partners, he 

was a personal adviser in the family 

office of one of Europe’s wealthiest 

families. He also served as a member 

of the management board and as head 

of the Wealth Planning department of a 

leading private bank in Austria and was 

a director in the Cross-Border Wealth 

Planning department of UBS in Zurich. 


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www.iiusa.org | info@iiusa.org | 202-795-9669


Citizenship by 

Investment: 

A Year of 

Transformation 

in the Caribbean 

The year 2023 has ushered in a series of significant 

alterations in the citizenship by investment (CBI) pathways 

of several Caribbean nations. Yet, the pressing question 

remains: has the overhaul genuinely persuaded the 

skeptics among international partners and critics? 

In 2023, the Caribbean investment 

migration nations witnessed the 

“Brussels Effect” in full force. Coined 

by Columbia University Professor Anu 

Bradford, this term refers to the EU’s 

unmatched ability to shape global rules 

and standards, extending far beyond 

its own geographical boundaries. 

Companies and nations worldwide find 

themselves compelled to pay attention 

to the requirements of one of the world’s 

most influential markets. Last year, the EU 

exerted significant pressure and introduced 

rules with the potential to profoundly affect 

investment migration in non-EU countries. 

Historical Background 

Investment migration has been a heated 

topic in the European Union ever since 

Malta decided to offer its passport in 

exchange for investment in the country’s 

economy back in 2013. While the practice 

had existed for some time outside the EU, it 

largely escaped public scrutiny until then. 

However, Malta’s pathway became a focal 

point of discussion due to the country’s EU 

membership, which grants Maltese citizens 

not only freedom of movement but also the 

freedom to settle in all other EU countries. 

Citizenship by investment (CBI) first 

emerged in islands in the Caribbean and 

the Pacific, shortly after they became 

independent from colonial powers 

and were looking for new economic 

growth drivers. In 1984, St. Kitts and 

Nevis blazed the trail, pioneering 

the concept just a year after gaining 

independence to reduce its reliance on the 

dominant sugar industry. Fast forward 

to today, and the nation’s CBI pathway 

contributes more than 20% to its GDP. 

In the subsequent years, additional 

Caribbean nations, including Dominica, 

Grenada, St. Lucia, and Antigua and 

Barbuda, followed suit. One of the primary 

advantages linked to Caribbean investment 

migration pathways has been the option 

of visa-free travel to both the EU and the 

US. However, discomfort has been growing 

in the EU, the US, and the UK regarding 

this practice, due to concerns about 

inadequate due diligence checks, a lack of 

transparency, and insufficient oversight. 

US Intervention 

In the US, two Members of Congress 

took steps to amend the Immigration and 

Nationality Act with the introduction of the 

No Travel for Traffickers Act in 2022. This 

legislation aimed to disqualify any country 

from participation in the US visa-waiver 

programme if it allowed individuals to 

obtain citizenship through investment. 

While the initiative was not successful, 

the US convened a roundtable meeting, 

urging the five Caribbean CBI states to 

undergo substantial reforms. Consequently, 

these Caribbean nations collectively 

embraced several principles proposed 

by the US, with some countries having 

already voluntarily adopted some of 

these principles prior to the meeting. 

The agreed-upon principles included 

a collective approach to handling denied 

applications, conducting interviews with 

applicants, performing additional checks 

with the country’s Financial Intelligence 

Units, annual or biennial audits following 

international standards, requesting law 

enforcement help to recover revoked 



passports, as well as suspending processing 

applications from Russians and Belarusians. 

In turn, the US recognised the 

importance of investment migration 

for the prosperity and prospects of the 

countries, and the CBI states requested that 

the US Government facilitates a similar 

engagement with the EU and the UK. 

UK Visa Restrictions 

However, in July 2023, the UK took a 

decisive stance by imposing stringent visa 

restrictions on Dominica and Vanuatu, both 

of which offer citizenship by investment 

pathways. This measure was rooted in 

concerns regarding potential misuse and 

exploitation of these citizenship routes. 

Prior to this, in 2022, the UK had closed its 

tier 1 investor route due to significant antimoney 

laundering (AML) apprehensions. 

Moreover, signaling its firm stance, 

the UK expressed its intent to broaden 

visa requirements to include passport 

holders from St. Lucia, Grenada, Antigua 

and Barbuda, as well as St. Kitts and Nevis 

if these countries continued offering 

Citizenship by investment first emerged in islands 

in the Caribbean and the Pacific, shortly after they 

became independent from colonial powers and 

were looking for new economic growth drivers. 

citizenship by investment. This proactive 

step raised expectations of a possible echo 

in the European Union, potentially leading 

to the exclusion of these nations from 

the Schengen Visa waiver programme. 

Proposed EU Regulations 

In October 2023, the European Commission 

proposed regulations aimed at simplifying 

the process for the EU to suspend visa-free 

travel from countries offering citizenship 

through investment migration. Currently, 

the European Union has a “suspension 

mechanism” in place that allows member 

states to temporarily halt visa-free travel 

for a specific country in the event of a 

sudden and significant rise in irregular 

migration or security concerns. 

However, the Commission, which 

proposed the regulations to the European 

Parliament, would like to make the visa 

suspension mechanism easier to trigger, 

arguing that citizenship by investment poses 

a threat to “the public policy or internal 

security of the member states.” This threat, 

according to the EU, encompasses issues 

such as organised crime infiltration, money 

laundering, tax evasion, and corruption. 

St. Kitts and Nevis’ Measures 

Meanwhile, in response to the international 

pressure, some Caribbean countries took 

action to safeguard investor benefits. In 

July 2023, St. Kitts and Nevis announced 

several changes to its pathway. To 

strengthen due diligence, the country 

introduced mandatory interviews for all 

applicants, either conducted virtually 



Industry experts highlight that the changes already 

encompass many of the recommendations outlined in 

a joint report published by the OECD and the Financial 

Action Task Force (FATF) in November 2023. 

or in person, with checks conducted 

by independent professional firms. 

St. Kitts and Nevis’ Prime Minister Dr. 

Terrence Drew stated that the government 

has “done some deep introspection,” 

analysed the programme, spoken to its 

international partners and decided to show 

the world that the country’s “citizenship 

is not accessible to those who do not value 

our citizenship or understand what St 

Kitts and Nevis has to offer the world.” 

St. Kitts and Nevis also introduced 

the Sustainable Island State Contribution 

(SISC) as a new investment option. The 

SISC replaces the previous Sustainable 

Growth Fund (SGF) and aims to advance the 

country in seven key areas, including local 

food production, green energy, economic 

diversification, sustainable industries, the 

creative economy, pandemic recovery, and 

social protection. Moreover, it raised the 

minimum investment requirement across 

all options. For example, contributions 

for the SISC start at $250,000 for one 

applicant and increase for spouses and 

dependents. The minimum investment for 

the Developer’s Real Estate Option is now 

$400,000, with a requirement to hold the 

property for seven years before it can be 

resold to another potential CBI applicant. 

“While we have always been the 

benchmark of the global investor 

immigration industry, we understand that 

in order to remain as one of the most soughtafter 

economic citizenship programmes in 

the world, we need to continue to evolve and 

forge a path for ourselves that is sustainable 

in the long term,” Michael Martin, who 

heads St. Kitts and Nevis’ CBI unit, added. 

Dominica’s Changes 

Elsewhere, Dominica also unveiled a 

series of comprehensive changes to its 

CBI pathway. One of the most noteworthy 

changes is the introduction of mandatory 

interviews for all CBI applicants over 

the age of 16. Furthermore, citizens 

from the Kurdistan region in Iraq, 

Russia, and Belarus will not qualify 

for citizenship in Dominica. These 

regions have been flagged as high risk 

by international security authorities. 

The government also introduced 

legislation to provide an enhanced 

due diligence fee for applicants from 

specific countries. This fee will provide 

additional resources to thoroughly 

scrutinise applicants from these regions, 

ensuring that the pathway maintains 

the highest standards of security. 

Speaking on these developments, 

Dominica’s Prime Minister Roosevelt 

Skerrit affirmed the country’s commitment 

to ensuring the highest standards of 

due diligence and risk mitigation in 

the CBI pathway. “We take this matter 

very seriously and will increase our 

efforts in showcasing our robust due 

diligence and risk mitigation efforts on 

all fronts,” the Prime Minister said. 

In addition, the government 

strengthened its Citizenship by Investment 

Unit (CBIU). A US-based firm has 

conducted extensive training in antimoney 

laundering and counter-terrorism 

financing for all CBIU staff. The Unit was 

also restructured under the supervision 

of a compliance officer, ensuring that 

all procedures were updated, quality 

control measures strictly followed, 

and all IT systems upgraded. 

Further, Dominica announced its 

intention to revoke the citizenship of 

those who made false declarations or 

misrepresentations in their applications. 

This measure particularly targets 

applicants with previous visa rejections 

from countries with which Dominica 

has visa-free treaties. Moreover, 

Dominica implemented biometric 

travel documents and updated its 

naturalisation certificate with enhanced 

security features. Additionally, it 

has issued regulations to restrict 

citizens from changing their names to 

maintain transparency and security. 

Grenada and St. Lucia’s 

Enhancements 

Following their Caribbean counterparts, 

Grenada also introduced mandatory 

interviews for all applicants over the 

age of 17, while St. Lucia also added a 

new interview and identity verification 

stage to its CBI application process. 

Along with the interview, an additional 

due diligence fee of $500 has been 

proposed; however, only the primary 

applicant will be required to attend the 

interview. The St. Lucian government 

stated this change aims to “enhance 

the authentication of critical biodata 

information and eliminate any 

information gaps that can potentially 

exist in the application process.” 

What’s Next? 

The proposed and implemented 

changes within the Caribbean mark a 

positive evolution. However, the pivotal 

concern remains: will these alterations 

sufficiently meet the expectations 

of the international community? 

Industry experts highlight that the 

changes already encompass many 

of the recommendations outlined 

in a joint report published by the 

OECD and the Financial Action Task 

Force (FATF) in November 2023. 

Moreover, an important aspect 

to consider is the enduring appeal of 

these pathways in light of potential 

restrictions on visa-free access to 

other regions. While specialists in 

investment migration emphasise that 

visa-free travel is just one component 

of the larger equation, the loss of this 

privilege will undoubtedly impact 

demand and subsequently harm 

the revenue of Caribbean nations. 

Hence, raising standards becomes 

imperative for the Caribbean countries 

to safeguard the future of their 

investment migration pathways. 


Bring Your 

Risk to the 

Surface 

with Exiger’s DDIQ 

SCAN TO GET 

STARTED TODAY


Official Airline 

Official Venue 

The Investment Migration Forum 2024 

16 th - 19 th April 2024, The Ritz-Calton DIFC, Dubai, UAE 

300+ 

Delegates 

39+ 

Speakers 

44+ 

Countries 

20+ 

Partners 

The Investment Migration Forum is the largest and most important non-profit forum in the 

world. Renowned academics, government officials, representatives of international 

organisations, as well as the world’s leading professionals dealing with investment 

migration will be gathering in Dubai for the 9 th edition of the Forum. The three-day event 

will cover a variety of related subjects which are of interest to the academic, professional 

and government community. Expect 300+ participants from over 40+ countries. 

19% 

20% 

46% 

7% 

2% 


3 Questions 

for 2024 

As 2024 unfolds, the world faces 

a series of pressing questions and 

challenges that reverberate across 

various domains. Cybersecurity 

threats, the far-reaching impact 

of economic shifts and A.I. , we 

explore issues that will impact 

investment migration in 2024. 



1Cyberattacks are 

proliferating, causing 

trillions of dollars of 

damage every year. 

How safe is investment 

migration data? 

As we step into 2024, investment 

migration firms are facing an 

increasingly complex landscape 

of cybersecurity threats. These firms 

traditionally hold sensitive client data, 

including information related to the source 

of funds and source of wealth, which makes 

them prime targets for cybercriminals 

looking to exploit vulnerabilities and 

steal valuable information. Cybersecurity 

threats are constantly evolving, and 

investment migration firms need to stay 

ahead of the curve to protect their clients’ 

confidential information. Here are some 

of the most significant cybersecurity 

challenges these firms will face in 2024: 

Ransomware Extortion 

Ransomware attacks have been a 

persistent threat, but experts believe that 

in 2024, they are becoming even more 

sophisticated. Double extortion attacks, 

where cybercriminals steal sensitive data 

before encrypting it, are on the rise. This 

approach makes it harder for firms to 

recover their data without paying a ransom, 

posing a significant risk to the security and 

reputation of investment migration firms. 

Cloud Third-Party Threats 

As investment migration firms increasingly 

rely on cloud services to manage client 

data, they become vulnerable to attacks 

targeting cloud service providers. 

Cybercriminals can exploit trust 

relationships between firms and their 

service providers, potentially gaining 

access to sensitive client information. 

Understanding the shared security model of 

the cloud and implementing best practices 

is essential for mitigating this risk. 

Mobile Malware 

With the widespread use of mobile devices, 

mobile malware has emerged as a growing 

threat. Cybercriminals are creating 

malicious versions of legitimate apps, 

making them difficult to detect. Investment 

migration firms must educate their 

employees about the risks of downloading 

apps from unofficial sources and implement 

robust mobile security measures. 

Wipers and Destructive 

Malware 

While ransomware garners much 

attention, wipers and other destructive 

malware can have even more devastating 

consequences. Instead of encrypting 

data for ransom, wipers delete it entirely, 

causing significant business disruptions. 

Investment migration firms should focus 

on data backup and recovery strategies 

to mitigate the impact of such attacks. 

Weaponisation of 

Legitimate Tools 

Cybercriminals are increasingly using 

legitimate penetration testing and 

system administration tools to infiltrate 

systems. This approach allows them to go 

unnoticed by signature-based detection 

tools. Investment migration firms must 

stay vigilant and monitor their networks 

for any unusual activity or tool misuse. 

Zero-Day Vulnerabilities 

in Supply Chains 

Zero-day vulnerabilities, where no fix is 

available for a known issue, pose a significant 

risk, especially in the software supply chain. 

Investment migration firms should conduct 

thorough assessments of their software vendors 

and third-party dependencies to identify and 

address potential vulnerabilities promptly. 

Mitigating Cybersecurity Risks 

To address these cybersecurity challenges 

effectively in 2024, experts suggest that 

firms consider streamlining cybersecurity 

efforts by adopting a single security 

platform with all required capabilities. This 

consolidation improves efficiency and makes 

it easier to monitor and manage security 

infrastructure. Companies should also shift 

the focus from detection to prevention by 

proactively identifying and blocking inbound 

threats. This approach reduces the window 

of opportunity for attackers to exploit 

vulnerabilities. Firms also need to ensure 

that their cybersecurity measures cover all 

potential attack vectors, including cloud 

services, mobile devices, and IoT devices. 

Investment migration firms must 

remain vigilant and adaptable in the face 

of evolving cybersecurity threats. The 

consequences of a data breach can be 

devastating, and agents, service providers 

and government units must be prepared 

to defend against threats originating from 

around the world. Comprehensive threat 

protection, continuous monitoring, and 

access to up-to-date threat intelligence 

are critical components of every robust 

cybersecurity strategy in 2024 and beyond. 


2In a world facing mounting economic 

pressures, the global economy is at 

a crossroads, with new challenges 

and uncertainties on the horizon. 

How will these economic shifts 

impact investment migration? 


The global economy today is 

teetering on the edge. Despite 

its relative resilience in the face 

of significant shocks like the Covid-19 

pandemic, skyrocketing living costs, 

energy crises, rampant inflation, and 

Russia’s war in Ukraine, the eruption 

of hostilities between Israel and Hamas 

on 7th October 2023 served as a stark 

reminder of how daunting it has become 

to protect economies from ever-more 

frequent and unforeseeable global shocks. 

The Forecast 

Global economic growth is expected to 

slow to 2.9% in 2024, according to the IMF’s 

October World Economic Outlook. The 

figure, down from growth of 3.5% in 2022 

and 3% in 2023, remains well below the 

historical average (2000–19) of 3.8% and 

marks the lowest growth forecast in decades. 

Advanced economies are expected to 

slow from 2.6% in 2023 to 1.4% in 2024 as 

policy tightening starts to bite. Emerging 

market and developing economies are 

projected to have a modest decline in 

growth from 4.1% in 2022 to 4% in 2024. 

Global inflation is forecast to decline 

steadily, from 8.7% in 2022 to 5.8% in 2024, 

due to tighter monetary policy aided by 

lower international commodity prices. 

The Unknown 

China’s looming real estate crisis, 

precarious banking stability, and 

volatile commodity prices amid 

climate and geopolitical shocks pose 

major threats to taming inflation. 

Moreover, the Israel-Hamas conflict, 

like past Middle East wars, holds the 

potential to disrupt the global economy 

and even push it into recession if 

more nations get involved. Bloomberg 

Economics predicts that in such a 

scenario, oil prices could skyrocket to 

$150 per barrel, while global growth 

could plummet to 1.7%, resulting in a 

trillion-dollar loss in world output. 

The Middle East’s significance 

as an energy supplier and a crucial 

shipping route amplifies the global 

impact of this strife, reminiscent of the 

1973 Arab-Israeli war that led to an oil 

embargo and stagflation in industrial 

economies. Rising energy prices 

could also impact the upcoming US 

presidential election, where gasoline 

prices heavily sway voter sentiment. 

In the broader region, tensions are 

simmering. Egypt, Lebanon, and Tunisia 

grapple with economic and political 

gridlock. Israel’s retaliation to Hamas’ 

assault has already sparked protests 

in multiple regional nations. Analysts 

believe that the leap from anti-Israel 

demonstrations to anti-government 

upheaval in many countries can be swift. 

A déjà vu of the Arab Spring, the wave of 

protests that toppled governments in the 

early 2010s, is not out of the question. 

One undeniable truth: dreams of a 

stable Middle East lie in ruins. Instead, it 

confronts a fresh inferno. Russia’s Ukraine 

invasion, the US-China trade showdown, 

and escalating Taiwan tensions signal 

the return of geopolitics as a potent 

force shaping economic and market 

destinies. The IMF, once more, raised 

concerns about a world fragmenting into 

geopolitical factions that threaten to stifle 

global trade and economic prosperity. 

The Impact on IM 

The current economic landscape carries 

profound implications for investment 

migration. The world could be on the brink 

of a new sovereign debt crisis as geopolitical 

tensions escalate. One pressing concern 

is the potential impact of China’s slowing 

economy on a global scale, with the IMF 

warning that nations integrated into the 

Asian industrial supply chain may be 

vulnerable to this loss of momentum. 

Adding to the complexity is the 

forecast that trillions of dollars will be 

needed over the next decade to address 

the alarming effects of climate change 

in developing nations. Amidst ongoing 

global conflicts, investment migration 

offers countries a means to bolster their 

public finances and support economic 

growth without incurring additional debt. 

These economic and geopolitical factors 

collectively create an environment of 

persistent uncertainty, driving demand 

among high-net-worth individuals for 

alternative residences and citizenships. 

Henley and Partners estimate that in 2024, 

128,000 millionaires will seek to relocate. 

This significant migration of human capital 

and wealth will exert a notable impact on 

the economic and societal dynamics of both 

the jurisdictions these affluent individuals 

depart from and those they invest in. 



3 

The 

meteoric rise 

of ChatGPT in 2023 

quickly became 

a sensation. 

What will AI 

bring us next? 

The year 2024 is poised to be 

a significant juncture in the 

evolution of artificial intelligence 

(AI). Investment migration is not new 

to AI – for example due diligence 

service providers have long been 

using and experimenting with AI. 

The integration of AI into immigration 

processes presents the potential for 

unprecedented efficiency and accuracy 

gains. Nonetheless, challenges persist, 

encompassing the assurance of data 

accuracy, elimination of biases, 

maintenance of transparency, upholding 

data privacy, and accountability for 

potential errors. What exactly can 

we anticipate from AI in 2024? 

Augmented Working 

Augmented working takes the spotlight 

in this transformation, with AI becoming 

a key collaborator across diverse sectors. 

While recent attention has focused on 

AI’s content creation capabilities, the 

upcoming year will see a broader spectrum 

of applications. This includes leveraging 

AI for advanced analytics, predictive 

insights, coding through automation and 

debugging, and employing sophisticated 

virtual assistance to enhance customer 

service. As AI integrates further into 

professional spheres, there is a pressing 

need to redefine traditional job roles, 

emphasising training programmes to 

effectively harness AI’s potential. 

A significant stride in AI 

advancement will be the emergence of 

truly multi-modal AI systems capable 

of seamlessly integrating diverse data 

types like text, visuals, and audio. This 

innovation promises a more natural 

and intuitive user interface, offering 

sophisticated virtual assistants adept 

at handling complex queries, customer 

service bots capable of interpreting 

emotions and intentions, and the 

creation of innovative educational 

tools, to name just a few. These 

multi-modal systems represent a leap 

towards AI that can interact with the 

world akin to human perception and 

cognition, opening new dimensions in 

AI applications and user experiences. 

AI Regulation 

Yet, this transformative AI landscape is 

not just about technological prowess; it 

necessitates robust and evolving legislative 

frameworks to balance innovation with 

responsibility. Countries around the world 

are currently crafting AI governance 

strategies and regulatory frameworks, 

emphasising ethical deployment, risk 

mitigation, and transparency. For 

businesses, staying agile and wellinformed 

is crucial to navigate these 

evolving legal environments effectively. 

Quantum AI 

A ground-breaking development poised 

to revolutionise industries is Quantum 

AI. Leveraging quantum mechanics, 

Quantum AI operates using qubits, 

allowing exponential increases in 

processing power by existing in multiple 

states simultaneously. This capability 

enables Quantum AI to analyse complex 

datasets at unprecedented speeds. 

This technology is transitioning from 

a theoretical marvel to a practical tool, 

offering businesses and governments 

unparalleled insights and decision-making 

capabilities, thereby paving the way for 

new frontiers in innovation and efficiency. 

IM Approach to AI 

Yet, some businesses who spoke to the 

IM Yearbook revealed a cautious stance 

toward AI adoption. They emphasised 

that much of the technology still requires 

refinement. Moreover, in the public 

sector, for example, in governments 

units, the uptake of new technologies 

traditionally moves at a slower pace. 

Additionally, there’s an observable 

reluctance among workers. Despite 

the technology’s potential to alleviate 

mundane tasks, many fear the looming 

possibility of being replaced in the long 

term. Despite these reservations, 2024 

foresees widespread AI integration. 

Now more than ever, future success 

hinges on smartly embracing changes. 


1. 

Due diligence is not 

a tick-box exercise. 

Many people use the phrase due diligence 

very glibly. By that I mean they throw 

the phrase around and think that a quick 

check across a search engine will tell 

them what they want to know. They then 

trust that it will satisfy regulatory bodies, 

clients, governments and colleagues. 

And there are many areas where it will, 

and many times when it will, because 

these processes are not properly checked. 

Superficial examination will just give 

an appearance of due diligence having 

been carried out and for many that is 

enough. There are due diligence providers 

who make a successful business out of 

providing ‘just enough’ information and 

if the client is satisfied, the whole cycle 

repeats itself ad-infinitum. At best this 

could be called ‘due diligence lite’. 

2. 

English language 

searching on its own 

is insufficient. 

Despite English being the language 

of international business and the 

predominant language of the internet, 

true searching needs native language 

ability (i.e., the language of the person 

being researched) to uncover information 

and material which would otherwise 

remain hidden. If you are serious about 

due diligence, investment is needed in 

such language skills. How many due 

diligence providers have substantial 

in-house language capabilities? 

3. 

Do not believe 

everything you read. 

The deeper you delve the more 

information you find. Of course, that 

is obvious. But how much of what you 

uncover can you trust. The phenomenon 

of social media has provided access to a 

wealth of information unheard of 20 years 

ago. That all must be treated with caution 

as quoting something uncovered online 

can give someone a misleading impression 

that the information is accurate. 

Corroboration is therefore essential, but it 

can be difficult to corroborate something 

that has been posted online (for example). 

So, treat everything with great caution 

and maintain the belief that it is unverified 


6 Things You Did Not Know about DD 

(or maybe you did) 

In a world awash with information, due diligence stands as a critical shield 

against the unknown, but it’s not a mere checkbox exercise. Kieron Sharp, CEO 

of FACT, sheds light on six essential principles for robust due diligence. 

until it is. And when it is substantiated, 

state the level of substantiation. The 

relevance of any information is directly 

proportional to its analysed veracity. 

4. 

Analysis – what 

does it mean? 

It is all very well finding all this information, 

whether it is a physical product or found 

via online research, but is there more that 

can be done? In itself, the information 

can provide an early indication to a client 

what they might be dealing with. But that 

is the easy part. To truly be affective as a 

due diligence provider you need to turn 

information into intelligence, and this 

requires analytical skills and expertise. 

Highly trained analysts can give insight 

and understanding into what has been 

uncovered. There is a night and day 

difference between the outcomes when 

you compare analysed intelligence to 

un-analysed information. Software tools, 

developed over many years, are an analyst’s 

best friend. Using this software, their 

skills in this area can turn the information 

and intelligence into different formats 

such as graphs, timelines and charts, 

which provide a clear picture of what 

can often be a jumble of information. 

Personal information, businesses, 

family members, addresses, vehicles, 

associates and more can all be linked, 

demonstrating, for instance, a subject’s 

complete lifestyle – a boon to the reader in 

terms of understanding. And that is true 

whether the subject is living a criminal 

lifestyle or is a legitimate, honest citizen. 

5. 

Intelligence 

to evidence. 

What does this mean? It is rare that pure 

due diligence research will be used as 

evidence as the bulk of due diligence 

enquiries are commissioned to simply 

understand as much knowledge about a 

person or entity as possible. But what if 

information suggesting criminal offending 

is uncovered? It is incumbent on the 

researcher to report the offending to the 

police. What then becomes of the initial 

intelligence or information? Collating and 

keeping the information to later provide as 

evidence could well be key. Experienced 

and highly trained investigators, 

researchers and analysts will know how 

to do this and will ensure the information 

is retained in an evidential format. 

6. 

Artificial Intelligence 

is leading to the end of 

society as we know it. 

If there is one subject that will not go away as 

a news article it is Artificial Intelligence or AI. 

