IM Yearbook 2020/21

IM
INVESTMENT
MIGRATION
Win-Win
Pathways
TO Sustainable
Development
YEARBOOK 2020/2021
Affordable and
Clean Energy
Peace, Justice and
Strong Institutions
Reduced Inequalities
Life on Land
Gender Equality
Life Below Water
Clean Water & Sanitation
Sustainable Cities
and Communities
Climate Action

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from IMC Education and Training:
Given the level of scrutiny and challenge that the
Investment Migration (IM) industry is currently facing,
now – more than ever – we need to demonstrate high
standards of integrity and processes.
As the IM industry matures and its popularity increases,
there is a pressing need to demonstrate that the
sector can regulate itself in an appropriate and
professional manner.
The IMC continues to honour its commitment of
setting standards of best practice and enhanced
professionalism. That is why the IMC established an
Education and Training division (IMCET) that is
mandated with the task of creating a globally
standardised education and training framework
for the IM ecosystem.
The professionalisation of the industry (including entry
cornerstone of responsible growth and development for
the future that should be welcomed by all those within and
those evaluating the status and value of the IM industry.
The
and only course of its type, worldwide, was launched
by the IMC during the IM Forum in Geneva in June 2019.
It is aimed to prepare its participants for work in this
competency – thus increasing the sector’s credibility
and providing transparency within it.
designation: Cert (IM)
The Objectives of the IMC Education and Training Division (IMCET)
The development of professional
competencies and standards for
those working in the IM industry
Learning opportunities that lead
to IMC professional status
The delivery of cutting –
edge professional training
and ongoing competency
development
Education and training for
Promoting integrity, ethics,
transparency and best practices
through education
To register visit https://investmentmigration.org/education/
Organisation in Special Consultative Status with the Economic and Social Council of the United Nations since 2019
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Contents
In Data
KEY FACTS & FIGURES
Doubling Down on Progress and Purpose
INDUSTRY OVERVIEW
Transparency & Accountability Will Lead to Credibility
INTERVIEW WITH MARIO GUTIERREZ, MACROECONOMIC
ADVISOR OF THE INTERNATIONAL MONETARY FUND
Investment Migration’s Great Inflection Point
COVID-19 IMPACT
The Rise of the Regional Citizen
INTERVIEW WITH KRISTIN SURAK, ASSISTANT PROFESSOR
AT THE LONDON SCHOOL OF ECONOMICS
Talking Economic Impact and Opportunity
INTERVIEW WITH BRUNO L’ECUYER, CEO OF THE
INVESTMENT MIGRATION COUNCIL
The EU’s Perspective on Investment Migration
BRUSSELS LEAKS
Why the EU’s Top Court Should Clarify EU Law
INTERVIEW WITH ELENA BASHESKA, LEGAL RESEARCHER AND
EU/INTERNATIONAL AFFAIRS CONSULTANT/ADVISOR
Corruption is the Real Risk
INTERVIEW WITH KIERON SHARP, CEO OF FACT GROUP
From Response to Recovery: Antigua and Barbuda
Prepares its Post-Pandemic Economy
SPECIAL FEATURE: ANTIGUA AND BARBUDA
Leading Back into Growth
INTERVIEW WITH GASTON BROWNE, PRIME
MINISTER OF ANTIGUA AND BARBUDA
Unwrapping our Cover Story
INTERVIEW WITH ANDRES SOLIMANO, FOUNDER AND CHAIRMAN OF THE
INTERNATIONAL CENTER FOR GLOBALIZATION AND DEVELOPMENT
Towards a New Impact Agenda
PHILIPPE FORET and JOHN CROWLEY
What’s going on in…
A SNAPSHOT OF KEY DEVELOPMENTS IN THE WORLD’S MOST
IMPORTANT INVESTMENT MIGRATION MARKETS
PROGRAMME UPDATES
Three Questions with Nestor Alfred
CEO OF THE ST. LUCIA CIU
Montenegro Seeks to Accelerate Economic Growth
INTERVIEW WITH DEJAN MEDOJEVIC, HEAD OF THE SECRETARIAT FOR
DEVELOPMENT PROJECTS OF THE GOVERNMENT OF MONTENEGRO
Three Questions with Somchai Soongswan,
PRESIDENT THAILAND PRIVILEGE CARD COMPANY
The Spirit of Dialogue
INTERVIEW WITH ALEX MUSCAT, MALTA’S PARLIAMENTARY
SECRETARY FOR CITIZENSHIP AND COMMUNITIES
From the Ground Up: St. Lucia’s Ever-Evolving CIP Pre And Post Covid-19
BRENDA FLOSSIG FLEMIG AND KEITH ISAAC
2
Investment Migration Yearbook 2O2O/2O21

60
62
63
65
68
70
75
76
83
89
91
92
96
98
100
102
104
An Entrepreneurial Difference
FIRST PERSON: BOB KRAFT, PRESIDENT AND CEO OF FIRSTPATHWAY PARTNERS
Lessons from Lockdown: MRVA Sees Productivity Surge during Covid-19 Crisis
CHARLES MIZZI, CEO OF THE MALTA RESIDENCY VISA AGENCY
American RCBI Investors: A Huge Market Waiting to be Explored
ROGELIO CACERES, FOUNDER AND CEO OF RCG GLOBAL
The Many Faces of Business Migration
PRODUCT DEVELOPMENT
Entrepreneur Visa Programmes Will See Explosive Growth
INTERVIEW WITH CHAD ELLSWORTH, PARTNER AT FRAGOMEN
Industry Certification Fast Becoming the New Standard
INTERVIEW WITH MARIE LOU CUTAJAR, EDUCATION AND TRAINING
ADMINISTRATOR OF THE INVESTMENT MIGRATION COUNCIL
Working with Those You Trust: The Importance
of Experienced Insurance Partners
MARK AND KEITH LAFERLA
Never Miss a Red Flag: Is the Standardisation of
Due Diligence the Way Forward?
DUE DILIGENCE ROUNDTABLE WITH INSIGHTS FROM
EXIGER, FACT, REFINITIV AND BDO
Real Estate Investment Options: Here to Stay
REAL ESTATE INSIGHTS
Don’t Be the Last to Know: The Importance of Monitoring
KAREN KELLY, DIRECTOR OF STRATEGY AND DEVELOPMENT AT EXIGER
How we Conduct In-Country Check in a Covid World
EDDY LEVITEN, COO OF FACT GROUP
Navigating a Changing Mobility Landscape
C-SUITE INSIGHT: HENLEY & PARTNERS
Explained: Permanent Residency Permit in Cyprus
FIVE QUESTIONS WITH ANNA GRIGORIEVA
Investing in a Global Britain
INTERVIEW WITH RUPERT GATHER, CHAIRMAN OF INVESTUK
Southeast Asia’s Growth will Outpace China’s
IN CONVERSATION WITH PARAG KHANA, GLOBAL STRATEGY
ADVISOR, AUTHOR AND FOUNDER OF FUTUREMAP
The IMPORTANCE OF EB-5 DUE DILIGENCE
NOREEN HOGAN, PRESIDENT OF CMB REGIONAL CENTERS
Who’s Who
DIRECTORY OF THE PEOPLE YOU NEED TO KNOW
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YEARBOOK 2020/2021
All rights reserved. Reproduction in whole or part is strictly prohibited without
the written permission of the publisher. Opinions expressed in IM Yearbook are
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ensure truth and accuracy, but the editor and publisher cannot be held responsible
for errors or omissions in articles, advertising, photographs, or illustrations.
Interested?
Contact:
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Publication Date: November 2020 • Printing: Gutenberg Press
Publisher: Investment Migration Council - info@investmentmigration.org
Editor: Sonja Lindenberg - sonja@storycom.net • Design: Ramon Micallef - ram@box-design.net
Cover illustration: Giulia Micallef - giuliamicallef@gmail.com • ISBN Nº: 978-99957-1-538-0
Investment Migration Yearbook 2O2O/2O21 3

The 5 th Investment Migration Forum
Save the Date
1 st - 4th June 2020
Save the Date
14th-16th June
2021
The 6 TH Investment
Migration Forum
investmentmigrationforum.org
investmigrationforum.org

INDATA
Key Facts
and Figures
100-60-30
There has been an explosion in the investment migration market in recent
years, with as many as 100 countries now offering some of form investment
migration pathway. Around 60 jurisdictions are actively promoting their
pathway and 30 pathways are attracting the largest share of applicants.
In perspective: Seven G-20 members operate some form of investment migration pathways
Migration and
Millionaires –
A Global Overview
in Facts and
Figures
Growth and
expansion have
defined investment
migration in the past
years – a sector
that is intertwined
with global wealth
creation and the
movement of people.
5,000
people are estimated to naturalize
abroad per year via a citizenshipby-investment
programme,
according to the IMC.
30%
Roughly 30% of migrating highnet-worth
individuals come
into countries using investor
migration pathways, New
World Wealth found out. The
majority still come in via work
transfers, citizenship by ancestry,
spousal visa and family visa.
4+ million
people are given residence and
citizenship rights in the EU via
other avenues than investment
migration every year.
Investment Migration Yearbook 2O2O/2O21 5

INDATA
Citizenship
Programmes:
Antigua & Barbuda
Austria
Bulgaria
Cambodia
Cyprus (suspended)
Dominica
Egypt (upcoming)
Grenada
Jordan
Malta (closed)
Moldova (suspended)
Montenegro
St. Kitts & Nevis
St. Lucia
Turkey
Vanuatu
1984
The year when St. Kitts
and Nevis introduced the
first CBI programme.
10%
of all programmes have
been established and
replaced with revised
versions between 2000
and 2015, research
trio Alan Gamlen,
Chris Kutarna and
Ashby Monk found out.
Top Residence
Programmes:
Anguilla
Australia
Canada
Cyprus
France
Greece
Hong Kong
Ireland
Italy
Jersey
Latvia
Malaysia (suspended)
Malta
Monaco
New Zealand
Portugal
Singapore
Spain
Thailand
UAE
UK
USA
90%
of investment
programmes are located
in high income countries
(63%) and upper middleincome
countries (30%).
400+
Timeline:
1984 St. Kitts and Nevis
1993 Dominica
2009 Bulgaria
2013 Antigua & Barbuda
2013 Cyprus
2013 Grenada
2014 Malta
2015 St. Lucia
2017 Turkey
2017 Vanuatu (already ran a programme in the 1990s)
2018 Moldova
2019 Jordan
2019 Montenegro
Several other countries had citizenship
pathways in place at different times in the past.
These include Ireland, whose programme was
terminated in 2001, Belize (until 2002), Cape
Verde, Seychelles, Slovakia, and several others.
550+
Small businesses and
consultancies dominate
the investment migration
sector. There are some
550+ agents licensed
across the world.
80%+
Chinese nationals
account for
approximately 80% of
applicants to any RBI
programme in the world.
Number of IMC members coming
from 45 different countries
$3 billion
Value of citizenshipby-investment
€9.2 billion
European countries benefited from investment migration
by receiving €9.2 billion during the 2008-2018 period,
the European Parliament Research Service revealed.
Rising Economic
Importance
Investment migration pathways
contribute anything between 2%
and 30% to countries’ GDP, and
many experts believe that the
programmes’ economic importance
will only rise as countries face Covid-
19 challenges on many fronts.
Up to 50%
Researchers estimate that more
than a third and possibly as many
as half of all investment migration
programmes target applicants
with wealth in the single-digit
millions and require a more passive
investment combined with few
residence requirements.
$100,000
to
$2.4 million
Range of minimum investment
required by different CBI
programmes around the world
6
Investment Migration Yearbook 2O2O/2O21

750 Million
People Would
Like to Move
More than 750 million
people worldwide - 15% of
the world’s adults - would
migrate if they could, a
Gallup World Poll survey
found out in 2017. The
countries where potential
migrants say they would
like to move to have more
or less been the same for
the past decade. Roughly
18 countries attract twothirds
of all potential
migrants worldwide. One
in five potential migrants
(21%) name the US as their
desired future residence.
Canada, Germany, France,
Australia and the United
Kingdom each appeal to
more than 30 million adults.
Record High:
272 Million
International
Migrants
In 2019, the number of migrants
globally reached an estimated 272
million, the UN’s 2020 World Migration
Report revealed. That’s 51 million
more than in 2010 and almost 100
million more than in 2000. The UN
projects that there will be 405 million
international migrants by 2050.
36% of HNWI have
a Second Passport
According to Knight Frank, 36% of
high-net-worth individuals already
hold a second citizenship, with 26%
planning to emigrate permanently.
Countries with the
Most Millionaires:
USA and China
For the past decade, global
wealth creation has focused on
China and the United States,
according to Credit Suisse’s
Global Wealth Report 2019.
The United States accounts
for 40% of dollar millionaires
worldwide and for 40% of
those in the top 1% of global
wealth distribution. However,
China overtook the United
States to become the country with most people
in the top 10% of global wealth distribution.
The number of new millionaires worldwide
was relatively modest, up 1.1 million to 46.8
million. The United States added 675,000
newcomers, more than half of the global
total. Japan and China each contributed
more than 150,000, but Australia lost 124,000
millionaires following a fall in average wealth.
Rising
Number of
Ultra-Wealthy
The world’s UHNWI
population – those with
a net worth of US$30
million or more – rose by
6.4% in the 12 months to
January 2020, according
to Knight Frank’s Wealth
Report 2020. Globally,
there are a total of
513,244 UHNWIs. The
US counts 240,575
people worth more than
US$30 million – nearly
quadruple that of the
next most concentrated
country, China, which
has 61,587 UHNWIs, and
more than Europe and
Asia combined. Knight
Frank predicts that Asia’s
UHNWI population will
grow by 44% over the
next five years, followed
by Africa at 32%. The US
will continue to dominate
in terms of gross
number of UHNWIs by
2024, with an additional
22% joining the ranks
of the super-rich.
150-170 countries
City Appeal
Large and dynamic global cities are
popular among the wealthy. New York
City is home to more ultra-wealthy
individuals than any other city in
the world, with 120,605 residents
worth US$5 million or more. That’s
according to data firm Wealth-X’s
latest report, “A Decade of Wealth.”
Tokyo and Hong Kong make it to
position two and three respectively.
Among the top 30 fastest growing
cities only four are in the US, the
other 26 cities are all in China.
Cities to Watch
Melbourne (Australia), Delhi (India),
Dubai (UAE), Hanzghou (China) and
Tel Aviv (Israel) cities are expected
to grow strongly in terms of total
wealth held over the next decade,
according to New World Wealth’s
Global Wealth Migration Review 2019.
AN EU passport typically allows visa-free
travel to between 150 and 170 countries.
Number of Millionaires
Worldwide Triples in 20 Years
The number of millionaires worldwide nearly
tripled in the last two decades, according to the
2019 Global Wealth Report published by Boston
Consulting Group. More than 24 million people
around the globe had reportedly personal wealth
valuing $ 1 million or more at the end of 2019. In
1999, this number stood at 8.9 million people.
Wealth Groups
90% of all wealthy individuals have a net worth
of between $1m and $5m, Wealth X claims.
Only about one in every 10 of the world’s
millionaires falls into the VHNW group, while
just 1.2% are UHNW individuals. However, when
taking into consideration the proportion of
total wealth held across the three tiers, those
in the lowest wealth bracket of $1m to $5m
account for around 40% of global millionaire
net worth. The cohort of VHNW individuals
command a share of just over 25%, while
the relatively small UHNW population holds a
combined 35% of global millionaire wealth.
Global wealth is expected to rise by 43% over the next decade, reaching US$291 trillion
by 2028, according to New World Wealth’s Global Wealth Migration Review 2019. This will be
driven by strong growth in Asia influenced by countries such as Vietnam, India and China.
Investment Migration Yearbook 2O2O/2O21 7

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INDUSTRY OVERVIEW
DOUBLING
DOWN ON
PROGRESS
What was once a niche industry has matured and proliferated with a host of new
investment migration pathways emerging around the globe. Amid changing market
dynamics and growing opposition, the sector is now rising to the challenge of
advancing positive trends and fast-tracking its own transformation journey.
The investment migration sector
began the year with nothing but
prosperity on the horizon. The
sector had evolved globally, with more
than 100 countries offering various forms
of investor visa options, including many
of the world’s richest countries such
as the US, UK and Australia. Growing
wealth in many of the sector’s main
source markets ensured that demand
from high-net-worth individuals
continued to expand at a robust pace.
Global organisations, including the
International Monetary Fund (IMF)
and the World Economic Forum (WEF),
described investment migration as one
of fastest growing economic enablers of
modern times for many small states.
A few months later, the sector is
contending with a wave of disruptive
forces. Amid the upheaval caused by
Covid-19, growth is shifting, investor
priorities are changing, and the level
of scrutiny is rising. The sector is still
growing, but also facing powerful
headwinds. The general consensus is that
investment migration’s future is full of
potential, but the industry must truly come
together to effectively address the genuine
concerns of international institutions.
Beyond the surface of this billion-dollar
industry, a lot of new and innovative
ideas are emerging that have the power to
transform investment migration into a tool
for sustainable and inclusive development.
A Long History
Investment migration is not a new
phenomenon. Some industry experts point
out that it was common in the Roman
Empire to grant citizenship in exchange for
money, while others say that in 17 th century
France, under Louis the Great, it became
a widespread practice to sell noble titles
to affluent commoners to finance wars.
Investment migration today is understood
to have its origins in the Caribbean when
St. Kitts and Nevis launched the first
citizenship-by-investment programme in
1984 as a tool for economic development.
Since then, the business model has
quickly evolved and was developed
further with the introduction of the golden
visa concept by Portugal. In 2010, four
EU member states hosted golden visa
programmes, just seven years later, nearly
half of all member states established
them. Investment migration has grown
into a global industry and is featured in
immigration law in most UN recognised
countries, albeit in different forms and
shapes. Globally, some 60 countries are
actively promoting their programmes, with
30 of them being the most relevant and
attracting the largest share of applicants.
Countries such as the US, Canada,
Australia, and the UK – all offering paths
for immigrant investors – have long been
among the favourite destinations of
high-net-worth individuals. Citizenshipby-investment
programmes are estimated
to receive 5,000 applications per year,
while tens of thousands of wealthy
migrants are acquiring golden visas
globally, generating billions in investments
that are being mobilised to create jobs
and encourage economic activity.
10
Investment Migration Yearbook 2O2O/2O21

AND PURPOSE
Evolution and Change
However, the market is in a state of
constant evolution and change. Some
pathways have been closed, others were
revised and relaunched. By far the greatest
number of residency- and citizenship-byinvestment
(RCBI) programmes has been
established in the years that followed the
2008 financial crisis when governments
were looking for new sources of income.
Once the exclusive domain of small island
states, the most recent entrants in the
market of investor citizenship are sizeable
countries such as Turkey and Jordan.
A relatively new phenomenon is
the emergence of start-up, entrepreneur
and nomad visa programmes, with
which governments seek to entice global
innovators and remote workers. Many
believe these programmes are setting
the stage for a positive evolution of the
product as these programmes are looked
upon in more favourable terms than the
more traditional RCBI programmes that
have never been far from controversy
and were often criticised by politicians,
the media and the public. The concept
of citizenship by investment in particular
stokes resentment that programmes
do little but allow the rich to buy
privileged access to their countries.
Fresh Controversy
The European Union has risen to the
fore as one of the industry’s harshest
critics, arguing that investment migration
programmes pose risks of money
laundering, security and corruption. The
European Parliament has called on EU
member states to phase out their schemes,
while the pressure kicked up another
notch when the European Commission
(EC) launched infringement procedures
against Malta and Cyprus over their
CBI programmes in October 2020. The
general feeling in the industry is that
the EC’s actions were accelerated by the
latest controversy surrounding Cyprus’
CBI programme, which was suspended
following a documentary by Al Jazeera
that implicates high-level politicians
in corruption related to the scheme.
While legal experts on both sides are
currently working on the big question
whether the EU has the right to interfere
in matters of citizenship and nationality,
many believe investment migration
programmes will need to address some
fundamental issues if they want to win
over the industry’s critics, change public
perception and ensure that the sector
continues to play an important role in
empowering struggling economies.
Important Income
Investment migration is estimated to be
a €20-billion industry, and programmes
represent anything between 2% and 30%
of GDP in some countries. Across the
world programmes have been a catalyst
for major infrastructural improvements,
including resorts, harbours, airports,
hospitals, office buildings and luxury
residential developments, which in turn
have had a massive multiplier effect
on the respective economies. These
programmes are not only influential in
delivering cutting-edge infrastructure,
investments into companies, start-ups
and R&D programmes; they are also
having the effect of generating whole
new economic sectors that did not exist
before their introduction. While these
programmes present a golden opportunity
for many countries, international
organisations such as the IMF are pointing
out that governments need to be stringent
in ensuring that the funds are channelled
towards productive investments that will
pay dividends in the future and not be
tempted to finance day-to-day expenses.
They equally acknowledge that income from
investment migration programmes provides
a vital source of funding for many countries
as the world is battling the impact of the
Covid-19 pandemic. This is especially true
for the Caribbean states whose income from
tourism dried up. It is likely that countries
that relied on RCBI income pre Covid-19 will
be even more reliant on it going forward.
A Year Like No Other
Although the investment migration industry
has continued to record considerable success
and a positive performance in 2020, the
pandemic has exposed the vulnerabilities
of existing structures and practices, forced a
change in status-quo and, at the same time,
opened a new window of opportunity. Travel
restrictions, border closures and quarantine
requirements during the pandemic outbreak
have severely curtailed global mobility
and visa-free access, one of the industry’s
key selling points. It is not yet known how
international travel will be affected in the
longer term. However, many in the industry
report that the ultra-wealthy are expressing
a greater interest in making long-term moves
or at least in relocating semi-permanently to
their new country of citizenship or residency,
which raises important questions about the
attractiveness of programmes and countries.
There are several answers to the
question what people will value in a postcoronavirus
world. One assumption is
that residency programmes will grow at
the expense of citizenship-by-investment
options, especially those of small island
nations as the countries are seen as
nothing more than a holiday destination.
Others say that the relatively weak Covid-
19 response of traditional immigration
nations, such as the US and the UK, could
negatively affect their attractiveness.
There is little doubt that the Covid-19
crisis is a challenge never witnessed before,
and many economies are bound to shrink
as a result of demand and supply shocks.
It is expected that the pandemic could
have a far more devastating impact on
the world economy than the 2008 global
financial crisis. This paves the way for a
further expansion of the supply side as
more programmes are expected to emerge
because of the financial stress caused by
Covid-19. Governments around the world
are looking for new revenue sources to aid
economic recovery, and just like after the
2008 global financial crisis, they might turn
to investment migration programmes to
attract fresh capital and fuel investment.
Investment Migration Yearbook 2O2O/2O21 11

A Changing Market
China has long been the dominant
market for the entire industry, accounting
for roughly 80% of applications to any
residence programme. In more recent
years, the industry has seen an increase in
business coming from new markets such
as India, Vietnam, Russia, South Africa
and Nigeria. In addition, a meaningful
shift is underway as applicants from firstworld
countries such as US and the UK are
showing interest in investment migration,
a remarkable development for an industry
that has traditionally zoomed in on highnet-worth
individuals from emerging
market economies. Surveys show that 17%
more British citizens per year have moved
to an EU country since the UK voted to
leave the EU. Meanwhile, 2020 also got
Americans consider moving out of the
US in ever greater numbers – many say
the unthinkable became thinkable due to
rising social instability and the country’s
poor coronavirus response. As a result of
travel restrictions, the US passport – once
one of the world’s strongest – has fallen
to the same level as some of the world’s
weakest. Southeast Asia is also developing
rapidly, both as a source market and as a
destination for high-net-worth individuals
from the region and beyond. Programmes
in Thailand, Malaysia and Singapore
are today attracting global interest.
The formation of a new international
mobility landscape is creating large
opportunities, particularly for companies
who understand how the dynamics of
global growth are shifting as the largest
emerging markets gain in importance.
In addition, regionalisation is a market
force the industry needs to be aware
of. An example of this trend is the
rise of citizenship-by-investment
programmes in the Middle East. The
programmes of Turkey and Jordan
mostly appeal to residents from the
region who are not charmed by visa-free
travel but by country-specific benefits
and commercial opportunities.
Full Transparency
In tandem with the growth of both the
demand and supply side, criticism of
the industry is intensifying. Fears of a
potential increase in security threats
and low consumer protection standards
reverberate across the entire sector.
Questions on transparency and adherence
to international standards on anti-money
laundering and compliance regulations
brought the sector into sharp focus
of other countries and international
organisations such as the EU, the IMF
and the OECD who have demanded
tighter controls across the industry and
tighter background checks on applicants.
Initiatives of the Investment Migration
Council, such as the development of
common due diligence standards and an
anti-bribery code, show that the industry
is recognising the need to either selfregulate
effectively or accept that rules
will be imposed on it. Recent scandals
and media reports, including Al Jazeera’s
investigations into the Cyprus programme,
are taken very seriously as they highlight
corruption as an area of vulnerability,
albeit this is not peculiar to investment
migration. A few bad actors can tarnish
the reputation of the whole industry. In
the presence of so much pressure, the
industry can only survive if every party
involved acts in a transparent manner.
It’s unfortunate that the sector still
remains largely unregulated, with only a
handful of countries having established
an independent regulator to oversee
the operation of their programmes. The
immediate challenge for the industry
is to get all industry stakeholders to
commit to the highest standards of
transparency and good governance.
Active versus Passive
A major task for programmes going
forward will be to find the right balance
between the needs of the country and
meeting the expectations of the applicants.
Up to now property investments of one
kind or another have featured prominently
in all programme offerings. Property
investment will always hold an appeal,
but it will be on a more equal footing
with other asset classes and investment
options. There are already alternatives
in the market that are resonating with
wealthy clients, including investing
in a property fund as opposed to
purchasing property, and loan provision
as opposed to equity investment.
There is also consensus in the industry
that in the future active investment will
play a much greater role than passive
investment as evidenced by the growing
number of entrepreneurial schemes which
are becoming ever more popular the world
over. The average age of multi-millionaires
in the world has decreased over the last
two decades. Service providers report
that in emerging market economies the
average age of applicants is between 35 and
45 years old, and many of them are young
entrepreneurs spurring demand for active
investment options as opposed to passive
alternatives. All the major destination
countries now offer entrepreneur visa
programmes, and the expectation is
that they will continue to experience
strong demand. Unlike traditional RCBI
programmes, they also often enjoy popular
support as countries seem to favour
immigrants who are actively engaged
in their workforce as opposed to those
who passively invest. Adopting elements
of these successful business and talent
migration programmes offers countries
various opportunities to build a lasting,
meaningful and substantive relationship
with their new residents or citizens.
Global Issues
Many argue that the most remarkable
side-effect of the Covid-19 pandemic has
been the pause. After years of exponential
growth, it gave the investment migration
industry a moment to breathe and
evaluate how it wants to evolve in the
future. In practice, emerging stronger from
the current situation requires forwardthinking
players who are taking steps to
own the solution, and over the past year
or so, sections of the industry have begun
developing new concepts. There is a
clear will to ensure that the sector works
for the greater good of all stakeholders.
Thus far, investment migration is often
overlooked as a factor within a country’s
overall sustainability and development
strategy. Aiming to lay a new foundation,
researchers are urging countries to align
their investment migration programmes
more closely to the United Nations’
2030 Sustainable Development Goals
(SDGs), highlighting that investment
migration can offer opportunities within
each aspect of the SDGs, most notably in
areas such as job creation, climate action
and health infrastructure. Meanwhile,
experts in the field of impact investment
are seeking to establish a new asset class
for investor migrants that aims to tackle
global issues such as climate change
and poverty reduction. Although it is
still early days for these initiatives, many
believe there is enormous potential in
questioning and challenging investor
preferences, as well as certain aspects
of the industry’s business model, so that
investment migration will unlock greater
economic benefit and societal value.
Future Outlook
Investment migration has gone through
enormous change since it started in the
1980s. It is today more diverse than ever
as illustrated by the growing number
of entrepreneur, start-up, innovator
and digital nomad visas available in the
marketplace that are competing with
the more traditional RCBI offering.
Like in every sector, business models
need to evolve over time. There is rising
awareness that the industry can reinvent
its business as one that is more socially
and economically attuned to today’s
societies. The Covid-19 pandemic, in
fact, offers the industry the ultimate
test scenario to find out what – beyond
visa-free travel and financial capital –
truly matters to investor migrants and
programme countries. Confronting and
responding to these dynamics should
provide a path to new growth.
12
Investment Migration Yearbook 2O2O/2O21

5 Questions with MARIO GUTIERREZ, Macroeconomic Advisor of the International Monetary Fund (IMF)
TRANSPARENCY
&ACCOUNTABILITY
WILL LEAD TO CREDIBILITY
CBI funds are an important source of revenue for Caribbean island nations, but
the programmes need to be administered more transparently and managed
more efficiently, says Mario Gutierrez of the International Monetary Fund.
What’s the current economic situation in the Caribbean
and what role are citizenship-by-investment
programmes playing in these countries?
All Caribbean economies are very reliant on tourism. They have
been affected quite badly by the coronavirus pandemic due to a
loss of travel revenue. Besides tourism, many Caribbean countries
do not have any other significant sources of foreign income.
Citizenship-by-investment (CBI) programmes are therefore
very important as those countries need to address a number of
economic and societal challenges. Their health and educational
systems – although we have seen improvements in recent years
– are still relatively weak, and there is a problem with brain
drain, with many educated and qualified professionals seeking
opportunities elsewhere. The Caribbean region is also prone
to natural disasters, such as Hurricane Maria that devastated
Dominica in 2017. So, in the past, CBI funds have been used
to re-build critical infrastructure. Given the current Covid-19
situation, it is difficult for many Caribbean countries to re-vitalise
CBI and their tourism industries, and it will certainly take a
number of years before the tourism sector has fully recovered.
How does the IMF view the investment migration industry?
In the view of the IMF, investment migration programmes are
an important source of revenue for many countries and have
the potential to stimulate economic activity and job creation.
However, wasting CBI funds is not good. Governance should
be improved and off-budget operations with CBI funds should
be discouraged. The full registration of CBI inflows in the
government’s budgets should be encouraged. In my opinion,
these programmes need to be above suspicion, and governments
need to be fully transparent in this regard. Accountability
and transparency are important measures to build credibility
and gain the trust of the international community.
I would also like to see a more targeted and efficient use
of CBI funds to address the Covid-19 crisis. With a view to
the current situation, countries should focus more on jobcreating
investments that will have a more lasting impact
compared to real estate investments, for example. Currently,
unemployment is rising, and countries should invest their
CBI funds in a way that they can generate income from it.
What policy decisions do you believe Caribbean
governments need to take to strengthen the
job-creating element in their programmes?
Projects that are earmarked to benefit from CBI funds need
to be thoroughly examined to ensure that they deliver a
good return for the country in terms of employment. I
suggest that countries develop a classification or ranking
system that evaluates potential projects according to the
direct and indirect impact on the creation of jobs. It could
be a good tool for public investment decision-making.
Then there are other measures. For example, the
Government of Dominica has just announced the
launching of an Entrepreneurship Visa programme
with lower disbursement as required in the regular
CBI programme. Applicants are required to invest in a
local venture in return for a two-year residency permit,
which can then lead to citizenship. I think entrepreneur
programmes are an interesting addition, and it is
something that could be replicated by other countries
in the region. After all, we do not yet know how stable
the CBI market will be in the coming years as a result of
Covid-19 and the related economic downturn. We might
see a decrease in the number of people actually having
the funds interested in investing in CBI programmes.
In your opinion, what are the prospects
of greater Caribbean cooperation in
the investment migration arena?
I think greater cooperation and the harmonisation
of rules will improve the industry for the benefit of
all countries operating such programmes. Without
coordination, there is a risk that countries will continue
to ease CBI requirements as a result of the competition
among the islands for the CBI pool of funds. This will
just reduce government revenues, whereas coordination
could also reduce administrative costs. We are aware
that all Caribbean countries have different interests and
are competitors, so this will be no easy task. However,
coming together is really in their own interest.
14
Investment Migration Yearbook 2O2O/2O21

What’s your economic outlook for the
Caribbean? How do you expect the region to
develop in the next three to five years?
I predict a slow recovery. In 2018-19 the region experienced
positive growth recovering from Hurricane Maria. This
year growth for the region will drop around 8.5 per cent
on average, before it might reach again levels above 4
to 5 per cent of GDP in a few years. In my opinion, the
next two years will be difficult, and a more prolonged
recovery will only start from the third year onwards. The
Caribbean countries should be extremely careful and
ensure CBI funds are put to good use. Otherwise we will
see countries building up very high external debts and,
ultimately, countries may find they are unable to pay.
Dr Mario Gutierrez has
more than 30 years of
professional experience
in advising developing
and poor countries and is
currently working as Marco
Economic Advisor for the
International Monetary
Fund (IMF) stationed in
Dominica. Previously,
he worked for the World
Bank, USAID, the Institute
of International Finance
and the International
Monetary Fund in Washington DC, as well as the
BIO
Central Bank of Chile. He has taught developing
economics at Georgetown University and
George Washington University in Washington
DC, as well as at Sciences-Po and American
University in Paris. In addition, he has produced
research for the World Bank and the European
Commission. He was born in Chile and holds a Ph.D
in Economics from the University of Chicago, US.
Investment Migration Yearbook 2O2O/2O21 15

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Investment Migration Yearbook 2O2O/2O21 17

COVID-19
IMPACT
INVESTMENT MIGRATION’S GREAT INFLECTION POINT
The coronavirus pandemic—for all its devastating impacts—
has the potential to transform the investment migration
industry into a more sustainable and acceptable industry.
18
Investment Migration Yearbook 2O2O/2O21

Covid-19 is upending the
investment migration industry
as it unfolds through 2020 and
beyond. Although investment migration
programmes have found increased
relevance in the pandemic, the worldwide
health crisis will undoubtedly
cause the industry landscape to reshuffle.
Like no other event before, Covid-19 is
shining a spotlight on the strengths and
weaknesses of the industry – many of
which existed long before the pandemic.
The coronavirus’ impact on travel
and mobility has been dramatic, and
although travel restrictions and border
closures were mostly temporary
measures, they are calling into question
investment migration’s primary role as
a tool to gain greater travel freedom.
The twin forces of lockdown and
health crisis will likely speed up a
positive evolution of the investment
migration product, which could
ultimately strengthen investor migrants’
connections with and contributions
to their host countries. In fact, many
in the industry believe the pandemic
can be a catalyst for change that
could lead to the development of new
programmes and financing tools, which
have the power and potential to endow
investment migration with a greater and
more sustainable economic impact.
Immediate Fallout
As the Covid-19 virus spread throughout
the world, governments across the globe
shut their borders or restricted travel
to try and quell the spread. However,
almost unanimously, the
investment migration
industry confirmed
that the immediate
fallout was limited.
While there might
have been some
early connectivity
challenges in
working remotely for
employees, for the most
part clients were looked
Eric
Major
after and advisors stayed busy.
Although applications were delayed,
most RBI and CBI units “quickly adjusted
to the pandemic. All of them now have
online platforms and have digitized the
process even more, which is a positive
development,” says Eric Major, CEO of
Latitude Consultancy Limited. Besides, he
says, the fact that there is currently very
little travelling going on, means many
busy entrepreneurs and investors finally
take the time to develop their ‘Plan B’.
Rise in Interest
Covid-19 provided a boost to the
investment migration industry, with many
businesses reporting a surge in enquiries.
“Following the initial shock, people
started looking for a second residency or
citizenship more actively than before. We
now receive many
requests from
people who are
in such a hurry
to get a golden
visa that they
would like to
conclude the
transaction
Alexander
Varnavas
‘yesterday’,
but the new
Covid-19 reality
has rendered the
process a little bit more difficult in terms of
time required,” says Alexander Varnavas,
a Partner at Varnavas Law Firm 1978 and a
Member of the IMC Advisory Committee.
Ron Klasko of Klasko Immigration Law
Partners in the US shares this view. While
he points out that many clients postponed
their migration plans during
the pandemic largely due
to travel restrictions,
he is convinced that
“the medium and
long-term future will
see an increase in
investment migration”.
For many in the
industry, investment
migration is among a
select number of sectors that
benefited from the pandemic.
Juerg Steffen, CEO of Henley &
Partners, says that the “the massive
volatility driven by Covid-19
has certainly pushed what we
considered a relatively steady
industry growth into overdrive”.
Changing Market Dynamics
Although the industry will likely
continue to enjoy significant growth,
Covid-19 is shaking up investment
migration’s long-established market
dynamics. Investment
migration has
ballooned in
popularity
in countries
which did not
handle the
pandemic well,
with agents
and service
Juerg
Steffen
Ron
Klasko
providers pointing to a growing client
base of first-world millionaires from
countries such as the US and the UK.
Many high-net-worth individuals have
added healthcare to their list of reasons why
they consider economic migration, says David
Borg, Advisory Partner of ARQ in Malta.
“Countries that have dealt with the situation
efficiently and can also prove that they have a
first-class medical infrastructure could stand
to benefit,” he says. However, Borg also points
out that given the speed with which the virus
took hold and crossed from one country
to the next, some
investor migrants
may wish to
remain close
to family and
economic
interests.
While
Covid-19
lockdowns
may be easing,
uncertainty about
the future is intensifying.
International experts argue that global
mobility might be more restricted and
unpredictable in the longer term. Some
are even concerned that governments
might use fears of a future pandemic
and other epidemiological
issues in order to impose new
immigration restrictions.
Although we can assume
that much of what is felt today is
temporary, if Covid-19 has taught
the industry anything, it’s that
global mobility cannot be taken for
granted. Besides, when the coronavirus
broke out, very few people thought it
would take so long, and it has left some to
wonder where best to live in times of crisis.
The Real Plan B
David
Borg
In the pre-Covid-19-
world, very few
applicants actually
moved to their
new country of
citizenship or
residence and
instead sought to
primarily benefit
from visa-free
travel opportunities.
However, during the
Savvas
Poyiadjis
pandemic, medium- and long-term
strategic relocations have gained in
importance. For many the Covid-19
crisis, says Savvas Poyiadjis, Managing
Director of Fides Corp, “has highlighted
even further the necessity or luxury of
Investment Migration Yearbook 2O2O/2O21 19

having a second passport or residency
as that allows for travelling and
relocation of family members to
safer countries than their own”.
Today many clients enquire
about the coronavirus
response of their
potential host country,
service providers say,
but the expectation
is that this will
not be the only
criteria determining
a country’s
attractiveness in the
future. Although it’s
too early to tell how many
investor migrants would move
semi-permanently or permanently,
many industry experts believe
countries offering diversified business
and lifestyle opportunities will be
most attractive. For many, investment
migration’s coronavirus winners are
residency programmes in both Europe
and Asia at the expense of programmes
in the Caribbean and those of other
small island states, whose paradiselike
remoteness is often cited as their
weak point from the perspective
of global entrepreneurs in need of
easy access to the world’s markets.
An Important Economic Tool
Covid-19 is an unprecedented shock to
the world economy, which is projected
to experience
its worst recession
since the Great
Depression
of the 1930s.
“Many
governments
are facing large
deficits and
will look to raise
capital. Investment
migration is
a logical solution
that can help all these issues,” says
Stéphane Tajick, President and Head
Advisor of Stephane Tajick Consulting
(STC). He expects new programmes
to come onto the market in the near
future. There is also the anticipation
that bigger countries will join the
investment migration arena, although
they are more likely to establish RBI
rather than CBI programmes.
Investment migration funds are
currently being used to help keep
economies afloat, with governments
Michael
Frendo
Stéphane
Tajick
clearly acknowledging how important
their programmes are to their economies
in this time of crisis. “Covid-19 has shown
the immense value of having a well and
transparently administered sovereign
fund arising from the global migration
industry, which can be utilised to
stabilise the economy during
the disastrous economic effect
of a pandemic,” says Michael
Frendo, Chairman of Frendo
Advisory in Malta, a country
which used revenue from
its CBI programme to bolster
its economic rescue package
following the Covid-19 outbreak.
A More Competitive Landscape
The need to generate new revenue
sources to support the economic recovery
post Covid-19 will almost certainly
lead to an expansion of the supply
side. This means competition between
countries offering investment migration
programmes will increase, which
may well push prices down. This can
impact programme revenues on which
many countries have become reliant.
In the post-Covid-19 era, countries
will need to rethink their programmes
and seek to strike the balance between
offering investment options that are
appealing to applicants while ensuring
that investment migrants’
contributions don’t fall
short on delivering
the desired
economic and
societal benefits.
From a
service provider
perspective, it
also seems likely
that competition
for clients might
increase. Covid-19
presented global markets
Edward
Bershara
with a severe test. Businesses everywhere
face immense disruption. Millions of
individuals are newly unemployed, and
the pandemic will almost certainly cause
global wealth to contract in the near
term. “As the world becomes poorer,
it can become harder to find wealthy
clients. Many in the industry will see a
fall in revenue. Investment migration
companies that were financially
unstable or overextended will face
difficulties. We might see closures,
downsizing or even mergers. The
weaker will perish but the stronger will
survive and thrive,” Tajick points out.
Positive Impact
The pandemic has highlighted the
interconnection of people and societies as it
has spread globally in a rapid manner. Much
like 9/11, Covid-19 is a defining moment
of historic proportions, in particular for
younger generations. Many policymakers
and investors are viewing the crisis as a
wake-up call that accelerates the need for a
different approach to investing, highlighting
parallels between the unforeseen risks
of a pandemic and issues such as climate
change. Over the long run, Covid-19 could
prove to be a major turning point for
sustainable investing and signal the start
of a more ethically balanced era for many
industries, including investment migration.
Much has been said and written about
the Great Reset, a term coined by the
World Economic Forum, which views the
pandemic as an opportunity to correct
past mistakes and build back better. The
green economy and sustainable initiatives
are central to many governments’ recovery
policies, with plans to invest and scale
up renewable energy, clean transport,
sustainable food production, while
diversifying supply chains and directing
funding towards essential industries
such as healthcare. There is widespread
agreement that investment migration
can make a meaningful contribution
to recovery packages that aim to build
better. The next generation of investor
migrants, which, unlike their parents,
has grown up discussing these issues,
will likely seek to pursue a positive
impact, and the investment migration
industry can survive and thrive
by adjusting to this new reality.
Post-Covid-19 Investment Migration
“Most high-net-worth investors and
companies agree that at the beginning
of 2021, there will be a return to a certain
degree of normality,” says Edward Bershara,
Managing Partner of Beshara Global
Migration Law Firm, and most industry
professionals agree with him. Yet, the
industry must think in mid and longterm
scenarios. What seems clear is that
Covid-19 has accelerated the industry’s
development – trends and issues expected
to affect the investment migration industry
over the next several years have been
compressed into a short few months. For
the investment migration industry, the
pandemic presents an opportunity to review
its current business model and analyse
how it could be redesigned to ensure a
resilient industry for years to come.
20
Investment Migration Yearbook 2O2O/2O21