To some it is a wondrous new development 

which will transform our lives. To others it 

is a dangerous development which is already 

out of control. But pure AI is not yet with 

us, and AI used in online due diligence 

research is nothing more than a faster and 

possibly more complete way of finding 

information. It scrapes the data, searching 

for relevant information, just like word 

searching, but is hugely more powerful and 

potentially more revealing – much more 

revealing. However, this data/information/ 

intelligence has to be treated with even more 

caution. Please go back to the section above 

on corroboration – it is dangerous just to 

accept as accurate what is found, and this 

is magnified greatly by AI data searching. 

Due diligence is a highly skilled and 

resource intensive process which requires 

specialist knowledge and investment in 

the appropriate tools to do the job. Do not 

cut corners or try to do it on the cheap. 

BIO 

Kieron Sharp has been in 

charge at FACT since 2006, 

overseeing the content protection 

and anti-piracy response to huge 

technological changes in the audio-visual 

landscape. He is a former senior City 

of London Police detective and head of 

the economic crime team at Interpol. 



From Idea to Unicorn: 

The Canadian 

Start-Up 

Visa Journey 

Discover the power and 

potential of the Start-Up Visa 

in fostering entrepreneurship 

as we delve into the past, present, 

and future of one of Canada’s 

most popular immigration 

pathways with Startup Visa 

Services CEO Slava Apel. 

In 2010, Martin Basiri arrived in Canada 

from Iran to pursue an engineering 

degree at the University of Waterloo. 

Then, in 2015, he, along with his two 

brothers, established a company under 

Canada’s Start-up Visa (SUV). Their goal 

was to simplify the application process for 

international students seeking admission 

to foreign universities, which they had 

realised could be quite complex. 

This venture, known as ApplyBoard, 

swiftly emerged as one of Canada’s 

most prominent and highly valued 

start-ups. By 2020, following multiple 

successful funding rounds, ApplyBoard’s 

valuation soared to C$2 billion, 

officially attaining unicorn status. 

“ApplyBoard stands out as one of 

the success stories within the SUV,” 

states Slava Apel, CEO at Startup Visa 

Services. “Its valuation has now soared 

to C$4 billion, and the firm has created 

employment opportunities for thousands 

of people in Canada,” he adds. 

The SUV was initially introduced 

as a five-year pilot programme in 2013 

and became a permanent fixture in 

April 2018. This federal programme 

swiftly gained prominence as one of 

Canada’s most sought-after business 

immigration pathways. Applicants don’t 

require much more than a promising and 

impactful venture proposal, which is one 

of the reasons why the programme is so 

unique and great, according to Apel. 

Features of the SUV 

A key advantage of the SUV is that it 

provides a direct path to permanent 

residence. “This sets it apart from 

numerous other start-up programmes, 

where residency is often closely tied to the 

success of the start-up itself,” says Apel. 

The SUV also does not require the 

founder-applicants to invest any of their 

funds or have a minimum net worth. They 

only need to show that they have ample 

funds to support both themselves and their 

families upon their arrival in Canada, with a 

benchmark of C$26,000 for a family of four. 

However, to be considered for the SUV, 

a start-up must meet specific investment 

criteria, such as either attracting a 

C$200,000 investment from a designated 

Canadian venture capital fund or securing a 

minimum investment of C$75,000 from an 

approved Canadian angel investor group. 

Another avenue to access this immigration 

pathway is by gaining acceptance into a 

Canadian business incubator programme, 

which do not require third-party funding. 

Facilitating the Process 

Facilitating this process is where Startup 

Visa Services’ team plays a pivotal role. 

Given the varying requirements and 

procedures of different organisations, each 

start-up’s pitch process may differ. While 

Startup Visa Services doesn’t directly 

engage with applicants, the firm provides 

essential back-office processing support to 

accredited agents and law firms involved in the 

SUV application process. The firm’s services 

encompass critical aspects of securing startup 

funding, including business validation, 

advisory, business plan preparation, 

intellectual property protection, market 

research, interview and pitch preparation, and 

even post-landing support and peer review 

defense. Apel is proud to have been able to 

assist over one thousand of the world’s leading 

mobility professionals, with a nearly perfect 

record of approvals throughout the year. 

Apel, who moved to Canada from his 

native Moldova over three decades ago, 

brings not only his personal immigrant 

experience but also valuable expertise in 

start-up finance to the table. With years 

of experience as a business adviser and 

mentor, he actively participates in various 

angel investor groups and networks 

dedicated to fostering entrepreneurship 

and nurturing start-up growth. 

Apel says the applicant pool is 

diverse, with individuals from various 

corners of the world and a wide range 

of backgrounds. Among the applicants 

are engineers, lawyers, manufacturers, 

bankers, software specialists, accountants, 

real estate developers, and company 

owners who wish to expand their products 

to Canada. The top applicant countries 

include Pakistan, India, Nigeria, South 

Africa, Russia, Vietnam, China, and Iran. 



Business and VC ecosystem 

Apel says the government is aware that 

around 80% of start-ups fail, but this 

outcome is not a significant concern. 

Entrepreneurs are also not required to leave 

the country should their venture not take 

off. The programme’s underlying rationale 

is to draw in individuals with a resilient 

entrepreneurial spirit: “We are attracting 

individuals who possess the ability to adapt 

and persevere. If their initial business 

venture, ‘A,’ faces challenges, they are 

poised to launch ‘B,’ ‘C,’ and even ‘D.’ They 

will persist until they achieve success.” 

Meanwhile, VC investment in Canada 

is flourishing, thanks in large part to the 

country’s robust business support system. 

Apel explains: “In Canada, we benefit from a 

plethora of government grants and subsidies 

designed to assist businesses. Whether 

you’re a fledgling start-up with minimal 

staff or a large corporation with hundreds 

or thousands of employees, the government 

offers programmes to aid entrepreneurs 

in areas like training, marketing, as 

well as research and development.” 

“VCs and angel investors here 

recognise that their investment dollars 

stretch further. If someone were to secure 

a million dollars in Canada, they might 

also receive a matching million from the 

government. Because of that, I would say 

our pockets are much looser than those 

of our colleagues in other countries.” 

Addressing the Backlog 

Ironically, much like many attractive 

programmes, the SUV is currently 

grappling with a backlog. In its early days, 

full permanent residency had been granted 

in under three months. However, as the 

programme became more popular, the 

processing time for permanent residency 

extended to 12 to 16 months. Presently, there 

exists a three-year backlog of applications 

awaiting assessment. However, efforts are 

actively underway to address this issue. 

“Reports are indicating that it is inching 

closer to the two-year mark. Former 

immigration minister Sean Fraser, and 

current Immigration minister Marc Miller, 

have made commitments to expedite 

the immigration process to Canada in 

general, including hiring of additional 

personnel to streamline the various 

immigration procedures,” Apel explains. 

Ongoing Evolution 

In the realm of investment migration, 

it’s common for programmes to either 

open or shut down over time. The 

fate of these pathways often hinges 

on factors like budget changes or new 

leadership. Fortunately, Apel says, 

recent history has shown a positive 

trend, with increased quotas and 

improved conditions for the SUV. 

One particularly notable development 

is the Canadian government’s commitment 

to allot a significant number of permanent 

residence admissions to the federal 

business category, which includes both 

the SUV and a self-employed programme. 

Historically, this allocation was limited 

to 1,000 per year. However, in 2023, it 

saw a substantial increase to 3,500, and 

according to Canada’s Immigration Levels 

Plan, it is projected to rise to 5,000 in 2024 

and further to 6,000 in 2025 and 2026. 

Furthermore, the SUV is continuously 

evolving. For example, entrepreneurs 

who have already applied for permanent 

residence through the SUV can obtain 

an optional work permit. This allows 

them to engage in business activities 

while their application is being processed. 

Originally limited to one year, in 2023, 

this work permit duration has been 

extended to three years, and applicants 

can even apply for an “open” work permit, 

which grants them flexibility beyond 

working solely for their own start-up. 

“In my view, the SUV is continually 

improving, which makes me optimistic 

about its future. Our support team is 

there to assist the increase in demand. 

These ongoing enhancements indicate 

that the government acknowledges 

its role in attracting the brightest 

people to Canada,” Apel concludes. 

A New Venture 

Underscoring the entrepreneurial 

zeal of Canada’s immigrant start-up 

pioneers, Martin Basiri, the founding 

CEO of ApplyBoard, set his sights on a 

new challenge in the summer of 2023. 

After passing the leadership role at the 

edtech company to his brother, Meti 

Basiri, he launched a start-up called 

Passage. The core mission of Passage 

is to address Canada’s skilled labour 

shortage by helping potential immigrants 

interested in studying and working in 

high-demand fields such as science, 

technology, engineering, mathematics, 

cybersecurity, and healthcare move to 

Canada. However, while ApplyBoard 

made it easier for financially privileged 

international students to pursue studies 

abroad, Passage is dedicated to assisting 

individuals with limited financial resources 

in obtaining the necessary funding to learn 

and work in Canada, removing a significant 

obstacle that often hinders their ability 

to come to the country in the first place. 

Slava Apel (right) with ApplyBoard 

co-founder Martin Basiri. 

BIO 

Slava Apel is the CEO of 

Startup Visa Services in 

Canada and has been an integral part 

of the Canadian startup ecosystem 

for over 20 years. He collaborates 

with immigration firms, aiding 

their clients with the necessary 

business documentation and training 

essential for obtaining approval for 

business immigration to Canada. 



Interview with Jacqueline Gauci, Head of Membership Services, Investment Migration Council 

New IMC Business 

Membership Tiers Foster 

Inclusivity and Collaboration 

The IMC has overhauled its corporate membership structure and introduced 

new Business membership tiers. The IM Yearbook sat down with Jacqueline 

Gauci, Head of Membership Services at the IMC, to discuss the changes. 

Can you explain the rationale 

behind introducing new IMC 

membership tiers? What were 

the key factors and insights 

that led to this decision? 

The decision to introduce new IMC 

membership tiers was driven by a 

combination of key factors and insights that 

we gathered through a thorough evaluation 

process. As the IMC approaches its 10th 

anniversary in 2024, our membership has 

grown significantly, now boasting over 

450 members hailing from 60 different 

countries. This remarkable growth has 

brought about a considerable increase 

in diversity within our membership, 

marking a notable evolution since the 

inception of our project, which initially 

started with only a handful of members. 

To provide context, our organisation 

underwent a successful review of our 

individual membership tiers in 2019, but 

it became increasingly apparent that 

our business membership programme 

required a similar assessment. Many 

of our individual members expressed a 

strong interest in transitioning to business 

membership status; however, they often 

found that the existing membership tiers 

and associated benefits were primarily 

tailored to larger organisations. 

The rationale behind introducing 

new IMC membership tiers is grounded 

in our commitment to inclusivity and 

providing value to all members, regardless 

of their organisational size or structure. 

Our goal is to ensure that our business 

membership programme aligns with 

the diverse needs and aspirations of our 

members. By doing so, we are not only 

adapting to the changing dynamics of our 

membership but also enhancing the overall 

experience and relevance of the IMC as 

we move into our milestone 10th year. 

What specific research, 

meetings and feedback 

from members and 

stakeholders played a crucial 

role in shaping the new 

membership structure? 

Can you highlight some key 

takeaways from this process? 

Our approach was multifaceted. First, we 

embarked on a comprehensive research 

initiative. This involved benchmarking 

our membership tiers against other similar 

professional bodies to understand best 

practices. Next, we conducted a series of 

face-to-face interviews, hosted roundtable 

events, and employed various feedback 

mechanisms to ensure we understand 

our members’ needs and expectations. 

Lastly, our team has many years of 

experience in managing a professional 

association and our prominent position 

within the IM sector provided us with a 

strong foundation for this undertaking. 

It allowed us to combine our historical 

knowledge with contemporary 

insights, resulting in a membership 

structure that addresses both current 

and future industry demands. 

A significant revelation during this 

process was the need for inclusivity. 

As mentioned, many stakeholders 

emphasised the importance of offering 

alternative pathways for smaller regional 

companies to access the benefits of IMC 

membership. This feedback resonated 

deeply with us, as we recognised the 

value of enabling organisations of all 

sizes to invest in their teams, nurture 

their talent, and cultivate a more resilient 

and trustworthy global network. 

We are proud to have transformed 

our membership offerings to better 

align with the evolving needs of our 

diverse membership base, ultimately 

fostering a stronger and more inclusive 

community within the IM sector. 

How do these new membership 

tiers align with the wider 

goals of the IMC? 

We recognise that the migration field 

is evolving rapidly, and as such, we are 

committed to accommodating a wider 

and more diverse range of firms and their 

exceptional talent from every corner 

of the world. By doing so, we reinforce 

our dedication to becoming a truly 

international organisation that mirrors 

the global, diverse nature of our sector. 

The IMC is a forward-thinking 

organisation prepared to navigate the 

forthcoming decade of transformation 

within investment migration. We are not 

merely adapting to change; we are actively 

driving it, with the aim of strengthening our 

community, providing valuable resources 

to members at all stages of their careers, 

and contributing to the ongoing success 

of the profession on a global scale. 

The new membership 

structure differentiates firms 

based on their size, reach 

and services offered. Do you 

expect that this segmentation 

will enhance collaboration 

and networking among 

members within each tier? 

Indeed, the introduction of our new 

membership structure is strategically 

designed to foster and amplify collaboration 

and networking within each tier. 

By grouping firms that share similar 

characteristics, we create organic 

opportunities for members to connect with 

peers who face similar challenges and 

opportunities. This shared context not only 

facilitates more meaningful interactions but 

also encourages the exchange of valuable 

insights and experiences specific to their tier. 

For instance, smaller firms may find 

common ground in navigating the intricacies 

of their tier, while larger organisations 



New IMC Business Membership Options at a Glance: 

Blue 

Silver 

Gold 

Platinum 

Titanium 

Membership at this 

level is for firms that 

generally operate with 

a domestic footprint 

offering a minimal of 


options to private clients 

and have around five 

employees. Benefits 

include up to four team 

members to join as full 

IMC members. Examples 

of such firms include 

domestic licensed agents, 

and small familyowned 

law firms. 

Annual Fee: 

€3,000 

Membership at this 

level is for firms that 

generally operate with 

a domestic or regional 

footprint offering a 

minimal of investment 

migration options to 

private clients and have 

around 10 employees. 

Benefits include up 

to six team members 

to join as full IMC 

members. Examples 


domestic licensed 

agents, familyowned 

law firms. 

Annual Fee: 

€5,000 

Membership at this level 

is for firms that operate 

with a regional or global 

footprint offering a 

variety of investment 

migration options to 

private clients and / 

or B-to-B clients with 

around 25 employees. 

Benefits include up 

to 10 team members 

to join as full IMC 

members. Examples 


international marketing 

agents, multi-national 

law firms, corporate 

service providers, 

accountancy firms, 

family offices, banks, 

due diligence providers. 

Annual Fee: 

€7,000 



with a global footprint 

offering a variety of 



and / or B-to-B clients 

and government advisory 

services with around 

50 employees. Benefits 

include up to 15 team 







service providers, big 

4 accountancy firms, 

multi-family offices, 

global banks, global due 

diligence providers. 

Annual 

Fee:€10,000 



with a global footprint 

offering a variety of 



and / or B-to-B clients 

and government advisory 

services with around 

200 employees. Benefits 

include up to 125 team 







service providers, big 

4 accountancy firms, 

multi-family offices, 

global banks, global due 

diligence providers. 

Annual Fee: 

€150,000 

can explore collaborations that leverage 

their collective resources and expertise. 

Similarly, firms with a more global 

footprints or service portfolios can engage 

in more targeted discussions, allowing for 

a deeper exploration of industry trends, 

challenges, and innovative solutions. 

We do believe that our tiered 

membership structure serves as a catalyst 

for deeper engagement within these 

sub-communities, enabling members to 

build relationships, exchange knowledge 

and collaborate on projects that directly 

benefit their specific circumstances. 

How did the transition 

from the old business 

membership levels to the 

new gold and platinum tiers 

affect existing members? 

The transition was seamless and hassle-free 

for our existing members. The membership 

benefits of the business members 

remained intact during this transition. 

There was no need for existing members 

to take any action, as the IMC handled 

all administrative aspects of the transfer. 

Corporate members became automatically 

gold tier members, while Corporate plus 

members seamlessly transitioned to the 

platinum tier. So, all that existing business 

members needed to do was to become 

familiar with the new tier names – gold 

and platinum – and start using them when 

referencing their membership level. 

Looking at the bigger picture, 

do you anticipate changes 

in the types of firms that 

will become IMC members? 

Are there expectations of 

attracting a broader range 

of organisations, including 

those operating in the 

wider migration field? 

Yes, we are actively seeking to attract 

organisations beyond the traditional 

boundaries of investment migration. The 

aim is to create a thriving ecosystem where 

not only experts in investment migration 

but also professionals from related fields 

can come together to reap the benefits 

of IMC membership, such as increased 

visibility, opportunities for professional 

growth, access to a talent pool, and the 

ability to tap into a global network of 

like-minded professionals. In essence, we 

are opening our doors wider to make the 

IMC an essential hub for professionals 

across the migration spectrum. 

Jackie Gauci is Head of 

BIO Membership Services at 

the Investment Migration Council. 

She is dedicated to overseeing the 

administration of the membership 

department and assisting members 

with their queries, ensuring a 

seamless experience. She has been 

working in the investment migration 

field for the last seven years. 


Global Enhanced 

Due Diligence 

Established in 1961, Globe Detective Agency (P) Limited stands as a pioneering and preeminent entity in the 

field of private investigations in India, showcasing global expertise, spanning 60 countries. Situated at its 

headquarters in New Delhi and supported by a network of 20 branch offices, GDA specializes in delivering 

Enhanced Due Diligence services tailored for the CBI/RBI industry. This comprehensive investigative process 

entails meticulous background verification, extensive data acquisition, and the utilization of well-established 

field resources. GDA’s service portfolio extends to document authentication and global security checks, focusing 

on sanctions, enforcements, watch lists, and the identification of politically exposed persons. 

The approach adopted by GDA is distinguished by its highly skilled and professional methodology, characterized 

by a personalized and rigorous framework. This meticulous approach is highly esteemed by governments, which 

routinely base critical Due Diligence decisions on the information furnished by GDA. 

GLOBE DETECTIVE AGENCY 

601-603, Eros Apartments, 

56, Nehru Place, New Delhi 110019 • India 

T: (+91) 9311042007 

E: sachitkumar@globedetective.com 

www.globedetective.com 

Sachit Kumar - Managing Director 

Trusted 

Since 1961 

Global 

Network 

20 

Offices 

100,000+ 

Cases & 

counting


Interview with Ronald Klasko, Managing 

Partner of Klasko Immigration Law 

The Quest 

for Certainty 

and Stability 

The IM Yearbook sat down 

with Ron Klasko to explore 

the impact of policy changes 

on investor sentiment in the 

EB-5 industry and beyond. 

The EB-5 programme has 

undergone significant 

changes in 2022. How is the 

programme doing now? 

It is currently benefiting from pentup 

demand after a period of limited 

progress spanning several years, marked 

by lapses and numerous short-term 

extensions. When Congress passed the 

EB-5 Reform and Integrity Act (RIA) in 

March of 2022, it effectively revitalised 

the programme. This renewal also 

came at a time when interest rates were 

soaring, and EB-5 served as a vital source 

of financing for real estate developers, 

often providing low-cost financing. 

There had been a long-standing 

demand from investors who, for years, 

lacked confidence in the programme. 

Therefore, at the same time as there has 

been a surging demand for EB-5 capital, 

there is also an increasing interest among 

investors. Consequently, it is booming times 

now, both for regional cent and for project 

developers working on assembling projects, 

as well as for the investors themselves. 

One of the most significant 

advancements for the EB-5 industry has 

been the ability for investors who are in 

the US to file for both their EB-5 visa and 

green card within the US, a change brought 

about by the RIA. Prior to this, such an 

option was not available. This change 

has been particularly advantageous for 

students, individuals on H1B visas, and 

others residing in the US. They can invest 

and, even if it takes the Immigration Service 

several years to process their cases, they 

can still obtain work and travel documents, 

providing them with the freedom to 

travel in and out of the country. This has 

significantly benefited the EB-5 industry. 

What are the current issues 

that are of concern? 

A recent issue that has arisen in the past 

couple of weeks is that the Immigration 

Service released a guidance memo stating 

that, despite previous understanding that 

an EB-5 investment must be sustained 

during the two years of conditional 

residency, they are now interpreting the 

RIA to mean that the entire investment 

period may be only two years. 

However, most projects in the market 

typically require funding for at least 

four or five years or more. This change 

has caused disruption in the industry, 

and we are currently dealing with this 

issue. It is possible that the courts may 

become involved in resolving it since the 

Immigration Service failed to follow the 

required formal regulatory process. 

What impact did the overhaul 

have on processing timeframes 

for EB-5 applications? 

Unfortunately, many of the EB-5 

applications are still taking years to 

process. However, it appears that the 

Immigration Service is expediting the 

processing of projects in rural areas, as the 

RIA specifies giving priority processing 

to such projects. Consequently, we are 

witnessing quicker adjudication of project 

and investor applications in rural areas. 

However, it is not uncommon that the 

processing time of applications for projects 

that are not in these designated areas 

extends to three to five years or more. 

How has the demographic 

composition of EB-5 

applicants changed? 

Initially, under the old programme, there 

was a massive demand from Chinese 

applicants, causing a 10 to 15-year waiting 

period. This resulted in diminished 

demand. However, when the RIA introduced 



reserved visas for investments in rural areas, 

high unemployment areas, or infrastructure 

projects, Chinese investors began flocking 

to this category to avoid the long wait 

times. As a result of this, demand from 

Chinese investors has skyrocketed again. 

Similarly, India has seen an increase 

in demand due to long waiting lists for 

other green card categories like EB-2 

and EB-3 with employer sponsorship, 

estimated to be 30 to 50 years. 

Indian applicants, aware of this, have 

turned to the EB-5 programme, which 

allows them to stay in the US, receive 

work and travel documents, and currently 

offers no waiting list. This has attracted a 

significant number of Indian applicants. 

Apart from China and India, there 

is also notable demand from other 

parts of the world, including Vietnam, 

the Middle East, and Latin America. 

However, the two major pockets of 

demand are clearly China and India. 

What comments can you make 

about the recent changes 

in the Caribbean and their 

impact on US immigration? 

We work a lot with Grenada because 

it operates a citizenship by investment 

pathway and has an investment treaty 

with the US. This treaty allows citizens 

of Grenada to apply for the valuable 

E-2 treaty investor visa, which offers 

several advantages, including a five-year 

issuance with unlimited extensions, 

work authorisation for spouses, and 

educational opportunities for children. 

Many individuals from countries 

like China, India, South Africa, 

Russia, Vietnam, and Brazil, where 

demand for US immigration is high, 

first applied for citizenship in Grenada 

and then obtained an E-2 visa. 

However, a sudden change came 

in December 2022 when the National 

Defense Authorisation Act (NDAA) 

altered the E-2 visa requirements. It now 

mandates a three-year domicile in the 

country granting citizenship through 

CBI. This change was unexpected, 

with no prior discussion or debate. 

This alteration has left affected 

countries, especially Grenada, dissatisfied. 

Legal issues have arisen, including the 

lack of clarity on the definition of domicile 

and questions about the authority 

of the US Congress to modify treaty 

terms between sovereign nations. 

The State Department, while aware 

of the situation, has not yet updated 

US consulates on this new rule. This 

uncertainty has led to mixed outcomes for 

E-2 visa applications, creating a sense of 

hesitancy among potential applicants, even 

though the programme continues to operate. 

Comprehensive immigration reform is a complex issue 

with no easy solutions, and politicians hesitate to tackle 

it due to potential opposition from their constituents. 

One important point you 

brought up earlier is the issue 

of investor confidence, which 

tends to wane during periods 

of policy changes. Could 

you share specific examples 

and insights in this regard? 

Without a doubt, change is generally 

unfavourable for investors in any 

investment programme, even if it’s 

unrelated to migration. What investors 

seek is certainty, preferably with clear and 

timely guidelines. We’ve long advocated 

for this with the US government. 

To illustrate, the new EB-5 law was 

passed in March 2022. Congress set a 240- 

day deadline for issuing regulations, but 

here we are, a year and a half later, with 

no regulations in sight and no foreseeable 

timeline. This lack of regulation creates 

uncertainty because a law might be just 

50 pages, but regulations could span 

400 pages, detailing how the law will 

be enforced. Without these detailed 

regulations, there’s ambiguity, leaving 

lawyers, investors, and developers 

unsure about what the agency expects. 

The same issue arises in other countries 

when they make changes or reconsider 

their programmes. Ultimately, no one 

knows what’s happening or whether 

their decisions might face unexpected 

alterations down the road. This uncertainty 

poses a significant challenge. 

What are your expectations 

for the future of the 

EB-5 programme? 

I tend to be optimistic. However, Congress 

created a five-year regional centre 

programme, that is still not permanent. The 

closer we get to 2027 when the five years 

end, the less viable the EB-5 programme 

will be. So, the key is to secure another 

long-term extension or, ideally, a permanent 

extension before 2026. My crystal ball only 

goes up to about 2026, and I see positive 

developments between now and then. 

Beyond that, it’s uncertain due to the 

complexities of the US political system. 

How does the US compare to 

other countries in attracting 

entrepreneurs and start-ups? 

Traditionally, the US immigration 

system hasn’t been very supportive of 

entrepreneurs, despite the success of 

many immigrant-founded businesses. 

President Obama’s “Entrepreneurs 

in Residence” programme aimed to 

encourage foreign entrepreneurs, but these 

efforts were reversed during President 

Trump’s administration, leading to a 

significant decrease in legal immigration. 

While the Biden administration has 

made some progress, it hasn’t fully 

returned to the Obama-era policies. 

There are positive signs, with recent 

Immigration Service proposals for new 

regulations to make start-up companies 

more eligible for certain visas, particularly 

the H-1B visa. Previously, the Immigration 

Services relied on factors like company 

revenue and CEO salary levels, which aren’t 

suitable for start-ups seeking capital. 

There’s also been discussion about 

assisting STEM (Science, Technology, 

Engineering, and Math) graduates. STEM 

graduates can already receive three years 

of practical training after completing 

their studies, allowing them to work in 

the US without employer sponsorship. 

However, the lack of a clear path to a 

green card can be a problem, especially 

for graduates from countries like India, 

where the green card wait can extend 

to 50 years. We’re aware that other 

countries actively recruit such talent. 