Interview with KRISTIN SURAK, Assistant Professor at the London School of Economics
THE RISE OF THE GLOBAL
REGIONAL CITIZEN
Covid-19 will transform the investment migration market and will accelerate the
already existing trend of regionalisation, says Prof. Kristin Surak from the London
School of Economics and author of the forthcoming book Citizenship 4 Sale.
The Covid-19 pandemic has challenged
international mobility like no other
event before. What observations
about the investment migration
industry during the coronaviruscrisis
can you share with us?
Covid-19 has shown us that we need to
rethink the mobility aspect of investment
migration as travel bans and border
closures haven proven how fragile this
element is. But more than that: the crisis
clearly highlighted a key difference
between citizenship by investment and
residence by investment. Demand for
citizenship-by-investment programmes,
much more than demand for residence
programmes, has long been driven by
promises of easy mobility and visa-free
travel. However, a Caribbean passport
holder was not able to use his or her
90-day-visa-free access to Europe during
the first part of the global lockdown.
On the other hand, despite the Covid-
19 travel restrictions, the majority of
OECD countries were not only allowing
citizens but also those holding resident
status to enter. In other words: An
RBI-investment in places like Portugal
or Greece opened a closed border.
How is this affecting the attractiveness
of RBI and CBI programmes?
For those worried about not being able to
enter Europe, the traditional RBI countries
suddenly looked more appealing. Russia
is the exception, where during the height
of lockdown, a person needed a second
citizenship to leave the country. But that’s
the exception that proves the rule. The
pandemic has strengthened the demand
for a real insurance policy. This has shifted
the focus away from mere border crossing
and short-term mobility towards securing
rights in a place where one would want to
spend a longer stretch of time. First and
foremost, I believe this will trigger demand
for investment migration programmes
of bigger countries – countries that have
a lot more to offer in terms of business
and lifestyle opportunities compared
to the micro-states that pioneered this
industry. The Caribbean has yet to
convince a significant number of highnet-worth
individuals to move there.
I believe wealthy investors will
continue to express interest in the
European RBI programmes of Portugal,
Spain and Greece. I also think Turkey
will continue to build on its substantial
success. Its CBI programme has a
different pull for people than the
Caribbean options, or even the EU
option. Many of the benefits that it offers
are located within Turkey, although
it does offer benefits outside the
country in terms of travel and business
possibilities in Europe, too. Istanbul
is a global city and Turkey a regional
powerhouse. Its booming economy
and emerging market status make it
an interesting country for investors
to engage with, especially for those
wanting to do business in the region.
22
Investment Migration Yearbook 2O2O/2O21

In recent years, more and more
mass affluent people developed an
interest in investment migration
as programmes became ever more
affordable. How do you believe the
coronavirus pandemic will change
the industry’s client profile?
The mass affluent – those with investable
assets between US$1 and US$5 million
– have been hit hard by the pandemic.
Many of them generated their wealth
through entrepreneurial activities, and
their businesses are now dealing with
the fallout from the global recession.
These funds would otherwise be
available for investment migration but
have now been re-allocated to shore
up their businesses. For investment
migration programmes this means that
the pool of potential clients for less costly
options is smaller – at least for now.
Once the global economy recovers, we
may see the release of pent-up demand.
How will the coronavirus pandemic
reshape the market from the
supply side? Will we see new
countries entering the industry,
possibly in order to secure revenue
for a post-Covid recovery?
I am certain that we will see more
countries establish programmes of their
own. In terms of citizenship, there are
many rumours about who’s next to join the
industry. Solomon Islands is probably the
most commonly cited case. I don’t think
EU countries will introduce citizenship
programmes given the current negative
stance of the EU towards the sector. At the
same time, we see that many EU countries
are trying to find ways to kickstart
their economies post-Covid. There is a
fuzzy border between the more passive
residency-by-investment programmes
and the more active entrepreneurial
programmes. In the EU, we already have
a big spectrum of programmes that vary
both in terms of the letter of the law and
in terms of the application of the law. I am
predicting that in Europe we will see future
programmes couched in entrepreneurial
terms but with a more passive investment
form. Overall this will lead to a situation
where there will be more programmes
competing for fewer investors.
How will programmes need to respond
to these changing market dynamics?
Rather than dropping their prices,
I believe programmes should raise
them. Let’s look at the Caribbean. The
Caribbean has been hit hard by the
pandemic because tourism has stopped,
which is the only other sizeable source of
income for those countries. This means
the revenue they can get from their
investment migration programmes is ever
more important. Because the Caribbean
programmes are among the cheapest
options available, they have traditionally
seen strong interest from the mass affluent
segment, which, as I’ve already mentioned,
is diminishing. If the Caribbean CIPs now
drop their price point further in an effort
to attract clients, it can just plummet into
nothing. Rather than a race to the bottom,
I think it’s a good time to keep price points
level, if not increasing them a bit in a
coordinated action. People are often more
interested in a product that costs more.
We see that in many other markets, for
instance in the wine market, where the
price changes the way we perceive and
appreciate a wine. I think this is something
that the Caribbean should keep in mind,
especially as Covid-19 has made people
much more concerned to hedge their
risks. Other programmes should also
consider revamping their price points,
especially those that are doing well at the
moment. They can afford to become more
selective in terms of whom they accept.
Looking to the future, how do you
believe the industry will develop
in the coming five to ten years?
When people talk about the investment
migration market, they mostly think
of the Caribbean and the European
programmes, as well as the traditional
immigration countries such as the
UK, US, Canada, Australia and New
Zealand. RBI programmes in the Global
South are often off the radar, but they
are performing exceptionally well. As
a result of Covid-19, it could well be
that places in the Global South with
good healthcare systems become very
attractive in particular for investors from
the region who may now prefer to stay
closer to their homes. We should not
underestimate the effects of the pandemic
in terms of people’s willingness to travel.
Malaysia’s My Second Home is a good
example of investors’ rising preference
for regional options. The programme is
receiving more applications than any of
the European ones and is very popular
with the Chinese. There are programme
options in the UAE, Thailand, Taiwan,
Panama and many others which all might
see an increase in demand, especially
if capital continues to accumulate and
flow within the Global South. Europe
will continue to remain attractive for
Russian and Middle Eastern investors,
while for people from the Americas,
the Caribbean is a more convenient
option. Across the board, I believe we
will see greater regionalisation.
In the EU, we
already have a
big spectrum
of programmes that
vary both in terms of
the letter of the law
and in terms of the
application of the law.
Prof. Kristin Surak, London
BIO School of Economics, is
known for her research
on international migration,
nationalism and political sociology,
which has been translated into
a half-dozen languages. She
has been an invited fellow at
Princeton University, the Institute
for Advanced Study (Princeton)
and Cambridge University. In
addition to publishing in major
academic and intellectual
journals, she also writes regularly
for popular outlets, including
the London Review of Books, New
Statesman and Washington Post,
and comments for international
news agencies including the BBC,
Deutsche Welle and Channel News
Asia TV. Her book Citizenship 4
Sale: Millionaires, Microstates,
and Mobility will be published by
Harvard University Press in 2021.
Investment Migration Yearbook 2O2O/2O21 23

Interview with BRUNO L’ECUYER, Chief Executive of the Investment Migration Council
TALKING ECONOMIC
IMPACT AND
OPPORTUNITY
Investment migration has gotten plenty of public
and media attention in recent years; however, the
industry’s economic benefit has been largely kept on
the sidelines. Bruno L’ecuyer, CEO of the Investment
Migration Council (IMC), shares his thoughts and
opinions on the challenges, opportunities and outlines
the organisation’s plans and priorities for the future.
As Chief Executive of the IMC,
what issues are currently
high on your agenda?
Defining and setting common
standards for investment
migration continues to be
one of our top priorities. We
feel self-regulation can be an
effective and efficient means
of control for investment
migration, which would
definitely benefit from
more harmonised practices, but is not
as systemically risky as the financial
services industry for example. We are of
24
Investment Migration Yearbook 2O2O/2O21
the opinion that improving standards
and ensuring that our members adhere
to the established standards will help
the sector expand even further.
The growth of our own organisation
is also very high on our agenda. The
IMC currently has around 450 members
and has established itself as a credible
industry body. However, I believe
we can grow our membership base
further by engaging with professionals
from around the world. We are also
looking to diversifying our membership
and are working on attracting other
professionals that don’t necessarily
focus on investment migration
but facilitate talent and business
migration – a segment that is seeing
tremendous growth the world over. At
the moment these professionals are a
little bit outside our catchment area,
but if we want to see growth, we need to
diversify who we communicate to and
work for as an organisation and give
potential members reasons to join.
Supporting and facilitating the
development of global investment
migration rules has long been a
priority of the IMC. What progress
have you achieved thus far?
The launch of a code of ethics and
professional conduct standards for
the industry back in 2015 was one
of our first initiatives, and we have
subsequently launched an antibribery
and corruption code. We
strongly support the development
of enhanced common due diligence
standards to ensure only bona fide
applicants are approved across all
investment migration programmes.
We have commissioned and published
independent research into due
diligence with a view of creating a
common framework of guidelines for
governments and agents to adopt.
Currently, we are working on a
set of guidelines for the sales and
promotion of investment migration
programmes globally. We have
established a working group made
up of members from 10 different
countries who are looking into
how investment migration should
be promoted. We are in talks with
various governments on this too. In
many cases they are providing us
with their own frameworks, and we
are taking a helicopter view of the
all the different guidelines in order
to develop a best practice document
that outlines what to do and what to
avoid when promoting investment
migration programmes globally. I am
hopeful that the draft document will be
ready by the end of December 2020.

Investment migration appears to
be facing an increasingly hostile
environment, with several international
institutions and organisations
criticising the sector. How should
the industry show that it’s serious
about addressing these concerns?
Investment migration is a complex legal
and technical phenomenon, and it’s the
sovereign right of states to determine their
national migration policy. Nonetheless,
we are aware that some organisations
have concerns that need to be addressed,
and those are mostly relating to security,
money laundering and financing of
terrorism. However, out of those three,
the only one that is really a risk is money
laundering. The level of due diligence
involved in investment migration is so high
that it isn’t worth it for a terrorist to gain
access to a country through this route. In
fact, there isn’t a single reported case. In
our opinion, investor migrants neither
pose a security nor a terrorism threat.
From a money laundering perspective,
the risk is still there even though it is very
small. As an industry, we have to abide
by the global Anti Money Laundering
(AML) and Combatting the Financing of
Terrorism (CFT) regulations to ensure
that the people coming through are really
fit and proper. Everybody in the industry
needs to be aware of the rules, and there
are no exceptions. Small agents dealing
with two or three applications per year
need to ensure they know the source of
funds as much as governments handling
hundreds of applications throughout
the year need to properly investigate
this matter. In addition to doing what
is legally required from the industry, I
think the fact that we have developed
and published different guidelines and
standards is showing that we are serious
about addressing those concerns.
European Commission President
Ursula von der Leyen recently
referred to investment migration
in her State of the Union address,
pointing out that European values
were not for sale. In October
2020, the Commission launched
infringement procedures against
Malta and Cyprus. What comments
would you like to make about the
EU’s attitude towards the industry?
I am completely in agreement with Ursula
von der Leyen: European values should
not be for sale. But if we are concerned
about European values, why don’t we
look at introducing a European values
test? After all, citizenship tests are quite
common. When investor migrants are
coming through an investment migration
pathway of an EU member state, they
could be required to sit an online test on
European values. We have thrown that
idea around Brussels; it hasn’t picked
up too much, but it’s one idea that could
be explored and developed further.
Moreover, I am spending an
increasing amount of time continuing
our constructive discussions with the EU
and other international institutions by
providing them with information that
is up to date, for instance about the socalled
Cyprus Papers published by Al
Jazeera. Cyprus’ decision to suspend its
citizenship-by-investment programme
following the damming and quite frankly
shocking revelations is the right thing
to do. A proper investigation needs to
take place into the allegations that were
made and the context. Our experience
with media programmes like the one of
Al Jazeera is that often they are twisted
to achieve a specific goal, in this case
to damage the reputation of Cyprus. In
response to the infringement procedures
initiated by the European Commission
against Malta and Cyprus regarding their
citizenship by investment programme,
I like to point out that citizenship of
EU member states remains a national
competence. The division of competence
between the EU and its member states
is the central postulate on which the
Union is based, and the latter can
sovereignly decide which individuals
and under what circumstances they
should acquire their citizenship.
How do you believe the dialogue
with supranational institutions,
including the EU, OECD and
World Bank will evolve? And what
role does the IMC aim to play in
establishing a better relationship?
I’d like to point out that we weren’t
established as an advocacy group, but as a
membership body. Our primary aim was
and is to bring the investment migration
community together, introducing certain
common standards and ensuring that
governments from around the world have
a platform to talk about this kind of legal
migration. We have been talking to the
EU and other policy bodies for about a
year and a half now. Our motivation was
to let everybody in the policy circles know
that the investment migration industry is
represented by our organisation – a nonprofit
Swiss organisation – and that we are
here to act as a bridge of communication
between the industry and policymakers
who need information about the sector so
that they can make informed decisions.
In many ways, we have been highly
successful. We have published many
policy papers, we have been cited by
the European Parliamentary Research
Service, and the OECD monitors our
work. We have morphed a little bit into
a think tank, at least on the reporting
side. In the past, we focused on the legal
side of what investment migration is,
now we are emphasising the economic
value of investment migration. Recently,
we’ve published a report looking at the
UN Sustainable Development Goals and
how investment migration contributes
to many of the 17 important goals.
I am
completely
in agreement
with Ursula von der
Leyen: European
values should not
be for sale. But if
we are concerned
about European
values, why don’t we
look at introducing a
European values test?
Bruno L’ecuyer is the
BIO first Chief Executive
of the Investment
Migration Council, the worldwide
association of investor migration
professionals. Bruno leads the
Secretariat and is responsible
for all IMC operations. A regular
contributor to international
publications such as Forbes,
and speaker at conferences in
Europe, the Middle East and
Asia, he has held positions in
London, Paris and Hong Kong.
He has extensive expertise and
experience in the management
and expansion of a professional
services association. A member
of the Governing Board,
Bruno acts as its Secretary.
Investment Migration Yearbook 2O2O/2O21 25

When the news broke about covid-19,
you quickly realised this pandemic
would jeopardise the Investment
Migration Forum. How did you stay in
touch with the industry during this
challenging and uncertain time and
are you planning a Forum for 2021?
In March 2020, when the pandemic
brought travel to a standstill, we quickly
transformed the way we communicated
and launched the IMC Streaming Service
‘Crossing Borders’ on YouTube. To date,
we’ve hosted close to 70 Crossing Borders
programmes, which have welcomed more
than 200 speakers and attracted some
2,700 delegates from 60+ countries. The
programme has been quite successful and
is now a permanent fixture in our events
calendar with a monthly broadcast. All
of the previous broadcasts are available
free to view on our YouTube channel.
Nonetheless, we feel the need of
the industry to meet face to face again
and are planning to host the Investment
Migration Forum between the 14th and
17th June 2021 in Brussels, Belgium. We
are excited to bring the Forum to Brussels
for the first time. We had wonderful four
years in Geneva, Switzerland, but a lot
of our regular attendees expressed the
wish to discover another European city.
Given the increasing amount of time that
we spend in Brussels nowadays, Brussels
was a natural choice. Besides, we are
hoping to increase the participation of
European policymakers by bringing this
high-calibre event to their doorstep, which
would allow them to fit the Forum in
their busy schedules. Without the need
to travel, it will offer them an opportunity
to learn more about the sector and meet
the people who are involved. As an
industry, we often get accused of being
secretive and not very transparent. This
was perhaps true in the past, but the sector
has changed and evolved a lot. We are
very welcoming and want to advance the
dialogue with European institutions.
We have
morphed a
little bit into a
think tank, at least on
the reporting side. In
the past, we focused
on the legal side of
what investment
migration is, now we
are emphasising the
economic value of
investment migration.
26
Investment Migration Yearbook 2O2O/2O21
IMC STREAMING
Keeping our community
together and informed
67
broadcasts
since March 2020
77
LIVE POLLS
TO DELEGATES
2,697
delegates
343
QUESTIONS ASKED
Q A
67
SURVEYS
WITH 69%
SURVEY RESPONSE RATE
85.5
HOURS OF
LIVE STREAMING
83%
interest rating
AVERAGE AVERAGE
76%
attentiveness rating
What new membership initiatives do
you have in the pipeline, and what
else can the industry expect from the
IMC in the coming 12 to 24 months?
Covid-19 has accelerated our digitalisation
programme. We had a 12-18 months
programme aimed at digitalizing many
of our services for our members. This
has now been fast-tracked, and we are
working on a new website, which is
focused on the user experience. Our
members will be able to manage their
profile, get in touch with the community
and the IMC, as well as accessing
information, facts and figures about the
sector in a much more user-friendly way.
We will also be launching IMC
Fellow membership, the highest level of
membership. It is open to any individual
who has been a professional member
of the IMC for 5 consecutive years and
has 10+ years of working experience
with 3 years at senior level. We are
planning to launch the IMC Fellow
membership at the same time as the
website towards the end of 2020.
The IMC’s Education and Training
division (IMCET) has also been busy
and will be launching two new bespoke
courses shortly. We are also restructuring
the Certification in Investment Migration
and are planning to offer students the
opportunity to choose individual modules
of this very successful course. These bitesized
learning options are great news
for both employees and employers
What final message would you
like to share with the investment
migration community?
Migration is always going to be a divisive
issue that will elicit a lot of discussion
and various viewpoints, no matter what
category of migrants it is. We need to
raise awareness about the contribution
that investor migrants make in their
communities. Often, their contributions
go well beyond the financial investment
that is required as part of an investment
migration programme. There are many
examples around the world, unfortunately,
the media often ignores those positives
as they are not newsworthy. Take, for
example, the late Thai entrepreneur
Mr Vichai Srivaddhanprabha. He was
predominantly famous for investing in
Leicester Football club – at least that
is what media focused on. However,
he was a lot more than that. He was
an investment migrant in the UK who,
throughout his stay in Leicester city, gave
away £2m in donations towards a new
children’s hospital, and a £1m gift to the
city’s university medical department. I
think as an industry, we have a unique
opportunity to address economic and
societal disparities and bring about
positive and impactful change – and
we need to recognise the importance of
effectively communicating how we are
creating value for all stakeholders.

Brussels Leaks
THE EU’S PERSPECTIVES ON
INVESTMENT
MIGRATION
The IM Yearbook has brought together insights and analysis from the very heart
of the European Union. We are explaining the EU’s political realities, highlighting
policymakers’ views and opinions of investment migration and pointing out key
policy themes that will likely influence the industry in the years to come.
values are not for
sale.” That’s how Commission
“European
President Ursula von der
Leyen referred to investment migration
programmes in her State of the Union
address in September 2020. While,
in principle, many in the investment
migration industry agree with her
statement, the European Commission’s
decision to launch infringement procedures
against Malta and Cyprus in October 2020
has left many to wonder how the sector’s
relationship with the European Union
will continue to develop in the future.
The EU has sounded alarm on
various matters related to the investment
migration industry in recent years.
It warned that investment migration
programmes operating in the EU posed
risks of money laundering, security and
corruption, and that they enable the
circumvention of EU rules and lead to
the commodification of citizenship. The
Commission’s latest attempt to crack down
on investor citizenship programmes are
based on two arguments: The first one is
that investor citizenship is incompatible
with the very essence of EU citizenship
and the second one is that they go against
the principle of sincere cooperation.
Both raise important legal questions for
which answers have yet to be found.
Even through it is unlikely that the
EU will govern citizenship and residency
matters directly anytime soon, the work
of the institutions will increasingly
impact the operations of investment
migration programmes. There’s a long list
of themes and topics that the investment
migration industry should follow closely.
Genuine Link and Sincere Cooperation
The question of a genuine link has
definitely risen to the top of the industry’s
watch list following the launch of
infringement procedures against Malta
and Cyprus. The Commission claims
that ‘the granting of EU citizenship for
pre-determined payments or investments
without any genuine link with the
member states concerned, undermines the
essence of EU citizenship’. Legal experts
point out that it is not clear whether
the Commission considers the absence
of genuine links alone as problematic,
or whether granting EU citizenship for
investment combined with the absence of
genuine links justifies its legal challenge.
It is not the first time that the Commission
points to a genuine link. In its 2019 report
28
Investment Migration Yearbook 2O2O/2O21

on investment migration, the Commission
already suggested that a genuine link
should be evidenced to claim a citizenship.
Yet, such a view would be at odds with
the fact that numerous member states
regularly grant citizenship to foreigners
in recognition of their exceptional
achievements or their contribution to the
state. Legal experts also point out that
this argument could have far-reaching
consequences, and it may also open
the door to further legal challenges to
national citizenship policies. In addition,
they say it is unclear how citizenshipby-investment
programmes potentially
affect the principle of sincere cooperation,
which the Commission mentions too.
The Commission has yet to explain its
legal arguments in detail; the investment
migration industry is ready to listen.
Transparency and Risk Management
There is little doubt that the industry
will have to step up and strengthen
transparency and risk management
further if it wants to win over critics in
EU circles. In 2019, both the European
Commission and the European
Parliament have released opinions on
money laundering and tax or justice
evasion, which made explicit references
to investment migration programmes
in some member states. It was certainly
a welcome development that the final
EU recommendations called for greater
transparency and better risk mitigation,
not an outright ban on investment
migration. However, in its report on
so-called “golden” visas, the European
Commission announced it will monitor
the steps taken by member states to
ensure transparency and mitigate risks
in investment migration programmes
very closely. Many in the industry believe
that the recent revelations surrounding
the Cypriot citizenship-by-investment
programme have prompted the European
Commission to open infringement
proceedings. The Council of Europe, a
non-EU institution, also urged member
states to find measures preventing
individuals from unlawfully abusing
investment migration programmes.
Rule of Law
Ursula von der Leyen’s reference to the
protection of European values needs
to be viewed in the context of the EU’s
growing ambitions in the field of the rule
of law. The legal basis for its “mandate”
is Article 2 of the Treaty on European
Union (TEU), which lists the founding
values of the Union. Traditionally, the
Commission merely monitored national
institutional setting, for instance to ensure
the effective separation of powers.
Recently, however, the Commission
has also been scrutinising domestic
governance and legal frameworks to
uphold transparency and risk mitigation
against fraud. It refers to those issues as
breaches of the common European values
that it ought to uphold throughout the
bloc. In September 2020, the Commission
published its first Annual Report
on the Rule of Law. The publication
provides a comprehensive review of
each member state, including on matters
of corruption, tax evasion and money
laundering. Yet, it does not include any
mention of investment migration.
Even though investment migration
programmes were not directly referenced
in the Rule of Law report, the industry
should remain vigilant. Industry experts
find it worrying that investment migration
continues to be looked at through the
lenses of its potential misuse. Many
argue that a proactive engagement with
the European institutions is paramount
to counter this political narrative.
Anti-Money Laundering and Taxation
In 2021, the investment migration
industry can also expect to hear more
from the Group of Member State
Experts on Investor Citizenship and
Residence Schemes. This group,
established in 2019 by the European
Commission, aims to identify areas
where the EU legislator could intervene.
The experts already determined that a
standard set of security checks and risk
management measures are essential
for efficiently governing investment
migration programmes across the EU.
The checks the experts referred
to are those the EU put forward in its
recent anti-money laundering (AML)
and combating the financing of terrorism
(CFT) regulations. The AML/CFT
rules establish stringent monitoring
mechanisms and due diligence procedures
on large financial transactions. These rules
thus apply to investment migration, and
the industry should continue to closely
monitor future update as they may affect
the governance of the programmes.
Taxation is another area that
is often brought in connection
with investment migration.
At the European Parliament,
since September 2020 a permanent
subcommittee on tax matters has started
to meet on a regular basis. Among
other issues, the newly established
subcommittee deals with tax evasion
and money laundering. It is too early
to argue whether their legislative
work will be harmful to investment
migration, but the industry should
closely follow how the subcommittee’s
2021 legislative agenda unfolds.
Supporters and Opponents
There is no clear line between
supporters and opponents of investment
migration among the political groups
in the European Parliament. Across
the political spectrum, each group
includes MEPs supporting investment
migration and other members opposing
it. In fact, geographic origin is more
important than political affiliation.
Representatives from Northern
and Western member states tend to be
more critical of the industry than their
Southern and Eastern counterparts.
There are, of course, some exceptions. For
example, there are a few vocal Southern
MEPs, often from opposition parties,
who also oppose investment migration.
Opponents usually argue that countries
with investment migration programmes
profit from selling access to the EU. This
view overlooks the fact that almost all
member states grant citizenship and
residency to foreigners based on financial
contributions, even if they have no official
investment migration programme in place.
Meanwhile, several MEPs from
Eastern and Southern member states
view investment migration in more
favourable terms. They understand the
threats but also the benefits. In recent
debates, they have helped identify
solutions to mitigate the risks of CBI
and RBI programmes, while preserving
the right of member states to operate
and regulate investment migration.
Comparison with other
International Institutions
The EU is a lot more critical about the
investment migration industry than other
international institutions. The reason
for this is that the remit of the European
Union is much broader and its nature
much more politically dynamic than
Investment Migration Yearbook 2O2O/2O21 29

most mandate-specific international
organisations. The EU institutions have
legislative powers on a wide array of issues
and manage a multiannual budget.
At the OECD, the mandate is
focused on gathering data, running
comparative studies and making practical
recommendations on common challenges.
With regard to investment migration,
the OECD is merely concerned about
how the misuse of investment migration
programmes could allow individuals to
circumvent reporting obligations under
the OECD/G20 Common Reporting
Standard (CRS). Thus, the OECD
provides guidance to finance authorities
on how to further strengthen the due
diligence obligations under the CRS.
The IMF and the World Bank consider
investment migration programmes from
a public finance perspective as a source
of revenue for national governments. In
its working papers, the IMF looks at the
industry from a cost-benefit perspective.
In its 2018 country report on Malta, it
praises the significant contribution IM
schemes make to the national economy. It
also makes recommendations about how
to sustain the benefits while mitigating
the reputational and financial stability
risks. Along with the World Bank’s
comprehensive data on FDI, the Bretton
Woods institutions help foster a greater
understanding of the size of the industry
and its contribution to the well-being of
developing nations. Whereas the OECD,
the IMF and the World Bank provide nonnormative
analyses and credible figures on
IM, the EU adopts a much more normative
stance according to industry insiders.
Effect on Non-EU Countries
The European Union is also a prominent
global political actor. Its power and
influence over non-EU countries
should not be underestimated,
although for the moment, European
institutions are focusing their
efforts mainly on the CBI and RBI
programmes of EU member states.
However, the EU already exerts
influence on candidate countries through
its enlargement policy. Investment
migration is likely to be on the agenda of
upcoming accession talks with Albania,
Moldova and Montenegro. In the eyes of
the Commission, investment migration
raises rule of law concerns – an essential
chapter in the EU accession negotiations.
A Look at the Political Landscape
The European election in 2019 has changed the political landscape quite
significantly. There is no more grand coalition leading the debates in the
Parliament. The two main political parties – European People’s Party (EPP)
and the Socialists and Democrats (S&D) – no longer hold an absolute majority
in the Parliament. A significant proportion of the electorate expressed a
clear support for more economic liberalism as the clear winner of the 2019
election was the ALDE group (Liberals). The Greens can also be regarded as
an election winner as environmental concerns are gaining in importance
for European citizens. These two political groups are now essential to build
a majority in the European Parliament. In addition, some argue that the
authority of the Commission over the European Parliament is not as strong
as it used to be. The new President, Ursula von der Leyen, was elected with
a mere majority of seven votes. In addition, three Commissioners nominated
by France, Hungary and Romania were rejected after their hearing.
The European Union also cooperates
with almost any third country in the
world. It’s the world largest donor
of international aid. The promotion
of good governance practices and
the fight against international crime
form part of this cooperation. An
example of the EU’s influence on third
countries is the pressure it has put on
the Government of Panama following
the release of the Panama Papers.
Besides, the investment migration
industry needs to consider the EU’s
fight against tax havens. There is the
real but distant possibility that the
European Union might cancel visa waiver
programmes with third countries that
are considered tax havens. Countries
whose citizens have visa-free access to
the European Union and promote this as
a benefit of their investment migration
programmes could potentially be the first
ones to lose their privileged access to the
European Union. Brexit could accelerate
this prospect in those countries that were
former colonies of the British Empire.
Working Hand in Hand
Among industry experts, there is the
opinion that predominantly negative
stereotypes and legal bias fuel the
work of European policymakers, while
EU institutions are mainly tackling
investment migration from a judicial
perspective. They say that this narrow
approach overlooks the economic, fiscal
and social benefits for host countries and
migrants alike. There is consensus in the
industry that it is important to directly
engage with European policymakers
to provide them the information they
need to make informed decision.
The Investment Migration Council
(IMC) shares the EU’s concerns on issues
such as transparency, due diligence
and the potential for illegal activities
that can occur in the minority of cases
when investment is abused. The trade
association, however, believes that
the best solution is for industry and
policymakers to collaborate in raising
standards across the board to mitigate
the risks of abuse. The organisation
follows an open, comprehensive and a
fact-based public affairs approach. On
various occasions, the IMC has attended
events with policymakers, answered
questions about investment migration
programmes and highlighted the
industry’s self-regulatory practice. The
IMC believes that a well-working system is
in the interest of host countries, migrants
and the industry, whereby properly
regulated programmes facilitate the
inevitable flow of migration. In 2021 and
beyond, the IMC will continue to engage
constructively with European institutions
and communicate its efforts to MEPs.
30
Investment Migration Yearbook 2O2O/2O21

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Interview with DR ELENA BASHESKA, Legal Researcher and EU/International Affairs Consultant/Advisor
WHY THE EU’S
TOP COURT SHOULD
CLARIFY EU LAW
A legal battle is brewing in the EU as the European Commission
has taken action against Cyprus and Malta over their citizenshipby-investment
programmes. Elena Basheska sheds light on
the Commission’s arguments and explains why it would be
good if the cases end up at the European Court of Justice.
In October 2020, the European Commission
opened infringement procedures against
Malta and Cyprus over their citizenshipby-investment
programmes, pointing
out that these schemes undermine
the essence of EU citizenship. What
general comments would you like to
make about this development?
It is not a secret that the EU is not happy
with the fact that some member states run
investment migration programmes. This
situation has been dragging on for quite some
time. Investment migration programmes
have been often criticised by the European
Commission and the European Parliament,
and both institutions demanded in the past
that countries phase out the programmes.
The infringement procedures against
Cyprus and Malta come as no surprise. Actually,
the European Commission first reacted to
the launch of the Malta Individual Investor
Programme (IIP) back in 2013 and reportedly
started to plan for an infringement procedure
against Malta due to the lack of the genuine link
requirement and on the basis of the principle
of sincere cooperation enshrined in Article 4(3)
TEU. Instead, however, Malta agreed to amend
its IIP to introduce a residence requirement
for those who wanted to acquire citizenship
through investment. Such compromise by
Malta seemed more like a tactic to prevent
escalation of the issue than being based on facts
and law as there is no such thing as a residence
requirement for the purposes of acquiring
nationality from a member state in EU law.
The investment migration industry has long
argued that the granting of citizenship is
the prerogative of member states. What’s
the EU’s competence in this area?
A simple answer to the question would
be that EU member states have exclusive
competence to determine who their citizens
are. Allow me to elaborate further.
First of all, the limits of EU competences
are governed by the principle of conferral.
This means that the EU acts only within
the limits of the competences that EU
member states have conferred upon it in the
Treaties, and nationality is not among these
competences. Limitations on the principle of
conferral are interpreted strictly and require
close involvement of member states.
Furthermore, EU citizenship is
complementary to, but does not replace,
national citizenship. Put differently, EU
citizenship protects the rights of member states’
nationals which are not granted by their states
but by the Union itself. It is for the EU member
states, however, to regulate who qualifies as
a national, having due regard to EU law.
The EU case law preserves this competence
of member states, with the only exception
of instances where it is necessary to ensure
effective and uniform protection of rights
of EU citizens. Thus, the EU has normally
interfered in nationality matters where
member states have enacted measures that
restrict rights of EU citizens rather than where
such rights are to be enjoyed by new citizens.
What’s the legal basis for the action
against Malta and Cyprus?
Article 258 TFEU is a standard infringement
procedure which empowers the Commission
to act against a member state that fails to
meet its obligations under the Treaties. The
Commission, however, enjoys discretion in its
right to commence infringement procedures
pursuant to that provision. If it finds that a
member state has not applied EU law and
has accordingly failed to meet its obligations,
it will not bring the member state before the
European Court of Justice (ECJ) immediately.
Proceedings under Article 258 TFEU comprise
Acquisition
of citizenship
through
investment is
a legal path of
naturalisation,
likeable or not.
32
Investment Migration Yearbook 2O2O/2O21

two stages: administrative and judicial. Under
the first stage, the Commission will make
various attempts to negotiate an agreement
with the member state concerned informally
and usually by exchange of correspondence,
documents, data etc. If no agreement is
achieved in the pre-infringement stage
and the Commission decides to initiate an
infringement procedure, it will send a formal
notice to the member state. The member
state is then given the opportunity to submit
its observations. After the member state’s
submission, the Commission decides whether
to deliver a reasoned opinion explaining
why it considers that the member state has
failed to fulfil its Treaty obligations. Once the
member state has replied to the Commission’s
reasoned opinion or the lack thereof, the
Commission will refer the matter to the
ECJ and thus start the judicial procedure.
The infringement procedures
against Cyprus and Malta have now
been initiated with the formal notices
sent by the Commission. What is less
clear, however, is what arguments the
Commission would use with regard to the
obligations under the Treaties that these
two member states allegedly failed to
fulfil if this case is brought to the court.
The EC’s objections are partially based
on the concept of “genuine links”. What
can you tell us about this notion?
In its Press Release on the matter, the
European Commission stated that it
‘considers that the granting by these member
states of their nationality – and thereby
EU citizenship – in exchange for a predetermined
payment or investment and
without a genuine link with the member
states concerned, is not compatible with the
principle of sincere cooperation enshrined
in Article 4(3) of the Treaty on European
Union. This also undermines the integrity
of the status of EU citizenship provided
for in Article 20 of the Treaty on the
Functioning of the European Union’.
The Commission will most likely argue
that Cyprus and Malta failed to fulfil their
obligations under Article 4(3) TEU and
Article 20 TFEU by granting nationality
in exchange for payment or investment
and without genuine link. This argument
is, however, somewhat problematic.
First of all, the ‘genuine link’ theory
has not developed into obligatory rules
or principles of international law, let
alone in EU law which provides for
non-discrimination on the basis of
nationality. Trying to impose a ‘genuine
link’ requirement on member states with
regard to their criteria for acquisition of
citizenship would not only be incompatible
with EU law but would also almost
certainly spark ethnic nationalism and
undermine the values of the Union itself.
Secondly, it is difficult to imagine that
the principle of sincere cooperation could
be successfully invoked in the context
of these cases. Article 4(3) concerns the
achievement of EU objectives and genuine
compliance with EU law, none of which
seems to be related with the investment
programmes. A possible infringement
of that provision could be imagined in
the case of mass naturalisation, which
may have a significant negative impact
on the internal market. This is where a
member state confers its citizenship to a
large, disproportional numbers of thirdcountry
nationals. However, this doesn’t
seemed to be the case with Cyprus and
Malta because the number of citizenship
granted through their investment
programmes remained low in general
and compared to the number of other
naturalisations in the EU in particular.
Dr Elena Basheska
BIO is an independent
legal researcher
and EU/international
affairs consultant/
advisor. She holds an LLM
in European law and a
PhD in EU law from the
University of Groningen
(The Netherlands). Elena
has extensive experience
as a researcher, working
previously in various
sectors, including
academia, NGOs, law
firms and professional
organisations. Her
research interests focus
on EU enlargement,
EU external relations,
citizenship, and protection
of human rights.
Investment Migration Yearbook 2O2O/2O21 33