Comprehensive immigration reform 

is a complex issue with no easy solutions, 

and politicians hesitate to tackle it 

due to potential opposition from their 

constituents. This cycle has persisted 

for decades, with universal recognition 

of a broken system but little progress in 

addressing the underlying problems. 

Ronald Klasko is a leading 

BIO US lawyer representing 

treaty investors (E-2) and green card 

investors (EB-5). He regularly speaks 

on investment migration globally and 

is known for pioneering innovative 

immigration solutions. A former 

national President of the American 

Immigration Lawyers Association, he 

chaired AILA’s EB-5 Committee for 

five years. His firm Klasko Immigration 

Law Partners is one of the largest 

immigration law firms in the world and 

is regularly recognized by Chambers 

Global and U.S. News and World Report. 



CBI Interviews Offer In-Depth 

Insights and Reveal Disparities 

Sachit Kumar, Managing Director of Globe Detective Agency (GDA), 

believes personal interviews are an important additional step in 

the due diligence process and help to paint a clearer picture. 

In 2023, Caribbean Citizenship by 

Investment (CBI) units integrated 

personal interviews into their 

application process. This strategic 

decision followed discussions between 

representatives from the United States 

and the Caribbean nations, aimed at 

standardising practices for CBI pathways. 

In conversation with the IM 

Yearbook, Sachit Kumar emphasises the 

significance of personal interviews in 

the due diligence process, considering 

them to be a crucial step in gaining 

comprehensive insights. GDA, with a 

network of vetted associates in over 60 

countries and offices in India and the UK, 

promptly adapted to the new requirement 

by initiating virtual interviews for 

the Caribbean CBI programmes. 

Navigating Discrepancies 

During these interviews, Kumar has 

noted instances where applicants’ answers 

significantly differ from the information 

provided in their initial applications. 

“This underscores the invaluable nature 

of personal interviews in revealing 

nuances that may not surface through 

traditional documentation,” he states. 

While discrepancies in information 

may raise concerns, Kumar is quick 

to point out that they are not always 

indicative of intentional deception. He 

suggests another plausible scenario where 

agents may complete specific sections 

of the application on behalf of clients, 

unintentionally leading to inconsistencies. 

“Therefore, to ensure a transparent and 

accurate assessment, agents are not to 

be present during interviews,” he says. 

Applicants can schedule interviews 

at times and in languages that suit 

their preferences and availability. 

The interview starts with an identity 

verification through facial comparison, 

thereby ensuring that the provided 

photograph aligns accurately with 

the individual’s face and passport 

details. Lasting between 30 minutes 

and one hour, the interview then 

progresses to cover various aspects of 

the applicant’s personal history, family 

details and even sources of funds. 

Challenging Questions 

Some of the more challenging questions 

during the interview process involve 

critical enquiries aimed at verifying the 

accuracy of the provided information. 

“For instance, applicants may be asked 

about the precise location of their 

residence. We had instances where the 

applicants house couldn’t be located by 

our on-ground associates,” says Kumar. 

Addressing the legitimacy of 

employment is another complex area. 

“In some cases, applicants provided 

fictitious employment details, such as a 

non-existent workplace or a dissolved 

company. Consequently, they may be 

asked directly about their work status, 

followed by a request for the precise 

address of their purported place of 

employment,” Kumar explains. 

“These discrepancies may not always be 

deliberate; variations or incompleteness can 

also contribute to the need for clarification. 

In Iraq, for example, house numbers 

are sometimes not displayed, making it 

difficult to locate a residence” says Kumar. 

Delving deeper into the legal realm, 

applicants are then queried about any 

ongoing or past litigation. This line of 

questioning aims to ensure a thorough 

understanding of any civil or criminal 

cases associated with the applicants. 

“Despite initial denials wherein applicants 

claimed no involvement in legal matters, 

we had to clarify with them specific 

cases previously uncovered by our 

investigative professionals,” Kumar says. 

Post-interview, GDA provides the 

CBI unit with a detailed transcript and 

a recording of the interview, ensuring 

transparency and accountability in the 

assessment process. Additional information 

furnished is also verified and an updated 

report is submitted to the CBI unit. 

Advocating Standardisation 

“I believe it’s crucial for all investment 

migration routes to adhere to stringent 

reporting standards and be governed 

by uniform guidelines,” he emphasises. 

Rigorous and dependable due diligence, 

he argues, ensures that CBI remains a 

valuable and legitimate tool for attracting 

investment and fostering economic growth. 

Having a thorough due diligence process 

validates the integrity of a country’s citizenship 

programme, and, most importantly, shapes 

the perceptions of that country in the eyes 

of the international market. “Not only is a 

country’s reputation important in shaping 

its diplomatic relations with other nations 

but is also ultimately a factor in determining 

the ‘strength’ of its passport,” Kumar says. In 

light of this, he concludes that strengthening 

the due diligence process through interviews 

should be a collective pursuit, embraced by 

all nations involved in investment migration. 

BIO 

Sachit Kumar, Managing 

Director of Globe 

Detective Agency (GDA), has 38 

years of experience in the realms 

of investigation, due diligence, and 

security services. He is a member 

of the Council of International 

Investigators (CII), the Investment 

Migration Council (IMC), the American 

Society for Industrial Security (ASIS 

International), the World Association of 

Detectives (WAD), and the International 

Intelligence Network (INTELLENET). 

He has also been the President of CII 

for four years. He plays a pivotal role 

in expanding the company’s global 

presence, currently operational in 60 

countries, with a particular emphasis on 

enhancing due diligence and background 

investigation services catering to 

the investment migration industry. 



The Mindset of an Investor 

Investors are at the heart of investment migration. Entrepreneur 

Dariush Soudi examines the mindset that drives investors 

and sets them up for long-term financial success. 

Investing is a sophisticated financial 

technique thousands of successful 

entrepreneurs use for wealth 

accumulation. However, it’s more 

than a series of financial transactions; 

it represents a strategic approach to 

freedom. It is a deliberate journey wherein 

successful investors don’t merely react 

to market fluctuations; they proactively 

shape their futures to achieve financial 

freedom and the ultimate luxury and 

most expensive commodity in today’s 

fast-paced world: freedom of time. 

My journey as an investor, spanning 

40 years across many different industries, 

coupled with interactions with many 

entrepreneurs, has led me to identify a 

recurring pattern of eight essential qualities 

fundamental to developing the mindset 

required to be a successful investor. This 

mindset is critical as it transforms the act of 

investing from a simple financial decision to 

a strategic and carefully planned process. 

These characteristics focus on having 

a long-term perspective, the importance 

of emotional control in investment 

decisions, managing risk, continuous 

learning, goal setting, being flexible in an 

ever-changing financial landscape, and 

the significance of a strong network. 

Long-term Vision and 

Emotional Discipline 

It is essential to view business as a 

marathon, not a sprint. It is quite common 

for investors who see potential in the 

market to wait years before receiving 

a return on their investment. 

Emotional discipline is crucial here. 

As humans, we are naturally expressive, 

and emotions can be a double-edged 

sword while investing, as there will 

be periods of ups and downs. 

Fear and greed are common pitfalls 

that can lead to irrational and impulsive 

decision-making. It is important to 

remember that business is not personal; 

it is purely about money. Therefore, 

as an entrepreneur, you need to lead 

with your head, not your heart. 

Resilient investors recognise the 

influence of their emotions and ensure that 

logic and analysis, rather than feelings, 

drive their choices. Successful investors can 

handle short-term market volatility because 

they have developed the patience and 

knowledge to capitalise on long-term growth 

potential and avoid erratic decision-making. 

Practical Approaches 

to Investment 

Risk Management involves a thorough 

understanding of potential investment 

risks and is a critical aspect of the 

investor’s mindset, as every investment 

carries some risk. Understanding how 

to assess, mitigate, and welcome risk is 

fundamental. Successful investors analyse 

risk by speaking to industry experts and 

referring to market projections or data. 

Diversifying portfolios and making 

informed decisions rather than succumbing 

to impulsive actions also limit risk. 

Continuous learning means staying 

informed about evolving conditions. The 

financial landscape is dynamic, with 

markets growing and new investment 

opportunities arising every day. Staying 

informed about trends and innovations 

in the financial world allows investors 

to adapt to changing circumstances and 

make informed decisions based on a solid 

market understanding. As a fledgling 

investor, there is no excuse not to learn. 

With the power of the internet, there is so 

much free information available online 

that anyone can learn about a specific topic 

or industry. Educating yourself builds the 

foundation of success in the investing world. 

Realistic and measurable financial 

goals are a crucial component of any 

investment strategy. Whether it’s saving 

for retirement, funding education, or 

achieving a specific level of wealth, having 

clear objectives provides a roadmap for 

decisions and helps maintain focus. I use 

the power of visualisation when defining my 

investment goals; it is a powerful method 

that enables me to plan how to reach them. 

Every day, ask yourself: “What can 

I do today that brings me closer to my 

goal?” This approach guarantees focus 

and a clear path to achieving objectives. 

Adaptability and the 

Value of a Network 

The financial world is dynamic, and 

what worked yesterday may not work 

tomorrow, so investors must adjust 

strategies in response to changing market 

conditions. Being adaptable guarantees 

investment approaches stay relevant 

and practical as climates fluctuate. 

Finally, any credible investor 

understands the value of getting advice 

from financial experts, consultants, and 

mentors. By surrounding themselves with 

experts and knowledgeable professionals, 

investors gain insights, access diverse 

perspectives, resulting in the ability to 

make well-informed decisions. Think 

of a network as being your net worth! 

Just remember: the mindset of an 

investor is a combination of vision, 

discipline, resilience, and continuous 

learning. Beyond mere buying and selling, 

successful investors embody a strategic 

approach that enables them to navigate 

the complexities of the financial markets. 

By adopting these attributes, individuals 

can cultivate a mindset that positions 

them for long-term financial success. 

Dariush Soudi is a serial 

BIO entrepreneur, business 

consultant and motivational speaker. 

He is the CEO of ARENA Capital and 

Consultancy, a private venture capital 

group in Dubai, New York, London and 

Sydney. ARENA Capital has originated 

from his passion for building brands 

and aligning high-performing teams. 



Unpacking Policy Intentions: 

A Closer Look at UK Immigration Changes 

The IM Yearbook sat down with Fragomen’s Nadine Goldfoot to 

uncover the latest shifts in the UK’s immigration system and place 

them in the broader context of global investment migration. 

Immigration has long been a major 

fault line in UK politics. Brexit 

was fought, in part, on the basis of 

controlling the inflow of people, and in 

recent years, the country’s immigration 

system has undergone several shake-ups. 

In early 2023, the Innovator Founder 

visa was launched, offering established 

entrepreneurs the chance to set up 

innovative, viable, and scalable businesses 

in the UK. This visa was intended to 

become the primary entry route for 

entrepreneurs, replacing the now-closed 

innovator and start-up visa categories. 

However, according to Nadine Goldfoot, 

Managing Partner of Fragomen UK, 

it is not always the most preferred 

immigration category for entrepreneurs. 

Innovator Founder Visa: 

Upsides and Downsides 

“There are several pros and cons of this 

new visa,” Goldfoot says. As a positive, 

she highlights the elimination of the 

minimum capital investment requirement. 

“This has been replaced by a need to 

demonstrate a genuine, scalable, and 

viable business proposal, along with 

sufficient funds to execute the plan— 

whether that’s £20,000 or £200,000.” 

Another plus, according to Goldfoot, 

is that sole ownership of the business is no 

longer a requirement; applicants can now be 

part of a team, although each applicant must 

demonstrate a significant contribution to the 

business idea and execution. Additionally, 

the main applicant can engage in secondary 

employment alongside running the 

business, provided it is skilled work. 

The new visa also involves fewer 

check-ins with the endorsing body 

responsible for verifying project scalability 

and viability – generally at the 12- and 

24-months marks. Moreover, an accelerated 

pathway to settlement exists, contingent 

upon evidencing progress in the business. 

“The departure from the previous limited 

options to evidence progress to a wider 

variety on which you can rely, including 

investment, revenue, job creation, expansion 

of customer base and Intellectual Property 

protection, is more reflective of how 

growing businesses operate in practice and 

certainly another plus,” Goldfoot says. 

The challenge, however, lies in 

presenting a completely novel business 

idea with no existing market counterparts, 

a viable structure poised for potential 

growth, and scalability indicative of job 

creation, expanding customer bases, or 

entering new markets. “In my opinion, the 

high threshold regarding innovation is 

challenging to prove and ambiguity about 

the scalability criteria has also deterred 

applicants, which has resulted in a relatively 

small number of applicants,” she says. 

Understanding the Motivation 

for Visa Adjustments 

Commenting on the rationale behind 

the visa changes, Goldfoot highlights 

that there has long been a desire in the 

UK to create more active investment 

that would foster entrepreneurship 

and innovation. However, concerns 

were raised by government that 

the original immigration route for 

entrepreneurs under the Points Based 

System was not being used to launch 

innovative business ideas but rather 

retail and general services. “While 

these applicants met the immigration 

requirements, they were not necessarily 

contributing significantly to the UK’s 

innovation agenda,” Goldfoot notes. 

Recommendations from the 

Migration Advisory Committee 

(MAC) prompted a shift toward the 

Innovator and Start Up visa routes 

intended to encourage such activity. 

However, the original Innovator and 

Start-up routes also posed challenges 

for attaining permanent residency 

(indefinite leave to remain), resulting 

in limited uptake. Consequently, these 

routes were replaced by the current 

Innovator Founder route, which, so 

far, has also seen limited interest. 

Moreover, Goldfoot points out that 

the UK has never actively marketed itself 

as a destination for investment migration 

compared to some other nations, despite 

having routes like the Investor Visa. The 

tightening of regulations around the 

Tier 1 Investor Visa and its subsequent 

closure were primarily motived by 

security and source of funds concerns 

rather than a fundamental shift in policy 

to actively court investment migration. 



Alternative Options 

Fortunately, there are several alternative 

pathways into the UK that do not 

specifically target entrepreneurs but prove 

effective, according to Goldfoot. Individuals 

often opt for the Skilled Worker category, 

especially if a UK entity exists and can 

apply for a sponsor licence. Alternatively, 

the Expansion Worker route can be utilised 

when there’s an established overseas 

entity, allowing individuals to be employed 

by the overseas company to set up a UK 

branch. Either of these routes can apply to 

the owner or majority shareholder of the 

business. For those deeply rooted in the 

tech industry, the Global Talent Visa is a 

viable option. “These alternative routes offer 

simpler ways to enter the UK compared 

to complexities of the Innovator Founder 

visa,” Goldfoot comments. She adds that 

the Innovator Founder visa is frequently 

seen as a final option, pursued only when 

all other avenues have been exhausted. 

“Political Posturing” 

Meanwhile, the UK hit the headlines in 

December 2023 when the government 

proposed a package of measures designed 

to deliver the biggest cut in net migration 

to the UK. These measures are set to take 

effect from spring 2024. “The suggested 

changes took everyone by surprise but are 

not inconsistent with the government’s 

current immigration policy,” says Goldfoot. 

She adds that the Government has 

had a mandate since 2010 to reduce 

net immigration numbers. However, 

figures released in November 2023 

showed that annual net migration to 

the United Kingdom hit a record of 

745,000 in 2022, with many migrants 

now coming from places like India, 

Nigeria, and China instead of the EU. 

“With an election expected in 2024, 

the government is keen to demonstrate 

that it has delivered on its mandate to 

reduce net migration,” says Goldfoot. 

Government’s proposed measures 

include increasing minimum salary 

thresholds to £38,700 from its current 

level of £26,200, removing the right for 

incoming care workers to bring dependents, 

potentially scrutinising graduates who 

have studied in the UK, and reassessing 

the shortage occupation list. This list 

identifies sectors with severe staff shortages 

and thus far allows employers to pay 

migrants only 80% of the going rate. 

Goldfoot believes that the changes 

are likely to disproportionately affect 

certain industries, especially those already 

impacted by Brexit, such as healthcare, 

hospitality, and construction. There 

is also a risk this could lead to wage 

inflation. “The level of the rise in salary 

threshold is quite staggering and raises 

concerns that the government’s attempts 

to lower net migration figures are taking 

precedence to an economic need. Sectors 

who relied on the EU workforce to thrive 

have not had sufficient time to see the 

benefits of grassroots level training yet 

and have relied on sponsoring workers 

in typically lower paying roles, also 

paying the very high government fees 

associated. The impact is that employers 

will also need to increase wages, which 

may simply prove unaffordable and 

exacerbate shortages already felt and 

undermine the progress being made to 

curb inflation,” Goldfoot summarises. 

Trends and Global Shifts 

Turning back to investment migration, 

Goldfoot says the sector is changing, 

partly due to public opinion affecting 

local economies and society. Pressure 

from various levels—local, governmental, 

or international bodies like the EU and 

OECD—has sparked talks about limiting 

these pathways. “But it’s not all negative,” 

Goldfoot says. “I think the current situation 

presents an opportunity for the industry 

to transform, shifting from passive, often 

real estate-based investment solutions 

toward innovation, entrepreneurship, 

job creation, sustainability, and social 

responsibility, all of which can address 

current economic and social needs.” 

One challenge is the assumption that 

commitment to a jurisdiction relies solely 

on physical presence. “We know that in the 

investment migration market, individuals 

are often global citizens with interests all 

over the world and cannot necessarily 

commit to an extensive physical presence in 

a single jurisdiction. Therefore, the industry, 

must illustrate that value, integration, 

and commitment to a jurisdiction can be 

demonstrated through capital investment 

and sharing expertise, talent, skill, and 

guidance, not just physical presence.” 

Both markets and products are evolving 

rapidly and Goldfoot noted an increased 

“regional focus”. She points to the Middle 

East, where the UAE golden visa has played 

a pivotal role in luring talent by offering 

10-year residency to individuals and their 

families, including household staff. This 

move, she says, has significantly opened 

doors to the Dubai market. “Similarly, 

the launch of residency visas in Saudi 

Arabia in 2019 is gradually enabling family 

moves following a similar path,” she adds. 

Across Asia, there is also a revived interest 

in investment migration, particularly in 

Hong Kong, Singapore, and Malaysia. 

As a global law firm and provider of 

immigration services, Fragomen is dealing 

with all facets of global mobility and 

immigration law. Goldfoot passionately 

advocates that investment migration holds 

untapped potential beyond the traditional 

scope, foreseeing its capability to expand 

even further. According to her, highnet-worth 

individuals are increasingly 

exploring retirement-based residency 

options, whereby they leverage passive 

income to meet residency criteria. This 

trend benefits countries like Portugal, Spain, 

Ireland, France, and Italy by attracting 

spending, although restrictions on work 

might limit active economic involvement. 

Moreover, digital nomad visas are 

increasingly available across several 

jurisdictions. Highlighting that aligning 

legislation with tax and labour laws is vital 

for their effectiveness, Goldfoot goes on to 

say that the big question remains whether 

“these temporary arrangements could 

eventually lead to long-term residency.” 

Moment to Redirect 

She believes investment migration 

is here to stay, however, to succeed, 

pathways must pivot their strategies. 

“Shifting from a passive to a more active 

investment approach is crucial, along with 

a continued emphasis on compliance, due 

diligence, and ethical best practices.” 

“Governments also need to enhance 

transparency without compromising 

individual confidentiality. Sharing 

redacted information on fund generation 

and expenditure is paramount.” This, in 

turn, might cultivate heightened public 

endorsement for investment migration. 

Nadine Goldfoot is 

BIO the Managing Partner 

of Fragomen’s UK practice, with 

almost 20 years’ experience in UK 

immigration law. She is considered an 

international authority on investment 

immigration solution globally and sits 

also on the board of the IMC. Goldfoot 

was instrumental in establishing 

Fragomen’s Private Client Practice, 

which provides immigration advice and 

strategies to private clients globally. 



Look for 

a Partner, 

not a Service 

Provider 

Exiger’s Karen Kelly believes 

investment migration programmes 

must seek partners, not mere service 

providers, to navigate the everevolving 

due diligence landscape. 

When Karen Kelly began her 

journey at IPSA International 

in 2008, the field of investment 

migration was on the brink of significant 

expansion. While IPSA initially had a 

broader focus, working for corporations of 

all sizes – from Fortune 100 companies to 

mid-sized and owner-managed businesses – 

across a broad range of industries including 

local, state and government agencies, it also 

started performing due diligence related 

to immigration, citizenship, and visas. 

As one of the industry pioneers, the firm 

also began collaborating with financial 

institutions working with applicants 

to investment migration programmes 

in Canada and the UK. “Looking back 

at that time, I can say that this early 

period marked the foundation for what 

would later become best practices in due 

diligence reports,” says Kelly. “Many of 

those fundamental elements that we 

developed remain in place, albeit with 

some subtle differences, while some aspects 

have expanded over time,” she adds. 

Growing Together 

Around the year 2011, IPSA started working 

directly with governments particularly in 

the Caribbean, and later in Europe. “Our 

work grew because the programmes took 

off, and throughout the years, due diligence 

evolved alongside the investment migration 

industry,” she says. In 2017, IPSA Canada 

was acquired by Exiger. “Then Exiger 

launched its Immigration, Citizenship & 

Visa (ICV) due diligence practice, and we 

continued with that focus on government 

programme due diligence,” Kelly explains. 

Reflecting on the early days, Kelly 

acknowledges that over the years, many 

Citizenship by Investment (CBI) units have 

significantly enhanced their understanding 

and expertise in due diligence. Moreover, 

she says the level has been taken up 

another notch in recent months. 

In many countries, CBI staff have 

undergone comprehensive training in 

anti-money laundering and countering 

terrorism financing. CBI units have been 

restructured on the advice of external 

compliance experts to ensure that all 

procedures are updated, and that rigorous 

quality control is strictly adhered to. 

While Kelly acknowledges that part of 

this dedication to training and development 

came in response to international pressure, 

she also emphasises that critics often 

speak of due diligence as if nothing had 

been done before, “but that’s far from the 

truth.” When examining the Caribbean 

CBI programmes, she noted “a profound 

dedication” to due diligence. “This 

commitment starts at the leadership level, 

which is crucial within an organisation. 

They are motivating their staff to grasp 

due diligence and undergo training.” 

Exiger has responded to this need, 

and a significant part of its work with CBI 

programmes today consists of training due 

diligence staff in government agencies. “We 

offer updates or refreshers to new staff, 

helping them build their internal capacity 

and grow their team. This approach ensures 

that everyone starts from a baseline level 

that is greatly improved over where it was 

10 years ago, for sure, and even five years 

ago. So yes, the commitment to training 

and learning is evident,” she says. 

A Close Relationship 

Kelly says that the relationship between 

investment migration programmes and due 

diligence providers has significantly evolved 

over the years. Due diligence firms are no 

longer mere service providers. “There is a 

mutual understanding that this is a genuine 

partnership. It only works when both parties 

share a commitment to raising standards. 

The programmes depend on us to meet 

their requirements and they appreciate 

our transparency and honest advice. 

So, I believe that the term ‘partnership’ 

accurately describes our current dynamic.” 

Kelly also emphasises that this 

partnership extends to addressing the 

challenges investment migration faces 

in the United States and the European 

Union. “Government units often find 

themselves in a position where they need 

to provide informal responses or describe 

the actions of their due diligence partners 

to other countries or international bodies. 

We have well-established methodologies 

and standards in place, and we are more 

than willing to share those details. This 

helps them effectively demonstrate 

the diligence of their partners.” 

While due diligence companies 

like Exiger do not handle the entire due 

diligence process, with programmes 

also incorporating additional 

information gathered through domestic 

or international law enforcement and 

intelligence agencies, “we know we are 

an important part”, says Kelly. “We 

want to give them all the ammunition 

they need for a successful dialogue with 

these international parties,” she adds. 



Tailored Training 

Exiger leverages subject matter experts to 

provide training on a wide range of topics 

relevant to due diligence based on its clients’ 

requests. Introductory sessions for new 

employees cover the fundamentals of due 

diligence, including understanding its key 

components and recognizing potential 

red flags. Exiger also offers training 

specific to the cultural context of due 

diligence in various regions or countries. 

“We help participants understand 

how certain factors may raise red flags 

in the Middle East, for example, but 

not necessarily in the US. This training 

underscores the significance of considering 

cultural factors and their impact on the 

interpretation of due diligence results,” Kelly 

explains. Training sessions also cover the 

availability of information, which can vary 

significantly from one country to another. 

“For instance, the absence of findings 

about a failed business might be due to 

the fact that bankruptcy isn’t recognised 

there. However, most individuals wouldn’t 

be aware of these nuances. So, our subject 

matter experts focus on highlighting 

the distinctions between jurisdictions 

to enhance understanding,” she says. 

Advanced Course 

Exiger also offers a comprehensive fourday 

advanced training course, which 

serves as a unique forum for programme 

practitioners involved in reviewing 

applicant due diligence. CBI unit staff and 

officers engage in extensive discussions 

and mutual learning about due diligence. 

“Participants can share their own 

experiences, focusing on general 

insights without disclosing confidential 

information. This collaborative 

environment allows attendees to learn 

from one another in terms of their 

approach to due diligence. Since not 

everyone approaches this process the 

same way, and different programmes 

have distinct procedures, this exchange 

of knowledge is invaluable,” says Kelly. 

A significant part of this training 

involves case studies with hypothetical 

due diligence and applicant profile 

scenarios. Attendees of the course, 

grouped with colleagues from other 

programmes, then analyse the 

case. They discuss what they find 

most relevant, what questions they 

would ask to mitigate risk, and how 

they would summarise or present 

the risk to a decision maker. 

“This exercise provides intriguing 

insights as attendees often have varying 

perspectives. It’s not because one 

person is taking it more seriously than 

another, but rather because different 

individuals have different preferences 

for the depth of questioning. Some 

may want to ask more questions, while 

others feel they have all the necessary 

information in front of them to make an 

assessment. This unique opportunity 

benefits the programmes we collaborate 

with, enabling their participants to 

bring this newfound knowledge and 

practical experience back to their teams 

to share and engage in meaningful 

discussions with their colleagues.” 

Be More Critical 

Despite the improved understanding of 

due diligence by CBI units, Kelly identifies 

areas for further enhancement. “In my 

experience, one of the questions that programs 

should pose more frequently, and I would 

appreciate being asked more, pertains to 

methodology. While due diligence providers 

may assert their ability to perform a service, 

it is crucial to request a comprehensive 

explanation of their methodology from 

inception to completion,” advises Kelly. 