It would
be very
good,
however, if
these cases
reach the court,
and EU law on
this specific
subject matter
is clarified.
The EU has also pointed repeatedly towards
other possible negative side-effects of
investment migration, including money
laundering, tax evasion and corruption.
In your opinion, what measures can the
EU implement to mitigate the risk of
crime related to investment migration?
Money laundering, tax evasion, corruption
and other illegal activities are one thing, and
acquisition of citizenship through investment
quite another. Acquisition of citizenship through
investment is a legal path of naturalisation,
likeable or not. Yet, associating money laundering,
tax evasion, and corruption with investment
migration make the latter look somewhat illegal,
and this is wrong. Similar to other industries that
involve large financial transactions, investment
migration is prone to all sorts of illegal activities
– which may come from both dishonest clients
pursuing illegitimate ends, or corrupt politicians
misusing the programmes for personal gains –
and this is unacceptable. However, these illegal
activities result from the malfunctioning of the
law and are not related to investment programmes
as such. The focus should be, therefore, on the
enforcement of the rule of law in EU member
states. Investment migration should undergo
the same scrutiny as other industries involving
large international financial transactions.
While the EC has also written to
Bulgaria to request further information
about its programme, Austria, which
also grants citizenship to foreign
investors, is not being mentioned. Why
do you believe this is the case?
The fact that the Commission is concerned
about the investment programmes of Bulgaria,
Cyprus and Malta, and has not raised its
concerns about other EU member states that
allow for acquisition of citizenship by investment
through their legislation, suggests that the EU
is more concerned with the form than with
the substance of investment migration. In its
2019 Report, the Commission explained that
the discretionary naturalisation procedures in
countries other than Bulgaria, Cyprus and Malta
are highly individualised and used on a limited
basis, and that, therefore, such procedures
were not the object of the Commission’s report.
That explanation, however, is contrary to the
arguments used by the Commission so far. If the
lack of a genuine link is problematic in the view
of the Commission, then all other practices of
member states granting nationality in absence of
a genuine link should be deemed problematic too,
as such practices, according to the Commission,
infringe the principle of sincere cooperation.
If the Commission is genuinely concerned
about the lack of a genuine link, then this issue
would go way beyond investment migration,
affecting other forms of naturalisation too.
Thus far the EC’s action is directed only
towards member states’ citizenshipby-investment
programmes and not
against the more common investor
residence programmes. Do you expect
that the EC will move to take action in
this area too? If so, what competence
does the EU have to adopt legislation
that restricts member states’ rights
to establish RBI programmes?
The EU has voiced its concerns about both
citizenship-by-investment programmes and
residence-by-investment programmes in the
past. Citizenship-by-investment programmes,
however, are of a more immediate concern
for the EU because mobility entitlements
of new EU citizens who have gained their
citizenship through investment are more farreaching
than the entitlements of new EU
residents who have gained their residence
through investment programmes.
Thus, new EU citizens do not have to
reside in the member state that granted their
nationality but have the right to move and
reside freely within the territory of any other
member state and beyond (in the EEA and
Switzerland, albeit with certain limitations in
some instances), to mention the most important
right stemming from EU citizenship. Unlike EU
citizens, new EU residents are entitled to lawful
residence in the member state where they
made their investment. Their residence permit
allows them to travel within the Schengen
area and in other non-Schengen EU countries
(Bulgaria, Croatia, Cyprus, and Romania) based
on the unilateral recognition of residence
permits by those states, but their residence
status does not allow for free movement
within the territory of other member states.
However, long-term residence leads often
to citizenship, and this is where the EU may
voice its concerns again and for the same
reasons discussed in the context of citizenship
by investment – absence of genuine link
and in particular, physical presence during
the residence of the investor, which takes
us back to the beginning of this interview.
Whether the EU will take action with regard
to RBI programmes would, in my opinion,
depend pretty much on the outcome of its
current actions against Cyprus and Malta.
How do you believe the situation will
develop in the coming months?
Launching infringement procedures against
Cyprus and Malta does not mean that we will
necessarily see a case on this matter in front
of the court. The European Commission has
discretion on whether or not to bring those
cases to court. It would be very good, however,
if these cases reach the court, and EU law on
this specific subject matter is clarified.
34
Investment Migration Yearbook 2O2O/2O21

In conversation with KIERON SHARP, CEO of FACT Group
CORRUPTION
IS THE REAL RISK
The EU has pointed repeatedly towards
possible negative side-effects of
investment migration, including money
laundering, tax evasion and corruption.
In your opinion, does investment
migration pose a security risk?
I think it’s worth to take a step back at first and
consider that people have always invested in
other countries as a means to be able to live
there or to improve their freedom of lifestyle.
The only thing that golden citizenship and
golden visa programmes have done is to
formalise the process. Any form of migration
presents a potential security threat and,
therefore, security must be a major factor
for investment migration programmes. No
country wants convicted criminals amongst
their new residents or citizens and increased
measures are being put in place to ensure that
the people who are going to become citizens
or residents are ‘fit and proper’ individuals.
The programmes that we at FACT work with
all have very high standards and processes in
this regard, which are reviewed continuously.
Cyprus has stopped its citizenship-byinvestment
(CBI) programme after a
report by Al Jazeera alleged high-ranking
politicians were willing to issue passports
to convicted criminals. What’s your
reaction to this recent development?
All efforts to screen applicants fall apart if there
are corrupt individuals who are in a position
to influence decision-making so that people
who are clearly unacceptable can become
citizens. That’s why it is important to have
checks and balances built into the programme,
but it’s even more vital to ensure that there
are checks and balances on the influence that
politicians and senior government officials
have on a programme. You would like to think
that governments are always trying to ensure
that their systems prevent undue influence,
but the problem with corruption is that it’s a
secret offence. You can put everything in place
– all the laws, regulations and safeguards – but
it can still happen. A corrupt act is usually
between two people – so it’s very difficult to
spot. All forms of economic crime usually
involve an insider because large scale fraud
rarely happens completely from the outside.
The moment there are corrupt individuals
involved, it presents an opportunity to
destabilise an entire system or government.
What about the money laundering risk?
Money laundering is often thrown into the
discussion because it is a catch-all term for any
economic crime that doesn’t fit in a specific
category. It is a simple fact that people who
are involved in any criminal activity will have
to clean their money at some point. In some
countries it is completely unnecessary because
it doesn’t seem to matter that they got the money
from an illicit source, but in the majority of
countries it does, so they need to find a way to
make that money clean. Money laundering is
actually a big part of a criminal lifestyle. There
are not many people who commit a crime
once and then need to launder money just
once. So, using a CBI programme as a means
of laundering money is not a very effective
way. The main reason is that you don’t get
your money back. Laundering money means
you are taking dirty money and you get clean
money back. When it comes to investment
migration, that’s not the case. Additionally,
you can only do it once as you can’t keep on
investing in different programmes. It doesn’t
really help when you have got criminal profits
coming from your criminal enterprise. It’s not
the most obvious thing that people would
want to use a CBI programme for. The same
can be said about the tax evasion argument.
CBI programmes require one-off payments,
so, you are only tax evading once. It may be
that you become a citizen of a country with a
more attractive tax regime, but that’s not tax
evasion, not even tax avoidance necessarily.
Is there anything that could be brought
in from a European security perspective,
such as another layer of checks and
balances, that would give comfort to
member states and EU institutions that the
new citizens are fit and proper persons?
I recall that some 25 years ago there were
discussions on a variety of security issues,
such as co-operation between national police
forces and the harmonisation of criminal
laws. Very little of it actually happened, and
I think one reason for it is that in areas such
as security, policing and criminal justice,
countries still feel the need to protect themselves
as individual countries first and foremost,
with the intention of maintaining their own
sovereignty in such key areas. This is the
argument that EU-based CBI schemes make.
How do you think the investment
migration industry’s relationship
with the EU will develop?
The sector has definitely recognised that it has
come under scrutiny, but I think nobody is
scared of that. What the industry wants to do is
to make sure that it can withstand the scrutiny.
Based on my experience, I can say that the
programmes we work with are improving their
processes, standards and checks all the time.
Kieron Sharp, former
City of London Police
detective and head of
the economic crime
team at Interpol,
talks about the threat
to EU security that
investment migration
programmes
bring about.
Kieron Sharp has
BIO been in charge at
FACT since 2006,
overseeing the content
protection and antipiracy
response to huge
technological changes in
the audio-visual landscape.
His 30-year career with
the Metropolitan Police
and City of London Police
included a four-year
secondment to Interpol as
Head of the Economic Crime
Department and culminated
in the position of Detective
Chief Superintendent in
charge of Specialist Crime
Operations in the City of
London. Kieron is also a
graduate of the Federal
Bureau of Investigation
(FBI) National Academy
in Quantico, Virginia.
Investment Migration Yearbook 2O2O/2O21 35

Special Feature: Antigua and Barbuda
From Response to Recovery:
Antigua and Barbuda
Prepares its Post-Pandemic Economy
The outlook for sunny Antigua and Barbuda has become cloudy due to the outbreak
of Covid-19, but the Caribbean island nation is determined to make the most out
of new opportunities. Its citizenship-by-investment programme is going to play a
key role in defining what the country is going to look like in 2021 and beyond.
Antigua and Barbuda is no stranger to crisis and
knows what it takes to rebound. From the region’s
economic and debt crises in 2013 to Hurricane
Irma in 2017, Antigua has always found a way to rally
back. Its citizenship-by-investment programme (CIP) has
been an important tool to drive the economy forward, and
the expectation is that it will help the twin island nation
recover from the economic fallout of the Covid-19 pandemic
much faster than many other countries in the world.
Like most of its Caribbean neighbours, Antigua and
Barbuda relies heavily on tourism, leaving it particularly
exposed to the side effects of the pandemic. But there’s a
feeling that this crisis creates an opportunity to diversify the
country’s economy – new activities in sectors such as blockchain
and medical cannabis are being encouraged. Meanwhile,
Antigua and Barbuda aims to strengthen its image as a safe
and sophisticated destination to live, work and invest in.
The country managed the coronavirus outbreak well and
appears to have limited its spread. This makes it attractive
for high-net-worth-individuals looking for a base away from
the global, but often crowded, megacities. The Caribbean
country responded quickly to new trends in the RCBI world.
It was among the first countries globally to introduce a
nomad visa and will shortly accept payments for its CIP in
cryptocurrencies. Initiatives such as these are fuelling hope
that the dual island nation can achieve what many other
countries think is impossible: return to growth in 2021.
Beauty and Beaches
Positioned where the Atlantic and Caribbean meet, Antigua and
Barbuda consist of two major inhabited islands, Antigua and
Barbuda, and a number of smaller islands. St. John on Antigua is
the capital city. The country is home to close to 100,000 people, with
the majority living on Antigua after Hurricane Irma destroyed most
of Barbuda and forced its residents to relocate. A former British
colony, Antigua and Barbuda gained independence in 1981 and
joined the Commonwealth. Locals often call their country ‘Land of
365 Beaches’ and are quick to point out that there is a different beach
for each day of the year. With beauty and beaches in abundance, it
comes as no surprise that tourism is a key driver of GDP, generating
around 70% of the island’s income, but this over-reliance has also
been the country’s greatest economic weakness for decades.
CIP Introduction
Some ten years ago, Antigua and Barbuda experienced an
unprecedented economic slowdown after its tourism industry
was battling the fallout from the 2008 financial crisis. The country
had no choice but to enter an International Monetary Fund
Programme in 2010 that would keep the economy afloat for the three
years that followed. When it became increasingly challenging to
restructure the country’s debts and access other funding sources,
Antigua and Barbuda looked for alternative revenue streams and
established a citizenship-by-investment programme in late 2013.
36
Investment Migration Yearbook 2O2O/2O21

● Codrington
Although initially it was not unanimously supported, the
CIP is today widely seen as beneficial to the country. After the
financial crisis, it helped to restore stability during the economic
slowdown, says Gaston Browne, Antigua and Barbuda’s Prime
Minister who promoted the CIP’s introduction. He adds that
it was also of great importance when Hurricane Irma hit the
country in 2017. The impact on Barbuda was particularly severe.
More than 80% of Barbuda’s buildings were destroyed or
severely damaged, and the island was deemed uninhabitable.
CIP funds were used to re-build critical infrastructure.
Funding in Times of Crisis
BARBUDA
Capital: St. John on Antigua
Official Language: English
Size: 170miles 2 (440km 2 )
Population (2017 estimate): 94,731
Currency: East Caribbean Dollar
Head of State: HM Queen Elizabeth II
Governor-General: Sir Rodney Williams
Head of Government:
Prime Minister Gaston Browne (2014)
Form of Government:
Constitutional Monarchy
National Elections:
last March 2018, next 2022
Literacy rate: 99%
● Saint John’s
ANTIGUA
Since 2013, the Citizenship by Investment Unit (CIU) has
received more than 2,200 applications from more than 80
countries; five percent of applications have been rejected.
It accounts for around 15% of government revenue and
remains a vital source of funding in times of crisis. When tourism
came to a standstill as a result of Covid-19, the CIP “helped us
significantly to fulfil our socio-economic obligations, otherwise
we may have defaulted,” admits Prime Minister Browne.
Besides tourism, construction plays a major role in
Barbuda’s economic mix, accounting for 15% of GDP. Thus
far, the sector is ploughing ahead and has not been affected
particularly by the pandemic. Large infrastructure projects
– the construction of a cargo port facility and a new cruise
terminal – helped to keep people in employment and somewhat
cushion the Covid-19 impact. Nonetheless, the island’s GDP
is expected to contract by around 10% in 2020, and there is
widespread agreement that the CIP is today more important
than ever for the economic development of the country.
Pandemic Management
Antigua and Barbuda has won praise for its effective response to
the coronavirus pandemic. Until the end of August, Antigua and
Barbuda confirmed a total of 94 cases and three deaths. When
it comes to global pandemic management, it certainly helps
being an island nation in the middle of an ocean. But Antigua
and Barbuda’s success in fighting the virus is so much more than
good geographic fortune. “Our health infrastructure has been so
robust that we have been able to control domestic spread,” says
the Prime Minister, although the country was one of the first in the
Caribbean to re-open its borders, accepting flights from the United
States, Europe and Canada. This was a conscious decision, says
the Prime Minister pointing out that social distancing, contract
tracing, as well as the requirement for all arriving travellers to
produce a negative Covid-19 test were just some of the measures
that the country introduced to prevent a public health crisis.
Equal emphasis has been placed on expanding healthcare
infrastructure. The number of hospital beds per 1,000
population has been increased from two to three during
the pandemic by establishing mini-hospitals in addition to
the main hospital in St. John. An Infectious Disease Centre
has also been established. “We now have in the region of
50 ventilators, which we believe is enough to treat people
who become critically ill from Covid-19,” says Browne.
Prior to Covid-19, healthcare was already one of
government’s top priorities. A bespoke kidney transplant
facility and a new cardiac unit are currently being built, while
the country also has a hospital offering stem cell therapy,
as well as a cancer centre. Given this recent investment,
Browne thinks “Antigua and Barbuda today has one of the
most modern healthcare facilities in the Caribbean”.
Rise in Interest
The island’s effective response
to the pandemic has been
recognised by high-net-worth
individuals from around the
world. Charmaine Donovan,
CEO of the Citizenship by
Investment Unit, says that her
unit has seen a surge in the
number of inquiries from persons
seeking safer, less densely
populated options, and countries
which have demonstrated a
greater ability to manage the
pandemic. “Applications from Charmaine Donovan
the traditional jurisdictions
have been consistent, however, particularly for 2020, we
have noticed an increase in applications from Southwest
Asia, Africa and the Middle East,” says Donovan.
In the second quarter of 2020, the CIU experienced a
slight dip in applications as a result of the pandemic. Potential
applicants found it difficult to access agencies and authorities
which generate original documents that are critical to the due
diligence process. However, according to Donovan, interest and
inquiries have seen a sharp increase since the global lockdown.
Investment Migration Yearbook 2O2O/2O21 37

Meanwhile, the CIU has made best use of its Agent’s
online portal that was launched at the beginning of 2020 to
enhance efficiency and ensure a shorter turn-around time
of applications. The portal enables agents to upload, submit
and track applications on behalf of their clients. Documents
required for the application process were also simplified to
make the whole process smoother. The electronic submission
of application is now a permanent feature of the programme.
Remaining Attractive
The country is doing its utmost to remain attractive for highnet-worth
investors while mobilising capital to be used for
social services, constructing infrastructure and supporting
its private sector. “Our programme has the most diverse
investment options through which individuals can apply
for citizenship. For example, it is the only programme in the
region which offers a business investment option,” explains
Donovan. Through this option, applicants can invest in existing
business opportunities or new ventures. The government has
been encouraging investment in agriculture, agro-processsing,
manufacturing, technology and other economically viable
industries to support the nation’s development goals.
Donovan also points out that Antigua and Barbuda is
currently one of the most attractive choices for large families.
In May 2020, fees for those contributing to the country’s
University of West Indies Fund (UWIF) have been reduced;
however, only families of at least six members are eligible for
this investment route. Applications under the UWIF option
entitle one member of the main applicant’s family to a oneyear
scholarship at the University of the West Indies.
Shortly, applicants will also be able to pay their CIP
contributions in cryptocurrencies. In the summer of 2020,
Antigua and Barbuda established a regulatory regime for
digital assets business, which paved the way for the shift to
cryptocurrencies as a payment method for the CIP. Prime
Minister Browne believes that cryptocurrencies will help speed
up the transaction process and lead to a more efficient payment
system. “This in turn will enable us to process applications in a
very efficacious matter. One of the problems that we have in the
Caribbean is that the due diligence on the source of funds is often
extremely slow and could take many months. This frustrates
applicants at times, and we believe that the cryptocurrency
framework will solve this problem.” Besides, it also addresses
correspondent banking issues that plague the Caribbean region.
Caribbean Cooperation
Increased cooperation among Caribbean CIP countries will
likely play a key role in ensuring the industry has a bright
future. The CIP programmes in the region have long been
very price-competitive. Prime Minister Browne stresses
that he does not want to become engaged in a price war
because “it will just reduce the effective yield and it will
undermine the integrity of the CIPs within the respective
countries”. He is in favour of some level of harmonisation,
especially when it comes to due diligence and the sharing of
information. He says he would also support a coordinated
move to raise the prices of the Caribbean programmes.
Greater cooperation among Caribbean CIP nations has
long been on the cards. The Organisation of the Eastern
Caribbean States (OECS) has established a taskforce devising
the way forward two years ago. While a common CIP may
be somewhat of a long shot, Ambassador Colin Murdoch,
Commissioner to the OECS for Antigua and Barbuda, expects
“the implementation of some confidence building measures”
and some direction on future cooperation by the end of 2020.
Promoting Dialogue
The OECS is also instrumental
in addressing the concerns of
international bodies such as the
EU and the OECD. “We know
that these organisations have
concerns about CIPs. We do not
disregard these concerns, but we
believe many of them are based
on misunderstandings,” Murdoch
says. “Our CIP programme
cannot be used to circumvent the
Common Reporting Standards, it
cannot be used to evade EU taxes.
I think we need further dialogue Colin Murdoch
to clarify some of these matters.”
He believes there is “good prospect for dialogue”, highlighting
that the OECS already had meetings with mid-level EU officials.
For the Caribbean nations it is important that all countries
operating CIPs are on a level playing field. “We do not want that
the CIPs of EU member states are treated differently than ours,”
he says. Murdoch also stresses that there’s a willingness to make
legislative changes in case of ambiguity. Antigua and Barbuda,
for instance, amended its legislation to “make it very clear that
a CIP cannot be used to evade taxes due in another country”.
Caribbean Living
Many in Antigua and Barbuda feel that the pandemic has created
conditions of increased demand and that the time has come
to create genuine interest in the Caribbean nation by offering
multiple opportunities to live and work in the country. Although
it is not as popular and well-known as the island’s citizenship
programme, Antigua and Barbuda’s permanent residency
programme has been in operation for a much longer period
than the country’s CIP. It provides interested persons with the
opportunity in the country requires a pathway to citizenship
and a much lower annual contribution threshold. In addition,
a digital nomad visa has been launched in the summer of 2020.
This, however, will not provide a pathway to citizenship, but the
expectation is that it will prove attractive to the growing number
of location-independent workers. While many argue that longstay
residents could compensate for the loss in tourism revenue,
interest in, and uptake of, these new visas remains to be seen.
Regional Economic Leader
The big opportunity for Antigua and Barbuda is in truly
diversifying its economy. The country strives to become the
financial capital of the region, especially in the cryptocurrency and
blockchain space, but it is also looking at fostering new ventures in
agriculture, light manufacturing and in the knowledge industries.
Green energy, high-end tourism, medical cannabis and medical
education are also high on the agenda. “The vision is to turn
Antigua and Barbuda into one of the most attractive island nations
for investments in order to increase our GDP rapidly, create jobs
and improve the living standards for the people of Antigua and
Barbuda,” says Prime Minister Browne. It goes without saying that
the CIP will play an important role in facilitating this transition.
38
Investment Migration Yearbook 2O2O/2O21

Interview with GASTON BROWNE,
Prime Minister of Antigua and Barbuda
LEADING
BACK
INTO
GROWTH
Prime Minister Browne, can you tell us why Antigua & Barbuda decided
to establish a citizenship-by-investment programme (CIP)?
In 2009, I promoted the introduction of a CIP while I was an opposition parliamentarian.
After the global crisis of 2008, Antigua and Barbuda suffered economically. Unemployment
increased; people were falling below the poverty line. I recommended to the thenadministration
the introduction of a CIP, however the idea was dismissed. Nevertheless, I
believed in the CIP and the socio-economic benefits it could potentially bring to Antigua
and Barbuda and continued to advocate for its introduction for several years. It was only in
2013 that the then-administration established the programme. The following year, I became
Prime Minister of Antigua and Barbuda, and my government is now the beneficiary of the
programme. The programme helped to accelerate the recovery from the crisis and restore
socio-economic stability. It was also of great importance when hurricane Irma hit our country.
Before Covid-19, your country’s growth forecast was positive.
The IMF now expects a GDP drop of -10% in 2020. How do you
see the economy develop in the coming months?
We thought that 2020 would be our best economic year on record, but unfortunately it
turned out to be one of the worst years. In fact, I can tell you that initially we expected a
GDP reduction of 20% due to our heavy dependence on tourism. Government has seen a
significant reduction in revenue, which fell by about 65% during the lockdown period. It is
now inching back up to around 50% of projected revenue for 2020. However, we expect to
return to growth in 2021 and have projected that we can recover within 18 months. However,
the recovery for the entire Caribbean region will take longer, probably around four years.
What role does your CIP play in attracting investment in this challenging period?
The
government
is very
entrepreneurial and
open to joint ventures
with prospective
citizens. We believe
public-privatepartnerships
will
play an important
role going forward.
We are trying to attract new capital investments utilising the CIP programme. We
already have a few leads, and once confirmed, we want to expedite these projects
as soon as possible. We witnessed a reduction in CIP investment in recent months,
but I believe that we will rebound and get back to normal revenue generation
within a matter of months. I am convinced that our management of the coronavirus
crisis goes a long way towards showing that Antigua and Barbuda is not only a
beautiful island nation, but also one of the safest places in the world to live.
Recently, we have also introduced a nomad visa. We are seeking to entice knowledge
workers as well as high-net-worth individuals to move to Antigua and work remotely in a safe
environment. A single individual pays a fee of US$300, a couple US$500 and any additional
person pays US$100 – so it’s quite reasonable. We already received several applications.
What message would you like to impart about Antigua & Barbuda’s
attractiveness as a country to live and invest in?
Antigua & Barbuda has one the most diverse populations in the entire Caribbean.
It is a melting pot of people and cultures, and everyone is very open to new citizens.
We have one of the lowest crime rates in the region, enjoy economic stability and
have been classified as a high-income country for many years. We are now doing our
utmost to ensure a quick recovery post Covid-19. I’d also like to point out that the
government is very entrepreneurial and open to joint ventures with prospective citizens.
We believe public-private-partnerships will play an important role going forward.
Antigua and Barbuda also has a history of attracting high-net-worth
individuals to relocate to the island. We have a number of high-end luxury resorts
and residences. Take Jumby Bay Island, a private island. The cheapest property
there costs roughly US$ 15 million. Real estate prices have also remained stable
in recent years, and there has never been a reduction in real estate value.
Besides our record in healthcare, last but not least, I’d like to mention that
we have also made great strides in the field of education. Among the Caribbean
countries that operate CIPs, Antigua & Barbuda is the only country that has its own
university campus. We are home to the fourth landed campus of the University
of the West Indies, with close to 500 entries expected this school year.
For all these reasons, I believe Antigua and Barbuda should definitely be on the
radar of anyone interested in applying for a second citizenship or seeking residency.
Investment Migration Yearbook 2O2O/2O21 39

Unwrapping our Cover Story
with Andres Solimano
Andrés Solimano says investment migration has the potential to
advance the 2030 Sustainable Development Agenda.
40
Investment Migration Yearbook 2O2O/2O21

What are SDGs?
They are a set of 17 SDGs
and 169 targets that are
applicable to different national
realities, including advanced
nations, middle-income developing
and emerging economies, small
island states, least developed
countries and post-conflict nations.
Can you please give
us a brief introduction
to the United Nations
Sustainable Development
Goals and explain what
they aim to achieve?
The United Nations
Sustainable Development
Goals (SDGs), adopted in
2015, provide an international
framework to create more
sustainable and fair economies
as well as resilient and
prosperous societies by 2030.
They are a set of 17 SDGs and
169 targets that are applicable
to different national realities,
including advanced nations,
middle-income developing and
emerging economies, small
island states, least developed
countries and post-conflict
nations. The SDGs include
initiatives to end poverty,
ensure quality education,
achieve gender equality,
promote decent jobs and
take urgent action to combat
climate change and its impacts.
The SDGs are not the
first initiative of this kind.
They were preceded by the
Millennium Development
Goals (MDGs) that were
agreed upon in 2000. The
SDGs are a second and more
ambitious step in realising a
global development agenda.
The MDGs promoted
economic growth combined
with social equity and
environmental protection.
The SDGs take on a more
comprehensive and holistic
approach to development,
sensitive to our ecological
and planetary boundaries
besides promoting poverty
reduction and lower inequality.
What capital investment
is required to implement
the SDGs?
The United Nations Conference
on Trade and Development
(UNCTAD) in 2015 estimated
global investment needs
between $5 to $7 trillion
per year to achieve the
SDGs. Developing countries
require around $4 trillion
per year, mostly in terms of
infrastructure investment such
as power, transport, water
and sanitation. Clearly, we
cannot meet the SDGs only by
utilizing public funds; private
support is required too. The
issue is more complicated for
low income countries as they
have to achieve the same set of
goals but have fewer internal
financing resources. Botswana,
Ghana or Sri Lanka, for
example, cannot be compared
with Switzerland, Sweden
or Germany in their ability
to meet the SDGs. Besides,
advanced economies have
already achieved some goals,
while developing nations
have a long way to go.
Beyond the country
differences, is the world
on track to achieving the
SDGs and is Covid-19
threatening progress?
The UN Secretary General
appointed the Independent
Group of Scientist to monitor
the progress in achieving
the SDGs. They produced a
report in 2019 and concluded
that the world is still far
away from reaching the
goals. For instance, we have
seen insufficient progress in
terms of reducing poverty in
Africa and low-income Asia.
Furthermore, climate change
is one of the biggest challenges
of our time and stopping or
reversing global warming
is a slow-moving process.
Covid-19 is definitely a setback,
hopefully of a temporary
nature. The world economy
in 2020 will experience the
greatest recession since the
Great Depression in the 1930s.
Estimates by international
organisations are that GDP will
contract by 6% to 7% worldwide
this year with positive
growth in 2021. However, the
pandemic presents both an
enormous challenge and also
opportunities for reaching
the SDGs. Gains in economic
and social progress made in
recent years are reversed. The
pandemic has also shown us
how interconnected people
and countries are for good
or bad, for example the virus
spread with utmost speed
across the world through
travel and people mobility
in a few weeks. The crisis is
forcing us to re-look at the
way forward and come up
with new solutions that truly
balance economic, social and
environmental progress. In
this sense, the SDGs provide
good priorities although
we need more in terms of
devising concrete strategies
for effective recovery and for
ensuring health and safety.
Investment Migration Yearbook 2O2O/2O21 41

What impact can
the investment
migration industry
have on the SDGs?
Investment migration brings
in fresh capital, human
skills and entrepreneurial
capacity for the receiving
nation. Some of this money
contributes, perhaps
unintendedly, towards
meeting the SDGs. It is
estimated that investment
migration programmes
worldwide have raised
around $60 to $70 billion
between 2008 and 2019. This
represents a rather small
proportion of the total $5
trillion to $ 7 trillion that are
at the very least required
to achieve the SDGs.
Nevertheless, for small states
citizenship-by-investment
(CBI) programmes have been
an important source of fiscal
revenue. For instance, the
CBI programmes in Antigua
and Barbuda, St. Kitts
and Nevis, Dominica and
Vanuatu represent over 30%
of fiscal revenue. In other
countries, such as Malta
and Cyprus, CBI revenue
accounts for 4% to 5% of
GDP, and this percentage
goes up to anything between
15% and 25% for Caribbean
CBI countries. So, for small
economies, this money can
make a large contribution
in terms of providing
both fiscal revenue and
foreign exchange. For
larger economies – the UK,
Spain, Portugal, Greece and
others – RBI income is not
as important as a share of
GDP or total public revenue
although it still plays a role
in strengthening certain
economic sectors and
creates value in distressed
regions. However, in macroeconomic
terms, investment
migration has the largest
impact on small states.
Can you share a few
concrete examples of
how investment migration
programmes have already
contributed to the SDGs?
CBI resources have made
important contributions to the
funding of physical and social
infrastructure, particularly
to finance the reconstruction
of infrastructure damaged by
hurricanes that have hit the
Caribbean. In 2017, Dominica
was severely affected by
Hurricane Maria and Antigua
and Barbuda was hit by
Hurricane Irma. CBI resources
helped rebuild nearly 60%
of all infrastructure that was
being damaged by these
climate events. These are two
examples of how investment
migration has contributed
through the inflows of foreign
resources that were mobilised
by domestic authorities, to
restoring living standards
after main natural disasters.
In terms of the SDGs they
broadly contribute to “Good
health and wellbeing”
(SDG3), “Clean water and
sanitation” (SDG6) and
“Industry, innovation and
infrastructure” (SDG9).
Residence-by-investment
(RBI) programmes can have a
potential impact on SDG8 –
Decent Work and Economic
Growth and SDG1 – Poverty
Reduction. Take the EB-5 in
the US that requires investors
to create at least ten jobs
per year. This is a source of
extra income for workers and
owners, although we have
relatively little information
on the extent the jobs created
have been accompanied by
effective social protection
of workers (decent jobs). In
Portugal, Spain, Greece and
other countries, investment
migration is directed
to business investment
that create jobs mainly
in the services sector.
Some investment
migration programmes
appear to have a broader
impact on the receiving
nations than others, while
critics are highlighting
even negative effects
of some programmes,
including overheated
real estate markets and
the overreliance on
investment migration
funds. With the SDGs
in mind, how should
government’s make
best use of investment
migration funds?
Today, we are seeing
two types of investment.
One modality is ‘passive
investment’, for instance
in government bonds or
in the real estate market;
another modality is ‘active
investment’ through which
the migrant may be directly
engaged in the creation of
new businesses and the
process of job creation.
Governments in the recipient
countries should encourage
more active investments,
although passive investments
also play a role.
A consequence of passive
investments in real estate
is the tendency to push up
property prices, especially
in big cities such as London,
New York, Paris, Sydney and
others. As a consequence of
price spirals in the property
market, housing becomes
unaffordable for the local
population with modest
and middle-income levels
who have to move to live
in locations away from
their jobs and schools of
their children. This shows
that investment migration
can feed into already
existing social inequality
mechanisms in the area
of access to housing. This
is a side effect that has to
be seriously considered.
Andrés
BIO Solimano holds
a Ph. D. in
Economics from
the Massachusetts
Institute of Technology
(MIT) and is founder
and Chairman of the
International Center
for Globalization
and Development
(CIGLOB) based in
Santiago, Chile.
It is estimated that investment migration programmes worldwide have raised around
$60 to $70 billion
between 2008 and 2019.
42
Investment Migration Yearbook 2O2O/2O21

Another feature of
investment migration is the
channelling of capital into the
tourism and entertainment
sectors such as hotels and
residential developments. At
the same time, a case can be
made for boosting investment
into the manufacturing sector
and higher value-added
products. The promotion
of green and clean-energy
activities and organic
agriculture are important
priorities in a sustainable
development strategy.
Funds from investment
migration programmes
could be geared to these
socially and environmentally
desirable destinations.
Service providers, however,
report that most of their
clients considering the
investment migration route
prefer passive investments.
How can governments
strike the right balance?
That’s true, although it
depends on the demographic
profile of people who are
moving across national
borders. There is a study
of foreign investment and
investment migration to
Canada which found out
that a proportion of foreign
immigrants aged over 60 yearsold
prefer passive investments.
They feel they have more or
less completed their active
working life and want a more
relaxed lifestyle in their
new country of destination.
However, there is also a
proportion of immigrants who
enjoy a direct entrepreneurial
role and want to in create
new productive ventures in
Canada and other nations.
We have to keep in
mind that most investment
migration programmes were
put in place after the global
financial crisis in 2008, and
governments were not making
very stringent requirements
because they wanted to attract
foreign investors. But with
these programmes coming
to maturity new priorities
are needed. Unfortunately,
we are being hit by a new
crisis, that of Covid-19,
and probably investment
migration will be needed
to support recoveries
and long-term growth.
How do you envision the
investment migration
industry will develop
in the coming years?
The industry has to learn
from the experience of past
years and be aware of the
new realities and challenges
emerging with Covid-19
as we are entering into a
new global age that will be
probably more uncertain,
fragmentary and risky. In
the past ten years after the
global financial crisis of
2008-09, globalisation has
been strained by several
factors: sluggish recoveries,
rising inequality, job
fragility, protectionism
and new waves of debt
creation. At the same time,
we have seen a political and
cultural backlash against
globalisation accompanied
by populism, nationalism
and xenophobia.
Global problems require
global responses and more
international cooperation
rather than inter-country
competition in critical areas
such as vaccine development
and new technologies.
The investment migration
programmes should
be an integral part of a
globalised world that
keeps the principle of free
international mobility of
people. Still this industry
would benefit from aligning
investment migration
more with the concept of
sustainable development
and gearing investments
towards high quality
jobs, more social equity,
green production and
ecosystem protection.
The
17
Sustainable
Development
Goals
GOAL
3
Good Health
& Well-being
GOAL
6
Clean Water
& Sanitation
GOAL
9
Industry,
Innovation &
Infrastructure
GOAL
12
Responsible
Consumption
& Production
GOAL
15
Life on
Land
GOAL
1
No
Poverty
GOAL
4
Quality
Education
GOAL
7
Affordable &
Clean Energy
GOAL
10
Reduced
Inequality
GOAL
13
Climate
Action
GOAL
16
Peace &
Justice Strong
Institutions
GOAL
2
Zero
Hunger
GOAL
5
Gender
Equality
GOAL
8
Decent Work
& Economic
Growth
GOAL
11
Sustainable
Cities &
Communities
GOAL
14
Life
Below Water
GOAL
17
Partnerships
to achieve
the Goal
Investment Migration Yearbook 2O2O/2O21 43