She highlights that, at times, buzzwords 

like “monitoring” are used without specifying 

the details. Consequently, she recommends 

that CBI staff pose specific questions related 

to scope, such as: What data, precisely, 

is monitored? What is the threshold for 

information to be reported? How frequently 

is it conducted? Is a quality assurance 

process in place? “These enquiries empower 

programmes to acquire a deeper understanding 

and refrain from merely accepting surfacelevel 

assurances,” she explains. 

She emphasises that there’s no need to 

hesitate when asking such questions. A due 

diligence partner should seamlessly integrate 

into the CBI team, becoming an extension rather 

than a distant outsourced provider. “Reputable 

due diligence providers should readily engage 

in open discussions and willingly share their 

methodologies. In essence, this dialogue not 

only enables programmes to establish elevated 

standards but also motivates providers to align 

with and meet those standards,” she concludes. 

Karen Kelly is Vice President, 

BIO Commercial Markets, based 

in Exiger’s Toronto office, where she 

focuses on supporting enterprise 

account relationships and leading 

Exiger’s Immigration, Citizenship, & 

Visa (ICV) strategy. She has 15 years 

of experience managing the delivery 

of due diligence solutions to leading 

investment migration programmes, 

financial institutions, and corporations. 

She is a Project Management 

Professional (PMP) and a Certified Anti- 

Money Laundering Specialist (CAMS). 



Rising Opportunities in Emerging Markets 

Emerging markets hold significant potential for new citizenship 

and residency pathways, as countries seek to attract investment and 

entrepreneurial talent, says Michael Waechter, Director of Abode Options. 

The UAE has transformed into 

a financial hub for the Middle 

East and Central Asia, drawing 

expatriates in droves in the process. 

In fact, expats have been pivotal in 

constructing and populating the UAE, 

which, in 1980, accommodated only 

one million people compared to today’s 

thriving community of 9.5 million. 

Meanwhile, Dubai, the UAE’s bustling 

business epicentre, has transcended its 

origins as a modest trading outpost to 

emerge as one of the globe’s most iconic 

cities. It is also home to Abode Options, 

an immigration and citizenship-byinvestment 

firm that was established in 

the UAE to empower global citizens. 

Over the years, the firm has helped 

500 clients in obtaining citizenship or 

residency across 14 different countries. 

It has expanded its footprint beyond the 

UAE, branching out to India, Kenya, 

Seychelles, and the United Kingdom. 

Michael Waechter, Abode Options’ 

Director, says his clients are int‐erested in 

Caribbean countries such as Dominica and 

St. Kitts & Nevis due to their favourable 

tax regimes, relatively low investment 

requirements, fast-track processing 

and visa-free travel to many countries. 

Likewise, European countries, such 

as Portugal, Greece, and Spain, have 

gained popularity given their attractive 

lifestyles, access to quality education 

and healthcare, and potential paths to 

citizenship after obtaining residency. 

UAE is in Demand 

However, according to Waechter, 

investment migration has recently made 

its mark in the Middle East. “In the 

past few years, the UAE has emerged 

as a sought-after destination following 

the introduction of the Golden Visa, 

offering compelling benefits such as 

lucrative business prospects, investment 

opportunities, and strategic access 

to global markets,” he remarks. 

Investment migration remains a 

relatively new concept in the Middle 

East. The UAE initially introduced the 

UAE Golden Visa in 2019, subsequently 

revamping it in 2022 to enhance 

accessibility and affordability. 

This programme aims to grant 

long-term residency to foreign nationals, 

enabling them to reside, work, or 

pursue education in the UAE while 

enjoying exclusive advantages. The 

visa can be extended for 5 or 10 years, 

depending on specific categories. 

There are several pathways to 

qualify: investors can meet the criteria 

by investing AED 2 million in a UAEaccredited 

investment fund or by 

possessing a commercial licence with a 

minimum of AED 2 million in capital or 

demonstrating payment of at least AED 

250,000 in annual government taxes. 

Real estate investors with properties 

worth AED 2 million can secure a renewable 

5-year visa. Entrepreneurs with innovative 

projects valued at AED 500,000 can 

obtain a 5-year visa, while there are also 

options for highly qualified professionals. 

“The UAE’s residency pathways stand 

as an immensely appealing choice for both 

individuals and families seeking to relocate 

to a vibrant, cosmopolitan nation renowned 

for its high quality of life. Its inclusive 

eligibility criteria cater to a diverse array of 

applicants, reflecting the UAE government’s 

dedication to enhancing the programme’s 

appeal. The country’s exceptional standard 

of living and thriving economy position it as 

an ideal destination for both residency and 

professional pursuits,” Waechter explains. 

Additionally, Waechter highlights the 

increasing interest among crypto investors 

in investment migration due to its capacity 

to diversify portfolios, access favourable 

tax structures, and offer heightened 

mobility and flexibility. “The UAE is also 

among the destinations that pique the 

interest of crypto investors, along with 

Portugal and Malta,” Waechter notes. 

A Changing Landscape 

However, he observes that increased 

regulatory scrutiny, programme alterations, 

and suspensions consistently present new 

opportunities and challenges for both 

investment migration clients and businesses. 

Businesses that remain adaptable 

amidst these changes are better positioned 

to thrive in this burgeoning market. An 

effective approach involves offering clients 

supplementary services. “Enhancing the 

allure of the investment migration journey 

can be achieved by delivering tailored 

support throughout the entire process. 

Businesses can extend their offerings to 

include services such as tax planning, 

wealth management, and family office 

services. Additionally, streamlining the 

application process, ensuring transparency 

in costs, and emphasising exceptional 

customer service are crucial,” he advises. 

Moreover, Waechter highlights 

the substantial benefits the investment 

migration market can reap from embracing 

digital transformation. Utilising technology 

to streamline procedures, elevate client 

interactions, and enhance overall efficiency 

can greatly impact the industry. 

Expanding Horizons 

Abode Options aims for significant 

global expansion in the coming years. 

This strategy involves establishing a 

presence in various emerging markets 

and fostering partnerships with local 

firms to cater to a broader clientele. As 

pathways in Europe and the Caribbean 

undergo modifications, “emerging markets 

hold promise for introducing fresh 

citizenship and residency programmes 

aimed at attracting investments and 

entrepreneurial talent,” Waechter adds. “I 

firmly believe in the continuous growth 

of the investment migration industry in 

the years ahead, and I am committed to 

adapting our firm to meet the evolving 

needs of my clients,” he concludes. 

BIO 

Michael Waechter is an 

experienced entrepreneur 

who started several ventures and 

turned them into successful companies. 

His ventures cover different industries 

and locations, including the UAE, 

Singapore, Philippines, Seychelles, 

Myanmar and Switzerland. 



Navigating Austria’s 

Merit-Based Citizenship 

Stefan Pacher from Austrian law firm Wolf Theiss contends 

that Austria’s merit-based pathway to citizenship stands as 

a genuine alternative to citizenship by investment. 

Austria, distinct from traditional 

citizenship-by-investment 

pathways, offers a merit-based 

route to citizenship through exceptional 

achievements. Governed by the Austrian 

Citizenship Act (Staatsbürgerschaftsgesetz), 

this pathway establishes unique 

conditions for individuals to acquire 

Austrian citizenship and consequently 

obtain an EU passport. This article 

serves as a comprehensive guide for 

immigration professionals, emphasising 

the programme’s merit-based nature. 

Granting Citizenship for 

Exceptional Achievements 

Under section 10(6) of the Austrian 

Citizenship Act, individuals may receive 

Austrian citizenship based on exceptional 

achievements they have demonstrated and 

are expected to continue demonstrating in 

the future. This grant is made if it aligns 

with the interests of the Republic of Austria. 

While the law doesn’t provide 

precise definitions for the terms used, 

generally, individuals such as sports 

personalities, renowned artists, 

entrepreneurs, and philanthropists have 

successfully utilised this provision. 

It is up to the Federal Government 

of Austria to confirm whether the 

naturalisation of a foreigner is in the 

particular interest of the Republic of Austria 

due to the exceptional achievements of 

the applicant. The government holds 

substantial discretion in determining 

whether an applicant’s case meets 

the specified criteria. Their decision 

is final and not subject to appeal. 

Guidelines for Exceptional 

Achievements 

To enhance clarity and transparency in 

evaluating exceptional achievements 

aligning with Austria’s interests, 

the Federal Government has issued 

guidelines. These guidelines aim to 

define extraordinary accomplishments 

as those significantly exceeding average 

standards. Furthermore, an individual is 

never naturalised “in lieu of honour”. 

Outlined below are the Federal 

Government’s criteria for assessment: 

• Scientific Contributions: Involvement in 

pioneering research or advancement of 

existing scientific domains, especially 

benefitting Austria. This includes 

international recognition and a high 

standing in the scientific community, 

substantial publications, and the 

transfer of knowledge to Austria. 

• Business Contributions: Holding 

influential positions or ownership 

in companies with high economic 

performance, job creation and 

investment in Austria, fostering 

international recognition, and 

strengthening economic relations. 

• Sports Achievements: Demonstrating 

exceptional performance unmatched 

by Austrian athletes, maintaining 

outstanding performance for at least 

a year, with potential for sustained 

success and immediate inclusion 

in an Austrian national team. 

• Artistic Contributions: Making 

significant artistic contributions 

in Austria, contributing to art 

education, enhancing Austria’s 

artistic reputation globally, attracting 

audiences through outstanding work, 

and innovating artistic forms. 

While these guidelines concentrate on 

science, business, sports, and the arts, 

it’s important to note that exceptional 

achievements in other domains, such as 

philanthropy, are also acknowledged. 

General Criteria 

In addition to exceptional achievements, 

specific naturalisation requirements apply 

universally. These encompass integrity, no 

adverse impact on Austria’s international 

relations, a positive attitude towards 

Austria, and no active residence ban. 

Of note, applicants under section 10(6) of 

the Austrian Citizenship Act aren’t required 

to renounce their foreign citizenship(s) or 

prove proficiency in the German language 

or knowledge of Austrian history. 

The procedure is quite technical 

and consists of several steps. Due to the 

fact that each case is unique, there is no 

timeframe until an applicant can obtain 

Austrian citizenship via this route. Usually, 

the entire process spans one to three 

years. It should also be noted that the 

names of applicants are not published. 

In conclusion, the Austrian Citizenship 

Act offers a unique and merit-based 

pathway to Austrian citizenship and an EU 

passport that differs widely from traditional 

citizenship-by-investment programmes. 

This pathway offers an intriguing option 

for individuals such as high-net-worth 

individuals (HNWIs), renowned athletes, 

globally acclaimed artists, and scientists 

seeking Austrian citizenship based 

on their exceptional contributions. 

BIO 

Stefan Pacher joined Wolf 

Theiss in 2019. He focuses on 

private clients and regularly advises 

HNWIs on obtaining Austrian residence 

titles and citizenship. In addition, he 

assists clients in tax matters, especially 

when moving to or from Austria. Stefan 

Pacher is also co-author of the “Vienna 

Survival Guide for Tax and Law”, 

a comprehensive English-language 

guide for new residents in Austria. 



Discovering the Hidden Charms of the 

Cayman Islands 

Nestled amidst the Caribbean’s splendor, the Cayman Islands beckon 

not just as a tourist haven but also as a realm of exclusive advantages 

for those seeking high-quality living. Kristy Rivers discusses the 

prospects of attaining permanent residency on these islands. 

It’s no secret that the Cayman Islands is 

an idyllic tourism destination boasting 

remarkable natural beauty with its white 

sandy beaches, crystal-clear turquoise 

waters and gorgeously diverse flora and 

fauna. Yet, beyond its tourist charm lies 

an enviable lifestyle that residents savour, 

characterised by exceptional advantages 

that make living on the islands a privilege. 

One of the foremost draws is the 

Cayman Islands’ tax-neutral system that 

exempts individuals from paying income 

tax on earnings or recurring property taxes 

on purchased real estate. “Additionally, 

as a tax-neutral jurisdiction, there is no 

company or corporation tax, inheritance 

tax, capital gains or gift tax,” says Kristy 

Rivers, Vice President of Business 

Development and Leasing for Dart. 

Dart is the largest real estate 

developer in the Cayman Islands with 

over US$1.5 billion invested in residential, 

commercial, office and hospitality ventures 

on the islands. It also owns Provenance 

Properties, the official Cayman Islands 

affiliate of Christie’s International 

Real Estate, a by-invitation-only global 

network of luxury brokerages supported 

by the art auction house. Provenance 

is the exclusive brokerage for Dart’s 

properties. This affiliation also grants 

Provenance access to in-house data 

analysts, providing in-depth market 

statistics and the latest real estate trends. 

Routes to Residency 

Situated about 280km northwest of 

Jamaica, the Cayman Islands are a British 

Overseas Territory in the Caribbean Sea 

consisting of three islands: Grand Cayman, 

Cayman Brac, and Little Cayman. The 

primary hub is Grand Cayman, especially 

the capital, George Town. There are 

multiple potential routes to permanent 

residency, including business ownership 

and substantial economic investment. 

“The simplest and quickest path to 

permanent residency in the Cayman Islands 

is through the purchase of developed 

real estate valued at US$2.4 million or 

higher,” says Rivers. “The Cayman Islands 

might not be the cheapest or easiest 

residency option, but we offer substantial 

value once you qualify,” she adds. 

Beyond financial benefits, residents 

enjoy access to quality healthcare 

and education, a sophisticated 

telecommunications infrastructure, worldclass 

shopping, dining and entertainment, 

a stable government with a judicial 

system based on English common law, 

and a healthy, stable economy with a 

renowned financial services industry. 

“The islands also boast a safe environment 

with a low crime rate and convenient 

air connectivity to major cities like 

New York and London,” says Rivers. 

Real Estate Trends 

Interest in residency primarily comes 

from high-net-worth individuals, ultrahigh-net-worth 

individuals, and young 

professional families seeking a diverse 

cultural experience. Provenance’s sales 

team has witnessed a marked rise in 

queries regarding residential real estate, 

particularly from those exploring avenues 

for residency through investment. 

There’s a noticeable trend towards 

sustainable living, with growing 

demand for eco-friendly waterfront 

properties, with high-end amenities that 

include the latest smart home features, 

fully-equipped guest dwellings, builtin 

solar arrays, private beaches and 

easy access to a boating lifestyle. 

On the commercial front, businesses 

are gravitating towards Class-A office 

spaces in modern developments that 

prioritise employee perks, integrating 

diverse amenities like retail outlets, 

dining options, entertainment venues, 

schools, and healthcare facilities. 

Meanwhile, the islands’ economy 

is thriving. While sectors like tourism 

and construction have recovered from the 

pandemic’s impact, others like financial 

services and healthcare are expanding. 

The Cayman Islands are also embracing 

emerging technologies like fintech, crypto, 

and blockchain, positioning themselves as a 

fertile ground for technological innovation. 

This prosperity has contributed to a notable 

population surge, with numbers growing from 

58,000 in 2013 to 84,000 in June 2023. This 

influx has also driven up real estate prices. 

“We expect an increased interest in achieving 

Cayman Islands residency due to the many 

attractive options available to individuals with 

means,” says Rivers. She advises seizing the 

opportunity while prime real estate remains 

accessible, acknowledging the finite availability 

of these coveted properties on the islands. 

Kristy Rivers is Vice President 

BIO of Business Development and 

Leasing for Dart. With her diverse team 

of experienced commercial leasing 

representatives, business development 

professionals and luxury sales 

specialists, she assists businesses and 

individuals who are seeking knowledge 

and expertise while relocating to 

or within the Cayman Islands. 


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With over 5,000 investment migration families 

served, we must be doing something right. 

Contact our Investment Migration product & 

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Laferla Insurance Agency Ltd (C14529), “LIA”, is enrolled under the Insurance Distribution Act, Cap 487 to act as an 

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The leader of the global investor immigraaon 

industry for four decades. 

For more informaaon visit ciu.gov.kn



St Kitts and Nevis: 

A Trusted Innovator 

St. Kitts and Nevis champions sustainability 

through investment migration, setting a high 

standard for future-focused development. 

Global citizens looking for a country 

they can trust on sustainability, 

transparency and innovation 

have the ‘ gold standard’ in St Kitts and 

Nevis. The island continues to innovate 

while also prioritising the integrity 

of its pioneering CBI programme. 

St Kitts and Nevis was the first 

citizenship by investment (CBI) 

programme. A past, present, and future 

leader and pioneer in the industry, the 

country boasts some of the strongest due 

diligence requirements in the world. 

The programme’s illustrious history 

was featured in the Financial Times’ 

CBI Index, released in September. 

It ranked first in the index. 

“The St. Kitts and Nevis Citizenship 

by Investment Programme epitomises 

excellence in the realm of CBI. 

Earning accolades and the title of 

being ‘The First and The Finest’ of 

CBI, this programme boasts over 39 

years of history,” the report noted. 

The report gave St. Kitts and 

Nevis top marks on due diligence. 

St Kitts and Nevis Prime Minister Hon. 

Dr Terrance Drew outlined the current 

state of the programme, emphasising 

“upgrade[s]” to the programme that 

have continued to reassure the United 

Kingdom, European Union, and other 

international partners of due diligence. 

Sustainable Island Vision 

CBI contributions to the island’s 

Sustainable Island State Contribution 

help the nation achieve its Sustainable 

Island State vision by 2040. 

Global citizens can join in on this 

innovation through investing in St Kitts 

and Nevis’ Sustainable Island State 

Contribution, along with the country’s 

public benefit option, real estate option 

and private home sales option. 

Michael Martin, head of the country’s 

Citizenship by Investment Unit (CIU), 

noted that “for four decades, we have 

crafted solid, innovative, and sustainable 

investment solutions through our 

Citizenship by Investment Programme.” 

Pointing to additions to the 

programme, such as requiring investors 

to have a mandatory interview and 

creating the Sustainable Island State 

Contribution, Martin noted that the 

programme is “filled with integrity, 

transparency and accountability.” 

“We take a measured and 

considered approach to everything 

we do,” he maintained. 

Innovation Path 

The Sustainable Island State vision is 

leading the country on a path of cuttingedge 

innovation: from moving towards 

sustainable geothermal and solar energy 

production, to modernising governmental 

apparatuses to suit a more digital age. 

Prime Minister Drew also spoke before 

the United Nations General Assembly, 

advocating the country’s future-facing vision 

for sustainable development and justice. 

Turning away from divisive and 

unstable politics, the Prime Minister 

emphasised the importance of 

creating an inclusive, collaborative 

geopolitical environment. 

“In a world of distrust, the United 

Nations and its member states must 

show a sense of caring, inclusion, 

respect for the dignity of all,” he said. 

Use of CBI Funds 

St Kitts and Nevis also has a strong 

economy with an innovative policy towards 

health and education. CBI funds go to 

preserving its healthcare and educational 

programming for future generations. 

For example, the country has promoted 

public and private sector stakeholder 

relationships to invest in health; 

notably, the country has implemented 

“We stand at the juncture of ‘what is’ and ‘what 

could be’. We know what is. We understand what 

could be. Ours is the challenge to ensure peace, 

prosperity, progress, and sustainability for all.” 

Dr Terrence Drew, 

Prime Minister of St. Kitts and Nevis 

a National Sport Policy to encourage 

physical activity for its youngest citizens. 

The Commonwealth Secretariat 

is supporting St Kitts and Nevis 

in its National Sport Policy. 

A spokesman for the Commonwealth 

Secretariat said, “we believe St Kitts 

and Nevis can become a model for 

other Commonwealth countries on 

how to effectively harness the power of 

sport for development and peace.” 

A proud supporter of women’s rights, the 

country also worked with the Commonwealth 

Secretariat to study and promote women’s 

engagement in politics in the Caribbean. 

CBI funds also go to improving education 

on the island, helping future Dominicans 

thrive. They contribute to building 

schools, while also funding programmes to 

preserve the island’s culture and history. 

According to a 2023 Freedom 

House report, the country offers free 

and fair elections along with a free and 

independent press. The country also 

is politically pluralist, with a robust 

opposition and regular changes of power. 

St Kitts and Nevis is a well-connected 

country to watch, especially for global 

citizens with an interest in innovation. 

The country prioritises sustainability in 

the present and continues to devise futurefacing 

solutions to the world’s problems. 

As the Prime Minister said in his UN 

speech: “We stand at the juncture of ‘what 

is’ and ‘what could be’. We know what is. 

We understand what could be. Ours is 

the challenge to ensure peace, prosperity, 

progress, and sustainability for all.” 




Dominica: 

The Country that 

Bounces Back 

Dominica’s resilience in the face of global challenges 

and its commitment to sustainable development 

shine through its Citizenship by Investment 

(CBI) pathway, offering investors a gateway to a 

dynamic, environmentally conscious nation. 

Some countries fall flat in the 

face of global challenges and 

environmental inequalities. Not so 

for the Commonwealth of Dominica: the 

country’s message of climate resilience 

in the face of natural disasters goes 

hand-in-hand with its irrepressible 

economic growth and diversification. 

Investors can aid this mission 

through CBI, gaining citizenship of an 

environmentally conscious nation with 

commitments to sustainable development. 

Dominica launched a mission to become 

the world’s first climate-resilient nation. 

To achieve this goal, the country utilises 

citizenship by investment (CBI) to reinforce 

its energy, infrastructure and economy 

against the impact of climate change. 

Sustainability Leader 

Dominica’s climate resiliency initiatives 

have made it the sustainability capital 

of the Caribbean. The country also has 

sustainably built bridges, roads, and an 

international airport, further supplementing 

its growing ecotourism industry. 

A trend-setter in the Caribbean region, 

Dominica’s economic diversification 

has attracted the attention of investors 

and world leaders alike. Though the 

enhanced global attention has only 

strengthened Dominica’s commitment 

to tough due diligence processes 

for potential CBI applicants. 

At the US-Caribbean Roundtable, 

Dominica agreed to six principles held in 

common with other Caribbean nations with 

CBI programmes. These principles further 

strengthened Dominica’s already tight due 

diligence requirements, adding another 

layer to its multistep due diligence process. 

Dominica was the first Caribbean 

country to make interviews mandatory 

as part of its CBI process. Other 

signatories of the six principles followed 

on Dominica’s heels in implementing 

these interview processes. 

Dominica’s employment and 

sectoral development programme are 

also helped along by CBI programmes. 

The National Employment Programme, 

for example, gives Dominicans on-thejob 

training to improve their skills. 

The National Digital 

Transformation Strategy fosters 

sectoral innovation and modernisation 

to unleash ‘Dynamic Dominica.’ 

Clean Energy 

Energy is one plank of the country’s 

Dynamic Dominica initiative, 

which aims to continue present 

efforts to diversify the economy. 

A leader in clean energy, Dominica is 

developing a geothermal plant to provide 

clean energy not only for the country 

but also for neighbouring countries. The 

country is working with the University 

of the West Indies on geothermal 

mapping for sites across the island. 

Dominican Prime Minister Hon. 

Roosevelt Skerrit emphasised that 

“geothermal energy can provide much 

more than just electricity for Dominica; 

it can be the catalyst for investments 

in the development of green hydrogen 

and ammonia production for export.” 

He added that “byproducts 

[of geothermal energy] can 

support investments in health and 

wellness centres, in aquaculture, 

greenhouses, agro processing 

and many other businesses.” 

Geothermal energy only adds to 

the country’s green energy credentials; 

Dominica already has a hydro 

power plant, with another unit to be 

online by the end of this month. 

Another plank of Dynamic Dominica 

is infrastructure. The country is 

building 5,000 climate-resilient houses 

to withstand natural disasters, while 

reinforcing existing houses. These 

homes are funded with CBI reserves. 

Roosevelt Skerrit, 

Prime Minister of Dominica 

Ecotourism Initiatives 

CBI also aids Dominica’s vibrant 

ecotourism offering, propelling a 

sector that keeps Dominica’s economic 

growth and diversification going. 

“We are continuously improving our 

sites and attractions and creating more 

opportunities for Dominicans,” Skerrit 

maintained in his address. “Dominica now has 

four five-star hotels, and four more are under 

construction, in Salisbury, Portsmouth, the 

Roseau Valley and at Loubiere,” he added. 

The country’s sprawling national 

park system, supplemented by protected 

marine parks and eco-hotels, led the 

country to be the first in the world to be 

officially benchmarked by Green Globe. 

Green Globe, a rating and certification 

system, certified Dominica as an ecotourism 

destination meeting its stringent community 

standards in sustainable tourism. 

Dominica’s Morne Trois 

Pitons National Park is a protected 

UNESCO World Heritage Site. 

In a national address, Skerrit described 

the island’s response to an existential 

“climate crisis, originating from actions 

elsewhere, but having devastating 

impacts on our islands in the region.” 

Skerrit also emphasised the importance 

of future-facing economic development, 

including risk assessment for climate-induced 

natural disasters. CBI funds go directly to 

aiding Dominica’s sustainable economic 

development and to minimising climate risk. 

“We all know life is complex, fast moving, 

difficult to predict or plan for, and high risk for 

island states like Dominica, with our small, 

open and vulnerable economies,” he said. 

Innovation, sustainability, modernisation, 

and economic diversification. This is 

what Dominica is capable of, enhanced 

and supplemented by CBI funding. 

Dominica presents a compelling choice 

to investors seeking a second citizenship 

from a resilient, dynamic country. Despite 

global challenges, Dominica bounces back. 


Belong to the Best, Invest in Dominica 

A sustainable investment for a resilient future 

Visit cbiu.gov.dm

Creating Unequalled Opportunities 

For Global Citizenship 

WHO WE ARE 

Abode Options was established with the 

aim of enabling high net-worth individuals 

& families to acquire second citizenship to 

unlock global opportunities for investing, 

banking, business formation and expansion 

in countries that were previously not 

accessible. Our team meticulously engage 

themselves in analysing various citizenship 

programs to assist clients and provide 

them tailored options. 

A solution that works for each client in the 

real sense, not theory. 

WHAT WE OFFER 

Our Services 

Citizenship By Investment 

Residency By Investment 

Portfolio Diversification 

Corporate Services 

Consulting 

Citizenship by 

Investment 

Programs 

Dominica 

Saint Lucia 

St. Kitts & Nevis 

Grenada 

Antigua & Barbuda 

Turkey 

Vanuatu 

Residency by 

investment 

programs 

Portugal 

Spain 

Hungary 

Greece 

Germany 

Tax Planning 

Offshore Banking 

Legal & Compliance 

Estate Planning 

You Aspire, We Deliver! 

www.abodeoptions.com 

Info@abodeoptions.com 

+971551859971 

+97144069658 

Visit our website


Unlocking Prosperity: Why 

Behavioural Sciences Matter 

in Investment Migration 

Sibylla Verdi and Davide Petroni explore the profound impact of trust, 

immigration, and behavioural insights on economic prosperity. 

The field of Behavioural Sciences has 

made significant progress over the 

years and has offered important 

insights into our understanding of human 

behaviour. This discipline focuses on 

the scientific study of human behaviour, 

emotions, and cognitive processes, 

providing valuable insights into how 

people make decisions, interact with each 

other, and adapt to their surrounding 

environment. One of the most evident 

successes of behavioural sciences has 

been their impact on public policies, 

economics, law, and many other fields. 

For example, behavioural economics 

has led to a better understanding of how 

people make strategic decisions and has 

suggested ways to improve the effectiveness 

of public policies in areas such as savings, 

health, mobility, investments, and social 

security. Furthermore, research in the field 

of social psychology has contributed to a 

better understanding of group dynamics, 

discrimination, prejudice, and strategies 

for promoting diversity and inclusion. 

All these factors come into play 

when thinking about our ever-increasing 

globalised economy and the need for an 

expansion of investment migration. 

Behavioural sciences can provide 

solutions to the many questions of 

how to communicate and create 

benefits for the individual, the host 

country, and wider society in an 

increasingly interconnected world. 

Nobel Prize-Winning 

Contributions 

These Behavioural Science contributions 

have been honoured through several 

Nobel Prizes awarded to researchers who 

have investigated and applied behavioural 

insights, including psychologists Daniel 

Kahneman and Amos Tversky, as well as 

economists Robert Shiller and Richard 

Thaler. One of the most appreciated features 

of behavioural sciences is the ability to offer 

research paradigms that are elegant and 

simple, yet capable of shedding light on 

aspects of human nature that explain complex 

economic and social phenomena. One of the 

most ambitious challenges is to understand the 

mechanisms that contribute to the material 

and emotional well-being of individuals and 

communities. In summary, understanding 

the socio-cognitive processes underlying the 

prosperity of individuals and countries. 

This ambitious goal is addressed by 

a research paradigm that was devised 

and then formalised in the middle of 

the last century by Merrill M. Flood 

and Melvin Dresher of the US Rand 

Corporation research centre to investigate 

a phenomenon that mirrors collective 

prosperity: the risk of nuclear catastrophe. 

Referred to (not so brilliantly) as the 

“Prisoner’s Dilemma,” it has become one 

of the classic paradigms of game theory, 

fundamental in modelling and understanding 

an enormous variety of behavioural 

phenomena in multiple disciplines, from 

economics to politics, ethics to engineering, 

and even theories of both biological and 

cultural evolution of the human species. 



Game Rules 

Let us therefore briefly and very plainly 

illustrate this game. You are placed 

standing in front of a stranger with your 

hands behind your back. You are now told 

that the goal for each of you is to obtain the 

maximum gain for yourself individually 

(in keeping with the fundamental 

individualism of human nature). The 

task for both consists of deciding whether 

to display the right hand to the other 

with an open palm or closed palm. Both 

players must engage in this action in 

a simultaneous fashion. The possible 

economic outcomes for this scenario are 

four. If you both show your open hand, you 

will each get $1,000. If you show an open 

hand and the other shows a closed hand, 

you will lose $2,000 and the other gains 

$2,000. Conversely, if you show a closed 

hand and the other shows an open hand, 

you gain $2,000 and the other loses $2,000. 

Finally, if you both show a closed hand, 

you both lose $1,000. The game can be 

repeated for as many rounds as you wish. 

Paradox of Cooperation 

and Rational Choice 

This elementary game captures a 

fascinating paradox that lies at the heart 

of creating or destroying social and 

economic value determined by the often 

implicit and instinctive choices of human 

beings. Indeed, the most enlightened 

decision would evidently be that of 

mutual cooperation: both individuals 

choosing to show an open hand, and 

both getting $1,000. However, rationally, 

choosing to play with an open hand 

is less advantageous (at best, you only 

earn $1,000, at worst, you lose $2,000) 

then playing with a closed hand (at 

best, you earn $2,000, at worst, you lose 

only $1,000), with the consolation that 

the other loses the same amount too. 

The implications of this paradox for 

the well-being of individuals, businesses 

and communities are vast and impactful: 

environmental damage, terrorism and 

warfare, financial crises, wasteful public 

spending, nationalism, ethnocentrism, 

and defensive conservatism pitted against 

social innovations and migration processes. 

We saw this game play out at our 

first annual workshop series held in 

December 2023 in Vienna, Austria. 

The workshop series was created to 

help support executives involved in all 

aspects of investment migration get a 

better sense of how to navigate a rapidly 

changing migration landscape and to 

create sustainable change and growth 

in their businesses and organisations. 

The event saw a successful turnout, 

with participants not only engaging in a 

lively round of the ‘prisoner’s dilemma’ 

tournament, full of unexpected twists and 

turns during the three-hour simulation, 

but also benefiting from theoretical 

insights into human behaviour and its 

potential applications in private, public, 

and non-governmental organisations 

during the subsequent debrief sessions. 

This led to spirited discussions 

involving real case studies, and plans 

for the next steps were developed. 

The Role of 

Interpersonal Trust 

Participants learned in our simple game 

that playing with an “open hand” implies 

the risk of suffering losses, being exploited 

by others, experiencing frustrations, 

and incurring economic and emotional 

costs. But playing with an “open hand” 

is also the most evolved and enlightened 

way to create stable personal and social 

prosperity and well-being. To be inclined 

to play with an “open hand,” it is necessary 

to cultivate one of the most generative 

and challenging mental attitudes: 

interpersonal trust. To trust, one must 

develop two propensities: one to see in 

the other resources and opportunities, 

not just problems and dangers, and the 

other to tolerate vulnerability to the 

risk of potentially being “preyed upon” 

by others. This risk, as demonstrated 

by the studies of Daniel Kahneman, 

is particularly painful for the average 

human mind, which is evolutionarily 

programmed to be more loss-averse than 

gain-oriented: the motivation to avoid 

pain is at least twice as powerful as the 

motivation to seek pleasure and gain! 

Immigration as a Key 

to Prosperity 

Statistics on socioeconomic indicators of 

prosperity in different countries clearly 

demonstrate that cultures in which the 

attitudes that fuel interpersonal trust are 

cultivated are the countries that record 

the highest levels of quality of life and 

the highest propensity for openness to 

skilled and value-enhancing immigration. 

A nation that adopts a trusting approach 

to healthy and sustainable migration 

demonstrates its willingness to 

collaborate and welcome those seeking 

opportunities. Furthermore, due to social 

reciprocity mechanisms, if a country 

shows openness and pre-established 

trust towards immigrants: for example, 

second passport seekers, it can inspire 

similar behaviour from them, leading to 

collaboration and mutual prosperity. 

A successful example of this 

approach is Canada’s immigration 

policies based on meritocracy. Canada 

has managed to harness trust and 

attract talent and investments from 

around the world, creating a prosperous 

and multiculturally rich society. 

In conclusion, behavioural sciences, 

through the Prisoner’s Dilemma and the 

study of the most effective approaches 

to play this game, teach us that trust and 

strategic cooperation are key resources 

for fostering prosperity. Opening doors to 

immigration with a well-managed, forwardthinking, 

inspiring, and proactive policy 

can not only enrich a nation culturally 

but also significantly contribute to its 

economic growth and social well-being. 

The prosperity of a country is the result 

of multiple factors, but trust and highquality 

immigration can be key elements to 

unlock its full potential. Openness towards 

constructive and flexible immigration will 

become even more critical to countries in 

the near future as Gen Z and millennials 

will no doubt seek opportunities for virtual 

citizenship or flexible multi country 

citizenship and new experiences where 

they hope to engage in socially responsible 

investment in the new host country. 

Sibylla Giulia Verdi is a 

BIOS lecturer at the University 

of Padua (Italy) & Ca Foscari (VE) and 

she works as a consultant for various 

international institutions. Her research 

is published in multiple journals, 

covering topics such as leadership, 

game theory, and well-being. She is 

an active member of the Behavioural 

Analysis Team in the Prime Minister’s 

Office in Italy, and she is also associated 

with the Herbert Simon Society. 

Additionally, she has served as a guest 

at the Max Planck Institute in Berlin. 

Prof. Davide Pietroni, holding a 

PhD in Cognitive Sciences, serves 

as the President of the master’s 

degree programme in “Economics 

and Behavioural Sciences” at the 

University of Chieti-Pescara in Italy. He 

is also a member of the Behavioural 

Analysis Team in the Prime Minister’s 

Office in Italy. Prof. Pietroni has 

authored numerous publications on 

mediation, negotiation, and conflict 

management and offers consultancy 

services to various international 

organisations and institutions. 


The Cayman Islands 

is calling 

With the purchase of residential property valued at 

US$1.2 million and above, discerning individuals and 

their families can qualify to earn permanent residency in 

the Cayman Islands, a British Overseas Territory with no 

restrictions on foreign ownership of property and no corporate, 

income, capital gains, inheritance or recurring property taxes. 

Our team provides seamless service to clients interested in 

full-time residency, vacation homes, investment opportunities 

and commercial office space. 

Contact us to learn more about the freedom and 

benefits of a Cayman Islands lifestyle. 

provenanceproperties.com


Malta’s Residency Options at a Glance: 

Solutions 

for Global 

Migrants 

The Residency Malta Agency, 

led by CEO Jonathan Cardona, 

outlines the key benefits 

Malta offers for families, 

digital nomads, as well 

as start-up founders. 

The world is witnessing a significant 

surge in global migration, with highnet-worth 

individuals from countries 

facing economic challenges seeking 

alternative jurisdictions to safeguard their 

future. The value of freedom of movement 

has gained newfound significance in the 

wake of the Covid pandemic’s restrictive 

periods. Additionally, as remote work 

has become the norm, digital nomads 

and remote workers have discovered 

the ability to work from anywhere while 

maintaining their employment and 

business ties to their home country. 

These remarkable shifts and trends 

are creating a growing demand for 

economic mobility and solutions that 

facilitate the relocation of families 

and businesses. Residency Malta has 

stepped in to provide answers and 

solutions to meet these evolving needs. 

Malta’s Appeal 

People considering relocating to a new 

country often have specific motivations. 

The desire to provide a better future for 

their families is a common driving force. 

Healthcare, education, and safety are key 

concerns for prospective immigrants, 

and Malta excels in these areas. The 

country is known for its safe environment, 

reputable educational opportunities, and 

top-notch healthcare services. Despite its 

multicultural community, Malta’s societal 

values are deeply rooted in family, and its 

small size fosters a close-knit community. 

The added benefit of English as an official 

language makes communication effortless. 

From a business perspective, Malta 

offers a robust jurisdiction with a diverse 

economy, access to the European market, 

a pro-business environment, and support 

from government entities. Daily air and 

sea connections to Europe, North Africa, 

and the Middle East, along with excellent 

telecommunications infrastructure, 

make it an ideal hub for businesses. 

Malta Enterprise, the government’s 

economic development agency, provides 

funding support for start-ups, and 

the country’s small size is perfect for 

testing new products and services. 

For digital nomads, Malta presents a 

unique opportunity to experience diverse 

cultures and histories, make friends, 

enjoy the pleasant climate and outdoor 

activities, meet like-minded individuals, 

and work from anywhere using the 

abundant public Wi-Fi hotspots. 

Residency Malta’s Offerings 

Residency Malta offers distinct 

solutions and migratory pathways 

for non-EU nationals through 

three flagship programmes: 

• Malta Permanent Residence 

Programme: This programme allows 

families to establish Malta as their 

permanent second home through a 

residency-by-investment solution. 

• Nomad Residence Permit: Designed 

for remote workers, this programme 

offers temporary residence for one 

year, with the option to renew twice, 

allowing up to three years of residence. 

• Malta Startup Residence Programme: 

Founders, co-founders, core employees, 

and their family members can obtain a 

three-year residency permit (extendable 

for an additional five years) (3 years + 3 

years for core employees) while setting 

up innovative ventures in Malta. 

Prioritising Due Diligence 

One of Residency Malta’s key focuses 

is due diligence, ensuring only fit and 

proper individuals are granted Maltese 

residency, maintaining the strength 

and reputation of its programmes. 

Stringent checks are conducted on all 

applicants across all programmes. 

Maintaining Service 

Excellence 

Residency Malta upholds high levels of 

service excellence through substantial 

investments in people, training, and 

technology. Specialised training for 

team members keeps them at the 

forefront of their respective fields. 

Our ongoing digitalisation efforts 

have improved efficiency and efficacy, 

allowing automated processes to handle 

routine tasks, and freeing up time 

for more complex responsibilities. 

Malta’s Irresistible Allure 

The true allure of our programmes 

lies in Malta itself— a strategic 

Mediterranean location, rich history, 

family-oriented culture, hospitable 

people, and world-class services 

create an unbeatable combination. 

In conclusion, Residency Malta 

offers compelling solutions for those 

seeking a change in their lives, 

whether for family, business, or 

adventure. Malta’s unique blend of 

opportunities and its commitment 

to service excellence make it a 

prime destination for those looking 

to enhance their quality of life. 



What is the Long-Term Future of the Immigration Industry? 

Henry Fan, CEO and Co-founder of Globevisa Group, shares 

insights on the future of the immigration industry and the 

strategies that will keep clients’ trust and journeys smooth. 

The world of immigration is like a 

constantly spinning wheel. With 

over two decades of experience in 

this field, I have learned to navigate the 

turbulent waters of policy changes. But 

here’s what keeps me up at night: How can 

we maintain our clients’ trust and ensure 

their immigration journeys remain smooth? 

How can we become more competitive in 

the immigration consulting industry? 

I want to share insights from the 

immigration consulting industry, exploring 

the long-term future that awaits us in this 

dynamic world. Together, let’s delve into 

strategies and approaches that will help 

us thrive amidst the constant shifts. 

B2B or B2C: The Path to 

Long-Term Success 

I am aware that many immigration 

companies are venturing into B2B 

operations these days. However, when 

it comes to ensuring the long-term 

growth of a company, I firmly believe 

that B2C should be the primary focus. 

The reason is simple: the B2C 

model allows us to have a direct line 

of communication with our clients. It 

empowers us to listen to our clients’ needs 

and craft immigration solutions tailored 

specifically for them. Moreover, in the 

event clients have new needs along the 

way, we are also well-equipped to offer 

them tailored solutions promptly. 

Since B2C is of paramount importance, 

my suggestion is to open offices in outbound 

countries where local individuals aspire 

to acquire another country’s residency, 

such as China, Vietnam, India, and more. 

These offices should host dedicated teams 

of professional immigration consultants, 

committed to delivering personalised, faceto-face 

immigration solutions to your clients. 

Creating Value 

through Diversity 

In a sea of immigration consulting 

firms, what sets you apart? 

Diversity is key. Many companies 

focus solely on traditional immigration 

destinations like Canada, Australia, or 

the United States. However, immigration 

policies change over time. If your company 

solely relies on a single pathway like 

the Portugal Property Golden Visa, you 

could lose business overnight, leaving 

your clients with no other option. 

Offering diversified programmes is 

therefore a wiser approach. However, 

with diversification comes the need for 

transparency and fluidity. You should 

provide ongoing programme updates to 

clients, ensuring transparency and reducing 

their concerns, thereby fostering trust. 

Fluidity equips the company to adapt to 

market changes and competitive pressures. 

Being an adaptable and dynamic firm can 

make your outbound consulting teams 

stronger and you can earn clients’ trust. 

Establishing Inbound Legal 

Service and Hosting Teams 

Consider this: if your client needs to travel 

to Greece for fingerprint registration, what 

services can you provide to enhance their 

experience? What about clients visiting 

Cyprus or Spain to select properties? Do 

you have a dedicated hosting team in place? 

Providing these personalised services 

can truly set your company apart in the vast 

landscape of the immigration industry. To 

achieve this, consider establishing highly 

specialised in-house legal teams in inbound 

countries such as Greece and Portugal. 

These teams can exclusively handle visa 

applications for your clients, ensuring a 

smooth and efficient process. In addition, 

they can offer first-hand information 

in the event of sudden policy changes, 

promptly relaying updates to the clients. 

Compliance: The 

Cornerstone of Success 

Not too long ago, news of a certain 

company’s non-compliant behaviour 

in the EB-5 programme made waves 

in the immigration landscape. As 

industry peers, we were shocked by such 

behaviour, but more importantly, we 

sympathised deeply with the innocent 

clients who became unwitting victims 

of these non-compliant practices. 

Implementing thorough due 

diligence procedures for clients, 

including comprehensive background 

checks and source of funds verification, 

is crucial, especially in pathways like 

Citizenship-by-Investment (CBI) that 

involve financial transactions. 

Furthermore, ensuring that your staff 

is well-versed in compliance matters and 

regularly updated on changing regulations 

is vital. When considering partnerships 

with programme providers to introduce 

new pathways, establishing a Programme 

Research & Development team is advisable. 

This team can collaborate with legal experts 

to ensure strict compliance with immigration 

laws, meanwhile the Compliance 

Department meticulously reviews the 

qualifications of the partners and projects. 

While it may require a willingness 

to bear the high costs of compliance, 

placing compliance at the forefront 

is paramount for the long-term 

viability of your immigration firm. 

This insight, drawn from my two decades 

of experience in running an immigration 

firm, reflects the path we are committed 

to pursuing and shaping our long-term 

future. Ultimately, my sincere hope is that 

we can continue to fulfil the dreams of 

many more individuals. “Your gateway to 

the world” is our motto; the world is vast 

and beautiful. Through our work, we can 

help people find a better place to call home, 

encapsulating the essence of our industry’s 

meaning. Perhaps in the future, we may 

even assist our clients in immigrating 

to different planets, such as Mars. Who 

knows what possibilities await us? 

BIO 

Henry Fan is the CEO and 

Founder of Globevisa Group. 

In 2002, he, along with his partners, 

established Globevisa in Singapore. 

Since then, the firm has evolved from a 

local immigration company into a global 

organisation. Globevisa now operates 

39 offices across the world, catering to 

clients from 96 countries or regions. 


EXPAND YOUR 

BUSINESS WITH 

RIF TRUST & LATITUDE 

– YOUR TRUSTED B2B PARTNER 

We at RIF Trust & Latitude invite you to consider 

us as your B2B partner for the following reasons: 

1. We pay quickly & generously 

Due to the high volume of case submissions that RIF Trust & 

Latitude and our partners command, we simply get better pricing 

from real estate developers and we are more than happy to share 

this with our partners. We also make it a practice to always pay 

commissions promptly. 

2. More RCBI Programmes on your shelf without more 

investment 

For any business, it’s impossible to be good at everything, so 

collaboration with an industry peer can often be an attractive 

option to enable you to offer your clients a more suitable RCBI 

solution without the upfront setup costs and challenging learning 

curve involved with taking on a new programme. We offer over 20 

RCBI programmes in the Caribbean, Europe and North America. 

3. We work with different sized firms 

Working collaboratively is in our DNA as we have partnered with a 

wide range of companies from some of the largest immigration 

firms in the world to single person operations. No matter the 

size of the partner, they all receive our full attention and service. 

4.We customize for you 

We offer a wide variety of options for our B2B partners that range 

from hand-holding your clients throughout the entire application 

process to staying in the background and providing white-labeled 

marketing materials for you to use. We customize solutions that 

are best suited for you, your firm and most importantly your clients. 

We even created a dedicated B2B team who is approachable and 

available 24/7 to better support our partners. 

Okay you got my attention! 

• What sets RIF Trust & Latitude apart from hundreds of 

other investment migration firms? 

We have offices in over 25 different countries around the world 

including the USA, UK and the UAE, thereby allowing us to offer 

24/7 support through our global network of offices. Also, our team 

is fluent in 15 different languages, so we can help you if English 

isn’t your or your client’s first language. 

• Why should I partner with you? What do I get out of it? 

It all about trust. Our partners entrust us to deliver on their behalf 

and we do our best to deliver each time. As long-time industry 

practitioners, we are more interested in building bridges than 

throwing sticks at our competitors. 

RIF Trust & Latitude is fully licensed under all of the citizenship-byinvestment 

programmes and we proudly display the certificates 

on our walls. We are also the Regional Representative Office in 

the Caribbean and the Middle East for the Investment Migration 

Council (IMC) and actively promote best practices and integrity for 

the industry. 

In addition to competitive client pricing, higher commissions, whitelabeled 

marketing material and multilingual team support, we can 

also provide you with new digital tools that make your lives easier, 

including the Country Access Tool (latitudeworld.com/cat). 

• I’m convinced, but I already have a B2B agreement in place? 

We have found many of our new B2B partners came to us because 

they were not satisfied with the quality of service being provided to 

them and their clients by other service providers. Please give us the 

opportunity to prove ourselves and you won’t be disappointed. We’d 

like to earn your business. 

Visit www.riftrust.com/partner-with-us or email us at partnerships@latitudeworld.com 

and we’ll discuss how to best move forward together 

RIF Trust & Latitude’s B2B Team 

Eric G. Major 

Executive Chairman 

Mimoun A. Assraoui 

Group CEO 

David Regueiro 

Group COO 

Ranny Muasher 

B2B Regional Director & 

Managing Director - Nigeria 

Jon Green 

Director 

Christopher Willis 

Managing Partner 

Ryan Darmanin 


Mohammad Motavasel 

B2B Regional Director & 

Managing Director - Turkey 

Our clients expect the world, we deliver it. 

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PARTNER 

WITH US 

MORE RCBI PROGRAMMES ON YOUR SHELF WITHOUT MORE INVESTMENT 

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& NEVIS 

UAE 

Visit www.riftrust.com/partner-with-us or email us at partnerships@latitudeworld.com 

and we’ll discuss how to best move forward together 

RIF TRUST INVESTMENTS LLC 

Dubai office | +971 (0) 4 520 6777 | contact@riftrust.com 

U-BORA Tower - Office 2804 - Business Bay 

PO Box 487381 - Dubai - United Arab Emirates 

Our clients expect the world, we deliver it. 

www.riftrust.com | www.latitudeworld.com

9 

2024 

16 th - 19 th April 2024 

#IMForum2024 

#SeeYouInDubai 

investmentmigration.org/forum/


Amendments to the 

Portuguese Nationality Law: 

A New 

Paradigm 

for Residence 

Permit 

Applicants 

Diogo Capela discusses the 

most recent amendments to 

Portugal’s Nationality Law. 

In January 2024, the Portuguese 

Parliament approved a significant 

set of amendments to the Nationality 

Law, marking an important turning point 

for those seeking to obtain a residence 

permit in Portugal. Among the various 

legislative changes presented, one of the 

most notable redefines the way in which 

the five-year period required to apply 

for Portuguese citizenship is counted. 

The Portuguese Nationality Law 

allows a person who has legally resided 

in Portugal for a minimum of five years 

to apply for Portuguese nationality. Until 

now, this period of time only began to 

count when the first residence permit was 

issued, which often resulted in considerable 

delays due to administrative delays in 

analysing immigration processes. Over 

the last few years, there have been several 

causes for a significant increase in delays 

in processing these applications, including 

COVID-19, the war between Russia and 

Ukraine and the restructuring of the 

Portuguese Immigration Services. 

Waiting Time 

The amendments now explicitly state 

that the waiting time for approval of the 

residence application will also be considered 

in the five years required for citizenship. 

With the new wording of Article 15(4) of the 

Nationality Law, it is now established that 

“ for the purposes of counting the legal residence 

periods provided for in this law, the time elapsed 

since the moment the temporary residence title 

was requested is also considered if it is approved.” 

This change makes it possible to 

mitigate the injustice long felt by those who 

had been waiting, sometimes for years, 

for their applications to be approved and 

who had to wait for their residence permit 

to be issued before becoming eligible to 

obtain Portuguese citizenship. Now that the 

waiting time for approval of the residence 

application will also be taken into account 

during this period, an unfair loophole that 

has affected thousands of people is being 

corrected, who have been disadvantaged 

by the mere effect of administrative delays 

of which they were completely oblivious. 

Positive Effects 

This legal change could have a positive 

impact on all immigration processes to 

Portugal, particularly those applying 

for the Golden Visa Programme, 

whose processes are, in some cases, 

waiting more than two years. 

The new legislation will come into 

force one month after its publication in 

the Public Gazette, subject to presidential 

promulgation. We are still waiting for 

the new Nationality Regulation to be 

drawn up, which will clarify some of the 

doubts that still remain and which the 

wording of the law does not allow to be 

fully clarified, namely knowing exactly 

when the five years of legal residence will 

be counted, since the Nationality Law 

applies indiscriminately to all types of 

immigration processes in Portugal, but for 

each type of process there is a different type 

of procedure to be adopted and it is not easy 

to see whether the regulation will be able 

to distinguish between them or whether 

it will make the criteria for counting legal 

residence more ambiguous; let’s hope not! 

Predictability and Fairness 

One thing is for sure, this change represents 

a positive step and aims to provide greater 

predictability and fairness in the processes 

of obtaining nationality for those applying 

for a residence permit in Portugal, giving a 

very positive signal by restoring credibility 

to the country, which, until now, was 

acquiescing to unfair situations and, in some 

cases, promising what, from the outset, 

it knew it wouldn’t be able to deliver. 

For all these reasons, we believe 

that for many applicants for the Golden 

Visa and other immigration processes 

to Portugal, these changes represent a 

substantial change in their life plans 

and could contribute positively to an 

increase in foreign investment this year. 

BIO 

Diogo Capela is the Founding 

Partner of Lamares, Capela 

& Associados. His primary focus 

areas include Immigration Law and 

Foreign Investment. Throughout his 

career, he has provided guidance 

to private clients, companies, 

and their employees on various 

immigration processes to Portugal. 



Unveiling Grenada’s Global Citizenship Oasis: 

The Synergy of Luxury, Sustainability, and Progress 

Galli Khurelee, Vice President of Global Markets at Hengsheng 

Group, shares insights about the Grenada National Resort and 

the Grenada Citizenship by Investment (CBI) programme. 