THE NEXT BIG IDEA
TOWARDS A NEW IMPACT AGENDA
The world of impact investing is expanded rapidly and could soon
break into the investment migration market. The IM Yearbook spoke
with two experts who are working on new concepts that could
revolutionise the way investor migrant funds are being utilised.
The impact investing industry has grown
and matured in recent years, but the Covid-
19 pandemic has firmly pushed it into
the mainstream. Governments, companies and
investors are joining the market in ever increasing
numbers. The concept is now expanding into the
investment migration industry as researchers and
academics are exploring ways of how to better
address the challenges of the 21 st century and
finance projects that aim to tackle global issues
such as climate change and poverty reduction.
The Background
There is a growing consensus in international
policy circles on the need to rethink the
United Nations’ 2030 Agenda for Sustainable
Development, at the heart of which are 17
individual Sustainable Development Goals
(SDGs). John Crowley, Chief of Section for
Research, Policy and Foresight in the UNESCO
Sector for Social and Human Sciences, is one
expert who is currently floating the idea of a new
framework for sustainable development. “One of
the big problems is how to achieve all the SDGs
by 2030. It’s a massive agenda, with design flaws
which were well known from the beginning.
However, the current pandemic has created
conditions in which we can no longer ignore these
shortcomings,” he says. “The idea of a new push
to achieve the 2030 Agenda in the next decade
is no longer credible. The push will be needed
just to recover the ground lost in 2020, notably
in terms of extreme poverty and inequalities.”
Poorly Defined Goals
More importantly, Crowley says it’s now much
harder to claim that there is a solid framework
within which international development
objectives can be achieved. “Arguably, that
wasn’t the case even in 2019. But 2020 has shown
how fragile the framework actually is. On the
other hand, what’s positive about all of this
is that it opens space to think differently.”
The core issue, he says, is that we don’t have a
clear picture of what is needed in order to achieve
sustainability. “We have some ideas in specific
areas, for instance when it comes to climate change.
It’s well recognised that an energy transition, which
replaces fossil fuels with alternative energy sources,
is required.” However, says Crowley, other SDGs
are very poorly defined. SDG 11 which refers to
Sustainable cities and communities is one such
example. “There are lots of ideas of what makes
a city sustainable but no technical consensus on
how to measure it and how to achieve it. While
there are some blueprints, I doubt anyone would
claim that there is a model that merely needs to be
rolled out.” This is just one example, says Crowley.
The other issue, Crowley highlights, is one
of territory. “The international system is based
on sovereignty, which means that every state has
exclusive jurisdiction over its territory, but this
notion is constantly challenged by issues such
as environmental pollution or transnational
capital flows.” Today’s understanding of territory
and state sovereignty is becoming increasingly
incompatible with our interdependent world.
After all, modern ideas of sovereignty emerged
as a result of the Treaties of Westphalia, which
were concluded to end the Thirty Years’ War
in 1648-49. “It’s a very narrow and unsolid basis
on which to build our future,” says Crowley.
Philippe Forêt, an expert in environmental
research and ecology, could not agree more
with Crowley. “We need to think about the
Westphalian system and ask if it is the best
possible system to confront the challenges
of today. I think the answer is no.”
Concept Development
Both Crowley and Forêt believe that there is
a need to strengthen the connection between
various forms of private finance and the global
public good. You can’t manage what you don’t
measure – this old management rule also applies
to sustainable development. A key priority for
Crowley is therefore to come up with metrics
that can better measure the effect of sustainable
initiatives. He points to methods such as natural
capital accounting, which can provide data related
to the management of natural resources that
contribute to economic development. “These
tools have been developed over the past 20 years
and are today very sophisticated.” Metrics such
as these could become key decision-making
tools in the new era of impact investment.
Forêt believes that they can become the
foundation for a new product offered by the
investment migration industry. “A new type of
asset class could be created, whereby investor
migrants can invest in projects that will leave
a measurable impact on the environment and
on communities.” Any project open to investor
migrants would be evaluated and certified in order
to prevent greenwashing, he explains. In return
for their investment, migrants would receive
citizenship or residency rights. “While for many
investors the return on investment is important,”
Forêt says, “there is also a growing number of
philanthropic high-net-worth individuals who
might find this concept very appealing.”
His task for the coming months is to convince
a reasonable number of countries to buy into
the idea and participate in a programme, which
would direct certain financial flows – such as
income from investment migration – towards
projects that create a lasting and measurable
impact in terms of sustainability and move
well beyond the limitations of the SDGs.
“Globally, this would contribute to a whole new
understanding of investment migration. It will
ultimately become an industry that is working
for the common good and promoting social
justice and sustainable development.”
John Crowley is
BIO Chief of Section for
Research, Policy
and Foresight in the
UNESCO Sector for Social
and Human Sciences.
Since joining UNESCO in
2003, he has also been a
programme specialist in
social science and head
of the communication,
information and
publications unit, chief
of section for ethics of
science and technology,
and team leader for global
environmental change.
Before joining UNESCO, he
worked as an economist
in the oil industry and as
a research fellow at the
French National Political
Science Foundation.
Philippe Forêt is
BIO Professor and
Dean of the
School of Humanities and
Social Sciences at Brac
University in Bangladesh.
Since 2013, he has
led the Environmental
Humanities Working
Group at the Swiss
Academic Society for
Environmental Research
and Ecology (University
of Basel). The Institute
of Advanced Studies
of Nantes, the Swedish
Collegium in Uppsala,
and the Rachel Carson
Center in Munich have
elected him Fellow.
Investment Migration Yearbook 2O2O/2O21 45

ADVERTORIAL
VCA boasts a specialized immigration and
private wealth department that handles all
kinds of requests with a greater focus on
immigration by investment. Our multilingual
team of lawyers has unrivalled experience,
outstanding technical knowledge and a proven
track record on immigration, private wealth,
family offices, real estate and tax advice.
“Immigration and Private Wealth are the fastest growing
areas of practice in VCA. We have been fortunate that
clients and peers got us to be recognized in Chambers
and Partners and Legal 500. We assembled a wonderful
team of young lawyers and paralegals focused on
delivering bespoke solutions to our clients. Despite the
global pandemic, we have been navigating 2020 almost
unscathed. Compare Portugal with any other destination.
You will be amazed with what this country has to offer.”
João Valadas Coriel, Managing Partner of VCA
“From my 30 years of practicing in different positions and
areas of activity, being Head of VCA Immigration Department
is the most fulfilling of all. The whole team is highly committed
and knowledgeable. An efficient communication with clients,
responding to all their queries on a daily basis, is definitely
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that has been carried out by this very special team.”
Sandra Fernandes, Head of the Immigration Department at VCA
Mitchell Kriegman, USA:
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Many of these other solicitors were
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Ms. Fernandes laid out the straight
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She’s experienced in every aspect
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Daniel Twomey,
La Vida Golden Visas:
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Sandra, Patricia, Vanda and
Cláudia, especially, go above
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kept up to date on changes to the
programmes and that professional
advice and comprehensive
assistance is always available.”
H. Wang, Germany: “(…) Due
to her strong legal technical skills
and excellent experience, Sandra
is a very competent legal advisor
for Golden visa applications. She
is resilient and authentic (…).”
Vernondo Boshoff and Louis
Douglas, South Africa:
“(…) Without a doubt, we will
recommend Mrs Sandra to assist
our family and our closest friends
should the need arise, the reason
is complete and utter trust.”
Richard Weedn, USA: “Sandra
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James Chan, Hong Kong:
“When my wife and I came
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With her patience and practical
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Mian Ali: “(…) The ONE person
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experience has been top notch all
thanks to her and her team (…)”.

Expand Your Business With Latitude
– Your Trusted B2B Partner
As we reflect on 2020 and look ahead to 2021, it is safe to say that the
world and the investment migration industry has been changed forever.
Never before in the short history of our industry has it ever been more
apparent why an individual and family should have a second residence
or citizenship as a viable “Plan B”; it’s no longer a luxury – it’s a necessity.
This shift in mindset is bringing even more demand to our
respective doors, and now more than ever, forging positive B2B
relationships with industry leaders will enable your firm to maximize
the opportunity before you.
We at 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 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.
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. While many firms are
slashing staff or cutting salaries, we are growing in all our offices. In
fact, our UAE office recently doubled their headcount making it the
largest investment migration office in the Middle East!
But why should I partner with you? What do I get
out of it?
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,
South Pacific 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 Latitude apart from
hundreds of other investment migration firms?
We have offices in over 13 different countries around the world including
the UAE, Lebanon, Malta, Cyprus, Montenegro, UK, Brazil, USA, Canada,
South Korea and Malaysia, thereby allowing us to offer 24/7 support
through our global network of offices.
Latitude’s B2B Team
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.
Latitude is fully licensed under all of the citizenship-by-investment
programmes and we proudly display the certificates on our walls. We
are also the Regional Representative Office in the Caribbean for the
Investment Migration Council (IMC) and actively promote best practices
and integrity for the industry.
In additional to competitive client pricing, higher commissions,
white-labeled 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) and
Programme Estimate Tool (latitudeworld.com/pet).
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.
Email us at partnerships@latitudeworld.com and we’ll discuss how to
best move forward together.
Latitude – Welcome to Your World
www.latitudeworld.com
Eric G. Major
Group Chairman
and CEO
Mimoun A. Assraoui
Group Vice-Chairman
and CEO Dubai
David Requeiro
Santalla
Group COO
Ranny A. Muasher
B2B Regional Director
Jon Green
Director,
Intermediary &
B2B Sales
Christopher Willis
Managing Partner and
Government Advisory
Ryan Darmanin
Managing Director,
Malta
Mohammad Motavasel
B2B Regional Director

WHAT’S
GOING
ON IN…
Programme Updates
A snapshot of key
developments in the world’s
most important investment
migration markets
2020 has not turned out how many of us expected but the
investment migration industry has not been as affected by
Covid-19 as many other sectors. Most golden visa and golden
passport programmes have in fact reported a surge in interest.
We picked out a selection of the biggest market winners and
losers for the past year. It isn’t an exhaustive list, but it will
hopefully give you a flavour of how different countries and
programmes are being affected by the current conditions.
48
Investment Migration Yearbook 2O2O/2O21

The Caribbean
At the end of 2019, many Caribbean countries
were on course to record economic performance
or, at the very least, were expected to turn in
respectable results. However, the coronavirus
pandemic has dealt the vulnerable, tourismdependent
economies of the Caribbean a heavy
blow. In the five Caribbean countries that operate
citizenship-by-investment programmes –
Antigua and Barbuda, Dominica, Grenada, Saint
Lucia and Saint Kitts and Nevis – hopes are high
that investor funds will help their economies
to recover. In an effort to remain attractive and
ensure a steady stream of fresh applications,
some nations have introduced discounts, mostly
in the form of accepting a greater number
of dependents. Applications are still flowing
in, although the industry is not yet sure how
attractive these programmes will remain in the
future. While some point to the Caribbean’s new
status as “Covid safe haven” given that the
region has handled the Covid-19 relatively well,
others believe investors will be more attracted
towards larger countries in the post Covid-19 era.
As things stand, there are several differences
separating the Caribbean programmes, with
the price being the most prominent one.
The minimum investment required for one
applicant in Saint Lucia, Antigua and Dominica
is $100,000, while in Grenada and St. Kitts,
it’s $150,000. Under the real estate option,
Antigua’s minimum investment is $400,000;
Grenada, $350,000; Saint Lucia, $300,000;
Dominica and St. Kitts, $200,000. The future of
the Caribbean CBI industry will most likely be
defined by greater cooperation and collaboration.
Although many in the industry doubt that the
islands will agree on a set price, the expectation
is that a joint approach can be achieved in areas
such as the exchange of information and the
harmonisation of application forms. Meanwhile,
some Caribbean nations started offering remote
work programmes in an effort to attract highflying
digital nomads. The Cayman Islands,
Barbados, and Antigua and Barbuda are among
the nations that have launched a new type of
visa for professionals who can work digitally and
are seeking a safe, attractive workplace option.
3 Questions with Nestor Alfred, CEO of the
St. Lucia Citizenship-by-Investment Unit
What can you tell us about your operations and the
1 challenges presented by Covid-19 in 2020?
Covid-19 did not impact negatively on our operations and presented
the first opportunity to put into action our Business Continuity Plan.
Our processing platform was so created to allow us to work remotely,
and by the 24 th March 2020, the CIP staff was working remotely.
Initially, there were some challenges being expressed by the due
diligence firms, but this did not last a very long time. Additionally,
some applicants had issues obtaining supporting documentation due
to lockdowns in certain jurisdictions. We held many consultations
with various stakeholders in the industry. We wanted all to be on
board with the new way of conducting the process. Where applicants
could not source supporting documents for their applications, we
agreed to accept the application and still undertake the verification
process and the due diligence. However, the decision on the application
would only be made once the necessary documents are submitted.
How do you believe investment migration will develop
2 in the Caribbean over the next few years?
I expect there will be a major shift in collaboration and
consolidation amongst the five islands operating citizenshipby-investment
programmes – a joint approach that will cover
application forms and the due diligence process. I believe there
will be discussions on the creation of a processing and decisionmaking
structure that would be accommodating for all islands.
Do you have a final message about the key
3 benefits of St. Lucia’s programme?
Citizenship-by-investment programmes should create significant
long-term yields for investors - but this can only occur when there
is an uncompromising commitment to impeccable standards
of compliance, rigorous due diligence and accountability. By
pursuing this agenda, we ensure a lifelong return on investment
to our investors and visa-free access to 146 countries.
Investment Migration Yearbook 2O2O/2O21 49

Europe
Europe’s attractiveness as a residency migration destination
is rising, according to many service providers. They note
that particularly applicants from Asia who traditionally
preferred English-speaking countries such as the US,
Canada or Australia are enquiring in ever greater numbers
about European residency and citizenship programmes.
However, we are seeing stark differences in the 2020
performance among European programmes. Greece, for
example, has reported that it has only issued 368 Golden
Visas since the beginning of this year, while in 2019 more
than 3,400 visas were issued. The coronavirus pandemic,
and associated financial difficulties and travel restrictions,
are cited as the main reasons for the sharp decrease.
Portugal’s golden visa programme held up better against
the Covid-19 impact. According to Portugal’s Borders
and Immigration Service (SEF), the programme granted
915 residence permits to main applicants. It generated
almost half a billion euro in the first eight months of
2020 and is expected to exceed its 2019 performance.
Revenue could reach €745 million. Of particular interest
to applicants is the country’s venture capital fund option,
which allows investors to direct €350,000 into investment
funds across a range of sectors such as technology,
energy and real estate. From 2021 onwards, however,
investors cannot purchase properties in the country’s
two major cities – Lisbon and Porto – to qualify for the
golden visa. To mitigate the impact foreign buyers can
have on real estate prices, applicants choosing the real
estate option will need to buy in lower density zones.
Never ending Brexit woes and the fact that the UK drew
global criticism for its weak coronavirus response have
affected applications for the UK’s Tier 1 (investor) visa. In
June 2020, the UK registered a 42% decrease in Tier 1
visas, with close to 3,400 visas granted. While the Home
Office says much of this decline is a result of the Covid-19
pandemic, interest in so-called high-value visa had been
declining since the UK changed its migration policy and
discontinued the Tier 1 entrepreneur visa. But there are also
some good news for investor migrants interested in the UK:
no changes to the Tier 1 (investor) visa were announced
in the post-Brexit immigration rules. In addition, the UK’s
innovator visa is becoming an increasingly attractive option.
Meanwhile, EU countries with a citizenship-byinvestment
programme are in for a bumpy ride ahead.
The recent revelations by TV station Al Jazeera, which
implicated high-level politicians in corruption related
to Cyprus’ investor citizenship scheme, have had wideranging
repercussions. Not only did it force Cyprus to
terminate its programme, industry insiders also believe
the scandal accelerated the European Commission’s
decision to launch infringement procedures against
Malta and Cyprus, while requesting further information
from Bulgaria about the country’s programme.
The expectation is that Cyprus will modify and re-launch
its programme, although this has not been officially
confirmed. Malta, for its part, had been working on a new
programme long before the European Commission’s
most recent action. Malta’s successful Individual Investor
Programme, which was introduced in 2014, has reached
its cap of 1,800 applicants and will be replaced by a
new programme under which the minimum investment
requirement has been increased and the residency
clause tightened. Although it is too early to assess the
full impact of the European Commission’s action, it has
created a high level of uncertainty, which will continue
to weigh on the industry in the coming months.
Outside of the European Union, but in Europe, Moldova and
Montenegro are of industry interest. Moldova scrapped
its citizenship-by-investment programme shortly after its
launch. According to media reports, the closure was one
of the EU’s conditions for providing financial assistance to
the country. In spite of growing EU pressure, Montenegro
launched its citizenship-by-investment programme in 2019.
Although the country is not an EU member yet, accession
to the Union is considered possible by 2025. Already an
Adriatic yachting hotspot with stunning natural beauty,
Montenegro is emerging as a luxury destination offering
interesting investment opportunities, with some calling
it ‘the next French Riviera’. Demand for the programme
was expected to be high; however, amid Covid-19 travel
restrictions, it generated only moderate interest, with only
40 applications submitted at the end of October 2020.
The programme is planned to close at the end of 2021,
and applications might multiply in the coming months.
50
Investment Migration Yearbook 2O2O/2O21

Interview with
DEJAN MEDOJEVIC,
Head of the Secretariat for
Development Projects of the
Government of Montenegro
Montenegro
Seeks to
Accelerate
Economic
Development
Dejan Medojevic gives an
overview of Montenegro’s
citizenship-by-investment
programme, which was
launched in 2019 in an
effort to raise capital for
economic development.
Can you give us a brief introduction to Montenegro’s CIP?
The programme is designed as a development programme and, among other
things, involves the payment of a grant of €100,000 for the development of underdeveloped
municipalities, and an investment between €250,000 and €450,000 in
a project selected by the government in sectors such as tourism, agriculture and
manufacturing. There are also certain administrative costs and due diligence
assessment fees, which applicants have to pay. Once applicants satisfy the investment
requirements and pass the due diligence assessment, they are checked by our national
institutions, including the Ministry of the Interior and national security agencies.
The implementation of the project is overseen by the Montenegro Investment
Agency, while the final decision is being made by the Government – the Prime
Minister and the Ministry of Internal Affairs. For the promotion of the programme,
we have contracted three licensed intermediary agents: the Arton Group, Apex
Capital Partners and Henley & Partners Government Services. The Government
has issued licenses to S-RM Intelligence and Exiger as due diligence providers.
What would you highlight as the main challenges that
you experienced in your first few months of operation and
how has the programme performed thus far?
The greatest challenges at the beginning were related to the definition of the main
criteria. Once we got this sorted, the hardest part of the job was done. Designing
suitable administrative procedures and selecting intermediaries and due diligence
agents also took some time. But these are important elements of the programme, so
I think that’s only natural. Keeping in mind the global economic situation caused by
the Covid-19 pandemic during 2020 and the fact that the programme started only in
the second half of 2019, we are satisfied with the performance to date. We experienced
some delays due to the travel restrictions at the height of the global lockdown, but
now everything goes smoothly, and we have received more than 40 applications so far.
What are the key benefits of Montenegro’s programme and
what sets your programme apart from its competitors?
This is not a cash for passport programme. Our programme has been designed
with a strong focus on economic development, and the projects that are eligible
for investment will create long-term economic benefits. In addition, the fact
that investors’ will have to contribute to our special development fund for less
developed municipalities – mostly in the northern part of the country – means
we direct investment into areas where it’s needed the most. Our CBI programme
is considered to be pretty demanding in terms of the criteria applicants need to
fulfil. However, we only want to attract serious and reputable applicants. The
implementation of the programme is also regularly monitored by the
European Commission, and so far, we have received no objections.
How do you believe the programme will
develop over the next few years?
The programme is planned to expire by the end of 2021. Thus far, we
don’t know whether it will be extended or not. It’s simply too early
to plan. However, as I already said, we are quite pleased
with the programme’s performance to date, especially
given the global situation. If interest remains at the
same level, it would be completely satisfactory.
Investment Migration Yearbook 2O2O/2O21 51

Southeast Asia
Southeast Asia is the rising star of the
investment migration world. Thailand
continues to attract growing numbers of
expat residents. The Thailand Elite visa is a
residence programme allowing visa holders
to stay in Thailand from five to 20 years, at a
one-time cost of approximately $16,000 or
$68,000, depending on the option chosen.
While the main target markets are business
travellers needing fast entry and exit in and
out of the country, thus far most demand is
stemming from retirees who, if they stay in
Thailand for more than 180 days per year,
stand to benefit from an attractive tax regime.
In addition to a residence permit, the Thailand
Elite visa comes with various privileges,
including access to airport pick-up services,
privilege passport lanes, airport lounges,
visa assistance, golf club memberships, and
discounts on various services in Thailand.
3 Questions with Somchai Soongswan,
President Thailand Privilege Card Company
How has the Thailand Elite visa programme
1 performed in 2019 and 2020?
In September 2020 our membership has grown by 32% when compared
to the same month last year. Especially during the past two months, we
have seen a strong increase in submitted applications. Looking at the
development over the past 12 months, so from October 2019 to September
2020, the figures are even better, and the number of applications has
increased by 68%. Given the challenging phase the world is going
through, we are quite satisfied with the programme’s performance.
How did Covid-19 affect your operations and how did you
2 respond to the challenges presented by the pandemic?
Thailand went into lockdown in late March 2020. This means our
members couldn’t come to Thailand, and we also had to delay decisions
about new members. However, we launched a Thailand Elite member
quarantine programme (TemQ) that has been approved by Thailand’s
Center for Covid-19 Situation Administration (CCSA). This means our
members can now enter Thailand. To keep the momentum going, we are
looking at an extensive marketing campaign, which includes elements
such as extended visa periods as well as early bird offers for new members
who can pay and register now but activate their membership later.
Do you have a final message about the key
3 benefits of your programme?
Thailand is often called the “Land of Smiles”. Thus, “Thailand Elite” is
the privilege visa that does not only offer a long stay visa but also exclusive
services, which differentiates our offering from other residency programmes.
These benefits and privileges are firmly reserved for friends of Thailand.
As one of the most thriving economies in Southeast Asia, Malaysia
is also increasingly on the radar of high-net-worth migrants. Already
a popular tourist destination, the country’s beautiful landscape and
cultural and ethnic diversity appeal to a greater number of foreign
investors. However, in August 2020, the Government of Malaysia has
decided to temporarily suspend the country’s successful “Malaysia
My Second Home” (MM2H) programme. The government offered
no explanation for its decision, other than saying it would halt
the processing of new visa applications and renewals of existing
visas to “comprehensively review and re-evaluate the MM2H
programme”. It said it would resume the programme next year.
Singapore has risen from a post-colonial backwater to one of
the most respected and admired countries in the world, and it is
attracting an ever-greater number of foreign residents. The Global
Investor Programme grants Singapore Permanent Resident status
to eligible global investors who intend to drive their businesses
from Singapore. While traditionally only established business
people with a strong and successful track record could qualify for
the programme, in March 2020, the programme has been opened
to next-generation business owners, founders of fast-growing
companies from certain industries and family office principals.
52
Investment Migration Yearbook 2O2O/2O21

The Middle East
Turkey’s citizenship-by-investment
programme continues to attract
applicants. According to media reports,
the country has granted more than
9,000 citizenship through real estate
investment since 2016. However, the
lion’s share of applications was received
after the country reduced the investment
threshold in 2018. Since then foreigners
who purchase real estate in Turkey
worth a minimum of $250,000, instead
of the previous limit of $1 million, qualify
for Turkish citizenship. In addition to its
attraction as a regional economic hub,
many investors chose to first invest
in a Turkish passport and then apply
for the USA’s E2 entrepreneur visa
through their new Turkish citizenship.
Jordan aims to attract more investors to
its citizenship-by-investment programme
and reduced its minimum investment
requirements by 25-50% depending
on the investment option in 2020. The
programme, which started in 2018, has
reportedly raised some $1.38 billion and
created some 7,400 jobs from just 200
investors. Meanwhile, Egypt’s cabinet
also signed off on granting citizenship
to foreigners who either buy property
or invest in the country. Under the new
law, foreigners have three ways to obtain
Egypt passport: They can either donate
$250,000 to the state treasury, purchase
real estate of at least $500,000, or
deposit at least $750,000 into a local bank
account, which is returned after five years.
Australia & New Zealand
Australia and New Zealand have closed their borders to almost all
foreigners as part of their Covid-19 response, and it looks like borders
may remain closed until late 2021. However, there is the general feeling
that the current restrictions will not affect their positioning as top
destinations for migrating high-net-worth individuals, although both
countries require a relatively large investment. New Zealand has two
investor visas, which either require an investment of NZ$3 million or of
NZ$10 million, whereby a combined total of around 2,200 applications
were approved since 2009. Australia’s Significant Investor Visa (SIV)
continues to appeal to Chinese nationals, with the visa number for the
permanent residence visa being subclass 888 – meaning triple fortune
in Chinese numerology. With 88% of applicants in Australia originating
from China, it becomes clear that the Australian government is
prepared to further encourage growth of this market. Some 2,400
SIV have been granted since the start of the programme in 2012.
America & Canada
Demand for the USA’s EB-5 Investor Visa dropped when the minimum
investment was raised from $500,000 to $900,000 in November
2019. EB-5 practitioners believe the market will stabilise again.
However, for others it is not yet clear whether, or to what extent,
the US will remain its status as the world’s leading immigration
nation, highlighting that the country’s image suffered on the back
of social and political unrest, while the Covid-19 pandemic did not
help either. Interest in EB-5 increased in the summer of 2020 when
the US paused green card applications and visa processing, with
the exception of EB-5. The White House said the freeze, in place
till the end of 2020, is aimed at protecting the US labour market.
Neighbouring Canada meanwhile has built a reputation of welcoming
immigrants and valuing multiculturalism. There is huge interest in
Canada’s Start-Up Visa on the back of Canada’s expanding tech sector.
Some commentators say the programme has become increasingly
popular after the USA’s temporary visa ban. Quebec’s Immigrant
Investor Program meanwhile has been suspended until March 2021.
To participate in the Quebec Immigrant Investor Program, individuals
were required to invest $1.2 million. According to government
officials, the main reason for the suspension is a huge backlog of
applications have yet to be processed; however, Quebec also wants
to use the suspension period to review the programme’s criteria.
Investment Migration Yearbook 2O2O/2O21 53

Interview with ALEX MUSCAT, Malta’s Parliamentary
Secretary for Citizenship and Communities
THE SPIRIT OF
DIALOGUE
Alex Muscat, Malta’s Parliamentary Secretary for Citizenship and Communities,
provides insights into the country’s decision to revamp its Individual
Investor Programme and shares his thoughts on the European Commission’s
decision to launch infringement procedures against the country.
54
Malta’s CBI programme has been
reworked. What changes should
the industry be aware of?
Malta’s Individual Investor Programme
(MIIP) is soon coming to an end,
having reached the pre-determined
capping of 1,800 families who have
successfully invested in the Maltese
Islands. The Agency has stopped
receiving new applications.
We shall continue giving the
opportunity to a number of exceptionally
talented people to invest in the Maltese
Islands. We will do this by completing
the existing programme, closing the
Malta Individual Investor Programme
Agency (MIIPA) and establish a new
agency that will administer all paths
leading to Maltese citizenship, and revise
and reform all residence regulations.
The new regulations will be in the
form of a residency plan that has the
potential for eventual nationality. Under
the new regulations, an applicant must be
a resident in Malta for three years before
applying for citizenship. Exceptionally,
through a higher investment in Malta, this
can be done after one year of residence.
Interested residents who want to
apply for citizenship will be required
to apply for an eligibility assessment
before applying for naturalisation. At this
stage, they will be subject to thorough
due diligence. The new agency will be
implementing the toughest criteria for
due diligence and background verification
reporting around the world. It will
cooperate more with local and foreign
Investment Migration Yearbook 2O2O/2O21
investigative and law enforcement
and tax authorities. An independent
regulator will continue to scrutinise
the application process executed by the
Agency and all resultant decisions.
What are the main drivers behind your
decision to change the programme?
One major driver is certainly a
willingness to innovate and to improve
our practices. The sustainability of
our economic success depends on our
constant readiness to innovate, together
with the diligent manner in which we
do business. Another major driver is
our readiness to distinguish ourselves
from programmes and initiatives that
are offered in Europe and around
the world. The Maltese Government
values a strict policy of due diligence in
order to make sure that only reputable
applicants are admitted to its initiatives.
The EU has long been critical of
Malta’s programme. In what ways
has this criticism influenced your
decision to redesign the programme?
EU legislation is clear in stating that
EU intervention as far as citizenship
goes is outside its legal authority.
However, the Commission and the
other institutions take legitimate steps
to underline the potential risks of
residence- and citizenship-by-investment
programmes, mentioning security
and money laundering concerns in
various reports and statements.
We believe in a spirit of dialogue,
and we have paid special attention
to the criticism that the original
programme received and availed
ourselves of constructive opinions. In fact,
stakeholder consultations were carried
out over the past two years, including
with the European Commission.
Malta has continued to strengthen
the already stringent due diligence
processes in order to make sure that only
reputable applicants are admitted to its
programmes. It is worth noting that when
analysing the previous programme, the
IIP regulator had already stated that it
was miles ahead of similar programmes
operated by other countries. The new
initiative is even more highly vetted than
the previous programme, and every
applicant goes through a detailed process
where their identity and source of funds
are verified by multiple parties, including
police and law enforcement agencies.
In view of the fact that the majority
of the EU members states have
such initiatives in place, we feel it is
important to understand the benefits
as well as the risks that are being
highlighted by EU institutions.
The European Parliament has called
on member states to phase out all
existing citizenship- and residenceby-investment
schemes. What
thoughts would you like to share about
the EP’s opinion on the matter?
The attribution of nationality is an
exclusive competence of individual

EU member states. It is in the national
interest of every member state to
protect its sovereignty, a principle
that is also enshrined in EU law.
The original programme was a highly
responsible one, where applicants undergo
stringent due diligence. Over the years,
a total of 368 applications for citizenship
were refused, and a further 35 were not
allowed to apply for citizenship following
initial KYC checks conducted through
local police authorities. In addition, 95
applications were withdrawn by the
applicants, most of which were following
questions raised by the Agency during
the due diligence process. The rejection
rate has varied throughout the years.
In 2020, the Minister has refused more
than 30% of the applications following
due diligence conducted by MIIPA. The
Agency has also spontaneously reported
numerous cases to Malta’s Financial
Intelligence Analysis Unit (FIAU) when it
identified suspicion of money laundering.
To top it off, EU member states
grant more than 600,000 citizenships
a year, of which only up to 1,000 are by
investment. In other words, this branch
of naturalisation represents a very small
percentage of the total new EU citizenry per
year, and those are thoroughly screened.
What can you tell us about the MIIP’s
role in cushioning the economic
impact of the covid-19 crisis in
Malta? What economic impact
do you envision the programme
will have in the coming years?
By welcoming just under 200 new families
a year, we have generated a total €1.5 billion
in seven years. The funds have been a
tremendous boost to the Maltese economy,
building Malta’s ‘war chest’ in these
times of global pandemic, and will prove
to be even more useful as the economy
recovers from the hit. The new regulations
will continue generating revenue for
areas of economic need in the future.
Although this is a new initiative which
is completely distinct, the benefits of
Malta’s policy for attracting international
investment are noticeable across the
country, especially through the €600
million allocated to the National
Development & Social Fund (NDSF) for
social and economic development of the
Maltese Islands. In this way, the Maltese
Islands have sought to strike a rational
balance, between opening their doors
for people who have distinct attributes
in their field and maintaining exclusivity
when it comes to the new Maltese.
In October 2020, the European
Commission opened infringement
procedures against Malta over
its citizenship-by-investment
programme. What comments would
you like to make about this issue?
The Government of Malta had already
announced that the Malta Individual
Investor Programme will be coming to an
end. We have taken note of the concerns
raised by the European Commission
and by the expert group established by
the Commission on citizenship- and
residence-by-investment legislations
found in most European member states.
Subsequently, Malta will be implementing
new residence regulations, which may
lead to citizenship and which take into
consideration the European Commission’s
concerns and recommendations.
The Government reiterates that
citizenship is a member state competence,
whereby every European country decides
on its own who are the individuals which
it believes should receive citizenship.
There are over 600,000 individuals
who become European citizens each
year with very minimal screening.
Malta is implementing regulations
which go way beyond what many
other European member states do to
scrutinise citizenship applicants.
The Government will formally reply
to the letter of formal notice in due course.
It is the intention of the Government to
use all possible legal measures to defend
the national interest and sovereignty.
We believe
in a spirit of
dialogue,
and we have paid
special attention to
the criticism that the
original programme
received and
availed ourselves of
constructive opinions.
Alex Muscat is Malta’s
BIO Parliamentary Secretary
for Citizenship and
Communities within the Ministry
for Home Affairs, National
Security & Law Enforcement.
An economist by profession,
Alex has extensive political
experience. He has played a
central role in government for
the past seven years within the
Private Secretariat team of the
Prime Minister, where he rose to
the position of Deputy Head.
Investment Migration Yearbook 2O2O/2O21 55

Simplicity. Safety.
Sophistication.
That is the essence of what attracts people to live and work in tax-neutral Cayman Islands.
Recognised as the friendliest country in the world,
The Cayman Islands has earned this accolade
as a reflection of its welcoming population long
accustomed to the presence of international
residents and visitors.
A breezy island lifestyle, no direct taxes, a low
crime rate and a high standard of living have
all contributed to making this British Overseas
Territory the jurisdiction of choice for globally
mobile high-net-worth individuals.
Located 475 miles southwest of Miami, this
tropical archipelago is renowned for its modern
infrastructure, luxury residential properties, rich
marine environment and world-class culinary
scene. From a modern airport, excellent schools,
three hospitals and over 1,000 health care
professionals, to quality telecommunications and
utilities, it’s small wonder that new residents are
often surprised by the livability of Grand Cayman
given its Caribbean address.
The impact of the global pandemic has prompted
increasing interest in tax-neutral Cayman Islands
as a safe place of refuge and a locale offering
straightforward residency by investment through
real estate programmes. Two options are available.
25-year Residency Certificate
This option entitles the holder to reside in Cayman for 25 years without the
right to work.
• Invest a minimum of US$1.2 million, of which at least half must be in
developed residential real estate.
• Demonstrate an annual income of US$145,000 or open a local bank
account and maintain a minimum deposit of at least US$500,000.
• Spend a minimum 30 days annually in the Cayman Islands.
Certificate of Permanent Residence for Persons of
Independent Means
This provides a lifetime right to reside in Cayman, with the opportunity to work.
• Invest a minimum of US$2.4 million in developed real estate in the
Cayman Islands.
• Demonstrate sufficient financial resources
• Spend at least one day a year in the Cayman Islands.
• This option offers a path to naturalisation as a British Overseas Territories
Citizen (after a minimum five years) and then a British passport. In taking
this up, there is no obligation to surrender any existing citizenships.

Kimpton Seafire Resort + Spa, and The Residences at Seafire
OLEA, a residential community in Camana Bay
Camana Bay
RBI applicants also choose the Cayman Islands
for residency due to the ease of acquiring
property; there are no restrictions on foreign
ownership of land, no alien landholding
licences, no recurring property taxes and title
insurance is generally not needed due to the
Islands’ Torren title system of land registration.
When it comes to property development, the
Islands’ largest developer, Dart Real Estate,
has made significant contributions, investing
over US $1.5 billion in luxury resorts and
residential properties, Class A commercial office
buildings, infrastructure projects and most
notably its flagship development, Camana Bay.
Camana Bay is a 685-acre waterfront town
centre founded on the principles of New
Urbanism and home to global firms, retail
boutiques, restaurants, an international school
with an IB programme, and OLEA, a residential
community offering condos, townhomes and
villas for sale.
A short drive from Camana Bay is another
Dart development, Kimpton Seafire Resort +
Spa, and The Residences at Seafire. The AAA
Five Diamond award winning resort shares a
12-acre property on Seven Mile Beach with The
Residences at Seafire, a luxury condominium
development. The 62-unit property offers
contemporary one-to-five-bedroom residences
that are suited for part- and full-time residents.
An optional rental program managed by the
Kimpton is available to owners interested in
renting their property when not on island.
Properties for sale at The Residences at Seafire
and OLEA, as well as other luxury real estate,
are represented by Provenance Properties, Dart
Real Estate’s brokerage and the official Christie’s
International Real Estate affiliate in the Cayman
Islands. Clients benefit from one-stop service
for all commercial, residential and relocation
service needs, in-depth and proprietary market
analyses, and access to the privileged Christie’s
Real Estate marketing programmes and network
of like-minded individuals.
Beyond the role of real estate developer, Dart
is committed to the Cayman Islands. The Dart
Real Estate team helps business owners and
individuals learn about the benefits of living and
working in the Cayman Islands, and assists with
making the relocation process an efficient and
positive experience.
Learn more about Dart Real Estate at
whycayman.dartrealestate.com
and Provenance Properties at
provenanceproperties.com
1
HSBC Expat Explorer Survey, 2012
RBI applicants also
choose the Cayman
Islands due to the ease
of acquiring property.
• no restrictions on
foreign ownership
of land
• no alien landholding
licenses
• no recurring
property taxes
• title insurance is
generally not needed
due to the Islands’
Torren title system of
land registration

INVEST IN PARADISE. MAKE IT HOME
A PIONEER AGENT FOR CITIZENSHIP BY INVESTMENT IN ST. LUCIA,
WITH OVER 50 YEARS COMBINED EXPERIENCE IN THE LEGAL, ADVISORY AND
CONSULTANCY INDUSTRY. LET US HELP YOU MAKE PARADISE HOME:
WWW.STLUCIACITIZENSHIP.CAPITAL
Address: Cnr. Brazil & Mongiraud Streets, Castries, St. Lucia
Email: info@stluciacitizenship.capital
www.stluciacitizenship.capital / www.floissaclawyers.com
T: +1 758 452 2887 M: + 1 758 714 7373

FROM THE GROUND UP:
ST. LUCIA’S EVER-EVOLVING CIP PRE AND POST COVID-19
The Caribbean CBI industry will experience a surge in demand, but it will also become
more competitive as a result of the coronavirus pandemic, write Brenda Floissac
Fleming and Keith Isaac of Polaris Citizenship & Investment Consultancy Services.
One may argue that Citizenship by
Investment is intrinsically Caribbean.
This once micro-industry kickstarted
by St. Kitts & Nevis in 1984 is now established
in 13 countries worldwide; five of which
are Caribbean. St. Lucia is the latest isle in
the region to have made that metaphoric
plunge, having established its citizenship-byinvestment
programme in 2016. Unlike most
regional CIPs, Parliament’s clear intention
was to offer a niche programme to the world’s
billionaire club, with starting investments
double that of the most competitively priced
programmes in the region. This proved
unpopular, and the island had limited success
in attracting economic citizens to its shores.
Emphasis Change
By 2017, St. Lucia aligned its approach with
that of its regional counterparts. Starting
investments were reviewed to create parity with
the region’s most competitive programmes, while
net worth requirements and other arbitrary
hindrances to citizenship were removed. This
shift was vindicated with an almost 1,000%
increase in applications for the year 2017.
Legislation has been complimented
by a focused marketing mix. This has
involved strategic partnerships with
global stakeholders in key markets in an
attempt to boost the programme’s visibility.
The selling point of St Lucia’s CIP has
transcended the cliché visa-free rhetoric
and has been multifaceted; incorporating
the island’s culture, a focus on foreign direct
investment and ease of doing business. This
has allowed St. Lucia, unlike similar thirdworld
CBI destinations, to be viewed by
many HNWIs as a viable second home.
These shifts, along with streamlining of
the application process and a focus on top-tier
due diligence, helped the programme gain
the investment migration industry’s respect.
Covid-19 Emergence
St. Lucia, like most Caribbean CBI offerings,
has been acutely affected by Covid-19. As a
nation largely dependent on tourism, shortterm
economic loss due to the pandemic
has been reported in several industries.
Quite uniquely, whilst causing ruin to
global economies, the coronavirus pandemic
has simultaneously accelerated growth in the
investment migration industry. The expected
long-term recession and the likeliness of tax
hikes in several first-world jurisdictions, coupled
with nationalist and protectionist policy trends,
have seen interest in Caribbean citizenship
surge from both traditional and non-traditional
markets such as South Africa and Europe.
Response to Date
Eager to make best use of this incidental
opportunity, Caribbean governments
have taken swift action to attract HNWIs
to their programmes. This has included
price reductions and fee waivers from
the likes of St. Kitts and Dominica.
Refusing to be outdone, St. Lucia’s
Parliament has approved amendments to the
country’s CIP. Those included a reduction of
the qualifying donation from US$190,000.00
to US$150,000.00 for a family of four and the
introduction of a limited time Covid-19 noninterest-bearing
bond starting at US$250,000.00
with a five-year maturity period. Most notably,
the definition of ‘qualifying dependent’ has
widened significantly to include children aged
30 and parents aged 55, provided that they are
fully supported by the primary applicant.
Whilst critics may argue that such actions
diminish an offering’s value and contribute
to a philosophical ‘race to the bottom’ by
third-world CIPs, these shifts are signs of
the times – nations with limited resources
are waging war against each other in a
competitive CBI industry. The opportunity to
earn foreign exchange amidst global financial
crises simply cannot be disregarded by newly
independent states still attempting to secure
post-independence economic utopia.
Meanwhile, improvements to the scope of
‘qualifying dependent’ should be welcomed as
it points towards greater opportunity for nontraditional
family structures to benefit from CBI.
We anticipate the legislative acceptance of nonheterosexual
family structures by regional CIPs.
Future Outlook
Whilst the verdict is still out on these initiatives,
one should expect sustained incentivising of
HNWIs in a post-Covid-19 St. Lucia, which will
likely continue to rely heavily on its CIP in the
wake of an impacted tourism sector. Externally,
demand for RCBI should continue to intensify
with prolonged economic, social and political
uncertainty forecasted in major markets. The
challenge for St. Lucia’s, and other regional
CIPs, post Covid-19 will be balancing the need to
attract economic citizens with the requirement to
maintain ‘programme integrity’ in an increasingly
regulated RCBI sector, shadow governed by global
superpowers, often far removed from, and with
little understanding of, Caribbean realities.
BIO
Brenda Floissac
Fleming is a Senior
Partner at the
firm Floissac Fleming &
Associates and Managing
Director of Polaris
Citizenship & Investment
Consultancy Services in
St. Lucia. Brenda has over
30 years experience as
an attorney and advises
primarily on commercial
and transactional matters.
She is St. Lucia’s Honorary
Counsel to Chile and a
Director of the island’s
largest indigenous bank.
Keith Isaac is an attorneyat-law
at the firm Floissac
Fleming & Associates and
General Manager of Polaris
Citizenship & Investment
Consultancy Services in
St. Lucia. Keith holds a
master’s degree in Law and
Certification in Investment
Migration. He is a five time
former St. Lucia National
Youth Parliamentarian and
a former St. Lucia Junior
Minister for Tourism.
Investment Migration Yearbook 2O2O/2O21 59

FIRST PERSON
BOB KRAFT, Chairman, President, and CEO of FirstPathway Partners and President of IIUSA’s Board of Directors
AN ENTREPRENEURIAL
DIFFERENCE
Robert Kraft spent 40 years running companies before he
started working in the EB-5 industry. Through his regional centre,
he has raised investor money for projects as diverse as aircraft
engines, student dorms, specialised business centres and
hotels. He talked to the IM Yearbook about his EB-5 journey, the
current situation in the US and future investment opportunities.
Robert Kraft is a shining example
of American entrepreneurship.
He has more than four decades
of international business experience
and sat on the boards of over a dozen
companies. Robert – who usually goes by
his American nickname Bob – was a serial
entrepreneur long before the term became
closely associated with multi-venture
technology mavericks like Elon Musk and
Steve Jobs. In 1993, he founded his first of
nine companies. Three years later, in 1996,
he set up a software company that he grew
from a one-man start-up into a business
with 600 employees in just 10 years.
It was around the year 2004 when he
got interested in the EB-5 regional centre
programme, but he didn’t jump right into
it. With decades of boardroom experience,
he knows that knowing the market and
competition is crucial when starting up. “I
spent three years investigating the industry.
I came to believe that EB-5 had great
potential and that this is something I’d like
to be involved in.” Shortly after, he sold the
software business and set up FirstPathway
Partners (FPP), with the mission to
become the leading EB-5 regional centre
practitioner in the United States.
Careful Project Selection
From the hundreds of thousands of
business ventures that entrepreneurs
launch every year, many never get off the
ground. Others struggle after spectacular
rocket starts. Kraft knows that and
has made careful project selection his
number one business mantra. One of
FPP’s first projects for which it raised
EB-5 investor capital was Delta Hawk
Engines, an aerospace company which
manufactured lightweight and fuelefficient
aircraft engines. Delta Hawk’s
engines are unique in the market as they
are powered by diesel, which means
they can be used in areas where it is
harder to get access to 100LL fuel, which
is typically used in similar sized aircraft
engines. “This was a very exciting project
that did very well, and the investors
have long been paid back,” says Kraft.
Other projects, Kraft says, were
perhaps less unusual and innovative
but all offered investors a very good
investment. Examples include student
dormitories at the University of Wisconsin,
specialised business parks and research
labs, hotels and restaurants. “We have
been very conservative in the projects
that we got involved in. They are not the
huge monster projects that we have seen
in some of the big cities, but all are very
successful. I think smaller projects are
beneficial for the investor because they
can easily get their arms around them.”
Hotels and Hospitality
Some 65% of FPP’s projects fall in the hotel
and hospitality category, a sector that is facing
some serious challenges at the moment due
to Covid-19 travel restrictions. “I am convinced
the industry will bounce back. I actually feel
pretty good about our projects. They are in
strong markets and have strong names behind
them as we usually work with big brands
such as Marriot, IHG and Hilton,” says Kraft.
FPP’s hottest project at the moment is
a restaurant franchise: Teriyaki Madness.
“The model yields the investor true business
ownership and continued potential for
income even after immigration goals are
achieved. Best of all, we have a management
company that expertly runs the restaurants
and day-to-day operations, jumpstarting
the business with their years of experience
and repeatable framework for success,”
60
Investment Migration Yearbook 2O2O/2O21

I think smaller
projects are
beneficial
for the investor
because they can
easily get their arms
around them.”
explains Kraft. This offering, he says, “is
very attractive to Indian EB-5 investors
who – more than many other nationalities
– like the value of entrepreneurship”.
FPP today works in 40 different
countries and expanded its footprint
years ago. “We kind of anticipated the
retrogression issue with Chinese nationals,
and we are active around the world,” says
Kraft. Last year, his firm also started offering
services for E-2 treaty country investors and
investors born in non-treaty countries who
can apply for this type of visa after obtaining
citizenship in the Caribbean country of
Grenada. “This year, due to Covid-19, we
spent a lot of time on rethinking projects
and also upgrading our sales process. We
are scaling up, bringing in people with
industry experience, to better serve our
investors. In 2021, things will start going back
to normal, and we will hit the road running
with a really good track record and some
very exciting projects to present globally.”
Driving EB-5 Forward
Part of Kraft’s mission throughout the
years has been to continuously improve
EB-5. For the past four years, he has
been serving as President of Invest in the
USA (IIUSA), the global industry trade
association of the EB-5 Regional Centre
Programme, which has been suffering
from a series of short-term extensions and
a constantly growing quota backlog. “The
programme has just been extended right
through to December 2020. I think that’s
the 18 th extension over the past four to five
years,” says Kraft. EB-5, he mentions, is
supported by Democrats and Republicans.
“This means there isn’t much of a problem
to get both parties to re-authorise a
programme, but to get them to agree to
a new programme is a different story.”
Although America’s EB-5 programme
has been the most successful immigrant
investor programme in the world, its overall
economic impact on the US economy is
still small, he admits. EB-5 could be of
tremendous benefit to the US economy in
the post-Covid-19 recovery; however, two
things are important for EB-5 to realise
its true potential, he says. The first is to
distinguish between main investors and
family members, as currently the cap of
10,000 visas is still interpreted in a way
that family members are counted toward
the annual visa allocation. “A proper
interpretation of investor visa units would
increase the programme by two-thirds,
which then can bring in $9 billion per
year and create at least 288,000 jobs per
year, so over the course of five years, we are
talking some very significant numbers.”
The second is a long-term authorisation
for about six years. “The extensions aren’t
much of a problem because everybody
understands that the programme just
gets rolled over, but it would still be nice
to have the regional centre programme
in place for a longer period of time.”
Drop in Demand
Rather than a general overhaul, EB-5
has seen incremental change, with some
new regulations coming into effect at the
end of 2019. The definition and selection
of “targeted employment areas,” also
known by its acronym TEA, has been
tightened to ensure that investment is truly
being channelled into areas with high
unemployment. In addition, the investment
threshold for the TEA option has been
raised from $500,000 to $900,000. Has
this affected demand? Yes, says Kraft. “It
had a negative effect. And just when the
market would have adjusted to the higher
number, Covid-19 hit. We all know that
it’s difficult over zoom and phone calls to
really move the programme forward.”
However, he’s convinced that there will
be a return to normality in 2021, although
he admits that the US is in crisis mode –
the presidential election, racial turmoil
and the impact of the coronavirus on the
country’s health all add up. “Right now,
politics is as aggressive as I’ve ever seen
it in my life time. There is certainly a lot
going on, but I am not sure whether this
has diminished immigration interest in
the US because interest in our projects is
still very high from around the world.” He
believes the US is still the top destination
for migrants and will emerge stronger
from the current pandemic crisis.
EB-5 can be a powerful tool to help
stimulate economic development and
job creation. “EB-5 has already proven
effective during an economic recession.
The programme has generated $20.6
billion in investment and created or
saved 730,000 jobs between the fiscal
years 2008 and 2015 when the US was
recovering from the financial crisis.”
New Opportunities
Kraft has extensive experience in running
manufacturing operations, but does he
believe manufacturing could play a greater
role in the EB-5 programme? “I think
manufacturing is getting stronger in the
US, but the problem with manufacturing
is that it is more subjected to global
disruptions and tougher to manage. A
hotel project, for instance, is fairly static
and predictable, and even if the business
fails, you still have the tangible real estate
asset to sell. In the case of manufacturing
operations, many times you are dealing
with lease facilities, so if the product
is out of favour, management makes a
mistake or there is a global interruption
in terms of trade, there is not much left.”
He believes hotels will always be a great
option for EB-5 due to their high potential
for job creation. But they may also be
opportunities in distribution centres on
the back of increased e-commerce activity.
Infrastructure investment is also high on
his agenda. IIUSA is currently working
with US policymakers on defining what
qualifies as infrastructure in terms of EB-5
investment. “The issue with infrastructure
is if it’s just road and bridges – how do you
repay investors? There is really no revenue,
so it would require a government bond or
similar. I think infrastructure investment
is really a big need and a good opportunity
in the US. We are not quite there yet
but it’s definitely an area to watch.”
Kraft is optimistic about the future as
the recent changes to the EB-5 programme
had brought it back to the original idea
of driving economic development in
areas that needed it most. “That’s a very
good change for the long-term, and it
will pave the way for EB-5 to play a key
role in the post-Covid-19 recovery.”
Investment Migration Yearbook 2O2O/2O21 61

LESSONS FROM
LOCKDOWN
MRVA SEES PRODUCTIVITY SURGE DURING COVID-19 CRISIS
Charles Mizzi, Chief Executive Officer of the Malta Residency
Visa Agency (MRVA), explains how the Agency operated
during the Covid-19 outbreak. He says rather than paralysing
productivity, the MRVA processed a record number of
applications while reducing a backlog of pending files.
62
The coronavirus outbreak was fast
and unprecedented. As Malta’s
authorities worked relentlessly
to put into place a series of mitigation
measures to strictly control the pandemic,
the MRVA rapidly set in motion a
business continuity plan. This had two
aims: firstly, to protect employees and
their families, and secondly, to ensure
that the quality service we gave agents
and clients remained constant, of a
high standard, and uninterrupted.
Swift Change to Remote Working
With secure technology readily at
hand, the majority of employees
worked remotely, with skeleton staff
remaining physically in the office. Like
with many other workplaces, this was
a first for us. But I must say it was a
positive experience, as not only was
performance maintained, but in some
cases, it even superseded expectations,
mitigating the potential impact on
our operations while safeguarding the
team. Even the momentum of staff
training – which I strongly believe
in and push – was maintained as
courses and seminars went online.
With this comfort, the Agency
went ahead with its file processing
and its four-tier due diligence work as
usual, revising operational procedures
where necessary to adapt to remote
working and re-distributing work flows
accordingly, without compromising on
our standards and quality benchmarks.
Submission of applications via our
accredited agents continued, and
letters of approvals as well as residence
certificates were issued normally.
The only area where Covid-19 had
an impact on the Malta Residence and
Visa Programme - the MRVP - is where
agents had difficulties in reaching
out to applicants in order to prepare
applications and documentation or
to seek clarifications. We understood
this challenge and supported
applicants coming from affected
regions by suspending deadlines
Investment Migration Yearbook 2O2O/2O21
on response times. We understand
this was greatly appreciated.
Appointments for the taking of
biometrics were also stalled because
potential beneficiaries of Maltese second
residency could not fly into the country
for the taking of biometric data.
Productivity Rise
In the meantime, we processed more
applications than ever, successfully
addressing a backlog of pending
files and significantly bringing down
waiting time. Indeed, our output this
year has already surpassed that of 2019.
We achieved this by investing heavily
in an operational rehaul involving
recruitment, training and outsourcing.
This figure is set to increase further
as we continue putting into place
measures that improve our efficiencies.
Our turnaround time for applications
has also hit the five-month mark, from
submission of a complete and correct file.
We also worked against all odds and
moved into new offices. We overcame
issues of disrupted supply chains
and delivery dates flying out of the
window, to move in and immediately
start giving a superior service to
agents from brand new premises.
I must say we are proud of the
fact that, unlike other competitor
programmes, some of which even closed
their doors completely, the MRVA
maintained its quality service offering,
while making sure all health measures
were taken to safeguard the team.
New Modes of Working
Our aim at MRVA is to sustain a
competitive programme in terms of
benefits offered to applicants as well
as to increase efficiencies without
compromising the rigorous due diligence
that applications undergo. Our swift
adaptation to new modes of working
meant we could continue meeting
our targets. We are now continuing
investing in IT in order to facilitate online
application submission, which will
further contribute to us going digital and
help maintain our productivity gains.
As we still contend with the effects
of Covid-19, we are optimistic that, like
most businesses in Malta, the MRVP
will rise to the current challenges
and continue to be the popular
programme it is, attracting important
foreign direct investment to Malta.
While offering families from third
countries a chance at a second residency
and another world of possibilities in
a safe and stable country, the ultimate
aim is that funds generated by the Malta
Residence and Visa Programme are
channelled towards Malta’s consolidated
fund with direct benefits to our citizens.
Charles Mizzi was
BIO appointed Chief Executive
Officer of the Malta
Residency Visa Agency in February
2019. He began his career in the
banking sector and worked with
a number of local banks, where
he occupied several roles in the
marketing department. In October
2014, he became Executive
Director Media and Marketing
of the Maltese Presidency for
the European Council. In 2017,
he joined the Individual Investor
Programme Agency as Chief
Officer for Communications and
Business Development, garnering
important experience in the sector.

AMERICAN RCBI INVESTORS:
A HUGE MARKET WAITING TO BE EXPLORED
Many Americans never thought of leaving the US. But 2020 has
changed all that, and it’s a topic that is on the minds of a growing
number of people, writes Rogelio Caceres of RCG Global.
Since the end of World War II, the global
ultra and high-net-worth (U/HNW)
community has viewed the United States as
one of the most dynamic business environments
in the world. Whether as an ideal launching
pad to commence a rewarding professional
career, realise entrepreneurial ambitions or to
pursue university and postgraduate studies at
many of the best educational institutions in the
world, the US has long been perceived as the
ideal location. It is not surprising, therefore, that
residency and citizenship by investment (RCBI),
colloquially known as “Plan B” investments,
have largely been perceived by American HNW
investors as assets needed by European jetsetters,
Middle Eastern oil magnates or soon-to-bedeposed
Latin American and African dictators.
Based on the US market’s lack of perceived
need, the global RCBI industry understandably
focused on serving much more fertile markets
in Asia, the Middle East, Africa and Russia,
while the United States, the world’s largest
and most dynamic HNW investor segment,
remained largely “out of sight, out of mind.”
Rising Concerns
As a result of the United States government’s
calamitous response to the Covid-19 pandemic,
however, elite American households began
to become increasingly concerned about
the short- and long-term outlooks facing
their US-based families. At my firm, RCG
Global, we asked ourselves a simple question:
Why should American citizens ensconced
in their homes in Miami, New York City,
San Francisco, and Chicago, to name just
four of the Top 10 wealthiest cities in the
world, not benefit from the same level of
unfettered access, freedom, stability and
security enjoyed by their international peers
in Shanghai, Mumbai, Moscow, and Lagos?
Doubling in Size
Based on our proven track record promoting
the US EB-5 programme, the world’s largest
RCBI programme in highly promising (yet
overlooked) EB-5 markets such as India, Brazil
and South Africa, RCG Global firmly believes
that the American HNW market is poised to
rapidly adopt RCBI solutions. It possesses
several of the most important demand drivers,
which, from a market attractiveness perspective,
are critical to the successful adoption of new
investment migration solutions. No other
country on the planet has the sheer number of
millionaire households than the United States.
If American HNW families begin to adopt RCBI
solutions at a rate anywhere similar to their
peers in China, India and the Middle East, the
entire $25 billion RCBI industry could easily
double in size within 10 years’ time. According
to a Wealth-X/Economist 2015 study, American
households overwhelmingly cite “Quality of
Life” as their number one driver to pursue a
second passport or alternative residencies.
Demand Drivers
Given the spectre of continued social unrest, the
ravaging effects of climate change (particularly
in California and New York City), combined
with the probability of new tax regimes taken
place under a new Biden Administration,
the US HNW market exhibits all of the key
demand drivers to propel a rapid growth curve
going forward. The global pandemic of 2020
fundamentally weakened investor confidence,
both at home and abroad, in the United
States’ capability to effectively manage future
global disruptions and crises. As the situation
worsened over the summer, I personally began
to explore potential RCBI solutions for my
own family. When speaking to friends and
colleagues here in Miami, or in New York and
the Bay Area, for example, I was intrigued by
how many of my peers were open to pursuing
well-structured RCBI solutions as an effective
hedge, an insurance policy of sorts, to sustained
political and economic instability. Their
primary reasons varied from a desire to preserve
their enhanced standard of living, to ensure
uninterrupted access to the best healthcare
providers, to eliminating the personal and
professional drawbacks caused by extremely
limited global mobility resulting from the US
passport’s lack of visa-free travel privileges.
Drop in Passport Power
At the top of my list of “things I never thought
would ever happen…” I would likely have
placed witnessing the rapidly escalating
deterioration in the power of the once allmighty
blue American passport. For as long as
I can remember and as recently as 2015, the US
passport was ranked as the #1 passport in the
world. However, a never before seen drop in
the passport’s global standing this year and the
sudden and unexpected lack of international
mobility in terms of visa-free international
business and leisure travel has encouraged
many to look for alternative solutions. For
example, at the beginning of 2020, an American
passport holder could travel to 185 countries
without the need to secure a visa in advance.
As of September 2020, this number shrunk to
fewer than 75 countries, a global ranking placing
the US slightly behind Botswana (no offense
to my Tswana-speaking friends.) When future
pandemics and other global disruptions strike,
those with the foresight to invest in RCBI assets
will be best placed to weather the storm.
Rogelio Caceres
BIO is the Founder and
CEO of RCG Global,
the first US-headquartered
investment firm solely
focused on the development
of the US-outbound RCBI
business. Prior to RCG,
Rogelio was the co-founder
of LCR Capital Partners
where he led the pursuit of
an audaciously contrarian
strategy focused on
greenfield development
of new investor markets
(e.g. India, Brazil and South
Africa) and ultimately
raising $200 million from
sophisticated U HNW
investors residing in 30
countries around the
world. Rogelio earned
an MBA from Harvard
Business School and a
BSE from the University
of Michigan, Ann Arbor.
Investment Migration Yearbook 2O2O/2O21 63

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PRODUCT DEVELOPMENT
The Many Faces of
Business Migration
Entrepreneurs, start-up founders and digital nomads:
Here’s how they are shaping business migration today
As an alternative or an addition to the residency-by-investment route, a new generation of
visa programmes is increasingly leaving their mark on immigration systems worldwide.
Alexander
Varnavas
Chad
Ellsworth
Stéphane
Tajick
Savvas
Poyiadjis
Juerg
Steffen
The words ‘Silicon Valley’ can evoke
many things – innovation, growth
and unicorn start-ups certainly
come first to mind – but more than
anything else Silicon Valley is a showcase
of immigrant success. No one illustrates
this better than Tesla and SpaceX CEO
Elon Musk who was born in South
Africa and became a US citizen in 2002.
Musk is the prime example of a category
of immigrants that many countries are
currently seeking to attract: talented
entrepreneurs and start-up founders.
While traditional entrepreneur visas
have been around for a long time, and
it’s also not the first time that start-up
visa initiatives are popular, many in the
investment migration industry believe
that these types of programmes will not
only increase in numbers but become
more economically important in the
coming years. They are widely seen as
more politically acceptable than the
conventional residency-by-investment
programmes and offer countries the
opportunity to promote themselves as a
globally competitive player and innovation
nation. Meanwhile, some governments are
seeking to attract a completely new breed
of professionals by introducing digital
nomad visas. Pioneer Estonia is being
followed by others, including traditional
CBI countries such as Antigua & Barbuda.
Anti-Immigration Trend
In most advanced economies, immigration
is a highly debated issue politically and
across society. When politicians discuss
migration, they usually talk about threats
rather than opportunities. The arguments
against it are similar everywhere: migrants
take jobs from locals, lower wages, don’t
integrate with society, strain public
resources and bring crime to the country.
Khalid Koser, Executive Director of the
Global Community Engagement and
Resilience Fund points out that there is
a polarisation of views between those
who champion migrants and those
who believe all migrants, and especially
wealthy migrants, are criminals.
In fact, immigration worries drove some
of the biggest upheavals of the past decade
– the election of Donald Trump, the rise of
populism in Europe and Britain’s decision
to break away from the EU. In this climate, it
comes as no surprise that entrepreneur and
start-up programmes are an easier sell for
governments as they attempt to transform
immigration from being a potential or
perceived economic burden to society
into a tool for economic development,
argues Fragomen’s Chad Ellsworth.
The Dying Entrepreneurs
Meanwhile, there is the general feeling that
the West’s golden age of entrepreneurship
and innovation is behind it. Various studies
show that no matter what measure or
definition of entrepreneurship is being
used, the underlying trend is downward.
“The Western world has been looking
at a demographic problem for decades
now. We have brought immigrants to
replace the ageing labour force, but there
is a large deficit in the replacement of the
entrepreneur class,” says Stéphane Tajick,
President and Head Advisor of Stéphane
Tajick Consulting. Many businesses owned
by the babyboomers are facing succession
issues with not enough buyers to keep those
assets alive, especially outside large cities.
“In Canada, we estimated that billions of
dollars are disappearing from our economy
because businesses are left to die. This
is a problem that Western Europe is also
facing and that immigrant entrepreneurs
could help solve,” he points out.
Politicians and economists are
increasingly interested in the question
of how migrants shape the economy
and how they influence national
innovation, economic growth and sector
competitiveness. Various studies show that
immigrants are more likely to establish their
own businesses, and there is plenty of data
that can be mined proving that immigration
is actually boosting economic growth. In
the US, migrants set up about 30% of all
businesses, even though they account for
just 14% of the population. Studies from
the UK show that immigrants were roughly
twice as likely as British-born individuals
to establish their own companies.
Start-up Mania
Most advanced economies today have a
complex system of immigration programmes
designed to maximise a county’s economic
competitiveness, including business visa for
professionals not sponsored by a destinationcountry
employer as well as channels for
the highly skilled. Start-ups, however, were
long excluded from the business migration
world as their business ideas and projects
were too unconventional and early-stage
for entrepreneur visa. In addition, many
start-up founders have eschewed degrees in
favour of entrepreneurship, which means
they do not qualify for programmes seeking
to attract highly skilled professionals
as these are often tied to a degree.
Start-up visas have attempted to fill
this gap. They have become increasingly
popular in recent years as they allow a
country to market itself specifically to young,
high-potential and innovative founders.
Traditional immigration nations such as
Canada, Australia and New Zealand have
introduced them, but so have a number
of European countries, including Ireland,
Spain, Denmark, the Netherland, Estonia,
Latvia, Portugal and Finland. In Asia,
countries such as Japan, South Korea,
Singapore and Thailand, all offer startup
visas in one form or another, while
in South America nations such as Chile
and Brazil launched them too. It is no
coincidence that many countries added
a tech focus – which country would not
want to attract the next Elon Musk?
Investment Migration Yearbook 2O2O/2O21 65

Impact on the IM Industry
Countries are responding in different ways
to this trend, either by inviting foreign
entrepreneurs to establish or relocate their
own businesses or by asking investors to
fund existing companies. Savvas Poyiadjis,
Managing Director of Fides Corp, believes
that for governments entrepreneur
and start-up programmes are more
important economically than traditional
investment migration programmes.
“They focus on entrepreneurship,
innovation and job creation by default
while traditional investment migration
programmes focus mainly on real estate
investments which, although the real
estate sector is crucial to every economy,
lead to one-sided economic growth.”
Juerg Steffen, CEO of Henley &
Partners, points out that countries are
constantly competing for scarce talent and
crucial FDI to diversify their economies
and introduce new opportunities to
their societies. He states that sovereign
states require a competitive edge. “This
is what both entrepreneurship-linked
investment migration programmes and
entrepreneur programmes can provide.”
Hybrid Options
The struggle though is that very few
entrepreneur programmes are attractive
to the traditional RCBI applicant and
high-net-worth investor. “People who
invest for immigration purposes still
prefer real estate programmes,” says
Alexander Varnavas, Partner at Varnavas
Law Firm 1978, a boutique law firm
based in Athens with special expertise in
investment migration. The passive nature
of the investment is a key attraction of
many investment migration programmes.
In addition to real estate, intangible
financial investments, similar to those
Greece has recently introduced, such as
time deposits and bonds, are of interest to
RCBI applicants according to Varnavas.
Many in the industry point towards
the creation of hybrid programmes,
which allow high-net-worth individuals
to invest in start-ups and even more
established businesses requiring
funding. The investment route can be
a direct investment into a company,
regulated loan funds or a national angel
investor platform. There are some good
examples that this model can work.
The USA’s EB-5 programme, which
matches foreign investors with local
projects, is one. The French Tech Visa
programme that offers a visa not only
to start-up founders, but also to start-up
employees and investors, is another.
Nomad Visas
Amid Covid-19, some nations have
been quick to seize a new opportunity,
launching special visas for the growing
pool of location-independent workers.
Thus far, the term digital nomad has
often been associated with gig workers,
millennials and young globetrotters
eager to spend a couple of years working
remotely, changing country whenever
they feel like. The reality though has long
been a different one, with the majority
of digital nomads being high-value
freelancers and consultants, mobile
entrepreneurs and company employees
that decide to embrace mobility and work
from outside the office. This lifestyle
suddenly entered the mainstream
in 2020 as at the height of the global
lockdown, millions of people, along
with their bosses, discovered practically
overnight that they can work remotely.
While since then many have returned
to their office desk, the expectation is
that WFA (work from anywhere) will
become much more common in the
future. Companies that were resistant to
remote work before the pandemic have
become more willing to offer flexible
working arrangements in the post-Covid
‘new normal’ – saving a handsome sum
on rent. In a global poll by research and
advisory firm Gartner, more than 80% of
company leaders surveyed said they plan
to allow remote work at least part time
even after it becomes safe to return to the
office. PwC’s Remote Work Survey asked
US financial services companies about the
topic in June 2020. It found 69% expect
almost two-thirds of their workforce to be
working from home once a week in future.
Legal Basis
Thus far though, remote workers faced
problems because they lacked the legal
basis for their work, leaving them with no
option but to enter on tourists visas and
work illegally. Little Estonia, which already
made global headlines with its e-residency
programme, was one of the first countries
to address this problem. Estonia’s plans
were in the public domain for quite a while,
and the launch of the Estonian Digital
Nomad Visa in the summer of 2020 only
coincided with the coronavirus pandemic.
Nearly 1,800 persons per year could be
eligible to apply for a digital nomad visa,
according to preliminary estimates.
Others followed: Barbados introduced
the 12-month Barbados Welcome Stamp,
while applications for the new ‘Work from
Bermuda’ visa were opened in August
2020, which also offers a 1-year pass to live
and work on the island. One of the biggest
differences between the two programmes
is the price. The Barbados Welcome Stamp
comes with a whopping $2000 price tag,
while the Bermuda visa only costs $263.
Antigua and Barbuda has also launched
a long stay visa programme for persons
who can work remotely. Prime Minister
Gaston Browne said the country has
already received several applications. Many
more countries are currently looking into
establishing similar visa programmes.
Smooth Transition
The idea is that these semi-permanent
residence programmes attract an entirely
new segment of the workforce that never
considered working from and temporarily
living abroad. There are big hopes that if
the new nomad residents like the lifestyle
and environment in their chosen country,
they might consider becoming long-term
residence or even citizens, especially if they
are able to smoothly transition between
the different business migration routes.
The same is true for the growing
field of entrepreneur- and start-up visas.
Start-up visas are often seen as a stepping
stone, rather than an alternative to
entrepreneur visas. Many start-up visas
have been introduced very recently, and
a few are still in the pilot phase, such as
Israel’s Innovation Visa and Australia’s
SISA programme. Governments all
over the world are currently testing
and adjusting their business migration
programmes and are surely keeping an
eye on their competitors. It’s a fast-moving
space that may soon enter a more mature
stage, with the coming years possibly
seeing a closer convergence of talent,
business and investment migration.
66
Investment Migration Yearbook 2O2O/2O21

Interview with CHAD ELLSWORTH, Partner at Fragomen
ENTREPRENEUR VISA
PROGRAMMES WILL SEE
EXPLOSIVE
GROWTH
Fragomen’s Chad Ellsworth believes that
governments will implement a greater number of
entrepreneur visa programmes to attract foreign
innovators who can help with economic recovery
and job creation in the post-Covid-19 era.
We are seeing an increasing
number of entrepreneurial visa
programmes being launched.
What’s driving this trend?
In my opinion it’s a result of a growing
global restrictionist immigration
environment driven by populism and
economic nationalism. It has been a
fairly recent phenomenon, and it’s hard
to pinpoint when it started. However,
we have already noticed that after the
2008 financial crisis and the economic
downturn, many governments began to reorient
their immigration systems towards
attracting the “best and brightest” global
talent and away from more traditional
family or employer-based systems.
Well-known receiving or in-bound
immigration nations such as Canada,
Australia, the UK and the US attempted
to move away from traditional paths of
immigration, to pivot towards a more
merit-based system that seeks to attract
the best and brightest talent including
entrepreneurs. The big question that’s
driving all of this is: how can governments
transform immigration from being a
potential economic burden to society in
some instances into a tool for economic
development? So, paradoxically, political
pressure and nationalism are making
programmes that have a demonstrated
impact on the economy very popular, in
particular in the current situation. For
instance, in the US President Trump
temporarily suspended the approval of
certain green cards until end of 2020 to
protect the American job market affected
by the coronavirus. The EB-5 programme,
however, was exempted from this order,
likely because of its job-creating nature.
The US, UK, Australia, New Zealand,
France, Singapore, Portugal,
Germany and many more countries
offer entrepreneur programmes
today. Which programmes are
standing out to you and why?
The French Talent Passport Programme
has recently been popular with an average
of more than 100 applicants per year,
although not in the same volume that
EB-5 has been popular, where there are
thousands of applicants per year and
major backlogs as a result given the 10,000-
annual limit. Still, it has gained traction.
The UK also runs the Start-up
and Innovator programmes geared
towards highly skilled graduates and
established entrepreneurs respectively.
The programmes are aimed at those
with new and innovative business
ideas and a relatively modest level
of capital investment is required.
There is also an attractive incubatorbased
programme in Canada, although
to my knowledge it has not been used as
widely as some of the European ones. I
think we are going to see a lot more of
these programmes in the near future.
Take the UK’s Tier 1 (Investor) Visa,
which requires a passive investment of £2
million in UK companies. Now, if there are
approximately 300-400 applicants a year,
that’s really a drop in the bucket if you
look at the total size of the UK economy.
It doesn’t make a huge difference into
the overall budget of the UK. So, I think
programmes that are tied towards job
creation, business formation as well as
attracting and retaining highly skilled
professionals are easier programmes
to support, and the UK government
is considering further changes in this
area post Brexit, in addition to recent
changes expanding the scope of its Global
Talent visa programme. We clearly see
that programmes that are tied to real
economic activity and job creation tend
to have support on both sides of the
political spectrum despite an overall
global restrictionist environment.
While from a policy perspective
these programmes might be very
attractive for governments, why
should they be on the radar of startup
founders and young graduates?
It really comes down to price point. These
programmes have a lower investment
threshold than the more traditional
investment migration programmes.
For instance, in France the investment
can be as low as €30,000. Therefore, it’s
attractive to recent graduates who might
have a great business plan and some seed
money or investors within their family
but might not have the $2 million, $1
million or even $500,000 required for
the citizenship or other residency routes.
So, these new programmes are really
geared towards younger immigrants
and recent university graduates.
Do you believe that entrepreneur
programmes will eventually overtake
the importance of traditional
investment migration programmes
and perhaps replace them?
I don’t think we are trending that way yet.
Unfortunately, the application process
around a lot of these start-up visas has
yet to align to today’s business practices.
68
Investment Migration Yearbook 2O2O/2O21

These
programmes
are not
going to be for
everyone. Yes, they
are attractive for
younger immigrants
with a good
business idea and
a corresponding
risk appetite.
Some are very specific in terms of their
sponsor and venture capital requirements,
while applicants also often have to
guarantee a certain level of job creation.
These programmes are not going to
be for everyone. Yes, they are attractive
for younger immigrants with a good
business idea and a corresponding risk
appetite. But I think there is still a lot of
risk associated with these programmes.
The traditional private client who already
has businesses and is looking to expand
globally is in many instances not willing to
take the risk associated with some of these
entrepreneurial programmes. Traditional
citizenship or residency programmes
that offer immediate status are more
established in many instances and have a
less complex application process. They will
remain the more popular choice among
more established high-net-worth investors
given the immediate status granted in
many instances although at a higher cost.
There is a lot of talk about hybrid
programmes, whereby applicants
can invest in start-ups or businesses.
Will this be the next incarnation?
Governments are currently experimenting
with different programme designs.
We are seeing different investment
and employment thresholds, while
investments are sometimes more on the
active and sometimes more on the passive
side. I think it all leads towards more
hybrid programmes and systems because
the trend is clear: more scrutiny will be
applied to immigration systems and there
will be more pressure on governments
to only admit the best and the brightest
global talent for the foreseeable future.
One of the big questions with the
new type of programmes is what
happens when the business fails. How
do programmes address this issue?
It really depends on the programme.
Each programme treats project failure
very differently with very different
consequences. So, the EB-5 programme
has historically not been very generous
with project failure. Investors and
entrepreneurs essentially lost their spot in
the US green card line, had to reapply and
most likely also lost their initial investment
money. Recently, there have been some
regulatory changes that allow investors
to keep at least their spot in line, but they
still have to re-file an application and can
still lose their investment funds in many
instances. So, in my opinion the US system
has not been very favourable to project
failure. In other countries project failure
is not necessarily fatal, and the investor
doesn’t need to immediately leave the
country. The visa can be revived or at least
proceed on a conditional status. There are
a whole host of approaches to that issue,
and the countries that are the most lenient
usually attract the greatest numbers of
entrepreneurs to their programmes.
Most traditional citizenship and
residence schemes have the objective
of convincing highly skilled people to
relocate to their adopted countries.
However, many programmes report
cases of entrants who drop off
the radar and – beyond their initial
investment – are not engaged
with the local community. How
could programmes be improved
to better achieve this objective?
Physical residence requirements are
helpful to governments when seeking to
ensure people spend time in the country.
In order to receive residence in most
of the traditional receiving countries –
the US, UK and Australia – one must
permanently reside in the country or at
least have an intention to permanently
reside in the country. However, it’s all
about governments striking the right
balance. In the US for instance, there is
no fixed number of days needed to spend
here, but we generally advise clients to
spend the majority of their time in the
US. There is discretion for international
business people and people that are
studying abroad, and there are things a
person can do to protect his or her status
if temporarily living aboard. Nonetheless,
the government really looks into whether
the applicant has ties to the host country
– so they do not only check whether the
applicant pays taxes in the US and has
a residence, but they might even check
whether the applicant’s doctor visits are
in the US, where they attend religious
institutions if applicable, if there are
local accounts, gym memberships etc.
What’s your future outlook for
the entrepreneur visa market?
I think we are going to see a real explosion
in this area globally. What happens
to US programmes will really depend
on the November election results.
Generally speaking, though I believe
entrepreneurial visa programmes will
become ever more popular, particularly
to cushion the impact of the Covid-19
economic crisis. A lot of the arguments
that were made after the financial crisis
with regard to immigration will be even
more pronounced in the current crisis.
That’s why I expect to see a greater
number of job-creation programmes.
Chad Ellsworth is a
BIO Partner at Fragomen’s
New York office, and has
been with the firm for more than
15 years. His practice focuses
on representing individual and
business clients in a wide variety
of corporate immigration, private
client and related employment
matters. Chad advises many
high-net-worth individuals
in their immigration related
investments. As investors
from Asia are the largest users
of global investor migration
programmes, including the
US EB-5 investor visa, Chad
regularly liaises with Asian
private clients to address
their global entrepreneurial
or investor citizenship or
residency immigration needs.
Investment Migration Yearbook 2O2O/2O21 69