In the ever-evolving landscape of global 

citizenship, Grenada stands out as a 

hidden gem, a destination brimming 

with untapped potential. In comparison 

to its Caribbean neighbours, Grenada 

retains vast opportunities for tourism 

development, making it a canvas for 

innovation and growth. This potential is 

precisely why our focus is on the Grenada 

National Resort, a visionary project 

strategically located in the less-travelled 

northern region known as Levera. 

Chosen for its unexplored beauty and 

promise, Levara becomes a canvas where 

we paint a picture of not just opulence but 

a sustainable and progressive future. Our 

decision to develop the Grenada National 

Resort here stems precisely from a belief 

that development should extend beyond 

the hotspots, reaching areas with untapped 

allure. This approach, we believe, contributes 

to overall island prosperity and growth. 

The Grenada National Resort, 

adorned with a thoughtfully designed golf 

course and five-star hotels, embodies our 

commitment to creating an environment 

that seamlessly blends luxury, sustainability, 

and progress. The inclusion of a sea water 

treatment plant for golf course maintenance 

and a solar power plant reflects our 

dedication to responsible practices. 

As we transition our focus from the 

Grenada National Resort to the broader 

perspective of global citizenship, it 

becomes evident that our commitment 

to sustainability and progress seamlessly 

aligns with the Grenada Citizenship by 

Investment (CBI) programme. In this 

context, the Grenada CBI programme 

stands out as a transformative force for 

positive change, steering investment funds 

toward projects that uplift the well-being 

of local communities and contribute to 

the overall development of the island. 

Simultaneously, the programme remains 

steadfast in its commitment to maintaining 

integrity, enforcing rigorous security 

measures that uphold its credibility 

while ensuring the continued quality and 

reliability of the investments made. 

As the allure of global citizenship 

grows, Grenada beckons with its unique 

blend of opportunities and experiences, 

making it an irresistibly attractive 

choice for those seeking a new horizon. 

Here’s what sets Grenada apart: 

1. A Gateway to 

Global Freedom 

Embrace the freedom to explore with a 

Grenadian passport that unlocks doors 

to 148 countries, offering visa-free or 

visa-on-arrival access. Navigate the world 

hassle-free, from the iconic landscapes 

of the UK to the cultural richness of the 

Schengen area. The Grenadian passport 

isn’t just a travel document; it’s your ticket 

to a borderless world, and with the added 

advantage of eligibility to apply for a US 

E-2 visa, it opens avenues for business 

opportunities in the United States, 

enhancing your global mobility and choices. 

2. Beyond Investment: 

A Commitment to 

Sustainable Development 

Dive into a CBI programme that goes 

beyond personal gains. The Grenada 

CBI channels investments into social 

development, housing, and infrastructural 

projects. Become a catalyst for positive 

change while securing your global 

future—a truly rewarding dual role. 

3. Business Horizons Unveiled: 

A Local’s Perspective 

Gain a local perspective by becoming 

a citizen of Grenada through the CBI 

programme. Access local business 

opportunities, strategically diversify your 

global portfolio, and navigate economic 

fluctuations with a unique lens for asset 

diversification and portfolio protection. 

4. Tax Efficiency: Managing 

Wealth Globally 

Unravel the advantages of dual citizenship 

as Grenada exclusively taxes income earned 

within its borders and exempts capital gains. 

Navigate the complex landscape of global 

taxation with efficiency and precision. 

Grenada’s CBI programme empowers 

investors to manage wealth on a global scale. 

5. Family Inclusion: Crafting a 

Global Future for Generations 

Elevate your family’s future by including 

them in Grenada’s CBI programme. 

Experience the joy of choices—choices 

on how and where to build a brighter 

future for your children. Open doors to 

world-class education and opportunities, 

all while paying domestic tuition fees. 

6. Grenada: A Sanctuary 

in Times of Turmoil 

In an era of uncertainty, a second passport 

from a stable and peaceful nation becomes 

more than a travel document. Grenada, with 

its political stability and serene environment, 

provides a lifeline in times of unrest—a 

sanctuary for you and your loved ones. 

Conclusion 

Picture yourself on this journey—where 

Grenada becomes more than a mere option, 

but an unparalleled experience in global 

citizenship, paving the way for a sustainable 

and prosperous future. Our endeavour with 

the Grenada National Resort goes beyond 

creating a haven for luxury and sustainable 

living; it’s an integral part of a holistic 

approach to island-wide progress. The synergy 

between our local development initiative 

and the broader scope of the CBI programme 

showcases our belief that responsible, 

impactful development should extend 

beyond the confines of individual projects. 

Our aim is to contribute to a positive 

narrative of growth, sustainability, and 

prosperity, shaping a brighter future 

for both locals and those who choose 

to make Grenada their global home. 

BIO 

Galli Khurelee serves 

as the Vice President of 

Global Markets at Hengsheng Group, 

Grenada’s foremost developer, 

and provider of the Citizenship by 

Investment (CBI) programme. 



Empowering Investment Migration Professionals: 

Executive Master’s 

Amid Unprecedented 

The Investment Migration Council unveils its Executive Master’s 

Programme, designed to assist professionals in navigating the multidimensional 

challenges of the rapidly evolving investment migration 

landscape. Dr Dee Allen and Philip Allen have assisted the IMC in developing 

the programme, and here they explain what students can expect. 

2023 was an eventful year for investment 

migration, and 2024 shows no signs of 

being any different. Elections will shape 

global politics in 2024, and ongoing shifts 

in the global order will trigger significant 

changes in the policies and approaches 

many governments will take towards 

investment migration. Investment Migration 

Council (IMC) members now face a new 

challenge: dealing with complex multidimensional 

threats and changes happening 

simultaneously at breakneck speed. 

In the face of a broad, complex and 

ever-evolving regulatory landscape, 

IMC members must prepare to enhance 

their knowledge, skills, and abilities to 

confidently present recommendations 

to their clients and drive successful 

outcomes. Why is this going to be critical 

in 2024? In an increasingly competitive 

residency and citizenship market, wealthy 

individuals and their advisers expect 

those they are seeking guidance from 

to not only predict but also proactively 

navigate the nuanced migration landscape, 

thus proving their credibility, value, and 

evidence of their subject matter expertise. 

The IMC Executive Master’s 

in Investment Migration 

Focused on providing IMC members 

with a 360° vision of what is transforming 

the world of investment migration right 

now, the IMC’s new Executive Master’s in 

Investment Migration Programme equips 

students with the knowledge to meet 

clients’ growing demands, the confidence 

to adjust a firm’s offering to new business 

conditions and the awareness to seize 

opportunities before competitors do. 

Programme Content 

Drawing on new research, case studies, 

data, and examples from a diverse set of 

geographies, business models, and economic 

contexts, The Executive Master’s in Investment 

Migration strengthens the standing of an 

investment migration professional. 

The Executive Master’s will be a highly 

interactive, immersive learning experience 

designed to expand the capacity to think 

and act strategically. The student will 

become a skilled problem solver who has 

the expertise and confidence to tackle 

the nuances of investment migration. 

With this new qualification, one will: 

• Obtain a holistic and in-depth 

understanding of the critical 

TABLE A 

Indicative Compulsory Modules 

CBI and RBI Programmes 

Ethics, Conduct and 

Professional Standards 

Anti Money Laundering and 

Financial Crime Prevention 

KYC, and Client Due Diligence 

Regulatory and Economic 

Impact of the Programmes 

issues in investment migration. 

• Distinguish between Residency by 

Investment (RBI) and Citizenship by 

Investment (CBI) and its implications. 

• Assess the key issues and initiatives 

in investment migration such as 

ethics, AML, KYC, and standards 

from different jurisdictions. 

• Utilise case studies to critically assess 

investment migration approaches, 

actors, and models in the ecosystem. 

• Develop an implementable project 

and gain professional development. 

Designed to run over 12 weeks, the 

Executive Master’s in Investment Migration 

Programme is currently being developed 

and will include a series of compulsory and 

optional modules as indicated in table A. 

Indicative Optional Modules 

Demand 

Alternatives to CBI and RBI Programmes 

(Business Investor Visas, Self-support Visas, etc) 

Dynamics of the wider Investment Migration 

“Ecosystem” (Supply Chains, International Actors) 

Assessing Investment Opportunities 

Immigration law 



IMC Launches new 

Programme 

Global Changes 

Programme Delivery 

and Assessment 

The programme will be delivered through 

a combination of live, tutor-led online 

sessions and face-to-face, in-person 

residential workshops, led by a faculty 

of hand-picked industry and academic 

experts. The distinguished members of 

our faculty include Professor Kristin Surak 

from the London School of Economics, 

the author of “The Golden Passport: 

Global Mobility for Millionaires”. 

A key benefit of the programme 

will be the provision of an interactive 

learning environment for participants 

through group activities to stimulate peer 

learning and knowledge sharing. In each 

cohort, students will be subdivided into 

small tutorial groups, all of whom will be 

supported by dedicated subject matter 

expert tutors who will facilitate group 

discussions, provide subject matter 

input, and facilitate the sessions. 

All students will be encouraged to 

collaborate and work towards developing 

an implementable project, report, tool, 

or output that is focused on a particular 

investment migration issue to be practically 

employed, as part of the assessment. 

Certification and 

Launch Date 

Upon successful completion, participants 

will be awarded with a certificate 

from the Investment Migration 

Council and an endorsing educational 

institution. The programme will be 

launched at the Investment Migration 

Forum in April 2024 in Dubai. 

For more information, visit: https:// 

investmentmigration.org/education/. 

Over the past decade, 

BIOS Philip Allen has held 

senior leadership learning positions 

in the UK’s largest financial trade 

associations, including the Institute 

of Risk Management (IRM) and 

UK Finance. Currently working in 

wealth management and private 

banking, he has recently designed 

sector-wide programs on ESG, 

Mergers & Acquisitions (M&A), 

and Women in Leadership. 

Dr Dee Allen is a senior higher 

education academic with over 20 

years of experience working with 

corporations, regulatory bodies, 

and development agencies. She 

is a former lawyer and training 

business owner. She currently serves 

as an Academic/Research Fellow 

at the University of Cambridge. 



CONGRATULATIONS: 

YOU ARE NOW PART OF THE IMCET COMMUNITY 

LET’S CELEBRATE YOUR SUCCESS! 

Below Is The Official List Of IM Certified Practitioners 

Adewole Adenle 

Adrian Faccio 

Adriano Vieira 

Afshin Sadeghi Demneh 

Aggelos Nizamis 

Agnes Varga 

Aimee Lisle 

Aimy L’ecuyer 

Alan Huether 

Aleksandra Smolen 

Alexander Zvarkovskiy 

Alexei Sakharov 

Aliza Thompson-Nurse 

Analida Vallarino 

Anastasiia Chekina 

Anca Patrascu 

Andres Gutierrez 

Andrew Hesner 

Andria Petrou 

Anna Ponte 

Areana Frank-Carter 

Arseniy Salalaiko 

Asim Mahmood 

Assala Isaeva 

Audra DeFalco 

Balkis Dargouth 

Binjal Makwana 

Bobbi Jo Kutch 

Bojana Minic 

Bruno L’ecuyer 

Caterina Assunta Passini 

Catherine Liddell 

Cedric Leblanc 

Chameil Neecola Joseph 

Cheldon Lewis 

Chelita Virdee 

Cheryl Francis 

Choyce Walcott 

Chris Siwei Chen 

Christian Wayne 

Christina Georgaki 

Christopher Clowes 

Claire Joseph 

Clare Monique Aquilina 

Colin Bishop 

Dalia Akl 

Daniel Ohana 

Daniel Saint-Davis 

Daniel Tran 

Daniel Twomey 

Darien Ellul 

Dario Aquilina 

Darnell Boxill 

David Adeola Olabode 

David Paillé 

Destina Aslan 

Dishita Sheth 

Dmitry Dudarev 

Dmitry Shishkin 

Dom Barnes 

Donna Krohn 

Dusan Marinkovic 

Eddy Leviten 

Edwina Keyser 

Eleni Acquarone 

Eliot Brendon Mc Gillivary 

Elizabeth Davison 

Elmarie Theron 

Erica Lake 

Evelyne Hantig 

Fabia Francis 

Fatma Elbadry 

Fayez Hwalla 

Gabriele Avellino 

Gemm Fedee 

Gianella Farrugia 

Guilherme Porto Santana 

Hangama Wanner 

Hanna-Liina Linnasmäe 

Hassan Sattar 

Heidi Charles 

Hudda Elmira Chehadé 

Ibifuro Sekibo 

Inera Sadykova 

Irene Davidson 

Irina Walsh 

Jacques Plante 

James Muscat Azzopardi 

James Swenson 

Jamie Alleyne 

Jasmine Campbell 

Jaynelle Lake 

Jennifer-Lynn Kent 

Jessica Debono 

Joana Madalena da Fonseca 

Peres Sampaio de Andrade 

Joel Telesford 

Johannes du Toit 

John Richardson 

Jose Luis Garcia Reyna 

Joseph Comer 

Joseph Gheorghe 

Joshua Lake 

Jude Clemoes 

Julie Anne Brown 

Jusztina Rebeka Juhasz 

Katarzyna Aldycka 

Kate Roberts 

Kathryn Wright 

Kathy Rivera 

Keira Elford 

Keith Isaac 

Keni Ma 

Kenisha St. Paul 

Kenny Arevalo-Lebrun 

Kervin Leonice 

Kezel Lopez 

Khanh Do 

Kimberly Andrews 

Kishona Hypolite 

Kyle Mathurin 

Laila Alrasheed 

Laila El Orfi 

Laura Austin 

Lesikel Ali 

Lilla Krifaton 

Linda Boiteau 

Lisa McShine 



Lucy Mckenzie 

Ludovic Mapessa 

Lukas Harries 

Madalena Monteiro 

Maja Pralas 

Marcus Lionel 

Maria Grech 

Maria Kouri 

Marie Lou Cutajar 

Matteo Cicero 

Michael Krakat 

Michael Martin 

Michel Soler 

Michelle Katherine Hawryluk 

Mohamed Isaydou 

Mohammad Asghar Ali 

Mounir Bendaoud 

Mphuthumi Soga 

Mtonya A. G. Deterville 

Muhammed Yusuf Coban 

Naing Ye Lin 

Nani Yuningsih 

Natalia Fridlender 

Neil O’Leary 

Nevnihal El Afifi 

Nguyen Hai Yen 

Nguyen Minh Tri 

Nguyen Thi Lan Phuong 

Nguyen Thi Minh Thu 

Nguyen Thi Minh Trang 

Nicolas Salerno 

Nikisha Delabanque 

Nikkita Nair 

Ninette Hendel 

Nora Gomori 

Olakitan Arogundade 

Oluwatosin Arobieke 

- Adegunle 

Opinder pal Singh 

Pablo Ostrick 

Patrick Ansah 

Pelin Güngör 

Philip Paschalides 

Pierre-Étienne 

Balthazar-Lacasse 

Rachel Micallef 

Rade Ljumovic 

Rebecca Williams 

Renee Moses 

Renee Pindar 

Richard Hallam 

Richard Jacks 

Rina Joseph 

Roddy Denness 

Roderick Cutajar 

Rohit Kapur 

Roleece Brookes 

Roma Khilwani 

Ron Frederick 

Rosendo Guimaraes da Costa 

Salih Murat CAGDASER 

Samantha Julien-Fontaine 

Samuel Morrell 

Sandeep Kapoor 

Sara Rebolo 

Sarafina Gabriel 

Sarah Young 

Sasha L’ecuyer 

Sebastien Pham 

Seethalakshmi Ramanathan 

Sergey Voinich 

Shanda Toussaint 

Shane Qu 

Shanise Daniel 

Sharlene Isaac-Louison 

Sherrien Francis 

Shirlanda Williams 

Shonari Robinson 

Stefanie Fetzer 

Stephann St John 

Steven Butler 

Stewart Koesten 

Sue Nickason 

Sumit Singh 

Sylvania Tobierre 

Sylwia Wolos 

Taj Elibox 

Tajma Brown 

Tertius Relihan 

Tessy Ekpunobi 

Theodore Prillaman 

Theresa Okeke 

Tishanna Higgins 

Titus Thankachan 

Tomas Bucek 

Trafford Busuttil 

Tran Thi Truc Linh 

Tran Tuan Anh 

Una Calliste 

Vadym Shevchenko 

Valentina Alekseyevna 

Sammut 

Valeriano Anibarro 

Vanda Marlok 

Vanessa Andrade de Souza 

Vanessa Lima 

Varun Singh 

Veronica Bulat 

Victor Lawson 

Victoria Atanasova 

Viviana Echeverria Pascual 

Xiangnan Gao 

Yakir Yosubash 

Yanica Woods 

Yuan-Yu Hung 

Yulia Veremeva 

Zachary Busuttil 

Zain Ahmad Butt 

Zamaris Saxon 

Zarah Gaba 

Zeleka Peters 

Zoe Dowe 

Community Malta Agency 

Staff Members 

Residency Malta Agency 

Staff Members 



Fellow Member / 

Certified IMCET Professional 

Afi Ventour de Vega 

IMCM 

CEO 


FIMC Cert(IM) 

Chief Executive 

& Co-Founder 

GLOBAL SERVICES INC. 

Citizenship by Investment Act, is a beacon in investment and 

immigration services. Led by CEO Afi Ventour de Vega, a renowned 

lawyer and Honourary Counsel (Netherlands), we’ve evolved since 

September 2013 into Grenada’s leading CBI processing and afterservices 

provider. With a remarkable track record, we’ve facilitated 

the aspirations of over 1,500 families from 30+ countries. Our 

expertise lies in seamless pathways for foreign investors in Grenada’s 

Citizenship by Investment Program, with offerings including 

Grenadian Citizenship acquisition through strategic investments 

and comprehensive post-citizenship services. Partnering globally, we 

provide insights for residency and citizenship in diverse jurisdictions. 

Join Global Services Inc. for a journey of global opportunities, where 

expertise meets excellence, and aspirations find a definitive home. 

INVESTMENT MIGRATION COUNCIL 

The Investment Migration Council (IMC) is the worldwide forum for 

investment migration, bringing together the leading stakeholders in 

the field. The IMC sets global standards, provides qualifications and 

publishes indemand research in the field of investment migration aimed 

at governments, policy-makers, international organisations, and the 

public. It is an impact focused Swiss-based membership organisation in 

special consultative status with the Economic and Social Council of the 

United Nations since 2019 and registered with the European Commission 

Joint Transparency Register Secretariat (ID: 337639131420-09). 

Unit 3, Upper Floor, Spiceland Mall, Morne Rouge, 

Grand Anse, St. GeorgeGe, Grenada. W.I 

T: (473) 435- 2888/ (473) 444 2888 

WhatsApp: 1 473 419 6911 

E: cbi@globalserviceincs.com or 

infocbi@globalserviceincs.com 

W:www.globalserviceincs.com 

Contact: Afi Ventour de Vega - CEO 

16 Rue Maunoir 1211 Geneva – Switzerland 

T: (+41) 22 533 1333 

E: info@investmentmigration.org 

W: investmentmigration.org 

Contact: Bruno L’ecuyer - Chief Executive 

Fellow Member 

Dr. Christian H. Kaelin 

FIMC 

Chairman 

HENLEY & PARTNERS 

With over 25 years of institutional experience and more than 35 offices 

worldwide, Henley & Partners is by far the largest globally integrated 

pure play residence and citizenship advisory firm in the world. Through 

the provision of bespoke residence and citizenship by investment 

solutions, we have helped thousands of individuals and families, their 

advisors, and many sovereign states to generate value. Our outstanding 

people and systems provide a world-class advisory service underpinned 

by strict confidentiality, data security, and limited transaction risk. 

20 Grosvenor Place 

London, SW1X7HN 

United Kingdom 

T: (+44) 207 823 1010 

E: uk@henleyglobal.com 

W: henleyglobal.com 

Contact: Dr Christian H. Kaelin - Chairman 



IMCM Cert(IM) 

Digital Channels Officer 












T: (+41) 22 533 1333 

E: dario.aquilina@investmentmigration.org 


Contact: Dario Aquilina – Digital Channels Officer 

Fellow Member 

David Chen 


Executive Director & 


VISAS CONSULTING GROUP (VCG) 

As one of the most prestigious immigration firms in China, VCG has 

been dedicated to the achievement of the immigration dream of the 

wealthy elites since 1997. With the assistance of VCG, thousands of 

families not only successfully acquire the residency in their desired 

destination but also swiftly fit into the new life. Visas Consulting Group 

perfectly understands the balance between the needs of the clients 

and the laws of immigration. To fulfill people’s pursuit for a better life 

is always at the heart of VCG’s philosophy: Visas to your future. 

29/F Huaihai Plaza, 1045 Huaihai Road, 

Central Shanghai, 200031 – China 

T: (+86) 21 6415 8666 

E: dchen@visas.to 

W: www.visas.to 

Contact: David Chen - Executive 

Director & Managing Partner 




Angelique Brunner 

Founder 

Estelle Nogues 


Head Stakeholder 

Concierge 

EB5 CAPITAL 

Established in 2008, EB5 Capital is one of the oldest Regional Center 

operators in the United States. We provide foreign investors with 

opportunities to invest in job-creating commercial real estate projects 

across the country under the US Immigrant Investor Program (EB-5 Visa 

Program). The firm has raised more than $1 billion of foreign capital 

across 35+ EB-5 projects. EB5 Capital’s distinguished track record and 

leadership in the industry has attracted investors from over 75 countries. 











6106 Macarthur Boulevard 1st floor 

Bethesda, Maryland 20816 

T: (202) 652-2437 

E: info@eb5capital.com 

W: www.eb5capital.com 

Contact: Natalia Pronina – 

Vice President, Investor Relations 


T: (+41) 22 533 1333 

E: estelle.nogues@investmentmigration.org 


Contact: Estelle Nogues – 

Head Stakeholder Concierge 


Certified IMCET Professional Fellow Member 

Karen Kelly 


Vice President, 

Strategy & 

Development 

Jacqueline Gauci 


Head of Membership 

Services 

EXIGER 

Exiger has been a pioneer, innovator, and leading provider of due diligence 

and advisory services to the investment migration industry since 2006. 

As a trusted partner to the largest and fastest growing Residency and 

Citizenship by Investment (RCBI) programmes operating today, we 

bring cost-effective and efficient, technology-enabled solutions to the 

industry. Exiger has developed specialized methodology, reporting, 

and training for the investment migration industry. Our awardwinning 

AI technology platform, DDIQ, is also changing the way 

programmes manage applicants and agents by anticipating their 

most pressing needs. With over 250 full-time research staff speaking 

35 languages in research centers around the globe, we empower you 

to make the world a safer and more transparent place to succeed. 











230 Park Ave, Floor 3, New York, NY 10169 

T: +1 778 945 7318 

E: kakelly@exiger.com 

W: www.exiger.com 

Contact: Karen Kelly – Vice President, 

Strategy & Development - 


T: (+41) 22 533 1333 

E: membership@investmentmigration.org 


Contact: Jacqueline Gauci – 

Head of Membership Services 

CINVEST MIGRATION 

Cinvest Migration is a Residency and Citizenship By Investment 

Firm headquartered in Dubai. The Company’s mission is to deliver 

quality service to our High Net Worth clients in the sphere of 

residency and citizenship. Kemal Nicholson’s vision for this 

company is to revolutionise the RCBI business and to take 

it to the future focusing mainly on its digital aspects. 

Kemal Nicholson 


CEO/Founder 

000000, Opal Tower, Business Bay - 

Dubai - United Arab Emirates 

T: +971-52-215-5551 

W: cinvestmigration.com 

Contact: Kemal Nicholson – CEO/Founder 




Dr. Maria Grech 


Senior Associate 

MUSCAT AZZOPARDI & ASSOCIATES (MA&A) 

Set up in 1971, Muscat Azzopardi & Associates (MA&A) are a team of 

multilingual advocates with an international outlook, advising private 

and corporate clients. MA&A has built up invaluable experience in 

advising on legal and practical issues that arise when considering a second 

citizenship or an alternative residence. Our global portfolio of high net 

worth and ultra-high net worth individuals are highly appreciative of our 

guidance. Our lawyers share a special work ethic and personally guide 

clients - not just by assisting our clients through every step of the process, 

from the first contact to the actual acquisition of a Maltese citizenship 

or of residence in Malta, but we continue to serve our clients beyond. 

40, Villa Fairholme, Sir Augustus Bartolo Street, 

Ta’ Xbiex XBX 1095, Malta 

Tel: (+356) 2133 6196 

Mob: (+356) 9993 0258 

Contact: Dr. Maria Grech - Senior Associate 


Marie’ Lou Cutajar 


Head of Education 

& Training 


Marie’ Lou is the Head of Education and Training at the Investment 

Migration Council, where she acts as the point of contact for all training 

related enquiries. She is responsible for the day to day co-ordination 

and administration of the training programme, making sure that 

all those who enroll for the course get all the assistance that they 

require and experience a positive learning journey. Marie’ Lou is also 

leading several projects within the IMCET, focusing on the growth of 

the education and training portfolio – with the intention to enhance 

professionalism and setting standards of best practice in the IM industry. 


T: (+41) 22 533 1333 

E: imcet@investmentmigration.org 


Contact: Marie’ Lou Cutajar – 

Head of Education & Training 

Fellow Member 

Nadine Goldfoot 



FRAGOMEN 

Fragomen is the world’s leading exclusive provider of immigration 

services. With more than 50 strategically located offices worldwide, 

we provide immigration services in more than 170 countries. Our 

Worldwide Private Client Practice helps individuals – from investors, 

high-net-worth individuals and entrepreneurs to executives, 

professionals, artists, athletes, students and their families – to 

navigate and plan for their long- and short-term movement around 

the world. Available in multiple countries, alternative citizenship and 

residency programmes promote economic growth through investment 

and offer immigration benefits to investors seeking to expand and 

secure their personal and financial security and stability, leverage 

global business opportunities and enhance their quality of life. 