5 Questions with MARIE’ LOU CUTAJAR, Education and Training Administrator of the Investment Migration Council
From Experienced Experts to Young Professionals:
INDUSTRY CERTIFICATION
FAST BECOMING THE NEW STANDARD
More than 160 students have enrolled for the Certification in Investment Migration course, rendering the
first year of the IMC Education and Training division a success, says Marie’ Lou Cutajar, Education and
Training Administrator of the Investment Migration Council (IMC). Plans for the future include a greater
focus on micro-learning opportunities to allow time-poor executives gain new skills and qualifications.
Can you provide a brief overview of the
IMC Education and Training (IMCET)
division and outline its mission?
The IMC Education and Training is a
specialised division within the Investment
Migration Council. It is the only provider
of certificated professional education
and training courses for advisors, agents,
lawyers, programme staff and others working
in or associated with the industry.
The IMCET was established to formalise
the sector by introducing global standard
qualifications and training which will help
the industry obtain external credibility and
trustworthiness. This initiative was designed to
enhance the participants’ technical knowledge,
competencies and expertise, and prepare
them for this vibrant industry where high
professional standards and values are required.
How many students are currently
following IMCET’s programme?
Over the past year, more than 160 students
globally enrolled for the Certification in
Investment Migration course. This is the
first course of its type – which was specially
designed for those working in the industry.
It is delivered online through our custom
Learning Management System and includes
five compulsory modules. The success rate
is very high. At the end of September, almost
100 participants completed the course and are
now IMC certified practitioners Cert (IM).
How would you describe your first year of
operation and what would you highlight
as IMCET’s main achievement to date?
The IMCET’s first year was a very busy one. We
have focused on the growth of the Certification
in Investment Migration course by reaching out
to practitioners from all over the world, through
social media, conferences and the like, with the
aim to explain the rationale for taking such a
course and the benefits of getting qualified.
A global pandemic outbreak was certainly
something we had to adjust to. We have in
fact made the course more accessible by
introducing discounts for those who wished
to get qualified. However, at the same time,
we have seen that online learning proved to be
beneficial to the many practitioners who had
to adjust their way of working and experienced
a downtime which they used to get certified.
One of our biggest achievements is
probably managing to successfully get the
message across that the professionalisation of
our industry through education and training
is very important. The number of students
who enrolled for this course already show
that many have indeed understood that global
standards, education and qualifications will
contribute to a well-respected industry.
Positive feedback from experienced
practitioners who acknowledge the value of
the Certification and appreciate the additional
knowledge they are getting from this course has
certainly been of great satisfaction for us as well.
What are IMCET’s plans and priorities
for the next 12 to 24 months?
Our focus for the coming months is to grow
our education and training portfolio. To this
end we have been working over the summer
months on some new and exciting projects. We
are in fact planning on launching some new
modules, with subjects that will be of extreme
interest for those working in the industry. We
are also looking into re-inventing the current
course into ‘bite-sized’ learning options, which
should be well received by practitioners who
wish to upskill, but their busy schedules do
not allow them to sit for longer courses.
What personal message would you like
to share with the investment migration
community about IMCET and the further
professionalisation of the industry?
The IMCET has been mandated with
the task of creating an Education and
Training Framework for the industry, with
the aim to build a solid ground for further
professionalisation of the sector. This past year,
with the introduction of the Certification in
Investment Migration, showed our commitment
towards enhancing the industry’s standards.
We are very excited for what is coming
next, as we keep creating courses aimed at
developing professional competency and
standards amongst those working in our
industry. All training content will keep the IM
community abreast of developments in the
industry and at the same time attract new talent,
which will sustain the sector’s growth.
Marie’
BIO Lou Cutajar has
joined the IMC
as the Education and
Training Administrator.
She acts as the point
of contact within the
IMC for all training
related enquires. She is
responsible for the dayto-day
co-ordination
and administration of
the training programme,
making sure that all those
who enrol for the course
have the assistance
they require. Marie’ Lou
is also leading several
projects within the IMCET
with the intention to
enhance professionalism
and to set standards
of best practice in
the IM industry.
70
Investment Migration Yearbook 2O2O/2O21

IN THEIR W,RDS
“I decided to follow an IMCET training
programme because I am aware that
the investment migration industry is a
relatively new industry, and therefore
it is really improtant to acquire
professional competencies that will
give more credibility and reliability to
the professionals in the sector. This
course has provided me with an advantage when I interact
with potential clients in terms of professianal trust.”
Matteo Cicero
Attorney - PKF China
“Obtaining the Certification in
Investment Migration allowed me to
quickly adapt my financial background
and transition smoothly into the
investment migration industry. I consider
it to be an essential tool for those looking
to better understand the fundamentals
and gain a practical approach to due
diligence, anti-money laundering risks, privacy regulations
and ethical standards. Being a certified professional
provides me with an additional layer of trust when dealing
with clients, stakeholders and other practitioners.”
Michel Soler
Associate Director LATAM - Henley & Partners Canada
“IMCET is the leading professional
entity within our industry, and I
wanted to learn from the most
reputable organisation. Completing the
course gave me definetly a much
stronger confidence when dealing
with different areas of our industry. I m
proud to hold an IMCET certificate.”
Nóra Gömöri
Business Development Manager - BEYOND, United Kingdom
“I have been involved in the
immigration and relocation industry
for 23 years. I decided to enroll in the
IMC course to continuously update
my knowledge and skills. With great
surprise, I realised that the tools
the course presented were more
comprehensive than I had expected. It
did not only assist me in enhancing training for my team,
but it also helped me in future-proofing our company.”
Maria Kouri
Managing Director - Corporate Relocations Greece
“I attended my first International
Residency & Investment Conference
in 2019 as I was concerned about
going beyond my professional
boundaries as an expert lawyer
in Immigration Law and Spanish
citizenship. This is where I
discovered the IMC and its training.
The training provided me with a deeper knowledge of
the history and functioning of the industry and gave
me the right tools to position my company at the
highest international level. The curriculum exceeded
my expectations. The areas studied gave us a complete
picture, and I consider it an essential training for those
who want to join and form part of the industry.”
Viviana Echeverria
Lawyer - Echeverria Abogados Spain
“My primary motivation for earning
the Cert(IM) was to further my
understanding of the CBI industry.
The evolution of technology has
completely transformed the
way people communicate and
conduct business within any
given society, but even more
so between various societies. To me, the continued
popularity of RBI and CBI programmes is a natural
outgrowth of this global evolution. Having the Cert(IM)
designation is credible evidence to my clients that I
have an understanding of this important industry.”
Ted Prillaman
Principal - Equinow USA
“The IMCET training programme
was a great step at the stage I was
in my professional development.
I had been looking after due
diligence work for actors in this
space for a few months, and I
felt it was the perfect time for
me to advance my knowledge
of the industry. The training programme helped me
understand my clients’ mission far better, helped me
understand the current challenges facing the industry,
which in turn improved the quality of my work and
enhanced my skillset as a professional in compliance. I
particularly appreciated the high-level overview of the
CBI and RBI programmes and the discussion around
moral considerations around the programmes.”
Anca Patrascu
Case Manager, Enhanced Due Diligence - Refinitiv, UK
Investment Migration Yearbook 2O2O/2O21 71

“When we study together, we
learn together, we work together,
and we prosper together.”
Barack Obama
CONGRATULATIONS:
IT IS NOW TIME TO CELEBRATE YOUR SUCCESS!
We are delighted with the number of students who successfully
completed the Certification in Investment Migration and are now
officially certified IM practitioners. Well done for your achievement.
Andres Gutierrez
Andrew Hesner
Alan Huether
Aimee Lisle
Aleksandra Smolen
Alexander Zvarkovskiy
Analida Vallarino
Anca Patrascu
Andria Petrou
Bobbi Jo Kutch
Eliot Brendon Mc Gillivary
Christina Georgaki
Caterina Assunta Passini
Cedric Leblanc
Cheryl Francis
Clare Monique Aquilina
Dmitry Shishkin
Dalia Akl
David Paillé
Dmitry Dudarev
Dom Barnes
Elizabeth Davison
Gabriele Avellino
Tessy Ekpunobi
Hangama Wanner
Hassan Sattar
Irene Davidson
Valentina Alekseyevna
Sammut
Viviana Echeverria Pascual
Irina Walsh
Jaynelle Lake
Jessica Debono
John Richardson
Joshua Lake
James Swenson
Jusztina Rebeka Juhasz
Katarzyna Aldycka
Kathy Rivera
Keith Isaac
Kenny Arevalo-Lebrun
Lilla Krifaton
Jennifer-Lynn Kent
Maria Kouri
Marie Lou Cutajar
Matteo Cicero
Michael Martin
Michel Soler
Madalena Monteiro
Nikkita Nair
Nora Gomori
Pablo Ostrick
Patrick Ansah
Philip Paschalides
Pierre-Étienne
Balthazar-Lacasse
Shane Qu
Rachel Micallef
Rohit Kapur
Roleece Brookes
Sara Rebolo
Sasha L’ecuyer
Chris Siwei Chen
Stefanie Fetzer
Sue Nickason
Sylwia Wolos
Trafford Busuttil
Theodore Prillaman
Vadym Shevchenko
Valeriano Anibarro
Varun Singh
Victoria Atanasova
Vanessa Lima
Christian Wayne
Yanica Woods
Zachary Busuttil
Zain Ahmad Butt
Natalia Zakharova
Malta Individual Investor
Programme staff
members (MIIP)
Malta Residency
Visa Agency staff
members (MRVA)
72
Investment Migration Yearbook 2O2O/2O21

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74
Investment Migration Yearbook 2O2O/2O21
W www.inialamalta.com E Info@inialamalta.com S Iniala Harbour House

WORKING WITH THOSE
YOU TRUST
THE IMPORTANCE OF EXPERIENCED
INSURANCE PARTNERS
Insurance is an often overlooked and underaddressed
topic in the investment migration industry, and there
are compelling reasons to work with a knowledgable
insurance provider, write Mark Jr and Keith Laferla.
As the world continues to fight
a global pandemic, amidst
economic and environmental
issues, the importance of mobility
has never been felt more strongly.
With thousands of flights cancelled
daily and airlines struggling to keep
afloat, the question arises as to the
importance of safeguarding both one’s
personal accomplishments as well as
those that are business-related. The
need for dual or multiple citizenship
has become more evident, and highnet-worth
individuals (HNWIs) are
looking into long term solutions
arising for imminent issues they are
facing as a result of the pandemic
and its impact on related markets.
Complex Requirements
The complexity and the number of
requirements required by wealthy
individuals to apply for programmes
that enable them to expand their
citizenship or residency, such as
CBI and RBI, mean that they cannot
proceed with applications without
the assistance of family offices
or migration specialists who are
very experienced in dealing with
similar requests, applications and
demands. Such providers must also
have the technical know-how to do
so, especially with more complex
and technical requirements such
as insurance, which requires both
expertise and adequate licensing.
As may have become more
evident through the pandemic,
each industry is intertwined with
a network of conjoined markets,
and when dealing with CBI &
RBI applicants, amongst other
clients, it is important for those
industries to have the same level
of understanding and dedication,
especially when dealing with
HNWI who may have demanding
requirements or/and schedules.
Here are the top 4 reasons to work
with a reliable, experienced and proven
partner within the CBI industry.
1. The Fine Print
The details specific to insurance covers
for such clients consist of a whole list of
requirements that necessitate policy providers
to have experience in order to comply
correctly due to the programme’s particular
requirements as well as very fine print.
Failing to have an insurance partner who
understands these requirements may mean
having applications held up at a later stage.
2. Ahead of the Game
It’s also important that partners chosen are
involved within the CBI & RBI industry
and are aware of the updates and changes
in the industry especially with regards to
regulation. Those providers who are not
fully equipped or knowledgeable about the
industry may decline assistance with such
applications due to the misconception that
clients coming through these programmes
are automatically considered high risk.
3. Lost in Translation
Similarly, providers whose work is not regular
within the CBI & RBI industry may not be
as fast or reliable as clients would expect
the process to be due to their inexperience
of working with clients in the industry.
For example, such providers may not have
staff who can accommodate their clients
by providing services in that client’s own
language, or they may not be accustomed to
going out of their way to meet with partners
or clients outside of normal business hours
to present the required documentation.
4. At your Service
Existing providers in the industry understand
the importance of issuing legal documents or
policies within a short period of time as well as
settling any pending issues or insurance claims
at the earliest. This is simply the level of service
that high-net-worth individuals expect, and
providers in tune with these expectations should
have the setup available to satisfy them.
About Laferla
Laferla and its related services
have joined the CBI & RBI
industry upon the introduction
of the IIP programme in Malta
in 2014 and have worked with a
number of HNWIs and families
throughout the years. Their
expertise and qualifications in
the industry mean that each
member of the Laferla team is
well-versed with the specific
requirements of the clients that
come through such programmes,
and are thus able to provide
professional risk assessment
services. The majority of
accredited agents have already
chosen to work with Laferla and
subsequently earn a fair referral
fee, and in turn, have allowed
the firm to assist over 2,000 IIP
and MRVP applicants to date.
Laferla’s in-house HNWI experts
and second-generation owners,
Mark Jr and Keith Laferla, also
provide advisory services to
HNWIs, their family offices and
service providers on insurance
matters outside of Malta. Both
members of the Investment
Migration Council and qualified
by the Chartered status from the
Chartered Insurance Institute
of London, Mark and Keith are
able to bring their experience to
the table and suggest methods
that governments offering
RBI and CBI programmes may
use to reduce any potential
exposure to state care systems,
for example healthcare and
pension systems, by introducing
insurance requirements
within their programmes.
Investment Migration Yearbook 2O2O/2O21 75

DUE DILIGENCE ROUND TABLE
NEVER
MISS
A RED
FLAG
Is the Standardisation
of Due Diligence the
Way Forward?
Four due diligence experts review the state of play of due diligence in
the investment migration industry and outline how the standardisation
and harmonisation of processes might lead to better outcomes
for the sector in a world of increasing regulation and scrutiny.
James Swenson
Senior Vice President,
Diligence, and Head
of EMEA & APAC at
Exiger Diligence
Sylwia Wolos
Risk Solutions Consultant
Enhanced Due
Diligence at Refinitv
Laura Austin
Head of Investment
Migration Due
Diligence at BDO
Eddy Leviten
Chief Operating
Officer at FACT
76
Investment Migration Yearbook 2O2O/2O21

Due diligence has long been a thorny issue
for the investment migration industry,
with scandals reported in the media
repeatedly suggesting that the depth and
breadth of checks on applicants, their family
members and the origin of their funds vary
significantly. In 2019, the Investment Migration
Council, in coordination with BDO, Exiger and
Refinitiv, formed a Due Diligence Working
Group to examine to explore the potential for
minimum standards across the industry. The
working group published two reports which
aim to address the issues that arise from a
lack of harmonised standardised and can
be downloaded from the IMC website. The
experts agree: The best due diligence is not
only about gathering information and data, it is
also about harmonising the system of checks
and balances that different stakeholders in the
investment migration industry have in place.
How would you describe the current state of
play of due diligence in the investment migration
industry? And what would you highlight as
the most important recommendations of the
due diligence reports published by the IMC?
JS: There is a dire need for more uniform application of due diligence across
the industry. We all know there are certain programmes that are doing a lot in
terms of vetting; but there are also numerous ones that do little to nothing. In
my personal view, these issues are exasperated by the sheer lack of transparency
amongst many programmes, especially residency-by-investment programmes.
All programmes should be transparent about the level of due diligence they
undertake and how the results are used to make informed decisions. Until
this happens, critics will continue to assume no due diligence is done.
For the first time, the two reports started to define the roles and
responsibilities of agents, government programmes, and third party due
diligence providers in safeguarding the integrity of our industry. This is
critical because we have traditionally assumed the responsibility of due
diligence sits only with the government programmes, but there are other
gatekeepers along the way, like agents, who can weed out bad actors from
the very beginning through standard know-your-customer (KYC) checks.
SW: To me, the most important takeaways from this project and resulting
publications are the need for increased transparency, the need for clarity
of roles and the need for practical solutions. It’s important that data and
facts-based information is provided to external stakeholders so that they
can comprehensively understand what the due diligence processes within
some CIUs are. In terms of the clarification of roles, we need to understand
that while the application approval responsibility lies with the governments,
each of the stakeholders engaged in the process carries responsibility for
managing financial crime risk exposure. It’s the first time these various roles
have been clarified in the sector. The second report provides a very tangible,
practical set of tools and recommendations, making it much easier to build
the risk management process or review and improve an existing one.
LA: The central theme of the two reports is the necessity of uniform
minimum due diligence standards for both government programmes
and agents. Uniform standards, coupled with strong governance and
transparency into the measures being taken, will lead to a more secure
industry, a more even playing field for industry participants, and will
significantly contribute to the industry’s perception and reputation issues.
The reports provide detailed guidance for minimum due diligence
standards, including five-step processes for both government programmes
and agents. While government programmes are the ultimate decisionmakers,
the suggested added level of responsibility and involvement
for agents is a further sign of the industry’s desire to implement strong
governance and oversight. Although implementation and regulation of
the standards outlined in the two reports remain the subject of further
debate, the reports are a significant and cohesive step in the right direction,
and the first of its kind within our industry and across providers.
We have traditionally assumed
the responsibility of due diligence
sits only with the government
programmes, but there are other
gatekeepers along the way, like agents,
who can weed out bad actors from
the very beginning through standard
know-your-customer (KYC) checks.
James Swenson
Investment Migration Yearbook 2O2O/2O21 77

The reports argue that both RBI and CBI programmes
should implement the same due diligence standards
based on a five-step process. However, there is
no supranational body regulating the investment
migration industry, and it falls on governments to
ensure that minimum standards are met. What are
your thoughts and opinions on this matter? Will we
see greater harmonisation in the years ahead?
JS: While there may not be a supranational body regulating the industry, there have
been some significant developments regulating how “golden visa” applicants should
be treated. The 5th EU Anti-Money Laundering Directive stipulates “Golden Visa”
applicants should be classified as “high risk” which in turn, requires enhanced due
diligence. This is an important step in institutionalising the level of due diligence
that needs to be applied. But ultimately, what would really move the needle is
industry self-regulation. We should use the recent scrutiny on the industry to selfpromote
the importance of uniform application of due diligence across agents and
governments. We will only address the criticism through standardization, otherwise
lax controls in certain programmes will adversely affect the whole industry.
SW: The agents and banks processing the application payments and opening
applicants’ accounts in many jurisdictions already need to follow Anti-Bribery and
Corruption (ABC) and Anti-Money Laundering (AML) regulations and apply the
verification procedures under their Know-Your-Customer (KYC) policies. These,
however, vary from one jurisdiction to another and so cannot be fully relied upon
by the investment migration sector. Because of the legal implications of citizenship
or residency status as independent state matters, the industry needs to rely on
standards driven by associations such as IMC. The lack of supra-national oversight
is somehow replaced in the sector by the scrutiny and attention that the press, NGOs
and civil society give. This, in turn, drives an increased reputational and political
risk for those governments who do not adhere to risk management best practices.
EL: The programmes with which we work all demand a high level of documentation
and substantial paperwork to support the application process. We apply the same
degree of due diligence to all CIUs and pride ourselves in our professionalism and high
standards. There is scope to introduce a minimum standard across the board, but the
responsibility also lies with the due diligence provider to highlight any areas lacking that
will result in ineffective due diligence, on a case by case basis. Technology could offer
some effective solutions to harmonise some areas, including standardising forms and
templates and allowing for digital IDs and security features to be built in at an early stage.
The lack
of supranational
oversight is
somehow
replaced in the
sector by the
scrutiny and
attention that the
press, NGOs and
civil society give.
Silvia Wolos
LA: Regulation of minimum due diligence standards, both at the agent and
government levels, remains a challenge and topic for further discussion. At the
agent level, similar to the banking industry, there is the possibility of implementing
measures such as fines and/or bans, but without an industry-specific regulatory agency,
infractions are difficult to investigate, and enforcement is seemingly impossible.
The question of enforcement and regulation becomes significantly more difficult
at the government level, as the autonomy and decision-making ability of the nation
states is an undeniable factor. Industry regulation and compliance is ultimately
possible, but it is going to take further exploration and solution-seeking.
Ultimately though, the agents and government programmes that choose to
subscribe to the minimum standards outlined in the reports will also hopefully follow
guidance from the reports around increased levels of transparency, which serves to
better the security and reputation of the industry. Regardless of the regulation in
place, all stakeholders in this industry have a vetted interest in its continuation and
success, and it is our desire that these reports serve as a catalyst for industry progress.
78
Investment Migration Yearbook 2O2O/2O21

There is scope to introduce a minimum standard
across the board, but the responsibility
also lies with the due diligence provider
to highlight any areas lacking that will result in
ineffective due diligence, on a case by case basis.
Eddy Leviten
How has the covid-19 pandemic affected
due diligence operations and particularly
your ability to verify information?
EL: We had planned ahead to ensure our business was resilient and we
migrated our staff to home working with no disruption to our clients.
In respect of our verification processes we did encounter some delays to
checks in-country, where government offices were closed and where travel
restrictions impacted on checks made on properties and locations in certain
territories. However, we have not had to curtail nor change the way we verify
information and have been able to continue to deliver reports to clients
within acceptable timescales. Inevitably, also, given the political and social
instability within some of the territories in which we conduct verification
we are constantly adapting our processes to ensure we can deliver the most
effective results for clients without compromising the accuracy of reports.
SW: Early on Refinitiv decided to move the entire company to a
virtual office environment before lockdowns were mandated by many
governments. We’re also fortunate to have robust and flexible technology.
We had upgraded our suite of collaboration and communication
tools recently, meaning we had access to teamwork applications,
and the transition to virtual office was relatively easy for us. As for
data retrieval and verification of information, of course, we observed
some delays in the retrieval of information from official sources in
countries with lockdown measures, especially those with less advanced
digitised databases. When it comes to local human intelligence, since
most of the industry source queries are within our existing network,
it has been possible to maintain a high rate of on-time delivery, as
telephone interviews replaced face-to-face meetings partially.
LA: Covid-19 has had an impact on industry operations around the world,
and the due diligence industry is no exception. Proper due diligence is
comprised of information garnered from public and proprietary data
sources, as well as local, in-country intelligence, comprised of human
source information, manual records searches, and in-person access to
official government ministries. In this way, much of our most valuable
intelligence was at the mercy of jurisdictional regulations and restrictions.
As Covid-19 intensified, most jurisdictions closed nonessential
businesses, implemented lockdown mandates and
banned public gatherings. These initial measures undoubtedly
impacted, and in certain cases temporarily halted, aspects of our
due diligence process, most significantly in the verification of
documents and credentials, reputational inquiries and site visits;
all of the areas requiring in-person interaction and contact.
Fortunately for due diligence operations, most countries experienced
some degree of lockdown measures at the same time, and only for a short
period of time, during which we all—providers and clients alike—took a
bit of a step back, got our new at-home worlds in order, and then resumed
operations at a time when most of the essential aspects of our due diligence
were able to proceed with some semblance of normalcy and without delay.
JS: When the pandemic intensified, we internally transitioned to 100%
remote work overnight across all of our locations. While working from
home was a relatively new concept for most of our researchers, the transition
has been remarkably seamless. Most digital sources have remained
unaffected during the pandemic though some in-person and telephone
verifications have been impacted by remote work. At the beginning of the
pandemic, there were some delays due to government shutdowns, but we
have recently seen a normalisation of lead times on most verifications.
The coronavirus
accelerated the adoption
of digital technologies
by most Citizenship by
Investment Units (CIUs),
which started to accept
online applications and
are requiring fewer
documents to lodge
applications and start the
due diligence process.
While this has made the
application process easier
for investors, do you have
concerns from a due
diligence perspective?
JS: The due diligence process relies
heavily on the review and verification
of documentation provided by the
applicants. As long as these are
transmitted to the due diligence providers
in a secure environment, there should
be no concerns. In fact, if the pandemic
has taught us anything, is that virtual
environments can facilitate the process
and potentially reduce the turnaround
times without compromising
the quality of the due diligence.
SW: This pandemic indeed unlocked so
many new opportunities people didn’t
think of or were not bold enough to
implement. We see a lot of innovation
happening in the client onboarding
processes—within the investment
migration sector but also in the banking
sector. The lower level of document
requirements should, however, be
balanced with a robust verification
process and with independent opensource
information collection. While
some documents may not be critical,
others—like those proving the legitimate
origin of the applicant’s sources of
wealth (SoW) and Sources of funds
(SoF)—remain critical to ensure that
CIUs do not accept illegitimate funds.
Common sense and a risk-based approach
need to be applied and adhered to
in the application-vetting process.
Investment Migration Yearbook 2O2O/2O21 79

As enhanced data privacy
restrictions are enacted
in jurisdictions around the
world, due diligence processes will
have to adapt accordingly, and, in
some jurisdictions, it will be necessary
to find alternate legal methods of
obtaining meaningful intelligence.
Laura Austin
LA: The changes implemented in light of Covid-
19 showcase the adaptability of the CIUs, and
in many ways are another great example of
positive progress emerging from the pandemic.
From a due diligence perspective, the more
comprehensive information and documentation
we have at the start of an investigation, the
better and more comprehensive the output
will be. However, this is in no way positing
that comprehensive and high-quality due
diligence cannot be conducted without the
comprehensive set of required documents
in hand. In reality, due diligence, when
conducted properly, only partially relies on
the documents and information reported,
while equally relying on intelligence and
information that was not disclosed.
Additionally, it is worth noting that to
date, we have not seen a significant number of
files submitted to us with missing documents.
Certain of the documents we have received
have not been notarized, as notaries in many
countries were not available during lockdown
periods, but with the exception of a few
jurisdictions, the lack of a notary stamp does
not typically impact our ability to confirm the
document with official in-country sources.
There is rightfully a concern on some
level about an impact to the due diligence
process if, for example, a significant number of
documents are absent at the time the diligence
is initiated, but this has not been our experience
to date, and we are confident that the CIUs
will continue to apply adequate standards
when it comes to the documents received and
the initiation of the due diligence process.
EL: We support the adoption of technology
to assist both applicants and the CIUs.
Whilst supplied documentation is, of course,
fundamental to the process, it does not tell
the full picture and our checks online and
in-country enable corroboration of genuine
information and discovery of false or
misleading information. We work alongside
the CIUs when conducting verification, and
if a perceived issue or threat is identified,
we would always liaise with the relevant
CIU and request further documentation to
alleviate concerns. As technology develops,
we believe that the application process
can be streamlined and, potentially, allow
for verification to be more transparent.
How do you expect the due diligence
practice to develop in the next five years?
SW: I think there will be further significant improvements
in the process of risk assessment and lower-risk application
vetting, driven by technology and automation. As more data
becomes available in digital format and Machine Learning
and Artificial Intelligence tools become smarter and more
available to practitioners, the vetting process will become
faster and more seamless, particularly for low-risk applicants.
However, where the risks remain high—either because of lack
of transparency, lack of documentation, remote location in highrisk
perceived countries—local and human based intelligence
will remain the sine qua non of effective due diligence.
JS: Hopefully we will start to see a more uniform adoption of
due diligence for agents and governments across the industry.
This is especially critical for the Western European residency
programmes that deal in high volumes but seemingly do very
little due diligence. Ideally, these Golden Visa programmes
would adopt the minimal due diligence standards outlined
in the IMC-coordinated reports, publicly outline what level
of vetting takes place at the applications stage and what
risk-based approach is taken when making decisions.
LA: Technology will continue to play a significant role in
the evolution of the due diligence industry, both in internal
process enhancements and end-user offerings. We expect
significant advancements in internal technology solutions that
allow for added efficiencies in record retrieval, analysis and
reporting, leading to improved turnaround times, increases
in capacity, and more sophisticated levels of risk-based
analysis. For end-user solutions, we also expect enhancements
to risk rating and post-investigation monitoring tools.
External to enhancements from providers, the next five years
promise to bring additional data privacy measures in a number
of jurisdictions, including increased use of anonymization
and pseudonymization in records. As enhanced data privacy
restrictions are enacted in jurisdictions around the world,
due diligence processes will have to adapt accordingly, and,
in some jurisdictions, it will be necessary to find alternate
legal methods of obtaining meaningful intelligence.
EL: With ever greater scrutiny on programmes by the media and
policymakers, it has become vital to ensure that every application
has been checked and all sources verified. Digital passports
and IDs will change the way we all verify our identities, both at
home and when travelling. That will inevitably alter the way in
which verification for citizenship takes place and should allow
for better initial checking. We also support the IMC’s work to
establish best practice in due diligence and that will help to allay
the fears of some on the quality of citizenship granting.
80
Investment Migration Yearbook 2O2O/2O21

United Kingdom
United States
Turkey
Malta
Canada
Portugal
Montenegro
Austria
St. Kitts & Nevis
St. Lucia
Dominica
Grenada
U.A.E
Greece
Andorra
Antigua
Switzerland
Vanuatu
Australia
Ireland
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info@beyond-immigration.com

REAL ESTATE
REAL ESTATE INVESTMENT OPTIONS:
HERE TO STAY
BUT INFLOWS SHOULD BE BETTER MANAGED
Real estate-linked investment migration programmes are a firm favourite among
applicants; however, they do not always deliver the intended economic impact. The IM
Yearbook spoke with five industry experts about the appeal of the real estate route and
what could be done to ensure that this investment option realises its full potential.
The real estate sector has long been closely intertwined
with the investment migration industry. Today, the large
majority of residence- and citizenship-by-investment
(RCBI) programmes offer a so-called real estate route, whereby
the purchase of property is considered an eligible investment.
Although property-based residency and citizenship programmes
remain popular choices among investor migrants, industry
experts say there is a need to better direct real estate inflows
to avoid potential negative repercussions on the local real
estate market and to ensure a wider economic impact.
Real Estate Attraction
“The real estate route is a well-tested option,” says Yiannos
Trisokkas, Chairman of Henley & Partners Real Estate Committee
and Director of Casamont, the real estate arm of Henley &
Partners. It offers investors opportunities for income generation
through leasing as well as a clear exit strategy, Trisokkas explains.
However, especially in turbulent times, investors appreciate
real estate investment as part of a long-term back-up plan, he
says. “Without a doubt, after the Covid-19 experience, people
will want to have a home in an alternative location as a backup
in case we face similar situations.” Gaye Hechme, Managing
Director of Island Living in Antigua and Barbuda, agrees.
“With the advent of the Covid-19 pandemic, we are seeing a
greater number of applicants looking to invest in property
that gives them the option to live in a safe country, a place to
reside should the need arise in today’s uncertain world.”
Frederico Seixas of Investaureum says real estate is
still the number one driver and vehicle for the investment
migration industry. “Real estate has been for decades known
as the most secure and solid investment when compared
with other investments options such as government bonds.
However, high-net-worth individuals do take advantage
of these assets. Purchasing property is more than just
fulfilling a government obligation. Properties are often
used for family vacations, although many clients also
appreciate the fact that real estate can be easily re-sold.”
Christos Kotsaidis, CEO of Filia Investment, points
to steadily rising real estate values in Greece. “Despite
the Covid-19 pandemic, the real estate market in Greece
keeps on a steady pace. There are many undervalued
properties due to the country’s 10-year financial crisis that
ended in 2019, which present an attractive investment
opportunity. In my opinion, I won’t be surprised if we see
an increase in property value of 15% to 20% in 2021.”
Investment Migration Yearbook 2O2O/2O21 83

Economic Impact
Economically, Seixas continues, real estate projects linked to
investment migration can have an enormous impact. “These
programmes often bring in important financial aid required
to rehabilitate communities and entire city centres. Then
there is the job-creation aspect. Here we need to look at both
the job creation as part of the construction and development
of a project, but when it comes to bigger projects, such as
hotels, we also need to take into consideration the jobs that
are created once these projects are up and running.”
Trisokkas agrees saying that “these programmes can possibly
provide a series of significant liquidity injections into an
economy and create paths for strategic investments that assist
with the modernisation and diversification of smaller nations’
economies, creating a better life for their citizens”. Gaye
Hechme highlights that real estate projects are also a source
of government revenue creating income in the form of taxes,
duties and fees related to the operations of the project.
Unbalanced Growth
Critics of real estate-linked investment migration options
often argue that they can lead to one-sided economic
growth and negatively affect the property market by
pushing up prices so that housing becomes unaffordable
for the local population with modest and middle-income
levels. “This can happen,” says Seixas. “That’s why it’s
very important that local authorities are very attentive
in legislating appropriate bills in order to minimise this
effect, although a higher demand will always impact
the pricing of real estate no matter whether it’s related
or unrelated to the investment migration,” he says.
“If the country does not structure the real estate route
correctly, then it might have a negative impact,” Trisokkas’
admits. “There is definitely a greater need to structure
long-term strategies for the real estate route so that local
communities enjoy the benefits of these foreign direct
investment inflows.” He believes countries should structure
their programmes “in a way that motivates applicants to
invest in less developed areas, for example away from the
city centres or prime locations, so that these areas see a fresh
injection of capital”. Moreover, he says, investment migration
programmes have a vast potential and could further assist
with the creation of a new branded touristic product and,
at the same time, upgrade the existing infrastructure.
For Cameron Fraser Antigua and Barbuda demonstrates
that this strategy can work. “Antigua required from the
start that all CBI real estate projects need to be within
clearly defined development zones that have primarily
been set aside for the development of hotel room stock.
This policy has been successful and has seen a significant
increase in the number of hotel beds in Antigua funded
by CBI real estate investments. If this policy is maintained,
we believe that some of the issues that have become
apparent in other markets will be avoided,” he points out.
84
Investment Migration Yearbook 2O2O/2O21

BIOS
Yiannos Trisokkas is the Managing
Partner of Henley & Partners Cyprus
and the Chairman of the firm’s Real
Estate Committee. He is also a Director
of Casamont Ltd, a real estate company
which is part of the Henley & Partners
Group. Casamont specialises in the
acquisition and management of distressed
assets and serves an international
clientele interested in investments in real estate linked to
residency-and citizenship-by-investment programmes.
Within that context, Casamont offers comprehensive
services, from buying and selling properties to after sales
services including property management and rental.
Frederico Seixas is the Sales &
Marketing Director of Investaureum.
He has 25 years of experience in the
real estate sector, of which seven are
directly with the investment migration
industry. The Investaureum Group is
a Portuguese Real Estate Investment
Group, specialised in Prime/Unique
Real Estate Chartered/Heritage
investments that are eligible for the Portugal Golden Visa
programme. Investaureum has been launching prime
real estate development projects, mainly located in
Lisbon, Porto, Alentejo the Douro Region and Algarve.
Unrealised Opportunities
Both Trisokkas and Seixas are convinced that real estate
will continue to play an important role in the investment
migration industry going forward. However, they acknowledge
that programmes are today offering a wider variety of
investment options, including investment in alternative
funds and start-up companies. They believe that offering
clients many different options is a positive development
for the industry, however, it will not challenge real estate’s
status as preferred route for investment migration.
Kotsaidis points out that global investors are becoming more
and more aware of the Greek market. “They have acquired a lot
of experience of the Greek real estate, and they know what to ask
for. In my opinion, agents and the developers need to recognize
that and help clients in a more efficient and transparent ways.”
According to Trisokkas, governments should pay more attention
to the benefits that real estate-linked investment programmes offer
and develop long-term strategies that would help them to better
manage and direct the flow of capital. “It doesn’t always have to be
residential property. Investor funds could also be channelled into
touristic, agricultural and industrial projects, for example.” Seixas
also foresees a positive evolution of the real estate route, which
will be closer linked to the development of a country’s economy,
for instance through investment in essential infrastructure such
as hospitals, universities and student accommodation. Policies
and regulations that take these elements into consideration would
help this investment option to fully realise its true potential.
Christos Kotsaidis started his
career in the shipping industry. With a
decade’s service in one of the largest
commercial shipping companies, he
gained profound knowledge of business
and then joined the energy sector as
the Commercial Director of a Greek
electricity company. Christos Kotsaidis
is now the CEO of Filia Investment,
which is currently constructing a luxury
complex on the island of Crete in Greece.
Gaye Hechme is the owner and
Managing Director of Island Living, one
of Antigua and Barbuda’s leading luxury
real estate companies, and Island Living
Investment Services Ltd, a corporate
service provider authorised to facilitate
and process applications for the Antigua
and Barbuda citizenship-by-investment
programme (CIP). She held a number
of senior management positions in both the private and
public sectors, primarily in inward investment and in the
acquisition, management and development of tourism
related residential and commercial real estate developments.
Cameron Fraser immigrated to Antigua
and Barbuda in 1967 and attended school
in both Antigua and Scotland. He’s been
involved with the expansion development
of Historic Redcliffe Quay, the development
and expansion of Cruise Tourism in Antigua
and Barbuda. Since 2004 to date, he has
been involved in the development and
management of Nonsuch Bay Resort as a
shareholder. He is currently a Director of Antigua Pier Group
Limited, a Director and shareholder of Coconut Beach Club,
a Director of key Properties Limited and Vice President of
the Antigua and Barbuda Cruise Tourism Association.
Investment Migration Yearbook 2O2O/2O21 85

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DON’T BE THE LAST TO KNOW: THE IMPORTANCE OF
MONITORING
Residency- and citizenship-by-investment (RCBI) programmes have to meet the challenge of not
only weeding out unsuitable applicants at the time of application, but also identifying those who
could bring disrepute after they go through the application process and receive approval. Meeting
this challenge involves employing a multi-pronged approach of enhanced due diligence along with
real-time, ongoing monitoring, writes Karen Kelly, Exiger’s Director of Strategy and Development.
The need for thorough, professional,
enhanced due diligence on
applicants to RCBI programmes
is a standard highlighted regularly by
industry advocates and programmes
themselves. The risks of not implementing
a comprehensive due diligence process
have become evident in cases where
applicants with ties to criminal activity
and corruption have been named publicly
and programmes were subsequently
forced to re-examine their procedures and
consider options for revoking citizenship
or residency. However, even programmes
with otherwise robust due diligence
processes can be caught unaware by
serious events that impact an approved
applicant after an approval is granted.
Applicants can and do experience
material changes to their circumstances
in the months or years following their
approval. External factors, such as
sanctions programmes that target new
jurisdictions or sectors, would be near
impossible for an RCBI programme to
predict. Likewise, yet to be announced
investigations against applicants or
future suspect business dealings present
a challenge when due diligence can only
reasonably (and realistically) examine what
has already transpired or is in progress.
Red Flags
By monitoring subjects through a
technology platform for adverse
developments in the months and years
after initial due diligence, one observes
that sometimes smaller red flags can
precipitate more serious adverse
findings in the future. Such red flags may
include pending litigation, judgments,
investigations, or regulatory actions
against a subject or their businesses.
The following examples are relevant to
the investment migration industry:
u A retired state official with a high
net worth that far exceeds reported
income and investments. Media
outlets report an investigation into
his financial activities has started,
but law enforcement cannot confirm
or deny such rumours at the time
of due diligence. Five months later,
the individual is charged with
financial crimes and detained.
u A business owner who heads a group
of companies had a recent falling out
with his companies’ shareholders and
left his position as a result of related
litigation, which has not yet progressed
through the courts. He is later charged
with multiple violations of local Anti-
Money-Laundering and Anti-Terrorism
Financing regulations and is already
thought to have fled the jurisdiction.
u Individuals with large personal or
business debts due or judgments
rendered around the time of
application, already residing in a
new jurisdiction in anticipation
of avoiding payment.
u Individuals whose political exposure
and relationships have changed
over time as new government
officials take office, or as they
enter new roles and industries.
RCBI programmes make decisions
regarding prospective applicants based on
the information available at the time of
the application. Holding off on decisions
where an applicant is involved in an active
legal case that could have a serious impact
on the applicant’s reputational, legal, or
financial standing can mitigate the risk of
pending outcomes. But in cases without
black and white findings, programmes
assess the risks using the information at
hand and make decisions accordingly.
A Proactive Response
Ongoing, real-time monitoring of
applicants, after the initial due diligence
report has been delivered, is fast becoming
a standard tool for an RCBI programme
to ensure it is alerted should serious
findings come up after an applicant is
processed. It is in a position to proactively
respond, rather than scrambling to react
to media reports and public pressure.
Ongoing monitoring also presents a
learning opportunity when applied
to applicants that were not accepted
or are still being considered, as it can
validate the programme’s risk assessment
framework and identify patterns to
look out for in future applications.
Monitoring across an applicant
population does not need to be a heavy lift
for a programme. Artificial intelligencepowered
monitoring can scan thousands
of sources in multiple languages in real
time, eliminating false positives, and
continuously refining an applicant’s
risk profile. The right technology can
be leveraged to scan for specific types
of events and red flags for which a
programme wants alerts, such as ties to
sanctions or criminal proceedings. RCBI
programmes that add technology-enabled
monitoring to their toolbox for assessing
applicants, and that are transparent
about its implementation, have an added
deterrent against bad actors. A combined
approach of third-party due diligence
and ongoing monitoring makes it more
difficult for those looking to escape
future consequences and strengthens a
programme’s reputation for accepting
only the highest-calibre individuals.
Karen Kelly is Director of
BIO Strategy & Development for
Exiger Diligence, focusing
on the Immigration, Citizenship,
and Visa (ICV) Practice. She
has 12 years’ experience that
includes managing due diligence
services for residence- and
citizenship-by-investment (RCBI)
programmes, financial institutions,
and corporations, and developing
specialised due diligence
training programmes. She also
participated in a large-scale RCBI
programme review focusing
on policies and procedures,
workflow, operational support,
and system implementation.
Investment Migration Yearbook 2O2O/2O21 89

HOW WE CONDUCT
IN-COUNTRY
CHECKS
IN A COVID WORLD
Trust and confidence matter more
than ever in a world turned upside
down by the pandemic. As the world
struggles to find a way out of the current
crisis, there is much that can be learned from
what happened in the run-up to Covid-19
taking hold and in the subsequent reaction
of governments businesses and individuals.
Investment migration provides opportunities
for individuals and their families to change
their lives for the better and for governments to
benefit from investment to improve the lives of
their citizens and future citizens. However, as we
know, it is vital that those applying for citizenship
through approved schemes are properly vetted
and verified to ensure they pose no risk to the
country to which they are applying for citizenship
nor to the countries to which they might travel in
the future using their newly acquired passports.
Complete Verification
Independent third-party due diligence is the
cornerstone of any citizenship programme
and numerous checks are required to verify
identity, location, property, financial interests and
personal information. Whilst some of this can be
verified through online checks, the only means
of carrying out a complete verification is through
in-country checks; visits to confirm addresses
and businesses and visits to local record offices
to check documents. This is particularly vital in
countries where digital records are non-existent
or where physical documents may be unreliable.
2020 has so far proved to be a challenging
year; for CBI and RBI programmes, for
applicants and for due diligence providers.
Lockdowns and restrictions on movement,
combined with the closure of government
offices, have slowed down the ability to apply,
process and verify. In the case of verification,
this has meant having to review on a daily basis
the situation in specific regions or countries
to assess the ability to obtain information, to
manage risks to agents and applicants and
to ensure that verification can be completed
satisfactorily. This may not always be easy
but communication with clients is crucial, as
is utilising a variety of methods to assess the
veracity of documents whilst maintaining
the highest standards of due diligence.
Ensuring Accuracy
Online resources can certainly offer some
solutions, but it is only through oversight by
experienced researchers and analysts that a
full picture of an applicant’s good standing
can be obtained and communicated to the
client. Whilst the overwhelming majority of
applicants to programmes are acting in good
faith and are not seeking to mislead or provide
fraudulent information, it is well documented
that there are some who may seek to use CBI
and RBI programmes as a cover for criminally
obtained wealth. A global pandemic may
also have given some the mistaken belief that
they can avoid detection during applications
if they think that less checks can be made.
In-country checks on residential and business
locations, finances and assets, and criminal
and civil records form the backbone of a
complete due diligence process, and, by and
large, these have all continued to be carried
out during 2020, though with some delays.
Detailed local knowledge should ensure
that, where there are intermittent interruptions
to travel, these can be overcome by alternative
means of verification or by referring back
to an analyst who can add their skills to the
mix. Identifying unusual behaviours or issues
with documentation requires sometimes
detailed understanding of cultural, political
and hyperlocal influences that need to be
reflected in the checks made in country
and online and then reported back to the
client in interim and final report stages.
That may also require a delay to standard
reporting timelines to ensure accuracy and
that all checks have been carried out.
On top of the ongoing need to ensure
that no shortcuts are taken in the due
diligence process, recent negative media
reports around some schemes mean that
due diligence is in the spotlight more than
ever. The Investment Migration Council’s
recommendations for best practice are to be
welcomed, yet it is vital that the investment
migration sector as a whole takes on board
and supports these measures. Pandemic or
not, there can be no cutting of corners in
any part of the verification process.
Pandemic
or not,
there can
be no cutting of
corners in any part
of the verification
process
Eddy Leviten
BIO is FACT’s Chief
Operating Officer,
managing all aspects of
FACT’s business. He has
over 30 years’ experience
in the creative industries,
retail, enforcement and
policy and was previously
Director General at the
Alliance for Intellectual
Property where he drove
policy across a range
of IP-related issues.
Investment Migration Yearbook 2O2O/2O21 91

Lagos, Nigeria
C-suite Insight
NAVIGATING A CHANGING
GLOBAL MOBILITY
Henley & Partners is one of the largest companies in the
investment migration industry. The IM Yearbook reached out to
the firm’s c-suite executives and country managers to find out
how they view developments in the firm’s most important markets
and what they think of the current state of the industry.
It is safe to say that most businesses didn’t
factor a global pandemic into their 2020
plans, budgets and predictions. Neither
did Henley & Partners. “No one could have
anticipated the tumult of 2020 owing to Covid-
19,” says Dr Juerg Steffen, the firm’s CEO.
While at the onset of the pandemic, the firm
experienced a slowdown from an operational Dr Juerg Steffen
perspective, Steffen is convinced that Henley
& Partners, along with the entire investment migration industry,
will emerge stronger from the Covid-19 crisis. “There has been a
steady increase in interest in our services over the last few years,
and we are looking forward to a record-breaking 2021,” he says.
Coronavirus Impact
The great lockdown, border closures and travel restrictions
have given scenario planning a whole new meaning. The
Covid-19 reality, Steffen explains, has affected clients who
were required but not able to travel to host countries to
proceed with their applications. This delayed applications
that were in process. “However, the various countries that run
investment migration programmes have been quick to adapt
to the current conditions, and we are now seeing smoother
application processes, greatly enhanced by technology.”
COO Stefan Kraus says Henley & Partners itself benefited
from pre-Covid-19 investment in digital platforms. “We have
invested considerable amounts of time, resources and effort
in developing digital solutions for both private clients and
governments, ranging from self-service application portals to
internal application management systems for governments.”
He is certain that many of the digital advances adopted
during the lockdown, such as digital application processing
and verifications, will become standard procedures.
Booming Business
Meanwhile, Covid-19 has greatly increased
demand for investment migration. “We saw
a 49% increase in demand for our services
between January and June 2020 compared to
the same period in 2019,” the CEO comments.
Stefan Kraus adds that demand has increased
once again at the beginning of Q3 2020. “In
August alone, we had double the number of Stefan Kraus
signed-up clients than in previous months.”
According to Kraus, the world’s wealthy today consider investment
migration as more than just a ‘nice to have’ but rather as a
safeguard against political strife, economic turmoil and, as a more
recent addition, healthcare crises, which all have the possibility of
endangering the wellbeing and future prospects of their families.
“We typically tend to see increased levels of activity
in countries and regions whenever there is turbulence or
political unrest,” says Steffen. He points to other volatile
92
Investment Migration Yearbook 2O2O/2O21

Beijing, China
“Wealth creation is
growing at a far faster rate
than the slow-moving
diplomatic engagement that
creates visa-free travel, and we
predict this growth to continue
further in the wake of Covid-19”
Juerg Steffen - CEO, Henley & Partners
LANDSCAPE
situations in 2019 that contributed to dramatic spikes in
interest and enquiries for alternate residence or citizenship
such as the political unrest in Hong Kong, Brazil’s economic
and political crises, Britain’s impending exit from the EU, US-
China trade tensions, Australia’s bush fires, and mounting
concerns over democracy and good governance in the US.
Shifting Criteria
Although political and environmental
risk generally generate interest in the
firm’s services, Dominic Volek, Henley &
Partners’ Group Head of Private Clients,
highlights that the events of 2020 have seen
clients’ objectives and motives shifting.
“While in the past, wealthy clients
Dominic Volek
sought to establish an alternative
citizenship or residence in countries that provided best
access, resources and opportunities, now some of them
are considering a country’s coronavirus response and
pandemic preparedness in general among other criteria.”
This means it’s not business as usual for the investment
migration industry. “We are witnessing the emergence of a
new global hierarchy in terms of mobility, with countries
that have effectively managed the pandemic taking the lead,
and countries that have handled it poorly falling behind,”
says Steffen. The firm is recording a surge in interest from
citizens of advanced economies, including a 324% increase
in enquiries from US citizens between January and October
2020 compared to the same period in 2019. Pre-Covid-19, the
US passport usually ranked within the top 10 of the Henley
Passport Index, with its citizens able to access 185 destinations
around the world visa-free. “However, during the height of the
pandemic, the number of countries Americans could access
without a prior visa dropped dramatically by over 100, with
US passport holders able to access fewer than 75 destinations,
with the most popular tourist and business centres notably
excluded,” says Volek. For Steffen, the marked increase in US
investors looking to diversify out of purely American portfolios
and considering international options is an exciting new
development. Plus, this trend is reinforced by the significantly
greater interest shown by Canadians and UK citizens.
Despite the remarkable interest experienced from Western
economies, Henley & Partners’ focus remains firmly on
countries that are seeing rapid rates of wealth growth such as
Bangladesh, India, Nigeria, Pakistan, the UAE, and Vietnam.
“Wealth creation is growing at a far faster rate than the slowmoving
diplomatic engagement that creates visa-free travel,
and we predict this growth to continue further in the wake of
Covid-19,” says Steffen. To service new, emerging markets, Henley
& Partners opened new offices in India and Nigeria in 2020.
Interest from India
Henley & Partners has long been operating
in India via its regional head office in
Singapore and has seen constant growth
in the market for the past few years. The
decision to open offices on the ground, in
Delhi and Mumbai, resulted in a strong
increase in enquiries this year. “From January
Nirbhay Handa
to October 2020, there was an 81% increase
in India enquiries compared to the same period last year.
Admittedly, Covid-19 has slowed down the actual execution and
processing of applications, but interest and enquiries are at an
all-time high,” says Nirbhay Handa, Head of the India Office.
Due to the slower development of Indian geopolitical,
diplomatic and trade relationships, Handa explains,
many Indians might be extremely wealthy, yet they face
restrictive global immigration policies. Indians are able
to visit only 58 destinations without obtaining a visa prior
to arrival. RBI options are most attractive to Indians as
India does not allow dual citizenship, unless they opt
for the Overseas Citizen of India option, an immigration
status permitting a foreign citizen of Indian origin to
live and work in the Republic of India indefinitely.
Investment Migration Yearbook 2O2O/2O21 93

Ho Chi Minh City, Vietnam
Nigeria: Window to West Africa
Henley & Partners’ office in Nigeria opened
its doors in May 2020 and is headed by
Stuart Wakeling. Thus far the vast majority
of interest is coming from Nigerians, but the
idea is that Nigeria will serve as the Group’s
West Africa hub. “Because of the uncertain Stuart Wakeling
outlook for the Nigerian economy, which has
been exacerbated by Covid-19 and civil unrest in 2020, Nigerian
clients are predominantly seeking alternative citizenship options
to secure their wealth and their families’ future,” says Wakeling.
According to him, there is currently significant interest in the
Caribbean CBI programmes as for Nigerian high-net-worth
individuals these programmes are the most cost-effective
way to achieve global access, plan-b alternatives, investment
diversification and advantageous opportunities for their families.
China: A Competitive Market
Denise Ng is the Head of Henley & Partners’
Hong Kong office and responsible for the
firm’s North Asian business, which also covers
China, Japan, South Korea and Taiwan.
However, the majority of clients are Chinese
nationals, and the firm also has a presence
in Guangzhou, China, while a representative
office in China’s capital, Beijing, is due to Denise Ng
open in late 2020. “Competition is very
fierce in China, with over 20,000 immigration agencies,” says
Ng. The agencies offer very competitive pricing and include
flexi-options and ‘after sale’ services such as assistance with
opening of bank accounts. While real estate-linked investment
migration options are favoured by many Hong Kong and Chinese
clients, Ng reports that in recent years clients have also been
looking more carefully at investment risk, exit strategy, resale
market, and rental yield. Hence, Ng explains, the firm is seeing
a small percentage of clients enquiring about security options
and investment funds. However, it is paramount that these are
well-structured, organised, clear and transparent, with processes
that are uncomplicated and that include an exit strategy. The
Chinese market still holds great potential for Henley & Partners,
especially since investment migration has become popular among
China’s middle class too due to the growing number of residence
programmes with relatively low investment requirements.
Vietnam: Rapid Growth
In 2019, Vietnam accounted for 20% of Henley & Partners’
business in Southeast Asia. “The pool of wealthy people in
Vietnam is expanding rapidly, and this segment of society cares
about global travel and welfare policies. As a firm, we consider
Vietnam to be a fertile market for growth, similarly to India and
Nigeria,” says Alexis Tan, Senior Manager of
Henley & Partners Vietnam. Travel freedom,
rather than relocation, is a main motivation
for many of her clients, which is why they are
keen on CBI programmes that provide them
with more powerful travel documents. If they
do have plans to relocate, Tan explains, they
eye the more traditional RBI options such Alexis Tan
as Australia, Canada and the US, although
there is a long waitlist for the latter. “Interestingly, in the last
year we’ve also been seeing a growing trend of Vietnamese
high-net-worth individuals enquiring about residence options
in Europe, namely Portugal, Switzerland, Malta and Austria.”
Tan’s typical clients are successful businesspeople between
the ages of 40 and 60, but she also sees younger entrepreneurs
who have succeeded early in life. She notes that today plenty of
the world’s wealthy are young, astute entrepreneurs interested in
increasingly varied and sophisticated investment options. “It’s only
fitting that we see many countries adapting their programmes
to suit the new global citizen. For example, in Singapore the
Global Investor Program introduced some changes earlier this
year to include a new category of applicant – next-gen business
owners – and a refined family office investment option.”
A Maturing Industry
In tandem with its clients, the investment migration industry
has matured significantly, which has made it easier to recruit
individuals to join the industry. “In the past, it was more
challenging because the industry wasn’t very well-known,”
says COO Kraus. Nonetheless, other challenges remain such as
scepticism towards investment migration as well as the lack of
regulation. “We are painfully aware that at times industry players
do not adhere to the best practice or corporate governance that
are in place.” Kraus points to some smaller players undercutting
on price because they cut corners on due diligence.
Where Do We Really Want to Live?
Henley & Partners, likes others in the industry, is predicting
a surge in demand for investment migration products in the
aftermath of Covid-19 as more states seek to tap into their unique
ability to expand their “sovereign equity by increasing the
number of citizens who actively contribute to the country’s future
well-being,” says Steffen. The firm wants to maintain a strong
presence in its existing markets while growing its footprint in
its new markets in Africa, India and South America. However,
where do people really want to live in the post-Covid-19 era?
“As the curtain lifts,” says the CEO, “people will seek to move
from poorly governed and ill-prepared places to more proactive
countries with greater resilience and better standards of medical
care.” This heightened level of awareness in terms of health and
security, he anticipates, will continue for the foreseeable future.
94
Investment Migration Yearbook 2O2O/2O21

“Wherever I go, I want to be a change-maker”
A direct solution for aspiring entrepreneurs seeking UK residency.
As the United Kingdom exits the European Union, there
has never been a better time for ambitious changemakers
to participate in the country’s rebirth as a new
Global Britain.
The UK Innovator visa offers a stress-free route for
international entrepreneurs to obtain UK residency and
a pathway to citizenship. The InvestUK Group has
successfully managed over 300 cases, helping clients
from over 34 countries to start the next chapter of their
life in the United Kingdom.
Applicants share their innovative, viable and scalable
ideas with InvestUK, who advise on how best to localise
their plan for the UK market, provide support with
market analysis, introduce to a local co-founder and
document their ambitions with a detailed business plan.
When they are ready, clients are introduced to an
authorised endorsing body prior to recommendation to
the Home Office for grant of Entry Clearance. This could
be Innovate in Britain (www.innovateinbritain.com), an
endorsing body organisation within the InvestUK Group.
Innovate in Britain will review the client’s application and
if approved, support their business across the duration
of their three-year period to UK settlement.
InvestUK attracts professionals from all sectors with a
wide range of business experience and expertise. This
diversity is a huge strength, stimulating conversations,
ideas and insights throughout our programmes. It
creates an enriched experience for our participants and
a foundation upon which we can build the UK’s future
prosperity and tackle the greatest challenges facing our
society.
Rupert Gather, Group Chief Executive
+44 (0)20 7629 2522 / rupert.gather@investuk.com
For more information visit www.investuk.com/change-makers
© 2020 InvestUK (Group) Limited. All rights reserved.
A part of

ADVERTORIAL
5 Questions with ANNA GRIGORIEVA, Managing Partner of AG ADVOCATES
EXPLAINED: PERMANENT
RESIDENCY PERMIT IN CYPRUS
While Cyprus has suspended its citizenship-by-investment
programme, the country continues to offer non-EU
citizens the opportunity to become permanent residence.
Anna Grigorieva outlines the main conditions.
What’s the permanent residence
permit and who’s eligible for it?
The Cyprus permanence residency permit
(PRP) is attractive to anyone wanting
to invest in property and permanently
reside in Cyprus but will not work in the
country. This means applicants need
to have an annual income of at least
€30.000 from abroad, so that they don’t
need to engage in any form of business,
trade, profession or employment. An
investment of at least €300,000 in a
brand-new house or apartment in
Cyprus is required to qualify for the
Cyprus residency permit. In addition,
the applicant must deposit a minimum
capital of €30.000 into an account of a
Bank in Cyprus, which shall be pledged
for at least three years. The applicant
must also prove that the funds come from
abroad and from legitimate sources.
How long does it take to
obtain such a permit?
It usually takes around two to three
months from the submission of the
application, but it depends a bit on
the workload of the department.
Typically, it takes a month or so to
complete the property purchase and
to collect all relevant documentation.
It takes another two or three weeks
to get an appointment to submit the
application, and once submitted, the
Civil Registry and Migration Department
reserves the right to request additional
information and/or documentation.
Are investors required to live
in Cyprus to maintain their
permanent residence status?
To maintain the permanent residence
status, investors cannot be absent
from Cyprus for more than two
years. If they are, their permits will
be automatically cancelled.
Can you give us a brief introduction
to AG ADVOCATES and tell
us a bit about yourself?
AG ADVOCATES is the distinctive
name of Anna Grigorieva & Co. LLC,
a reputable boutique law firm, which
I founded in 2012. I am qualified to
practice law in Russia and Cyprus and
have a strong legal background in areas
such as corporate and commercial
matters, insolvency and restructurings,
international tax matters, immigration,
real estate, intellectual property, M&A
and trusts. Today, the firm’s team
consists of experienced qualified
lawyers, insolvency practitioners,
accountants and other professionally
qualified administration staff.
Can you please explain how
you got involved in the field of
residency by investment?
We were looking for new opportunities
to expand our services in 2013, and we
decided to expand our immigration
department. We saw this as a natural
extension of our services and as a good
way to attract new clients and to offer
legal advice on all matters relating
to immigration law. Since then, we
have been providing non-EU clients
with advice on all legal and practical
matters of taking up residency in
Cyprus under Regulation 6(2) of the
Aliens and Immigration Regulations
or otherwise known as Fast Track
procedure – Category 6(2).
We are checking whether the
client fulfils the required financial
criteria, and we conduct an indepth
examination of the specific
circumstances of each client. We assist
our clients with the preparation and
submission of the relevant application,
and upon the submission of the
same, we constantly follow up with
the Civil Registry and Migration
Department for feedback on its status.
Do you have a final message
for potential investors wanting
to obtain a PRP in Cyprus?
Cyprus is not only a popular tourist
destination but also a top spot for
globetrotting professionals and retirees
looking for a safe living environment in
a Mediterranean island setting. Cyprus
is an attractive financial centre due to
its fiscally attractive tax system and
strategic position at the crossroads of
three continents. Besides, the island
offers a high standard of living, modern
transport and infrastructure, excellent
academic institutions, access to quality
medical services, a stable government
and a robust legal framework which
is based on British law and fully
harmonized with EU directives. In my
opinion, Cyprus offers the right mix of
economic opportunities and a stress-free
lifestyle – and this makes it an attractive
destination to live and invest in.
96
Investment Migration Yearbook 2O2O/2O21

INVESTING IN A
GL BAL
Rupert Gather, Chairman of InvestUK, explains what’s driving immigration to the UK at the
moment and talks about the country’s investment attraction in a post-Brexit world.
acts as a great catalyst
for investment,” says Rupert
“Immigration
Gather, Chairman of InvestUK,
a firm specialised in Foreign Direct
Investment (FDI) into the UK economy.
Over the past six years, more than 50% of
investments facilitated by InvestUK have
been motivated by the opportunity to
obtain a UK visa. “We have helped around
300 clients to build their businesses
in the UK, and the total value of those
investments is well over £100 million.
This has created a big contribution
to the UK enterprise economy.”
Three Routes
Despite Brexit and Covid-19, the UK
has lost nothing of its immigration and
investment appeal, says Gather. There
are three different investment migration
paths for foreign entrepreneurs. Investors
can choose between the tier 1 (investor)
visa, the sole representative visa route
and the UK Innovator Visa. All those
programmes have an investment
component in them, which ranges from
£2 million for the tier 1 investor visa to
£50,000 for the sole representative and
the innovator visa route. “What unites
these three programmes is that they are
all related to active entrepreneurship,”
explains Gather. “They are not designed
as passive investments programmes.
The UK government has decided that
it wants to run these programmes
specifically for the enterprise economy.”
The majority of InvestUK’s clients
chose the innovator visa. “There was a
big surprise in the market when the UK
decided to discontinue the quite successful
entrepreneur visa in 2019,” he admits.
“However, once we started working with
the innovator visa, we found that it’s a
very good solution both for the client
and for the country. It is focused on
immigrants starting their own business,
and 80% of our clients want to start their
own business, while 20% of clients are
looking for a UK company to work for or
to partner with.” Under the innovator visa
rule, the applicant’s business proposition
is tested by an endorsing body, which
reviews the business plan and makes a
recommendation to the home office to
either refuse or grant the visa. “If the
visa is granted, in just three years the
client will get permanent residence.”
More than Tech
To qualify for the innovator visa route,
the business has to be innovative, viable
and scalable. Innovation, Gather says, is
often simply thought of as tech innovation,
but it’s so much more. “We have clients
that focus on innovation in the service
economy, while others have come up
with new ideas and processes for the
manufacturing or education sector.”
Viability is a bigger challenge. Applicants
who wish to stay in the UK need to come
up with a new business idea within a
reasonable timeframe if the first one does
not materialise. “Businesses generally do
not fail if there is a good business plan,
and the client is willing to invest sufficient
funds to give the business a good start.
Even though the government only requires
a minimum investment of £50,000, we
recommend a minimum of £200,000 in
order to help manage the risks.” The third
condition is scalability. InvestUK often
introduces clients to local partners to help
them gain specialist knowledge on how
to sell their products in the UK market.
Driving Interest
Gather says there are a number of
geopolitical developments that are currently
driving interest in the UK. “Firstly, there
is Brexit, which in a way forces people to
make a decision. Those that wish to stay
in the UK are required to formalise their
residency, and many are doing this though
an immigration programme.” The second
development relates to British Overseas
Passport Holders in Hong Kong and the
new visa route being announced for them.
“This is actually a free visa route. But in
reality, it has a lot to do with investment
migration because people have to prove
they have a job, and the simplest way
to do that is to create your own job.”
The UK is also benefiting from new
visa rules in Dubai, which is not renewing
certain visas for people who have not
established roles there as a result of Covid-
19. “There is a large cohort of South Asians
– among them many accomplished business
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Investment Migration Yearbook 2O2O/2O21

BRITAIN
This strategy signals that the country
will not become inward-looking after
Brexit, but on contrary will have
global aspirations that go beyond Europe.
people – who now have to leave Dubai
and are looking for an alternative base. For
them the UK is an obvious choice due to
cultural and business reasons.” In addition,
InvestUK is seeing a spike in applications
from Lebanon. “Lebanon is a small
country but with very entrepreneurial
people whose decisions to emigrate are
primarily a result of Lebanon’s political
instability.” Lastly, Gather says, the UK
is the biggest destination for Chinese
students in Europe. “Their numbers are
in fact increasing because many are not
going to the US, which is obviously a
political decision. Some, not all of them,
are interested in investment migration.”
Societal Impact
Investment migration has not only to do
with money but Gather points out that
it’s also about permission from society
to run those programmes. “I think it
is absolutely vital that any migration
programme maintains popular support
so that government can explain to its
people why it’s offering a programme
that is a pathway to citizenship.”
There are many reasons why
investment migration can make a
meaningful contribution to society. Job
creation, says Gather, is certainly the most
obvious one. “But I think we can go further
than this.” He points to a report published
by the Female Founders Forum, which
found that the UK’s economic potential
is being held back by low rates of female
entrepreneurship. According to the report,
only 6% of women in the UK set up their
own business – and for every female
entrepreneur, there are more than two
male entrepreneurs. Closing this gender
gap could add billions to the UK economy,
help make up for jobs that have been lost
and potentially aid a faster recovery from
the coronavirus-induced recession. “I am
proud to say that 42% of the businesses
that we facilitated were founded by
female entrepreneurs last year.”
Global Britain
Gather is confident about the future
and certain that the “UK will stick to its
business-led immigration strategy”. This,
he says, is an important element in the
country’s Covid-19 recovery plan as well
as its post-Brexit strategy ‘Global Britain’.
This strategy signals that the country
will not become inward-looking after
Brexit, but on contrary will have global
aspirations that go beyond Europe.
Rupert Gather graduated
BIO in Law from Exeter
University in 1984 and,
following operational service
in the British Army, has built a
distinguished career in private
equity and corporate finance.
His 20 years’ experience and
150 completed deals have
given him a unique insight
into selection, appraisal and
management of direct private
equity investments into UK
and international companies
across multiple sectors. Rupert
founded InvestUK in 2012. The
firm is based in London but has
representative offices in Lagos,
Beijing, Dubai and Hong Kong.
Investment Migration Yearbook 2O2O/2O21 99

In conversation with PARAG KHANNA, Global Strategy Advisor, Author and Founder of FutureMap
SOUTHEAST ASIA’S
GROWTH WILL
OUTPACE CHINA’S
China has long been
viewed as Asia’s anchor
economy, but the focus
of global growth is
fast shifting towards
Southeast Asia. The IM
Yearbook spoke with
Parag Khanna about the
Western perception of
Asia, the rise of Southeast
Asia and how it will
affect the investment
migration industry.
Can you tell us a bit about
yourself and your work?
People like to call me a global citizen
because I have lived in many different
countries. I was born in India, grew up in
Abu Dhabi in the UAE, and when I was
seven, we moved to the US. Until I was 16, I
lived in New York. Then I spent one
year in Germany as an exchange
student before returning
to the US to study at the
School of Foreign Service
at Georgetown University.
I became fascinated by
geopolitics from a very early
age. I was 12 when the Berlin
Wall fell. My parents said,
‘we have to go and see
this in person’.
So, we went on
a holiday to
Berlin, and
it was truly
magical to
see history in
the making.
I was hooked
and decided that
I want to work
in this area. Later
in life, I’ve worked
for different think
tanks and government institutions in the
US, Germany, Switzerland and London.
Now I am running my own company,
and I am living in Singapore with my
family. So, migration and a layered
identity are a big part of my own story.
I was born as an Indian citizen, became
American when I was 15, and a few years
ago, I became a Singaporean citizen.
Your last book is called ‘The Future
is Asian’, but you actually argue
that the present is already Asian.
Can you explain this a bit more?
Yes. That’s something people quite
often forget. It is as if we have to wait
for America or Europe to say that
the future or the present is no longer
Western in order for it to be true,
but that’s not the way it works.
When I moved to Asia seven
years ago, the world was
already Asian. If you need
to identify an objective
of convergence, where
it is not a matter of
opinion, you would
say that more than
50% of the world
population is
Asian, and that’s
been true for
quite some time. Then in terms of the
economy, 51% of global GDP in PPP terms
is Asian, and that’s been true for about
two or three years. In addition, the rise of
the Asian Infrastructure Investment Bank
(AIIB) and China’s Belt and Road initiative
marked the launch of new Asia-centric
diplomatic initiatives some five years
ago. I see no objective measure to dispute
the notion that the present is already
Asian. Of course, the present is Asian
doesn’t make for a good book title. So, we
decided to call it ‘The Future is Asian’.
Asia is a very vast and diverse
region. China is leading the charge
today. Which Asian countries
could take on a more important
role in the coming years?
For many policymakers, Asia didn’t matter
until China rose, but Asia as a region has
been rising since the 1950s after it hit rock
bottom. You had the atomic bombs of
Hiroshima and Nagasaki 75 years ago, the
Indian Pakistani partition and genocide
in 1947, as well as the Chinese civil war
that ended in 1949. Asia was on its knees.
Let’s not forget the Vietnam War a couple
of decades later. Japan is the real miracle
story – Japan rose to become the world’s
second largest economy, overtaking West-
Germany in 1975. At that point in time,
100
Investment Migration Yearbook 2O2O/2O21

in 1975, China was a desperately poor
country. So, Asia has always been much
more than China. Then we saw the rise
of the tiger economies - Singapore, Hong
Kong, South Korea, and Taiwan, which
became spectacularly rich as well. China
was still backwards. We can say that Japan
represents the first wave of Asian growth,
the Tigers the second wave, and China is
only the third wave of growth. For many
people in the West, China is the beginning,
the middle and the end. China is Asia.
That’s not true, and it has never been true.
No empire has ever dominated Asia, with
one single exception and that was the
Mongol Empire. And Asia’s rise continues
as we are now witnessing the fourth wave
of growth, which is Southeast Asia.
What are the drivers behind
Southeast Asia’s growth?
South and Southeast Asia have a
combined population of more than 2.5
billion people, a billion more than China,
with a population that is also younger. I
believe Southeast Asia’s growth will even
be greater than China’s. If 2.5 billion are
getting connected, benefit from better
urbanization, of course, those countries
are going to grow rapidly. In fact, the
GDP of that set of countries will equal
China’s GDP in less than a decade.
So, the problem with our discourse
about Asia is that we can’t really ask
who else matters. All Asian countries
matter and are important at the same
time. Asia has always been multipolar
because it is home to many diverse,
rich, deep civilisations in one region.
China as well as the countries in
Southeast Asia are key source markets
for the investment migration industry.
With those countries becoming
richer and growing in geopolitical
importance, do you believe Asians
will still be interested in investment
migration in 10 years’ time?
That’s a good question, and I think the
answer is yes. The reason for it is that
there are as many different motivations
behind investment migration as there are
Asians. I envision a future where instead
of us seeing many Chinese people in the
West, we will see a lot more Indians in
the West. That’s going to be one of the
big shifts in the years ahead. I also don’t
think the Chinese will lose their appetite
for investment migration. Let’s not forget
that even though China is wealthy, the
Chinese have a long list of concerns,
including tax policy, anti-corruption drive
and political regulation activities. Climate
change, which is going to affect large parts
of China, India and Indonesia, will also
influence Asian’s decision to migrate.
At the same time, we are seeing labour
shortages in the West, where governments,
given the declining populations in their
countries, will need to shore up the
demographic foundation and attract people
to build the tax base. Investment migration
is one option to do that. So, I believe that
from the supply side and the demand side,
there is going to be significant opportunity
and movement in the years ahead.
Human rights groups regularly criticise
Southeast Asian governments. What’s
your opinion on this issue and what
can the West learn from the East?
In Asia, there’s a strong focus on
technocratic governance. We have no
patience for bad leaders. They get thrown
out. Technocratic governance is what Asian
people want. That’s how Narendra Modi
got elected in India. Yes, he is controversial,
but he is also someone who gets things
done. He said: we are going to build ten
thousand kilometres of railways, clean
up the streets, defend our borders, and
stand up for ourselves. That’s what makes
him the most popular leader. Then there
is Rodrigo Duterte, the President of the
Philippines. In Western eyes, he is even
worse. I am not defending him, I am
simply pointing out that if a guy comes
along who says I am going to end poverty
and corruption on every level, and I am
going to fix electricity, build hospitals and
guarantee education, then of course people
vote for him. For developing countries, it
is better to be technocracies as they need
to make structural changes fast. They
can’t afford to make endless mistakes.
Let’s also keep in mind that technocracy
is a European idea. Germany is a
technocratic country but it’s also a liberal
democracy. These two are not opposing
concepts. But the issue is that most Western
countries are not like Germany. Germany
is the most Asian country of all Western
countries. And Asian countries aspire to be
like Germany. They don’t aspire to be like
the US or the UK. Education, industrial
policies, export, vocational training – in
all of these critical areas of state-building,
Asian countries want to be like Germany.
I am fierce critic of Asian Governments’
approach to censorship as way to silence
critics, and I am not championing it at
all. It’s wrong, but at the same time, they
have adopted an incremental approach
to liberalizing discourse in a way that
does not lead to tension, and that’s
how you can maintain multi-ethnic
states and peace at the same time.
I envision a
future where
instead of us
seeing many Chinese
people in the West,
we will see a lot more
Indians in the West.
In your opinion, which investment
migration programmes are most
appealing to Asians at the moment?
I think all countries that promise stability are
very attractive. If you are in Asia right now,
you are worried about China-US tensions,
territorial disputes in the South China
Sea or the potential for conflict between
Taiwan and China or between China and
India. Those are very valid concerns. In
my opinion, Europe is the winner, with its
focus on sustainability, independence and
welfare. In addition, the euro offers a very
important diversification hedge from a
dollar that is being devalued, while Europe’s
action to stop climate change is also an asset.
So, investment migration programmes in
Europe are definitely appealing to Asians.
While America, Canada and the UK
were the recipients of the first wave of
outbound Asians in the post-war decade,
I am fairly certain that the next wave is
much more likely to go to Europe.
Parag Khanna is a
BIO leading global strategy
advisor, world traveler
and best-selling author.
He is Founder & Managing
Partner of FutureMap, a data
and scenario based strategic
advisory firm. Parag’s newest
book is The Future is Asian:
Commerce, Conflict & Culture
in the 21st Century (2019).
Investment Migration Yearbook 2O2O/2O21 101