1st Floor, 95 Gresham Street, 

London EC2V 7NA - United Kingdom 

T:(+44) 2070 909 156 

E: NGoldfoot@Fragomen.com 

W: www.fragomen.com 

Contact: Nadine Goldfoot – Managing Partner 

Hany Mostafa 


Managing Director 

PRIME PROPERTIES 

Established in 2009, Prime Properties offers integrated real estate solutions 

for property developers and high-net-worth real estate investors. In 

2011, Prime Properties entered the market of citizenship and residency 

programs due to the increasing demand in local and regional markets. With 

partnerships with renowned real estate companies, consultants, financial 

experts, lawyers, and government entities, Prime Properties provides 

comprehensive investment services tailored to its clients’ diverse needs. 

Its extensive network enables the provision of exceptional investment 

opportunities for second citizenship and residency applications in over 16 

countries worldwide. The company has successfully assisted hundreds of 

foreign investors in obtaining Egyptian citizenship through investment. 

52 Nehro Street, 9th Floor, Office 

No. 19, Maryland, Heliopolis, Cairo, Egypt 

T: +201099933661 +20101335332 +201022281883 

E: sales@primeproperties.com.eg 

W: www.primeproperties.com.eg 

Contact: Hany Mostafa – Managing Director 

Alexander Osetinskiy 

LLM, IMCM 

Investment 

Migration Lawyer 

PRO.RELOCATION S.L. (VALENCIA, SPAIN) 

PRO.Relocation is a boutique immigration law firm with deep expertise in 

Spanish immigration law, international commercial law and legal assistance 

to HNWI and UHNWI. We assist our clients in all immigration matters in 

Spain, from Golden Visas (best RBI program in the EU) and Digital Nomads 

to non-lucrative visas, student residencies and family reunification. Our 

office in the UAE assists clients to start business, place their wealth 

and move families to the most dynamic country in the Middle East.Our 

vision is families moving together and people doing what they love, enjoying 

every moment of life wherever they are. That’s why we believe in tailored 

products and dedicated service for our clients. Our continuing support 

department helps our clients after their relocation to find the best tuition 

at school and university level for children, best medical assistance for the 

whole family and the most tax efficient solution for the clients’ businesses. 

46002, plaza Ayuntamiento, 19, off. 3G. Spain 

T: +34601442274, +34960730029, +971561062061 

E: info@pro-relocation.com; 

osetinskiy@pro-relocation.com 

W: www.pro-relocation.com 

Contact: Alexander Osetinskiy, LLM, IMCM, 

Partner & Investment Migration Lawyer 



Fellow Member 

H. Ronald Klasko 



KLASKO IMMIGRATION LAW PARTNERS, LLP 

H. Ronald Klasko is a leading U.S. lawyer representing treaty investors 

(E-2) and green card investors (EB-5). Ron was the lead attorney on Matters 

of Walsh and Pollard, the key precedent for E-2 visas and co-counsel 

on a 2022 lawsuit reopening the EB-5 regional center program. His firm 

is the North America Regional Representative office of the Investment 

Migration Council, of which Ron also serves on the Governing Board. 

Ron regularly speaks on investment migration globally and is known for 

pioneering innovative immigration solutions. Under Ron’s leadership, 

Klasko Immigration Law Partners is regularly recognized by Chambers 

Global and U.S. News and World Report. Ron was President and General 

Counsel of AILA and served five terms as Chair of the EB-5 Committee. 

1601 Market Street, Suite 2600 

Philadelphia, PA 19103 

T: 215.825.8600 

E: rklasko@klaskolaw.com 

W: www.KlaskoLaw.com 

Contact: H. Ronald Klasko – Managing Partner 

Ronit Sharma 


Founder & Managing 

Partner 

IMMIGRANT INVESTOR GROUP INC. 

Immigrant Investor Group Inc. “IIG” is an international Residency & 

Citizenship by investment firm that specializes in the Start Up Visa 

Program to Canada which is administered via various Government 

of Canada designated organizations such as, Angel Investor Groups, 

Venture Capital Funds and Incubators. IIG is led by Ronit Sharma 

the Founder & Managing Director. The Start Up Visa Program to 

Canada is the premiere investor immigration program at the moment 

for global high networth individuals who are seeking permanent 

residency in Canada which eventually leads to Canadian citizenship. 

177 Churchill Avenue 

Toronto Ontario, M2N1Z3 Canada 

T: 001-647-295-7664 

Office: 001-647-341-4502 

E: ronitsharma@immigrantinvestorgroup.com 

W: www.immigrantinvestorgroup.com 

1. Headshot in CMYK – 

Contact: Ronit Sharma – 

Please use one of the below pictures. 

Founder & Managing Partner 

Fellow Member 

Sachit Kumar 

FICM 

Managing Director 

GLOBE DETECTIVE AGENCY (P) LIMITED 

Established in 1961, GDA is the pioneer and leader in private Investigations 

in India with Global expertise. Headquartered in New Delhi with a network 

of 20 branches, GDA specializes in Enhanced Due Diligence worldwide for 

the investment migration industry in 40 countries. This includes a “deep 

dive” into a subject’s background to verify information, acquire relevant 

inputs and fill gaps through field resources. It also includes authentication 

of documents and global security checks related to sanctions, enforcements, 

1,200 watchlists originating from more than 80 countries and identification 

of politically exposed persons. GDA’s highly skilled, professional approach 

is personalized and rigorous. GDA is aware that important decisions 

are made partly/wholly based on the information that we provide. 

601-603, Eros Apartments, 56, Nehru Place, 

New Delhi-110019, India 

T: (+91) 9311042007 

2. Full Name and Designation – 

E: sachitkumar@globedetective.com 

Barr. Tessy Ekpunobi 

W: www.globedetective.com 

Investment Migration Attorney 

Contact: Mr. Sachit Kumar – Managing Director 

3. Company Name and Logo in CMYK 




Barr. Tessy Ekpunobi 



Attorney 

Valentina Sammut 


Founder and Chief 

Executive Officer 

GLOBAL RESIDENCE AND CITIZENSHIP LTD. (GRCL) 

Global residence and Citizenship Ltd. (GRCL) is a full-service 

international Law Firm in Nigeria, with a sister company in Canada, 

specializing in international migration with a specialty in Second/ 

Alternative Residency and Citizenship programs. With over 25 years of 

International Migration experience, we have successfully assisted over 

3000 clients to legally obtain citizenships and permanent residency 

through Investment Migration Programs including but not limited to: 

Start -Ups, Provincial Nominee, Real-Estate/Donation options, and 

significant investments option of some EU, North America and the 

Caribbean that offer alternative residency/citizenship programs. Our 

global team of legal professionals and affiliates ensure that all clients 

are treated with respect and confidentiality, all files handled with 

competence and efficiency geared towards a successful outcome. 

BIZ CONSULT LIMITED 

BIZ Consult Limited is the leading exclusive provider of customer oriented 

immigration services with the focus on the residency and citizenship by 

investments, due diligence, compliance. BIZ Consult offers its clients and 

their family members — which include high net worth individuals from 

the Commonwealth of Independent States, Asia and Middle East — the 

full support with documents, translations, legalisation, and real estate 

since 2014. The company provides its services with the highest professional 

standards. BIZ Consult founder Valentina Sammut is an IMC certified 

professional. Our team of legal professionals provides sound advice with 

respect and diligence with strict confidentiality and data security. The 

company is an approved accredited agent by the Malta Community Agency. 

GLOBAL RESIDENCE AND CITIZENSHIP LTD 

GLOBAL MIGRATION AND INTERNATIONAL REAL ESTATE LAW FIRM 

N0. 20, 641 Rd. Off 64 Road. Off 6 th Avenue. 

Gwarimpa. FCT. Abuja. Nigeria 

Tel: +234.805.897.3551. +1.513.729.7703 

Nº 20, 641 Email: Rd. globalresidences@gmail.com 

Off 64 RoadOff 6th Avenue. 

Gwarimpa. URL: FCT. https://global-residence-and-citizenship.business.site/ 

Abuja. Nigeria 

T: +234.805.897.3551 Contact: Tessy Ekpunobi • +1.513.729.7703 

Esq. – Investment Migration Attorney 

E: globalresidences@gmail.com 

W: 

4. 

https://global-residence-andcitizenship.business.site/ 

A 120-word write-up describing the main activities of the organisation 

Contact: Global Tessy residence Ekpunobi and Citizenship Esq. Ltd. – (GRCL) is a full-service international Law Firm in 

Canada, specializing in international migration with a specialty in Second/Alternative 

Investment Migration Attorney 

With over 25 years of International Migration experience, we have successfully assiste 

citizenships and permanent residency through Investment Migration Programs includ 

Provincial Nominee, Real-Estate/Donation options, and significant investments option 

Caribbean that offer alternative residency/citizenship programs. 

Our global team of legal professionals and affiliates ensure that all clients are treated 

files handled with competence and efficiency geared towards a successful outcome. 

146, Fl. 4, Constitution Street, 

Mosta, MST 9055, Malta 

W: https://bizconsultmalta.com/ 

T: (+356) 99 020 654 

E: info@bizconsultmalta.com 

Contact: Valentina Sammut - Founder 

and Chief Executive Officer 



Kenneth Camilleri 


CEO 

VERTEX ALLIANCE 

Vertex Alliance is your trusted partner for personal and business 

solutions including investment migration, corporate, tax and wealth 

management services. With over a decade of experience, the Vertex 

Alliance team continues its successful track record in investment 

migration helping families achieve their residency and citizenship goals. 

Vertex Alliance advises on multiple residency and citizenship 

programmes in Malta, Europe and beyond. We have a dedicated 

Private Client Services team with in-house multi-lingual staff fluent 

in various languages including Cantonese, Mandarin, Vietnamese, 

Italian, Portuguese, German, Romanian, and Russian, helping to 

ensure a seamless and personalised service for our clients. 

Aragon House, Dragonara Road, 

St Julian’s STJ 3140 - Malta 

T: +356 9944 2356 

E: info@vertexalliance.com 

W: www.vertexalliance.com 

Contact: Kenneth Camilleri - CEO 

In a bid to reduce our carbon 

footprint, we no longer be 

printing mountains of 

material, therefore the 

following pages includes 

information about IMC 

initiatives in the coming year. 

In a bid to reduce our carbon footprint, 

we are no longer printing mountains 

of material. Therefore, the following 

pages include information about us. 



A Guide to the Investment Migration Council 

84 - Investment Migration Yearbook 2O23 

investmentmigration.org


Who’s Who 

GOVERNING BOARD 

Andrés Solimano 

(Chairperson) 


(CEO) 

Nadine Goldfoot 

David Chen Ronald H. Klasko Christian H. Kalin 

SECRETARIAT 

Jacqueline Gauci 


Head of Membership 

Services 

Marie’ Lou Cutajar 


Head of Education 

& Training 

Estelle Nogues 


Head of Stakeholder 

Concierge 



Digital Channels 

Officer 


About Us 

We are the worldwide 

association for 

Investment Migration, 

bringing together the 

leading stakeholders 

in the field and giving 

the industry a voice. 

Our Mission 

Our mission is simple 

and straightforward: 

it is about setting the 

global standards for 

others to follow and 

promoting competence 

and ethical behaviour. 

Additionally, we improve 

public understanding 

and transparency of the 

industry through various 

initiatives, including 

academic research. 

We are the leading 

platform for 

governments, academia 

and professionals. 

Structure of the IMC 

- Legal form: non-profit Swiss-based 

Association (Art 60 seq Swiss Civil Code) 

- A solidly funded association, through 

membership & donors 

- Professional, full-time secretariat headed by a CEO 

- The leading industry firms are already members 

- World’s most-respected experts on the 

governing board and advisory comittee 

The leading industry firms 

are already IMC members 

- Refinitiv 

- Henley & Partners 

- RIF Trust 

- Visas Consulting Group 

- Fragomen Worldwide 

- Exiger DD 

- Latitude 

- Polaris Citizenship & Investment 

- Sotheby’s International Realty 

- ProPanama 

- Reef View Enterprises 

- immVest International 

- FACT Due Diligence 

- S-RM Intelligence 


Three Essential 

Reasons to Join 

1. Achieve greater industry-wide 

visibility to grow your business 

2. Build and contribute to a worldclass 

network of contacts 

3. Learn about all the latest 

developments taking place 

Membership 

Criteria 

To become a member, one must 

have proven expertise within the 

sector, a good reputation, and a clean 

professional and personal record. 

The IMC has very strict membership 

admission criteria to ensure 

its members are of the highest 

professional standards. 

The IMC offers different levels of 

annual memberships for individual 

practitioners, academics, firms, 

associates, governments and 

affiliates. Membership packages 

include the below, each offering 

various levels of benefits. 


Two Routes to Membership 

1. Membership by Education 

1. Membership by Education 

The journey to membership via the education route is the 

recommended Please click here one for since further this information. strengthens the skills and knowledge 

of members and by consequence the wider industry. 

The journey to membership via the education route is the recommended one since this 

strengthens the skills and knowledge of members and by consequence the wider industry. 

2. Membership by Experience 

2. Membership by Experience 

To follow suit with other professional bodies, membership by 

experience is offered to those practitioners who meet the necessary 

members of the IMC. 

criteria in any membership tier to be members of the IMC. 

To follow suit with other professional bodies, membership by experience is offered 

to those practitioners who meet the necessary criteria in any membership tier to be 

Application can be filled online on ww.investmentmigration.org/membership 

Application can filled online on www.investmentmigration.org/membership 

Membership Levels 

Membership Levels 


Benefits for Business Membership 

Benefits for Business Membership 

Benefits for Individual Membership 

Benefits for Individual Membership 


Application Process Timeline 

Application Process Timeline 

Investigative Due Diligence 

Investigative Due Diligence 

Our Due Diligence checks on prospective members are carried out by a roster of Due 

Diligence firms. They apply a leading edge methodology to generate information from a 

broad range of sources, including on-the-ground, in-country investigative intelligence. 

Our Due Diligence checks on prospective members are carried 

out by a roster of Due Diligence firms. They apply a leading edge 

methodology to generate information from a broad range of sources, 

including on-the-ground, in-country investigative intelligence. 

Types of risks identified: 

- Criminal activity 

- Misrepresentations or factual omissions 

Types - Unreported of risks identified: 

financial issues 

- Criminal - Civil litigation activity 

- Misrepresentations - Character issues or factual omissions 

- Unreported - PEP checkfinancial issues 

- Civil litigation 

- Character issues 

- PEP check 


FAQ’s 

Why does the industry need the IMC? 

Until the IMC was established, there was no body to act as a bridge 

between governments, academia, and practitioners. The IMC brings 

all stakeholders together in an independent manner, and the interests 

of all stakeholders are considered for the benefit of the industry. 

How many members are participating? 

Today, there are nearly 450 members from over 

55+ different countries and territories. 

Can anyone join? 

To become an active member, you must be a practitioner with proven 

expertise and experience in investor immigration, have a good reputation 

and a clean professional and personal record. Each application is assessed 

on its individual merit and considered by the governing board. 

Contact Us 

Secretariat: 

info@investmentmigration.org 


IMC Qualifications and Training 




investmentmigration.org/education 

Contact: imcet@investmentmigration.org 

investmentmigration.org/education 

Contact: imcet@investmentmigration.org 

Contact: imcet@investmentmigration.org

Certification in Investment Migration ‐ Cert (IM) 

Overview and Objectives 

The Certification in Investment Migration is an intermediate 

level course designed to be studied over about 6 months. 

This practical introduction leads to a professional status 

with the IMC and is benchmarked at Associate level for those 

working in the IM industry. This is the first global Investment 

Migration course of its type - specially designed for those 

working in the industry. The course is taught online through 

our custom Learning Management System and includes 

5 compulsory modules. 

Target Audience 

All staff working in, allied to, or intending to work 

in the industry 

Advisors 

Agents 

Lawyers/paralegals 

CIP programme staff 

Regulators and government staff 

Compliance professionals 

Financial services practitioners 

Investment advisors 

Assessment 

The programme is assessed via: 

Two hour, online, multiple choice test 

100 multiple choice questions to be answered 

70% Pass mark 

Certification and Designation 

Individuals who successfully complete the programme will 

be awarded the 'IMC Certification in Investment Migration'. 

The certificate carries with it the designation Cert (IM) 

and leads to membership of the IMC. 

Example designation - Carmen Swift Cert (IM); IMCM (Associate) 

Professional Status 

On successful completion of the Certification, 

Non-IMC Members will become eligible to apply for membership 

of the IMC at Associate level. 

Course Format 

Delivered online via an easy to use, 

comprehensive Learning Management System (LMS) 

Accessible by a range of mobile and laptop technologies 

Needs to be completed within 6 months, however actual 

study time is around 25 hours 

Comprehensive support materials including: 

— comprehensive module manuals 

— interactive e-learning modules 

— case studies and examples 

— specimen test questions 

Entrance Requirements 

Applicants should possess: 

Good educational background 

Ability to complete the readings and comprehend core 

principles in the English language 

How to Apply 

To apply for the Certification in Investment Migration course, 

please go to investmentmigration.org/education to enrol online. 

Rationale for Taking the Certification 

The IMC Certification is a groundbreaking initiative 

designed to prepare participants for work in a new 

and vibrant industry where high professional 

standards, values and enhanced competencies 

are required. This certification will: 

Provide verifiable evidence of competency 

(knowledge, skills and behaviours) 

Provide a practical focus and benchmarking of 

your work in the industry 

Help you to reduce risk in your firm and enhance 

the firm’s reputation 

Enhance your career prospects 

Keep you abreast of developments in the industry 


Programme Structure / Course Format 

Module 1 

Module 2 

Citizenship and Residence by Investment 

Industry Overview 

Understanding Citizenship and Residence 

Ways of Acquiring the Status of Citizenship 

The Concept of Residence 

Development and Characteristics 

of Investment Migration 

Citizenship and Residence by Investment: 

Assessing the Arguments 

Ethics, Conduct and Professional Standards in 


Ethics 

Codes of Conduct 

Corporate Culture and Values 

Integrity 

Competence 

Transparency 

Marketing of Citizenship & Residence by 

Investment Programmes 

Practical Application of the IMC Code 

Whistleblowing 

Module 3 

Module 4 

Anti-Money Laundering (AML) 

and Financial Crime Prevention (FCP) 

Nature of AML, Terrorist Financing (TF) and 

Sanctions 

Terrorist Financing 

Sanctions 

Key International AML and Sanctions Bodies 

Suspicious Activity Reporting 

Concept of Risk Management 

Bribery and Corruption 

Cybercrime 

Investor Migration — Know Your Customer (KYC) 

and Customer Due Diligence (CDD) 

Generic KYC and CDD 

Customer Due Diligence 

Types of Due Diligence 

Politically Exposed Persons 

Customer Risk Rating 

CDD Gone Wrong – Regulatory Action 

Citizenship by Investment and Residence by 

Investment – the need for CDD 

Minimum Standards for Agents 

Module 5 

Personal Data: Management and Protection 

What is Personal Data? 

Principles of Data Protection 

Risks Associated with Inappropriate Management of 

Personal Data 


New Modules Added to IMCET Portfolio 

Module 6 

Module 7 

Demand for Residence and Citizenship by Investment 

The expansion of dual citizenship provisions 

and their implications 

Key demographics of demand for CBI and RBI 

programmes 

People’s motives in participating in CBI and RBI 

programmes 

The differences in demand from different 

countries of origin 

Examine the impact of Covid-19 on demand 

General factors that determine patterns of 

demand 

Factors that lead to increased and decreased 

demand 

Common Reporting Standard and Mandatory Disclosure 

Rules 

The reporting framework established by the 

OECD Common Reporting Standard 

The different financial institutions involved in 

the domestic CRS reporting process 

CRS due diligence processes and procedures 

and its application to entity and individual 

account holders 

Contents of a CRS report and various financial 

account information reporting requirements 

Understand the contents of MDR disclosure 

Identify circumstances when a client will be 

required to file an MDR disclosure 

IMCET’s training portfolio now consists of 7 specialised modules. Students can choose to create their own learning journey 

through a combination of 3 compulsory and 2 Elective Modules chosen from the 4 options offered, to convert successful 

completion into the renowned ‘Certification in Investment Migration’, hold the designation Cert (IM) and be considered a 

certified IM practitioner. Students can now also choose to study modules individually at their own leisure in the bite-size 

option – no need to make an outright commitment to the entire course, but still with the option to graduate as a certified 

IM practitioner. 

3 Compulsory Modules 

+ 

2 Elective Modules 

Ethics, Conduct and Professional Standards in 

IM 

Anti-Money Laundering and Financial Crime 

Prevention 

Investor Migration – Know Your Customer and 

Customer Due Diligence 

Citizenship and Residence by Investment 

Personal Data: Management and Protection 

Demand for Residence and Citizenship by 

Investment 

Common Reporting Standard & 

Mandatory Disclosure Rules 

= 

Awarded the IMC Certification in Investment Migration, Cert (IM) 


Testimonials 

Pelin Güngör IMCM Cert(IM) 

This certificate gives me great confidence in my concern to provide 

Investment Migration consultancy on international standards. While 

customizing the given services for each investor, it is expected to 

handle the cases with the utmost attention. I am thrived to be a part 

of this community and can’t wait to interact with the value network. 

Brendon McGillivary Cert(IM) 

It was indeed a wonderful experience completing this Certification 

program. The content was very relevant and the staff of the 

Investment Migration Council was helpful throughout my studies 

Andria Petrou IMCM Cert(IM) 

The IMC certificate is a great tool for every professional in the 

Investment Migration Industry. The main idea is to ensure that 

those working in or associated with the Industry serve the same 

high professional standards and values and the best way to do so is 

through education and continuous professional development. I am 

glad I got the certificate and I encourage other professionals to do 

the same. 

Nguyen Minh Tri Cert(IM) 

I am thankful for the opportunity to learn and expand my knowledge 

of Investment Migration. This program showed me the aspects of the 

industry that I've never known before, making me feel more confident 

on my journey. Thank you IMC for this amazing experience. I will 

recommend my colleagues to get themself registered for the IMC 

courses. 


9IM YEARBOOK 

2024 

16 th - 19 th April 2024 

#IMForum2024 

#SeeYouInDubai 

investmentmigration.org/forum/ 


About the Forum 

The Investment Migration Forum is the largest and most important non-profit 

residence & citizenship by investment event in the world. Renowned academics, 

government officials, representatives of international organisations, as well as 

the world’s leading professionals dealing with investment migration will be 

gathering in Dubai for the 9 th edition of the Forum. 

The three day event will cover a variety of related subjects which are of interest 

to the academic, professional and government community. Expect 400+ 

participants from over 40+ countries. 

A limited number of partnership opportunities are available for highly respected 

firms to participate in the success of the Forum and to improve their visibility. 

About Us 

The Investment Migration Council (IMC) is the worldwide forum for investment 

migration, bringing together the leading stakeholders in the field. The IMC sets 

global standards, provides qualifications, and publishes in-demand research in the 

field of investment migration aimed at governments, policy makers, international 

organisations, and the public. It is an impact focused Swiss based (non-profit) 

membership organisation in special consultative status with the Economic and 

Social Council of the United Nations since 2019 and registered with the European 

Commission Joint Transparency Register Secretariat (ID: 337639131420-09). 

Who will Attend 

Individual Practitioners 

Law Firms 

Accountancy Firms 

Corporate Service Providers 

Academics 

Governments 

Real Estate Developers 

Specialised Service Providers 

Wealth Managers / Family Offices 

Private Bankers 

Migration Agents 

Due Diligence Providers 


Why should you participate? 

Why should you participate? 

3 


54 Speakers 

54 Speakers 

In 2023, the Investment Migration Forum succeeded in bringing together 54 high 

ranking speakers from around the world. The speakers included academics, 

In 2023, government the Investment offficials and Migration industry Forum professionals. succeeded in bringing together 54 high 

ranking speakers from around the world. The speakers included academics, 

government offficials and industry professionals. 

8% 

8% 

8% 

8% 

84% 

84% 


4

Austin Fragomen Jr IMCM 

Austin Fragomen Chairman Jr IMCM Emeritus 

Chairman Emeritus Fragomen, New York 

Fragomen, New York 

Fabienne de Blois IMCM 

Fabienne de Associate Blois IMCM Director, 

Associate Director, S-RM, London 

S-RM, London 

Eric Major FIMC 

Eric Major Executive FIMC Chairman, 

Executive Latitude, Chairman, London 

Latitude, London 

Joe Lynam 

Former Disinformation 

Joe Lynam Specialist, Brussels 

Former Disinformation 

Specialist, Brussels 

Kieron Sharp IMCM 

CEO, 

Kieron Sharp FACT IMCM Due Diligence, London 

CEO, 

FACT Due Diligence, London 

Marina Brizar 

UK Director, 

Marina Brizar Talent Beyond Boundaries, London 

UK Director, 

Talent Beyond Boundaries, London 

Peter Vincent 

International Security 

Consultant, Virginia 

Peter Vincent 

International Security 

Consultant, Virginia 

David Regueiro IMCM 

COO, 

RIF Trust, Dubai 

David Regueiro IMCM 

COO, 

RIF Trust, Dubai 

Dr Christian Kaelin FIMC 

Chariman 

Henley & Partners, London 

Dr Christian Kaelin FIMC 

Chariman 

Henley & Partners, London 

Nadine Goldfoot FIMC 

Managing Partner, 

Fragomen, London 


Managing Partner, 

Fragomen, London 

Karen Kelly FIMC 

Director - Strategy & 

Development, 

Exiger, New York 


Director - Strategy & 

Development, 

Exiger, New York 

Prof Dimitry Kochenov 

CEU Democracy Institute 

Budapest & CEU Legal Studies 

Department, Vienna 

Prof Dimitry Kochenov 

CEU Democracy Institute 

Budapest & CEU Legal Studies 

Department, Vienna 

5 


Regions 

Regions 

Represented 

Represented at 

at 

the 

the 

Forum 

Forum 

19% 19% 

20% 

46% 

7% 

2% 

7 

Expected 

Expected 

Attendance 

Attendance 

in Dubai 

in Dubai 

400+ 

400+ 

Delegates 

Delegates 

Based on the success of the past Forum and high demand of the industry, we expect 

Based on the success of the past Forum and high demand of the industry, we expect 

to have 

to 

well 

have 

over 

well 

400+ 

over 

delegates 

400+ delegates 

attending 

attending 

the next 

the 

Forum 

next Forum 

in 2024. 

in 2024. 

c. 10% 

c. 10% 

b. 20% 

b. 20% 

a. 70% a. 70% 


Previous Forum Partners 



POLARIS 

INVEST IN PARADISE. MAKE IT HOME 

POLARIS 


POLARIS 


FACT 

D U E D I L I G E N C E 

FACT 


FACT 



8

9 

Previous Previous Government Partners 

PR PR PANAMA 

EXPORT AND INVESTMENT PROMOTION AUTHORITY 

EXPORT AND INVESTMENT PROMOTION AUTHORITY 


The Investment Migration Forum is such a great way to keep 

in touch with all the professionals across the industry, 

whether you’re speaking to the agents or the due diligence 

providers as I am , or the government units themselves.” 