THE IMPORTANCE OF
EB-5 Due
Diligence
Investors need to do their homework and vet the regional centre they plan
to work with, writes Noreen Hogan, President of CMB Regional Centers.
She recommends non-vertically integrated EB-5 projects and debt-based
investments as opposed to equity structures to minimise the financial risk.
Thousands of families every year
from around the world make
the decision to immigrate to
the United States through the EB-5
visa programme. Through a minimum
investment of $900,000, an immigrant
investor and their qualified family
members are able to participate in
an expeditious path to permanent
residency in the United States. The
qualified investment must create 10 fulltime
American jobs, and unlike other
US immigrant and non-immigrant
programmes or immigration by
investment programmes from around
the world, the EB-5 regional centre
programme does not require the investor
to run the business/project they invested
into or live in a defined location.
Those participating in the EB-5
programme choose to immigrate to
America for many reasons. These reasons
range from a better education for their
children, to better business opportunities
or access to the US market, or just
simply for retirement. Regardless of the
specific reason behind pursuing EB-5,
all investors must carefully evaluate the
risks associated with achieving their
immigration goals. The biggest risk is
not the financial risk (though that is
incredibly important), rather, it is the
immigration risk of not being able to
permanently immigrate to the United
States. This is why due diligence is key
when choosing the right regional centre.
Three Goals
There are three goals for any EB-5
investor: first, obtaining permanent
residency in the United States; second,
ensuring the investment is secure and the
ability to receive their money back at the
end of the process; and third, receiving
some modest return on the investment.
If these goals are not prioritised in the
appropriate order, an investor and their
family will likely increase the risk of
not achieving the most important goal:
their immigration pursuit, even if they
succeed elsewhere. Not only are these
three goals of utmost importance, they
also must be maintained in correct
order to ensure the highest likelihood
of success for the EB-5 investor.
The Right Structure
As an investor considers an EB-5
opportunity, they must make certain that
the goals of each party in the investment
are clearly understood. It is especially
important to ensure that the goals of the
regional centre/general partner align with
the goals of the investor. The responsibility
of the regional centre/general partner is
to be a fiduciary for the investors. That
responsibility includes standing on the
side of the investor and their family to
ensure that the project moves forward,
creates jobs and eventually returns
their capital. This is why choosing nonvertically
integrated EB-5 investment
opportunities (when a regional centre
and developer/borrower do not share
common ownership or interests in the
project) and debt-based (Loan Model)
investments (as opposed to an equity
structure) should be the preferred path
for any investor looking to make an EB-5
investment. In a loan model, the EB-5
investor participates in a partnership that
loans the raised EB-5 capital to a borrower
who provides certain collaterals to the
partnership to help mitigate the risk in
the investment. The general partner of
the partnership acts as the responsible
party to hold the developer and borrower
accountable for the use of the funds and
the performance of the project, which
allows the investor and their family to have
peace of mind, knowing that someone is
monitoring the investment at all times.
In doing so, the regional centre more
closely aligns their goals with the goals of
the investor. This also demonstrates the
importance of avoiding investments that
are vertically integrated; not only are the
developer/borrower’s and regional centre/
general partner’s interests aligned, should
something go wrong there is a major
conflict of interest for the regional centre/
general partner, which typically results in
the investors having to stand in opposition
to both parties with little or no rights.
Ask Questions
Ensuring that the regional centre’s goals
align with the investors is a significant part
of the investor’s due diligence, but it cannot
end there. Investors must also evaluate the
project, the developer, the immigration
attorney (especially if assigned or required
by the regional centre), any agency or
third-party promoter of the project, broker
dealer, and any other parties assisting in
the decision-making process. The number
one thing to remember while conducting
EB-5 due diligence is to ask hard questions
of everyone involved in the EB-5 process
and make them prove their answers.
Noreen Hogan is the President
BIO of CMB Regional Centers. As
the President, Noreen manages
the day to day operations of CMB and
its nearly 6,000 EB-5 investors, from
102 countries. Noreen is noted as an
expert in EB-5, as she is invited to
speak on panels throughout the world
each year. Her expertise comes from
her years of experience within the
CMB companies as a VP of Company
Operations, Project Manager,
economist and her work to establish
CMB Swiss Co GmbH with operations
in Schaffhausen, Switzerland. Noreen
Hogan holds a Master’s degree in
Economics from the University
of Illinois at Chicago and a B.A. in
Economics from Augsburg College.
102
Investment Migration Yearbook 2O2O/2O21

WHO’S
WHO
105
106
107
108
109
110
111
112
Auray Capital Canada
BDO USA, LLC
Beyond
Biz Consult Limited
Casamont
Celeveland International Fund (CIF)
CJ INternational Group
CSB Group
Deloitte Malta
Exiger
FACT
Fragomen LLP
Global Information Consulting Group (GICG)
Globe Detective Agency (P) Limited
Golden Visa Greece by Energopiisi
Henley & Partners
Hilton Global Associates Inc.
Investment Migration Council
IMC Education and Training (IMCET)
Immvest International Ltd
Integritas Group
Invest UK
Island Living Investment Services
Kayhan Swiss
Klasko Immigration Law Partners, LLP
Mia Jug Dujakovic
Malta Residency Visa Agency - MRVA
Polaris Citizenship & Investment Consultancy Services Limited
Provenance Properties International
Raymond Chabot Grant Thornton
RCG Global
Rostova Westerman Law Group
Scheibert & Associates INC International Migration Service
Swiss Insurance Partners AG
The Sovereign Group
Varnavas Law Firm 1978
Visas Consulting Group (VCG)
Vistra
WDM International
Xiphias Immigration Private Limited
104
Investment Migration Yearbook 2O2O/2O21

MARC AUDET
PRESIDENT AND CEO
AURAY CAPITAL CANADA
Looking to immigrate to Quebec, Canada? Look no further.
AURAY Capital Canada is the leading financial intermediary
authorized by the Quebec Government to offer the Quebec
Immigrant Investor Program. Along with its global network of
immigration advisors, AURAY has successfully assisted over
25,000 investors worldwide in the realization of their immigration
plans. Our team of professionals average over 25 years of
experience in the field and are ready to assist you. Contact us now
at info@auraycapital.com to prequalify as spaces are limited.
600 De La Gauchetière
Street West, Suite 2740
Montreal, Quebec - Canada H3B 4L8
T: +1 514 499 8440
E: audet.marc@auraycapital.com
W: www.auraycapital.com
Contact: Marc Audet - President and CEO
LAURA AUSTIN
HEAD OF INVESTMENT
MIGRATION DUE DILIGENCE
BDO USA, LLC
BDO delivers advisory services around the globe, and the
Investigative Due Diligence Practice draws on deep experience
to uncover risk and provide critical intelligence from our 1,500+
global offices in over 160 countries. We understand the need for
the highest quality due diligence, conducted by our experienced
investigators and expansive global network of resources. We also
offer a proprietary monitoring solution, eConnaissance®, which is
the first of its kind in the Investment Migration (IM) industry. BDO
is a corporate member of the IMC and is actively committed to
supporting IM programs and their ability to positively influence the
global community. With our international presence, outstanding
reputation, industry expertise, knowledge of best practices, and
advanced technology, BDO is unmatched in the IM industry as
a leading provider of due diligence and monitoring services.
100 Park Avenue, New York,
NY 10017- USA
T:(+1) 212 885 7493
E: laustin@bdo.com
W: www.bdo.com
Contact: Laura Austin - Head of
Investment Migration Due Diligence
HAKAN CORTELEK
CHIEF EXECUTIVE OFFICER
BEYOND RESIDENCE & CITIZENSHIP
BEYOND was established over a decade ago to allow globally
minded, locally connected, seasoned professionals to provide
seamless service and successful outcomes for its internal and
external clients. BEYOND provides multijurisdictional solutions
worldwide with its extensive partnership networks. Also active in
government advisory, education consultancy, and international
real estate, as well as the due diligence space, BEYOND has
its core operations in Dubai, Hong Kong, London, Istanbul,
and Kiev. Having extensive experience with Russian, Chinese,
Turkish, West African, Middle Eastern, South East Asian as
well as North and Latin American clients, BEYOND provides a
platform to serve intermediaries along with direct clients in all
possible residency-and-citizenship-by-investment programmes.
Dubai | London | Hong Kong | Istanbul
| Kiev | Shanghai | Budapest | Moscow
E: info@beyond-immigration.com
W: www.beyond-immigration.com
Contact: Hakan Cortelek -
Chief Executive Officer
VALENTINA SAMMUT
FOUNDER AND CHIEF
EXECUTIVE OFFICER
YIANNOS TRISOKKAS
MANAGING PARTNER
BIZ CONSULT LIMITED
BIZ Consult Limited is the leading exclusive provider of
immigration services with focus on residency and citizenship
by investments, due diligence and 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. The company’s CEO Valentina Sammut
is in possession of a Master’s Degree in Economics, Certificate in
Investment Migration and International Compliance Association
Certificates in Compliance and Anti Money Laundering.
CASAMONT – THE HOME OF GLOBAL LIVING
Casamont’s luxury real estate portfolio includes a selection of
the world´s most exceptional lifestyle properties, providing
our global high-net-worth clients with access to a suite of
investment opportunities in the stunning island nations of
Cyprus and Malta as well as mainland Greece and some
of its most sought-after islands. With their unrivalled local
knowledge and highly connected partners, Casamont’s
specialists will ensure that you find the perfect Mediterranean
property for your unique requirements, hassle free.
12, St. Zachary Street, Valletta,
VLT1133 - Malta
T: (+356) 99 020 654
E: info@bizconsultmalta.com
W: www.bizconsultmalta.com
Contact: Valentina Sammut -
Founder and Chief Executive Officer
Dimokratias 38
3012, Limassol - Cyprus
T: +357 2531 1844
E: yiannos.trisokkas@casamont.com
W: www.casamont.com
Contact: Yiannos Trisokkas
- Managing Partner
Investment Migration Yearbook 2O2O/2O21 105

STEPHEN STRNISHA
CHIEF EXECUTIVE OFFICER
CLEVELAND INTERNATIONAL FUND, LTD. (“CIF”)
CIF has been a designated U.S. EB-5 regional center since
2010. Its service area includes the metropolitan areas of
Cleveland, Columbus and Cincinnati, Ohio and Pittsburgh,
Pennsylvania. In the past ten years CIF has raised investor
capital and funded commercial real estate loans totaling
approximately $300 million. Loan activity focuses on office,
retail, residential and hotel development as well as financing
health care system expansions. CIF’s track record reflects
its focus on investor and project due diligence with a strong
record of timely repayment and approval of U.S. residency
for its investors. CIF is a Leadership Fund contributor to
Invest in the U.S.A, trade association for the EB-5 industry.
CIF’s CEO, Stephen Strnisha is an IIUSA officer.
12434 Cedar Road, Suite 15
Cleveland Heights, Ohio 44106 - USA
T +1 (216) 245-0808
E: strnisha@clevelandinternationalfund.com
W: www.clevelandinternationalfund.com
Contact: Stephen Strnisha -
Chief Executive Officer
JACQUES PLANTE
CHIEF EXECUTIVE OFFICER
ANDRES GUTIERREZ
INVESTMENT MIGRATION ADVISOR
CJ INTERNATIONAL GROUP INC.
CJ International Group Inc. is an international consultancy firm
specialized in Residency and Citizenship by Investment Programs
around the world for high-net-worth individuals. We offer, among
others, Canadian Immigration Programs such as the Provincial
Nominee Programs, Start-up Visa and Quebec Immigrant Investor
Program, for which we have an annual quota available. With more
than 20 years of experience in the industry and with offices in Canada,
China and Vietnam (along with its affiliated company CJ Legal
Services), CJ International Group Inc. provides bespoke immigration
services to meet the ever-changing challenges of today’s mobile
and informed investors. Our global team of legal professionals and
Investment Immigration Relationship Managers have a shared aim
in providing sound advice with courtesy, respect and diligence.
CSB GROUP
Established in 1987, CSB Group provides discreet and
confidential Citizenship and Residence advice to private
clients, high-net-worth (HNW) individuals and their families
in their search for global mobility and relocation to Malta.
Our vast portfolio of services including Corporate, Regulatory and
Tax & Accounting services amongst others, and associated brands,
including Malta Sotheby’s International Realty and Regus, enable
us to offer a 360° approach where our clients can set up or relocate
to Malta with all their needs being met by one trusted provider.
Being entrepreneurs ourselves enables us to understand our
clients’ expectations better, giving them the peace of mind that
all of their business needs will be met while reassuring them
that our support is available in good as well as in bad times.
1 Place Ville-Marie, Suite 1082,
Montreal, Quebec - Canada H3B 4S6
T: (+1) 438-333-1882
E: contact@cji-group.com
W: www.cji-group.com
Contact: Jacques Plante -
Chief Executive Officer
The Penthouse, Tower Business Centre
Tower Street, Swatar
BKR 4013, Malta - EU
T: (+356) 2557 2557 • M: (+356) 9924 1428
E: andres.gutierrez@csbgroup.com
W: www.csbgroup.com
Contact: Andres Gutierrez -
Investment Migration Advisor
CHRIS CURMI
PARTNER | INTERNATIONAL TAX
DELOITTE MALTA
Deloitte Malta provides a market leading immigration service.
Headed by UK Chartered Accountant Chris Curmi and
former senior diplomat Jonathan Galea, Deloitte’s dedicated
multilingual immigration team offers an unparalleled level
of experience and competence in representing clients in
Malta. Deloitte Malta is not only a successful immigration
practice in one of Europe’s most successful economies. With
almost 500 professional staff it is a distinguished provider of
audit, tax, financial and risk advisory services to an extensive
array of international private and corporate clients.
Deloitte Place, Triq l-Intornjatur, Central
Business District, CBD 3050 - Malta
T: +356 2343 2000 | D: +356 2343 2708
E: ccurmi@deloitte.com.mt
W: www.deloitte.com/mt
Contact: Chris Curmi -
Partner International Tax
KAREN KELLY
DIRECTOR, STRATEGY
& DEVELOPMENT
EXIGER
Exiger has been a pioneer, innovator, and leading provider of due
diligence and advisory services to Residency and Citizenship by
Investment (RCBI) programmes since 2006. As a trusted partner to
the largest and fastest growing programmes operating today, we bring
cost-effective and efficient enhanced due diligence and advisory
solutions to the industry. We developed specialized methodology
and reporting for the investment migration industry, including a
one-of-a-kind risk assessment matrix. Exiger’s AI-powered automated
due diligence solution, DDIQ, and applicant management system,
Exiger Insight AMS, are also changing the way programmes manage
applicants and agents. Exiger has over 200 full-time research
staff speaking 35 languages in research centers in Washington,
D.C. metro, Vancouver, Bucharest, London and Hong Kong.
1675 Broadway, 15th Floor,
New York, NY 10019 - USA
T: (+1) 778 945 7318
E: kakelly@exiger.com
W: www.exiger.com
Contact: Karen Kelly -
Director, Strategy & Development
106
Investment Migration Yearbook 2O2O/2O21

KIERON SHARP
CHIEF OPERATING OFFICER
FACT
Trusted by governments, law enforcement and private
organisations, our worldwide due diligence services provide
insights to manage risk and inform decision making. Our
reputation and experience in intelligence-gathering and
investigations since 1983 has enabled us to remain at the
forefront of technological advances and partner with law
enforcement agencies globally to deliver success. FACT’s
strategic and tactical solutions reduce clients’ vulnerability
and exposure to revenue loss and reputational damage, from
fraud and intellectual property crime to international serious
organised crime. We develop bespoke approaches to solve
problems and bring results whilst continuing to innovate.
Regal House, 70 London Road
Twickenham, Middlesex TW1 3QS - UK
T: (+44) 20 8891 1217
E: contacts@fact-uk.org.uk
W: https://www.fact-uk.org.uk/
Contact: Kieron Sharp -
Chief Operating Officer
NADINE GOLDFOOT
NADINE PARTNER GOLDFOOT
PARTNER
PARTNER
FRAGOMEN LLP
LLP
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W: www.fragomen.com
Contact: Nadine Goldfoot - Partner
ATEF EL KADI
MANAGING DIRECTOR
GLOBAL INFORMATION CONSULTING GROUP (GICG)
Established in 1996, GICG is a leading multinational firm
offering second residence and citizenship solutions to U/
HNWIs globally, various investment opportunities and a
client advisory department. Our highly experienced team
of over 20 professional in-house lawyers and qualified
agents serve our global clients from 6 offices worldwide,
offering 13 different investment migration programs. The
expertise acquired over 25 years of business enables GICG
to provide a complete, bespoke and efficient management
of the application procedure. GICG collaborates with
legal firms and immigration advisors globally to provide
guidance and advice on residence and citizenship matters.
Angelica Court, Flat 2, Triq Giuseppe Cali,
Ta’ Xbiex, XBX 1424 - Malta
T: (+356) 2133 7030
E: info@gicg.net
W: www.gicg.net
Contact: Dr. Yanica Woods, Senior
Lawyer & Head of Malta Office
SACHIT KUMAR
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 CBI/RBI industry and
for governments in 56 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, Watch Lists and Identification of Politically Exposed
Persons. GDA’s highly skilled, professional approach is personalized
and rigorous. GDA is aware that important decisions are made
partly/wholly based on the information that we provide.
601-603, Eros Apartments, 56,
Nehru Place, New Delhi-110019 - India
T: (+91) 9311042007
E: sachitkumar@globedetective.com
W: www.globedetective.com
Contact: Mr. Sachit Kumar - Director
MARY TSIGANOU
VICE PRESIDENT/FINANCIAL
& LEGAL CONSULTANT
GOLDEN VISA GREECE BY ENERGOPIISI
A team of expert inspired consultants established in 2012,
Energopiisi SA. Our Mission: to facilitate international investments
in Greece, simplify the complicated processes, ensure sustainable
and profitable solutions and create tailor made proposals. Our
Philosophy: “We believe in having options”. Merged with “Synergia
S.A.” in 2019, a technical & consulting company of our group,
focused mainly in RES. This integration strengthens more our
position in the Greek investment consultancy sector and gives us
the chance to serve our customers more efficiently by providing
high quality services at all levels. We always had a dream: to
expand our services outside Greece, and provide real time services
to our customers. We are very glad to announce the promotion
of “Golden Visa Greece” in Dubai with our new office in A4
Building-#418, Al Marjan Industrial-FZ, Ras Al Khaimah, UAE
Synergia S.A. - Investment Consulting
42 Leoforos Vasilisis Amalias,
Athens 105 58 - Greece
T: (+30) 210 45 14 892, 210 323 9676
E: info@goldenvisa-greece.com
W: www.goldenvisa-greece.com
Contact: Mary Tsiganou - Vice president/
Financial & Legal Consultant
Investment Migration Yearbook 2O2O/2O21 107

DR JUERG STEFFEN
CHIEF EXECUTIVE OFFICER
MELISSA KELLEY-HILTON
FOUNDER & CEO
HENLEY & PARTNERS
Henley & Partners is the global leader in residence and
citizenship planning. Each year, hundreds of wealthy individuals,
families and their advisors rely on our expertise and experience
in this area. The firm’s highly qualified professionals work
together as one team in over 30 offices worldwide. The firm
also runs a leading government advisory practice that has
raised more than USD 8 billion in foreign direct investment.
Trusted by governments, the firm has been involved in strategic
consulting and the design, set-up and operation of the world’s
most successful residence and citizenship programs.
HILTON GLOBAL ASSOCIATES INC.
Hilton Global, an investigative due diligence firm, provides timely,
relevant, and actionable results for mission-critical decisions
made by governments and other clients worldwide. We undertake
investigations globally, providing clients with the fact-gathering
they need as they face exposure to regulatory, compliance, or
reputational risk. Founder and CEO, Melissa Kelley-Hilton, PI,
CFE, CII, IMCM, has 20+ years’ experience specializing in global
investigative due diligence on behalf of governments, Fortune
Global 500 companies, multi-national law firms, and investment
management firms. She has 10+ years of direct experience as
an authorized due diligence provider for CBI programs.
20 Grosvenor Place, London
SW1X7HN - United Kingdom
T: (+44) 207 823 1010
E: uk@henleyglobal.com
W: henleyglobal.com
Contact: Dr Juerg Steffen -
Chief Executive Officer
445 Park Avenue, 9th Floor
New York, NY 10022
T: (833) HGA-1234
E: melissa@hiltonglobalassociates.com
W: www.hiltonglobalassociates.com
Contact: Melissa Kelley-Hilton -
Founder & CEO
BRUNO L’ECUYER
CHIEF EXECUTIVE
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 in-demand research
in the field of investment migration aimed at governments,
policy makers, international organisations, and the public.
It is a non-profit 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).
16 Rue Maunoir 1211 Geneva - Switzerland
T: (+41) 22 533 1333
E: info@investmentmigration.org
W: investmentmigration.org
Contact: Bruno L’ecuyer - Chief Executive
MARIE’ LOU CUTAJAR
EDUCATION & TRAINING OFFICER
IMC EDUCATION AND TRAINING (IMCET)
Marie’ Lou is the Education and Training Officer 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 enrol 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.
E: imcet@investmentmigration.org
E: marie.cutajar@investmentmigration.org
www.linkedin.com/
company/34657610/admin/
W: investmentmigration.org/education/
RODERICK CUTAJAR
CEO
IMMVEST INTERNATIONAL LTD
The satisfaction of our clients is second to none. The company
specializes in residency and citizenship by investment services.
Located on the island of Malta, ImmVest International
continues to be the choice of many seeking to invest in a
second residency or citizenship in Europe or the Caribbean
islands. Led and managed by Roderick Cutajar, the ex CEO
of the Malta Residency Visa Agency, ImmVest collaborates
with various Governments interested in developing their own
residency or citizenship by investment programs. ImmVest
provides a range of real-estate opportunities for the RCBI
business through its portal www.immvestproperties.com.
ImmVest International – Your Bridge to the World!
SmartCity, Building One,
Level 5, Suite 5, Ricasoli - Malta
T: +356 21234231, +356 7950 0008
E: enquiries@immvest.com
W: www.immVest.com
WeChat: immVestInternational
Contact: Roderick Cutajar - CEO
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Investment Migration Yearbook 2O2O/2O21

FRÉDÉRIC VILLA
MANAGING DIRECTOR
INTEGRITAS GROUP
The Integritas Group is a multidisciplinary group of companies
(based in Malta and having representative offices in the
UAE, Switzerland, Azerbaijan, Algeria and South Africa),
specializing in residence/citizenship by investment (R/CBI) and
relocation services, corporate structuring and the formation
of companies, corporate management and compliance from
a corporate and fiscal viewpoint, mergers and acquisitions,
re-domiciliation, trusteeship and fiduciary services, yacht and
aircraft registration. Integritas Corporate-Services Ltd is a CSP
duly licensed by the Malta Financial Services Authority as well
as an approved accredited agent by the Maltese authorities
with respect to citizenship and residence applications.
114/3, The Strand, Gzira GZR 1027 - Malta
T: (+356) 2385 0611
E: info@integritas-trustees.com
W: www.integritas-trustees.com
Contact: Frédéric Villa - Managing Director
RUPERT GATHER
GROUP CHIEF EXECUTIVE
INVEST UK
Since our founding in 2012, the InvestUK Group of companies has
helped over 300 foreign investors and innovators to invest, start
businesses and settle in the United Kingdom while contributing
over £100 million in Foreign Direct Investment to the UK
economy. Over this time, our work has grown substantially to
encompass three distinct organisations – InvestUK, Innovate
in Britain and IUK Academy – each providing support and
assistance with making investments, business development and,
where necessary, UK residency under the Innovator and Tier 1
(Investor) visas. This year we open offices in Dubai and Lagos
to complement our offices in London, Beijing and Hong Kong
in line with our strategy to serve global clients in key regions.
Claridge House, 32 Davies Street
London W1K 4ND - UK
T: +44 (0)20 7629 2522
E: enquiries@investuk.com
W: www.investuk.com
Contact: Rupert Gather -
Group Chief Executive
GAYE HECHNE
MANAGING DIRECTOR
ISLAND LIVING INVESTMENT SERVICES
Island Living Investment Services (ILIS) is a corporate service provider
with an extensive network of experienced professionals, including
Government Authorized Representatives and License Agents certified
to facilitate and process applications for Caribbean Citizenship by
Investment Programs, offering personalized and professional services
in five Caribbean island states. We provide up to date, reliable
information on investing in the Caribbean, providing the necessary
information and support to clients during the decision making process.
From exclusive gated communities to pristine beachfront plots, luxury
resort settings to commercial developments, we have successfully
marketed and brokered high value real estate for over 14 years.
“Global Views, Personal Services”
Suite 201, Village Walk,
Friars Hill Road , St. John’s - Antigua
T: + 1 268 562 2626
E: info@ilis.ag
info@islandlivingantigua.com
W: www.caribbeancitizenshipinvest.com
Contact: Gaye Hechme -
Marketing & Advertising
HANGAMA WANNER
FOUNDER
KAY HAN SWISS
Founded in 2018, KayHan Swiss offers RCBI services in
tandem with intricate banking and financial solutions. At
KayHan we believe that everyone deserves a better life; and
as we live in a world bursting with opportunities, we strive
to provide our services to anyone who needs them no matter
their situation. Our expertise in RCBI coupled with in-depth
knowledge of banking and finance, provides us with the
confidence to break down barriers even in the most difficult
of regions. We believe in building foundations of trust in
the most sensitive of industries, and for the long term.
KayHan Swiss LLC.
Selnaustrasse 5 - 8001
Zürich - Switzerland
T: +41 76 566 05 75
E: hangama.wanner@gmail.com
W: kayhanswiss.ch
Contact: Hangama Wanner - Founder
H. RONALD KLASKO
MANAGING PARTNER
KLASKO IMMIGRATION LAW PARTNERS, LLP
H. Ronald Klasko is one of the U.S.’s leading lawyers representing
treaty investors (E-2) and green card investors (EB-5). Ron was
the lead attorney on the Matters of Walsh and Pollard case, the
key precedent for E-2 visas. Klasko Immigration Law Partners
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 around the world. Under Ron’s leadership, Klasko
Immigration Law Partners is regularly chosen by Chambers
Global and U.S. News and World Report as a top tier business
immigration firm. 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, Pennsylvania, PA 19103, USA
E: rklasko@klaskolaw.com
T: (+1) 215.825.8600
Contact: H. Ronald Klasko
- Managing Partner
Investment Migration Yearbook 2O2O/2O21 109

MIA JUG DUJAKOVIĆ
PARTNER
MIA JUG DUJAKOVIĆ
Croatia, one of the most desired touristic destination and with
great potential for investment could be your next investment
destination or residency option. Our goal is to assist both private
clients and companies towards their smooth transition.
Having worked with some of the market leaders in private client
business and investment migration, our office is devoted to high
international level of service. We tailor our service to meet the
specific needs of each of our clients to ensure their success in
Croatia. Our belief is that only with a deep understanding of
local investment environment proper council can be smithed.
Mia Jug Dujaković
ATTORNEY AT LAW RECHTSANWALT
Tršćanska 57, Split, Croatia
Mala Podloža 20, Stari Grad - Croatia
M: +38598539067
E: attorney@lawcroatia.com
Linkedin: mia-jug-diujakovic-03aa5511a
linkedin.com
CHARLES MIZZI
CHIEF EXECUTIVE OFFICER
BRENDA FLOISSAC
FLEMING
DIRECTOR
SUE NICKASON
VP MARKETING AND SALES
MALTA RESIDENCY VISA AGENCY
The Malta Residency Visa Agency is the Government entity
responsible for managing and promoting the Malta Residence and
Visa Programme. The programme grants beneficiaries from third
countries the right to settle permanently in Malta and travel visafree
across Schengen. Beneficiaries can enjoy residency in a safe
and stable country boasting excellent educational opportunities
and economic prosperity. All applications submitted through
accredited agents undergo a rigorous due diligence process to
ensure that only fit-and-proper individuals are granted residency.
POLARIS CITIZENSHIP & INVESTMENT
CONSULTANCY SERVICES LIMITED
Polaris is a licensed Authorised Agent for Citizenship by
Investment in St.Lucia. Built on the infrastructure, ethics and
values of its affiliate, Floissac Fleming & Associates, a full service
commercial and corporate law firm founded in 1960, Polaris takes
a bespoke, hands-on and personalized approach to CBI which
is both client oriented and regulatory compliant. Our advisors,
one of whom holds a Certification in Investment Migration from
the IMC, are all United Kingdom trained and qualified attorneys
with over 50 years’ experience in the legal, investment and
advisory sectors. Our expertise and competence have, to date,
resulted in a 100% approval rate on all Polaris’ CIP applications.
PROVENANCE PROPERTIES INTERNATIONAL
Provenance Properties International (PPI) is based in the
Cayman Islands, a tax-neutral British Overseas Territory located
a 70-minute flight south west of Miami, Florida. Cayman is
internationally acclaimed for its high standard of living, sound
governance and modern infrastructure. This safe and sophisticated
Caribbean island is increasingly a jurisdiction of choice for
HNWI’s. PPI assists these individuals interested in relocating
to the Cayman Islands and acquiring residency by investment
through real estate by identifying real estate which meets the
programme investment criteria and by introducing qualified
professionals who can assist with the application process.
Zentrum Business Centre, Level 2
Mdina Road, Qormi QRM 9010 - Malta
T: [+356] 2203 4000
E: customercare.mrva@mrva.gov.mt
W: mrva.gov.mt
Contact: Roberta Rodoligo -
Senior Manager Customer Care
POLARIS
INVEST IN PARADISE. MAKE IT HOME
Cnr. Brazil & Mongiraud Streets
P.O Box 722, Castries – St. Lucia
T: (+1) 758 714 7373
E: info@stluciacitizenship.capital
W: www.stluciacitizenship.capital
Contact: Brenda Floissac Fleming – Director
89 Nexus Way, Camana Bay, Grand
Cayman, Cayman Islands
E: Sue.nickason@
provenanceproperties.com
W: www.whycayman/dartrealestate.com
Contact: Sue Nickason -
VP Marketing and Sales
STEPHANE BOISSELLE
GENERAL MANAGER
RAYMOND CHABOT GRANT THORNTON
Looking to expand your business in Canada? If you want to scale
your existing business into new markets or simply find a target
to acquire, we can help. Raymond Chabot Grant Thornton is the
largest accounting firm in Quebec and part of Grant Thornton
International. Our extensive network allows us to find business
opportunities for you. We offer various advisory services including
mergers and acquisitions, business valuation, business plans and tax
advisory. We also offer traditional accounting services and provide
due diligence reports on net worth and source of funds. With more
than 2,800 professionals working in over 100 offices, we are well
versed to support your management team and their ambitions.
600 De La Gauchetière
Street West, Suite 2740
Montreal, Quebec - Canada H3B 4L8
T: +1 514 499 8440
E: boisselle.stephane@rcgt.com
W: www.auraycapital.com
Contact: Stephane Boisselle -
General Manager
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ROGELIO CACERES
FOUNDER & CEO
RCG GLOBAL
As the first U.S.-based investment advisory firm launched to help solve the
2nd passport and alternative residency challenges faced by American U/
HNW investors, RCG Global is on a mission to change the face of the RCBI
industry by helping 1,000 investors over the next ten years successfully
hedge against future global disruptions by allocating well-structured “Plan
B” assets into their investment portfolios. RCG’s principals pioneered
innovative market entry strategies which helped transform Brazil, India
and South Africa markets into three of the top 10 EB-5 markets in the
world by 2019. RCG’s track record driving the global expansion of the
most heavily regulated RCBI market in the world should be critically
important as they replicate their groundbreaking success earned as a new
market pioneers by turning their attention to the unique mobility and
2nd residency needs faced by families based in the U.S., Latin America,
as well as the thriving global Indian diaspora around the world.
601 Brickell Key Drive
Suite 901, Miami, FL 33131 - USA
T: +1 786.477.9935
E: rcaceres@globalrcg.com
W: www.globalrcg.com
Contact: Rogelio Caceres - Founder & CEO
IRINA ROSTOVA
FOUNDING PARTNER
ROSTOVA WESTERMAN LAW GROUP
Rostova Westerman Law Group, P.A. is an award-winning fullservice
immigration and nationality law firm based in the U.S.
Founding Partner Irina Rostova focuses her practice on the EB-5
and E2 Investor Visas and other business and employment-based
visa categories. Ms. Rostova was named a Top 25 Immigration
Attorney by the EB5 Investors Magazine. The firm is among just a
handful of law firms to be recognized nationally by Invest In USA
(IIUSA) with a Quality Achievement Award 2019, for work with
the EB5 Investor Program. The RW Law team has successfully
filed more than 700 investor visa petitions and is actively involved
in developing new markets for investor migration into the U.S.
4901 NW 17th Way Suite 303,
Ft. Lauderdale, FL 33309 - USA
T: 786.408.3183
E: irina@usainvestorvisas.com
W: www.usainvestorvisas.com
Contact: Irina Rostova - Founding Partner
HANS-PETER SCHEIBERT
DIRECTOR
SCHEIBERT & ASSOCIATES INC
INTERNATIONAL MIGRATION SERVICE
We are a full-service law firm with offices in Cape Town and
Germany. Our migration department provides comprehensive
services to South African residents seeking to emigrate to
another country. We assist with tax and forex compliance
and estate planning as well as the transfer of funds and assets
abroad, e.g. by liaising with SARS, SARB and the banks. We
are well networked with most popular destination countries,
and able to assist clients in finding their feet abroad – with
property, pensions, medical insurance and the like.
Suite 401, 42 Keerom Street
Cape Town 8001 - South Africa
Tel. +27 (0) 21 422 0660
E: info@scheibert.com
W: www.scheibert.com
Contact: Hans-Peter Scheibert - Director
ROBERT MACIEJEWSKI
CEO
CERI PRATLEY
HEAD OF RESIDENCY &
CITIZENSHIP SERVICES
SWISS INSURANCE PARTNERS AG
Established in 1997, Swiss Insurance Partners is committed to
protecting what is your real wealth: Your Health. Pioneering the
SIP Medical Family Office® concept, we are the world’s leading
independent consultants for private international medical
insurance and health management, based in Zurich, Switzerland.
Founded with the mission to protect the health of our clients
around the world, Swiss Insurance Partners provides a complete
range of health insurance and health management services.
This provides fast-track access to the best medical services
worldwide through our large global network. For over 20 years,
individuals, families and companies as well as their advisors
have been relying on our unique expertise and experience.
THE SOVEREIGN GROUP
Established in 1987, the Sovereign Group manages over
20,000 clients that include companies, entrepreneurs, private
investors, high-net-worth individuals/families and has assets
under administration in excess of US$10 billion. Sovereign
offers a comprehensive suite of international investment
migration and private client services, enabling our partners
and clients to successfully create and implement compliant,
tax efficient and flexible international migration and wealth
management strategies. Sovereign’s global network of offices
and highly experienced professional advisers enable us to
provide local expertise with a truly international dimension.
Streulistrasse 19
8032 Zurich, Switzerland
T: +41 44 266 6111
E: zurich@sip.ch
W: www.sip.ch
Contact: Robert Maciejewski - CEO
Level 5, St. Julians Business Centre,
Elia Zammit Street,
St. Julians, STJ 3153 - Malta
T: +356 27888132, +66 80 727 2556
E: rcbi@sovereigngroup.com
W: www.sovereigngroup.com
Contact: Mr. Ceri Pratley - Head of
Residency & Citizenship Services
Investment Migration Yearbook 2O2O/2O21 111

ALEXANDER VARNAVAS
PARTNER
DAVID CHEN
EXECUTIVE DIRECTOR &
MANAGING PARTNER
VARNAVAS LAW FIRM 1978
We are an awarded Law Firm based in Athens, with expertise
in Real Estate Law and Investment Immigration. Our
dedicated team consists of trustworthy and highly trained
lawyers, notaries and financial advisors, who provide our
domestic and international clientele with high-quality
legal services. Being the first ‘Greek’ IMC Members
since 2015, and believing in teamwork, we pursue the
establishment of long-term collaborations with lawyers
and professionals dealing with investor immigration
programs worldwide, to provide global, multi-dimensional
solutions related to the Golden Visa program in Greece.
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.
25-27 Kyrillou Loukareos Str.
PO 11475 Athens - Greece
T: (+30) 2106 400 300
E: legal@varnavas.gr
W: www.varnavas.gr
Contact: Alexander Varnavas – Partner
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
DR ALISTAIR SCHEMBRI
COUNTRY MANAGING DIRECTOR
VISTRA
We are a multi-disciplinary service provider with teams of dedicated
professionals transforming expertise into opportunity for our clients.
Present in Malta since 2010, we provide a wide range of services within
the private wealth sector and offer tailored solutions for our clients’
requirements. Vistra specialises in the setup and management of
Maltese legal entities and is a market leader within the marine and
aviation industry. Furthermore, we also offer bespoke private client
services and have considerable experience in assisting clients and their
families with their immigration requirements. Ranked as a top three
service providers globally, Vistra is present in 46 jurisdictions with 83
offices, employing more than 4,600 professionals over the world.
114 The Strand, Gzira GZR 1027 - Malta
T: + (356) 22 586 400
E: alistair.schembri@vistra.com
W: www.vistra.com
Contact: Dr Alistair Schembri -
Country Managing Director
DR JONATHAN DE GIOVANNI
PARTNER
WDM INTERNATIONAL
WDM International is a full-service firm, presenting a
multidisciplinary offering to its clients, ranging from legal and
tax consultancy, to audit and business advisory. WDM Lex
Advisory, the firm’s legal services arm, is at the forefront in the
following lines of expertise: international taxation; residence,
citizenship planning and private client services; setting up of
funds, fund managers, forex companies, credit and financial
institutions and operations involved in blockchain and
cryptocurrency; setting up of fintech and iGaming operation
and aircraft and yacht registration. The firm is an approved
agent for Malta’s citizenship-by-investment programme
and is also licensed to act as a trustee or co-trustee and as
an administrator in the context of private foundations.
35, The Penthouse, Salvu Psaila Street,
Birkirkara BKR 9072- Malta
T: [+356] 2123 2096
E: jdegiovanni@wdm.com.mt
W: www.wdm.com.mt
Contact: Dr Jonathan De Giovanni - Partner
VARUN SINGH
MANAGING DIRECTOR
XIPHIAS IMMIGRATION PRIVATE LIMITED
Varun Singh is Managing Director of XIPHIAS Immigration Pvt
Ltd, Bangalore India - a certified IMC Consultant and one of the
leading and most trusted Immigration service providers with
over 10 years of experience in Investment, Skilled and Corporate
migrations and thousands of successful family resettlements.
Varun is a software engineer from Manipal and has
done his advanced leadership from IIM-Bangalore and
Talent Management from XLRI Jamshedpur.
He has been awarded as ‘“Rising Star of India”.
Immigration
8th Floor, BMTC Bus Depot, 6th Block
Koramangala 560095, Bangalore - India
T: +91-9019-400-500 • Dubai +971-521021001
E: Varun@xiphias.in
W: www.xiphiasimmigration.com
www.xiphiasimmigration.ae
Contact: Varun Singh - Managing Director
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Investment Migration Yearbook 2O2O/2O21

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