Vice President - Strategy & Development, Exiger, USA 

If you can attend only one Investment Migration conference this year, 

you must make it the IMC Forum. It gathers the Who's-Who of the 

industry, both from the private and public sectors. Great speakers and 

relevant topics. A must attend for anyone interested in international 

residency and citizenship by investment.” 

Eric Major FIMC 

Executive Chairman, Latitude, United Kingdom 

The team did a great job and hope to be a partner at next 

year’s Investment Migration Forum. Congratulations!” 

Steven Pepa 

Managing Director, Saratoga Capital, Cyprus 

Undoubtedly the most important annual meeting for 

RCBI professionals, service providers and 

governments. Connecting with like-minded delegates 

offers us all an opportunity to drive our visions 

forward to ensure the sustainability of the industry.” 

Charles Mizzi 

Former CEO, Residency Malta Agency, Malta 


Having attended many industry events, this remains my top choice every 

year. Very well organized and excellent for connecting with global leaders in 

our industry. 

All the relevant stakeholders in the industry attend and therefore is THE 

must go conference in the Investment Migration industry.” 

David Regueiro Santalla IMCM 

Group Chief Operating Officer, Latitude, United Arab Emirates 

The IMC Forum has been a great success. It’s been 

jovial, it’s been energetic, it’s been exciting! 

I think for every stakeholder who’s been here, I can see 

a sort of lightness and vibrancy to the atmosphere and 

yet also the opportunity to speak about really serious 

issues and the issues that are most pertinent to the 

industry today ” 

Fabienne de Blois IMCM 

Associate Director, S-RM, United Kingdom 

A truly excellent event - it goes from strength to strength 

each year! Thank you to you and the team for all your 

exceptional work.” 


Managing Partner, Fragomen, United Kingdom 

It’s a critical place for professionals to come together, to 

interact, to learn, to understand and to speak in one voice to 

the industry...” 

Thomas Anthony IMCM 

CEO, Grenada CIU, Grenada 


Closing Dinner in the Dunes of the Dubai Desert Partner 

EUR 60,000 

Positioned as our esteemed partner for the first Dubai Investment Migration Forum, we 

invite you to be an integral part of an extraordinary collaboration. Join us in co-hosting a 

unique evening at Sonara Camp Dubai, a venue synonymous with luxury and entertainment. 

For this dinner, Sonara Camp Dubai will be providing an intimate setting for our closing 

dinner exclusively for The Investment Migration Forum. 

Nestled in the heart of the Dubai desert, it is a captivating location that offers a 

once-in-a-lifetime experience. Imagine an evening under the starlit desert sky, where the 

camp transforms into an oasis of elegance and sophistication with excellent food & animation. 

The event will include presentation of the IMC recognition awards with the opportunity to 

make a welcome speech. 

NOTE: 

Titanium / Platinum / Gold / Silver / Blue Business Members are eligible for a 25% / 15% / 10% / 5% / 5% discount on the above mentioned packages. 

Kindly contact events@investmentmigration.org for further information. 

Prices exclude Malta VAT charged at 18%. VAT charges are only applicable to Maltese billing details & EU billing details without a VAT Number. VAT 

charges are not applicable to EU billing details with a VAT Number & non-EU billing details. 


12

We have worked hard with our partners to bring you an exhaustive list of terrific benefits: 

7 Delegate passes including access to all social functions 

1 table of 10 delegates reserved at the Gala Dinner 

Company profile on forum webpage and forum delegate book 

Exhibitor display table at the forum 

Company logo to appear on forum holding slide in plenary room 

Keynote presentation during one of the plenary sessions 

Welcome signage at Gala Dinner venue 

Company logo in forum delegate book 

Full page advertisement to be included in forum delegate book 

Company logo to appear on general forum signage 

Social media coverage 

Company hyperlinked logo on forum webpage 

Company name on the cover of forum delegate book 

Web advertisement on IMC website for a period of 6 months 

Rotating advert (x2) to be shown during breaks on the 

main screen 

Private Meeting room to be reserved for 4hrs during the Forum 

Panel discussion participation with your company logo 

to be displayed on a screen 

To receive list of delegates 1 week prior of the forum 

(Includes: Name, Company & Country) 

Company logo & hyperlink to appear on all forum mailshots, 

both pre & post forum 

Working Lunch “case study” presentation 

(optional attendance by delegates) 

1 year Silver Business Membership to the IMC 8% discount on full price extra delegate passes purchased 

50% discount on full price extra delegate passes purchased 

(limited to 3 passes) 

13 


Forum Partnership Opportunities 

Benefits 

Delegate passes including access to all social functions 

Company logo in forum delegate book 

Company profile on forum webpage and forum delegate book 

Full page advertisement to be included in forum delegate book 

8% discount on extra delegate passes purchased 

Exhibitor display table 

Company logo to appear on general forum signage 

Company logo to appear on forum holding slide in plenary room 

Panel discussion participation with your company logo 

to be displayed on a screen 

Company logo & hyperlink to appear on all forum mailshots, 

both pre & post forum 

Social media coverage 

Keynote presentation during one of the plenary sessions 

Company hyperlinked logo on forum webpage 

Company name on the cover of forum delegate book 

To receive list of delegates 1 week prior of the forum 

(Includes: Name, Company & Country) 

Web advertisement on IMC website for a period of 6 months 

3 

Titanium 

Package 

EUR 35,000 

7 

120 words 

EUR 21,000 EUR 18,000 EUR 14,000 EUR 9,000 EUR 5,000 

4 3 2 1 1 

100 words 80 words 60 words 50 words 40 words 

Rotating advert to be shown during breaks on the main screen 

x3 x2 x2 

Reserved private meeting room for 4 hours during the Forum - 

Reserved only for first 4 partners 

Working Lunch “case study” presentation (optional attendance by 

delegates) - Reserved only for first 2 partners 

Full page advertisement on back cover, inside front cover or other 

prominent position of forum delegate book (first come first served basis) 

Mention of company by Forum Chair in opening speech 

Choice of stand location in exhibition hall 

(first come first served basis) 

One mailshot to all delegates one week before the event 

Reserved delegate table near stage 

1 year Blue Business Membership 

Complimentary Branded A5 Notebook Partnership 

50% off on extra delegate passes purchased (limited to 3 passes) 

3 

3 

Partner delegate passes, included in partnership agreement, are not tranferable. The pass can only be used by a representative of the partnering 

company in their capacity as a delegate 

Speakers (panel/keynote) passes included as part of package 

Discount applicable on full price 

NOTE: 



Prices exclude Malta VAT charged at 18%. VAT charges are only applicable to Maltese billing details & EU billing details without a VAT Number. VAT 

charges are not applicable to EU billing details with a VAT Number & non-EU billing details. 


14


Welcome Drinks Reception on day 1 / Networking Drinks Reception on day 2 

A Welcome Reception or Networking will be held on the first or second day of the Forum for all the delegates. 

Benefits 

Delegate pass including access to all social functions* 

Company logo to appear inside Forum delegate book 

Company profile on Forum webiste and Forum delegate book 

Branded Tent Cards during reception 

Web advertisement on IMC website for 4 months if package is booked by 29 February 2024 

Exhibitor display table 

Full page advertisement to be included in Forum delegate book 

Company logo to appear on general Forum signage 

Welcome Address at the Drinks Reception** 

Drinks Reception 

Partner 

EUR 18,000 

1 

50 words 

Lunch Breaks 

Gain more visibility during the Lunch Break on one of the Forum days. (1 per day, 2 in total) 

Benefits 

Company logo on Forum webpage 

Company Logo in Forum delegate book 

Company Logo on signage at two Forum lunch breaks 

1x Lunch Break 

Partner 

Delegate pass including access to all social functions* 1 

EUR 7,000 

Networking Breaks 

Get additional light for your company during Networking Breaks on 1 of the Forum days. (Day 1 - 2 breaks, Day 2 - 1 break) 

Benefits 

Company logo on Forum webpage 

Company Logo in Forum delegate book 

Company Logo on signage at two or one Forum networking breaks 

* Partner delegate passes, included in partnership agreement, are not transferable. The pass can only be used by a representative 

of the partnering company in their capacity as a delegate 

** To be co-ordinated with the programme committee. 

NOTE: 

Titanium / Platinum / Gold / Silver / Blue Business Members are eligible for a 25% / 15% / 10% / 5% / 5% discount on the above mentioned 

packages. 


Networking Break 

Partner 

Day 1 EUR 6,000 (AM+PM) 

Day 2 EUR 3,000 (AM) 

Delegate pass including access to all social functions* 1 

15 

Prices exclude Malta VAT charged at 18%. VAT charges are only applicable to Maltese billing details & EU billing details without a VAT 

Number. VAT charges are not applicable to EU billing details with a VAT Number & non-EU billing details. 



Delegate Tote Bag Partner 

Delegate Tote EUR Bag 6,000 Partner 

EUR 6,000 

Delegate tote bag to be co branded with the IMC 

Delegate 40 word tote bag company to be profile co branded on website with the & delegate IMC book 

40 word Logo company to appear profile on all on campaigns website & related delegate to the book event 

Logo to 25% appear discount on all on campaigns 1 delegate pass related to the event 

(Discount applicable on full price) 

25% discount on 1 delegate pass 


USB Charging Cables Partner 

USB Charging EUR 5,000 Cables Partner 

EUR 5,000 

USB Charging Cables to be co branded with the IMC 

USB 40 Charging word company Cables profile to be co on branded website with & delegate the IMCbook 

Logo to appear on all campaigns related to the event 

40 word company profile on website & delegate book 

Logo 

25% 

to 

discount 

appear on 

on 

all 

1 delegate 

campaigns 

pass 

related to the event 




Branded Coaster Partner 

EUR 4,000 

Branded Coaster Partner 

EUR 4,000 

Coasters that are distributed at coffee breaks to be 

branded with company logo 

Coasters 

40 word 

that are 

company 

distributed 

profile 

at 

on 

coffee 

website 

breaks 

& delegate 

to be 

book 

branded 

Logo 

with 

to appear 

company 

on 

logo 

all campaigns related to the event 



Logo to (Discount appear applicable on all campaigns on full price) related to the event 



Branded A5 Notebook Partner 

EUR 5,000 

Branded A5 Notebook Partner 

EUR 5,000 

Desktop delegate notebook to be co branded with 

the IMC 

Desktop 

40 word 

delegate 

company 

notebook 

profile 

to 

on 

be 

website 

co branded 

& delegate 

with 

book 

the 

Logo 

IMC 

to appear on all campaigns related to the event 



Logo (Discount to appear applicable on all campaigns on full price) related to the event 



NOTE: 


NOTE: Kindly contact events@investmentmigration.org for further information. 

Titanium Prices / Platinum exclude / Malta Gold VAT / Silver charged / Blue at 18%. Business VAT charges Members are are only eligible applicable for a to 25% Maltese / 15% billing / 10% details / 5% / 5% & EU discount billing details on the without above mentioned a VAT Number. packages. VAT charges are not 

applicable to EU billing details with a VAT Number & non-EU billing details. 


Prices exclude Malta VAT charged at 18%. VAT charges are only applicable to Maltese billing details & EU billing details without a VAT Number. VAT charges are not 




Speaker Gift Partner 

Leather Card Holder & Passport Cover 

Speaker Gift Partner 

Leather Card Holder EUR & Passport 5,000Cover 

EUR 5,000 

Speaker Gift to be co branded with the IMC 

Speaker 40 Gift word to company be branded profile with on website the IMC& delegate book 

40 word Logo company to appear profile on all on campaigns website & related delegate to book the event 

Baseball Cap Partner 

Baseball Cap Partner 

EUR 6,000 

EUR 6,000 

Baseball Cap to be co branded with the IMC 

Baseball 40 word Cap company to be branded profile on with website the IMC & delegate book 

40 word Logo company to appear profile on all on campaigns website related & delegate to the book event 

Logo to 25% appear discount on all on campaigns 1 delegate related pass to the event 

Logo 25% to appear discount on on all 1 campaigns delegate pass related to the event 



25% discount on 1 delegate pass 25% discount on 1 delegate pass 



‘Sweet Shop’ Partner 

‘Sweet Shop’ EUR Partner 5,000 

EUR 5,000 

Sweet shop to be co branded with the IMC 


Sweet shop to be co branded with the IMC 




Logo to (Discount appear on applicable all campaigns on full related price) to the event 



Powerbank Partner 

Powerbank EUR Partner 9,000 

EUR 9,000 

Powerbanks to be branded with company logo 


Powerbanks to be branded with company logo 




Logo (Discount to appear applicable on all campaigns on full price) related to the event 



NOTE: 


NOTE: Kindly contact events@investmentmigration.org for further information. 

Titanium Prices / Platinum exclude / Malta Gold / VAT Silver charged / Blue at Business 18%. VAT Members charges are are only eligible applicable for a 25% to Maltese / 15% / billing 10% / details 5% / 5% & discount EU billing on details the above without mentioned a VAT Number. packages. VAT charges are not 







Fan Partner 

EUR 4,000 

Phone Ring Holder Partner 

EUR 4,000 

Fan to be co branded with the IMC 





Phone ring holder to be co branded with the IMC 





Luggage Tag Partner 

EUR 5,000 

Luggage Tags to be co branded with the IMC 



Rubiks Cube Partner 

EUR 4,000 

Rubiks Cube to be co branded with the IMC 



25% discount on 1 delegate pass 25% discount on 1 delegate pass 



NOTE: 






18


Photo Booth Partner 

EUR 12,000 

Photo booth to be co branded with the IMC 

Company logo to appear on each photo taken by delegates 





Refreshing Wipes Partner 

EUR 2,000 

Refreshing wipes to be co branded with 

the IMC 





NOTE: 





19 


Partnership Opportunities Application Form 

This form is for individuals and companies (or other legal entities) who wish to participate in 

The Investment Migration Forum 2024 as a partner. 

1. Partnership details 

Partnership package 

Fee 

2. Billing Information 

Please complete as you want it to appear on the invoice - note all fields MUST be completed. 

Company 

Name 

IMC Membership No. 

(If applicable) 

Surname 

Address 

City 

Country 

Email 

Post Code/ 

Zipcode 

Telephone 

VAT Number 

(If applicable) 


3. Declaration 

I certify that I am authorised to sign this application and enter into this contract on behalf of the abovenamed 

company: 

Authorised Signature 

Name & Surname 

Date 

Contact details of the person managing your participation: 

Name & Surname 

Email 

Please sign, and return to: 

Tatiana Muntean, Director of Stakeholder Relations 

Email:events@investmentmigration.org 

Tel/Whatsapp: +1 215 510 0156 



Visibility Opportunities for Your Business 

The Investment Migration Council provides numerous opportunities to increase 

your corporate visibility and to enhance your Business Growth 

investmentmigration.org/partner-with-us/ 


Introduction 

The IMC provides a range of high-quality and specifically targeted 

promotional channels; these include the IMC website (which benefits from a 

sustainable Introduction 

subscriber growth), as well as Email Newsletter software which is 

targeted towards specialised niche segments of the market. 

Introduction 

The 

The 



Media 

provides 

Channels 

a range 

provide 

of high-quality 

cost-effective, 

and specifically 

measurable 

targeted 

and 

results-oriented 

promotional channels; 

means 

these 

of enhancing 

include the 

your 


business 

website (which 

development. 

benefits from a 

sustainable subscriber growth), as well as Email Newsletter software which is 

This targeted document towards is designed specialised to niche provide segments a deeper of the knowledge market. about the IMC 

Visibilty Opportunities. 

The IMC Media Channels provide cost-effective, measurable and 

Please results-oriented contact us means on info@investmentmigration.org of enhancing your business development. 

for more details. 

This document is designed to provide a deeper knowledge about the IMC 

Visibilty Opportunities. 

Please contact us on info@investmentmigration.org for more details. 

Reasons to to partner with with us us 

Precise Audience Targeting 

When partnering with the IMC, you 

Reasons to partner with us 

know that your message will reach 

a specialised target audience which 

suits your business interests. 

Precise Audience Targeting 

When partnering with the IMC, you 

High-Quality Content 

know that your message will reach 

Both 

a specialised 

the IMC website 

target 

and 

audience 

e-Newsletters, 

which 

offer suits high-quality your business content interests. that attracts 

industry professionals, thus giving your 

advertising more opportunities to be 

seen by the right audience. 

High-Quality Content 

Both the IMC website and e-Newsletters, 

offer high-quality content that attracts 

industry professionals, thus giving your 

advertising more opportunities to be 

seen by the right audience. 

Exclusivity of one advertiser 

per opportunity 

All IMC Visibility Opportunities are limited 

to one partner per medium/package. 

Exclusivity of one advertiser 

per opportunity 

Extensive post-campaign 

reporting 

All IMC Visibility Opportunities are limited 

to one partner per medium/package. 

Each partner will be provided with 

a detailed post-campaign report which 

will be compiled for you by the 

Extensive IMC team. post-campaign 

reporting 

Each partner will be provided with 

a detailed post-campaign report which 

will be compiled for you by the 

IMC team. 


Membership Facts 

Membership Facts 

IMC Members represent companies and are industry professionals with proven expertise 

and a good reputation within the field around the globe. 

f. 2 % 

g. 1 % 

e. 7 % 

h. 1 % 

b. 14 % h 

Oceana 

a Europe 

b 

Middle East 

d. 11 % 

c 

Asia 

c. 11 % a. 53% 

d 

USA & Canada 

e 

Caribbean 

f 

Africa 

g 

South America 

(July 2022) 

Our Members - - Your Audience 

Our Members include the world’s leading industry professionals, service 

providers, academics and government officials who are dealing with investor migration 

and representing the following sectors: 

- Citizenship-by-investment Consultancy 

- Immigration Law 

- Wealth Management 

- Financial Advisory 

- Private Banking 

- Government and Academia 


Website Facts 

Website Facts 

Key traffic channels: 

d. 8 % 

e. 1 % 

c. 15 % a. 48 % 

a Direct Traffic 

b Organic Search 

c Social Media 

d Referral from partner sites 

e Email Marketing 

(July 2022) 

Here are our top 5 visited pages on IMC’s official website: 

1. Home Page: a lively hub of activity 

2. Membership: dedicated information about membership 

3. News: latest News, Articles and Reports, all industry focussed 

4. About: a comprehensive breakdown of insider’s information 

5. Contact Us: popular page about the IMC and its global locations 


Visibility Opportunities 

Visibility Opportunities 

The IMC Website 

Our website is an informational platform for industry stakeholders who are exploring 

latest updates within the RCBI Industry. The website is regularly updated with the latest 

industry-related news, articles, academic papers and the latest overview 

of residency- and citizenship-by-investment programmes from around the world. 

IMC website Key Performance Indicators: 

7.800 sessions 

Average visits per month 

+85% new users annually 

Constantly growing audience 

Accessed from 150+ countries 

Global Reach 

2 pages per session 

Average page views 

65% desktop 

35% mobile & tablets 

Technology 

Top 25 Geo-locations 

4 

18 

17 

7 11 25 8 

21 22 

13 12 

9 

10 15 23 

24 

2 

5 

1 

3 

14 

6 

20 

19 

16 

(July 2022) 


1. Horizontal Banner on top visited pages 

1. Horizontal Banner on top visited pages 

This opportunity offers a hyper-linked horizontal banner at the base of the page of the 

This opportunity offers a hyper-linked horizontal banner at the base of the page 

most visited sections of IMC website, such as the Homepage, “About Us” section and 

of the most visited sections of IMC website, such as the Homepage, “About Us” 

“Membership” page and limited to one banner per page. 

section and “Membership” page and limited to one banner per page. 

Your Brand Here! 

Size: 728px x 90 px 

In partnership with 




Page / location 

6 months 

Homepage €3,500 

Membership €3,000 

About Us €2,500 

The Governing Board €2,500 

The Advisory Committee €2,500 


2. Standard Horizontal Banner on Knowledge pages 

2. Standard Horizontal Banner on Knowledge pages 

The IMC website is regularly updated with industry-related news and articles. 

This The information IMC website is is published regularly under updated the “Knowledge” with industry-related section and news consists and of articles. news, 

thought This information leadership, is reports published & papers under and the newsletter-related “Knowledge” section pages. and consists of news, 

thought leadership, reports & papers and newsletter-related pages. 







Page / location 

6 months 

Contact Us €2,500 

News €2,000 

Thought Leadership €2,000 

Reports & Papers €1,500 


e-Newsletter Overview 

We issue regular email newsletters that are sent to senior and influential 

stakeholders of the industry. Each of our email newsletters feature high-quality 

content. This medium offers a deep insight into readers’ behaviours, covering 

aspects such as open rates and links clicked, amongst other metrics. 

There are three types of Newsletters that are issued by the IMC: 

• Members News Round-up – issued once a month (12 per year) 

• IMC Crossing Borders Bulletin – issued every quarter (4 per year) 

• Corporate Announcements - exclusive dedicated messaging to deliver a specific, 

important message to a selected audience (more details on page 14) 

Email marketing communications issued by the 

IMC have a proven track record: 

Average open rate of 51% 

Low unsubscribe rate 

Consistent increase in the 

subscribing audience 


3. Members News Round-Up 

3. News Round-Up 

The “Members News Round-up” is a regular e-Newsletter issue that provides readers 

The 

with 

“Members 

a selection 

News 

of the 

Round-up” 

latest news 

is a regular 

and developments 

e-Newsletter issue 

within 

that 

the 

provides 

industry. All articles are 

readers objective with and a selection industry-related of the latest only. news and developments within the 

industry. All articles are objective and industry-related only. 

Description 

1 month 

(2 mail-shots) 

3 months 

(6 mail-shots) 

One banner located at the very top of the newsletter template 

which is the prime spot visibility-wise 

One industry-related press release 

Press release to be published on the website 

€1,000 €2,500 

Banner Specifications: 

Target Audience: 

IMC Members 

File type: 

.jpg, .jpeg, 72 dpi 

Frequency: 

Banner Position: 

Every month 

Prime position at the top 

Reports: 

2 reports per mail-shot 

(1 and 2 weeks after email is sent out) 

Size: 

600px x 200 px 


4. 4. IMC IMC Crossing Borders Bulletin 

The The IMC IMC Crossing Crossing Borders Borders Bulletin Bulletin is is a a quarterly email email newsletter with with valuable valuable interesting 

industry-related content. content. Each Each issue issue of of the the IMC IMC Bulletin, Bulletin, which which begins begins with with a a welcome note note 

by by the the CEO CEO or or a a guest guest editor, editor, features features articles articles that that are are contributed by by IMC IMC Members as as well well 

as as by by members of of the the Advisory Committee, academics and and prominent contributors. A A list list of of 

recently recently joined joined members is is also also included. The The Bulletin Bulletin is is sent, sent, personally addressed (Dear (Dear Dr 

Smith, Dr Smith, etc.), etc.), to more to more than than 1,600 1,600 recipients, recipients, and enjoys and enjoys a sustainable a sustainable opening opening rate rate of 20%. of 20%. 

Description 1 issue 2 issues 

Two hyperlinked banners (details below) 

One paid industry-related article 

One featured event to be displayed at the top of the events section 

Banner to be placed in the News Section on the IMC Website 

(only if two issues are purchased) 

€5,000 €9,000 

Banner Specifications: 


Frequency: 

Position: 

IMC Members, IMC Subscribers, IMC 

Contacts 

4 issues per year 

1 banner after editorial 

and 1 after articles 

Size: 

File type: 

Reports: 

600px x 200px 

.jpg, .jpeg, 72 dpi 

2 reports per main-shot 

(1 and 2 weeks after email is sent out) 


5. Corporate Announcements via Dedicated Email Shots 

5. Corporate Announcements via Dedicated Email Shots 

The IMC Corporate Announcement provides a unique opportunity to deliver a message 

to 

The 

all 



Corporate 

Members, 

Announcement 

with a possibility 

provides 

of selection 

a unique 

by line 

opportunity 

of business 

to 

or 

deliver 

by country 

a message 

to 

of citizenship/business. 

all IMC Members, with 

This 

a possibility 

message can 

of selection 

contain an 

by 

important 

line of business 

Press Release, 

or by country 

of 

Call 

citizenship/business. 

for a Collaboration or 

This 

any 

message 

other objective 

can contain 

and industry-related 

an important Press 

update. 

Release, 

Call for a Collaboration or any other objective and industry-related update. 

Description 

Format: 

Dedicated email template containing two hyperlinked banners, text 

(up to 200 words) and a ‘Read More’ link to only one website 

1 mailshot 

€6,000 

The Announcement includes the following: 

One banner at the top of the page 

One Face photo with name and title on the left (will appear as 

paragraph breakdown on device version) 

One banner under “read more” button 

One article up to 200 words 


Can be pre-identified according to the country, membership status 

(members, leads, etc.) and line of business. 

Service includes: 

Creation of a newsletter using IMC template & content provided 

Provision of a newsletter preview for approval 

Sending of a newsletter to agreed Target Group (contact lists) 

2 post-campaign reports will be provided (1 and 2 weeks after email is sent out) 

Creation of customised template or campaign design is available on request at an 

additional cost. Contact us on info@investmentmigration.org for more details. 


Save the Date 

The Investment 

Migration Forum 

16 th -19 th April 2024 

The Ritz-Carlton DIFC, 

Dubai, United Arab Emirates 

Opening doors to immigration with a 

well-managed, forward-thinking, 

inspiring, and proactive policy can not 

only enrich a nation culturally but also 

significantly contribute to its economic 

growth and social well-being. 

IM Yearbook 2024, pgs 63-64 

investmentmigration.org 

Organisation in Special Consultative Status 

with the Economic and Social Council of the 

United Nations since 2019 

ISBN 978-2-8399-4156-3 

Commission Européenne / European Commission Joint 

Transparency Register Secretariat ID: 337639131420-09

IM Yearbook 2024

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