Special Report August/September 2021

A GUIDE TO GLOBAL THE 2021 CBI INDEX

in association with CORPORATE STATEMENT MAP

The 14 citizenship by investment jurisdictions

Austria

Bulgaria Montenegro Turkey St Kitts and Nevis Egypt Cambodia Jordan St Lucia Vanuatu Grenada

2 AUGUST/SEPTEMBER 2021 CONTENTS August/September 2021 pwmnet.com cbiindex.com

Published by: Financial Times Ltd, Bracken House, 1 Friday Street, London EC4M 9BT +44 (0)20 7873 3000 www.pwmnet.com

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Adrian Northey 6333 Global Business Director [email protected] Head of Marketing, Audience Marketing Raj Rai 6340 [email protected] Marketing Manager, Audience Marketing Dimple Khatri SPECIAL REPORT +44(0)20 7873 4028 [email protected] Design Kostya Penkov 3255 A GUIDE TO GLOBAL [email protected] Production Daniel Macklin 4120 CITIZENSHIP [email protected] Printed by Walstead Group in the UK

THE 2021 CBI INDEX Annual subscriptions: £415 | €525 | $675 Subscription Enquiries: tel: +44(0)20 7873 4240, 04 INTRODUCTION [email protected] Having lost mobility during the health crisis, Change of Address Notification wealthy individuals are showing increased [email protected] interest in citizenship by investment schemes, © Financial Times 2021 though some programmes remain controversial

PWM is a trademark of Financial Times. “Financial Times” and “FT” are registered trademarks and service marks of the Financial Times Ltd. 12 NOMAD VISAS All rights reserved. No part CORPORATE CBI jurisdictions stand to benefit from the new of this publication may be reproduced or used in any form work-from-home normal, and from the employees of advertising without prior STATEMENT permission in writing from the who want to trade in office life for a chance to editor. No responsibility for loss occasioned to any person 06 THE 2021 CBI INDEX work overseas acting or refraining from acting as a result of material in this The CBI industry continues to evolve, with key publication can be accepted. developments including abolishing its 14 PAYMENTS On any specific matter, reference should be made to an Programme, a new Maltese citizenship offering, CBI and cryptocurrency already have a storied appropriate adviser. Registered Office: Number One Southwark and the addition of Egypt to the economic history, but with the rise of decentralised finance, Bridge, London SE1 9HL, UK citizenship arena perhaps now is the time for jurisdictions to The Financial Times adheres to a reconsider their stance on this new method self-regulation regime under the FT Editorial Code of Practice: 07 LOOKING TO 2022 of payment www.ft.com/editorial code Though family inclusiveness seems to have reached an apex, it is expected that CBI nations 16 METHODOLOGY will continue to enhance the integrity of their The CBI Index is built around nine pillars, real estate offerings and may move closer to designed to measure global citizenship harmonised due diligence standards programme features and jurisdictional desirability 08 OPERATIONAL PROGRAMMES Not all countries with CBI legislation are 20 KEY FINDINGS included in the CBI Index. The question the The CBI Index’s key findings present CBI Index asks is whether programmes are an evaluation of each country both overall fully operational. and within the parameters of the nine pillars 10 RESPONSIBILITY Governments that fail to take due diligence 26 THE NINE PILLARS seriously face a very real risk of a premature end An overview of the nine pillars that form the to their economic citizenship programmes, as CBI Index, and where the 14 countries rank seen recently in Europe among them

youtube.com/ Professional Wealth @FT_PWM Published in FTPWM Management Group association with:

PWMNET.COM 3 Covid lockdowns add to the appeal of second

WRITTEN BY YURI BENDER Clients, he says, are particularly INTRODUCTION interested in island nations such Having lost mobility during as Antigua and Barbuda, and St the health crisis, wealthy Kitts and Nevis, although few plan I don’t believe that the individuals are showing to actually live permanently in the half-baked, politically- increased interest in jurisdictions they invest in. While high net worth migrants citizenship by investment motivated pressures to from restrictive regimes typically schemes, though the favour cities like London, Paris or clamp down on these programmes remain Los Angeles, there is a recognition controversial among practitioners that the programmes will be more peripheral islands, as well he Covid-19 pandemic as providing a potential second sufficient to suppress the appears to have given passport, can serve as an ultimate demand side a new lease of life to a “bolthole” should things go wrong colourful cross-border in the authoritarian country where PARAG KHANNA FUTUREMAP industry, which offers they make their money. wealthy individuals and their Traditionally, clients came from Tfamilies second citizenships in Asia, Russia and the Middle East, obtaining a Maltese passport and the return for investments into tourism but new sources of investment are protection it offered once issued. facilities or infrastructure. also being identified. “We are seeing But following twin pressures from Countries recently offering high- more and more clients from Africa, European regulators, and domestic profile Citizenship by Investment and Nigeria in particular. Nigerians protests linked to the assassination (CBI) programmes include are favouring a St Kitts passport to of journalist Daphne Caruana players St Kitts and Nevis, allow them to travel to London and Galizia, which led to the resignation and Dominica, which have used CBI other places more easily,” reports Mr of prime minister Joseph Muscat in revenues to successfully mitigate Errington. 2019, Malta replaced its Individual the effects of national disasters, Investor Programme with a new and Mediterranean jurisdictions, STORMS IN THE MED strategy. Maltese authorities have Malta and Cyprus, where they have Once attractive Mediterranean hubs since promised greater transparency encountered major political issues. have not, however, been enjoying and increased dialogue with the EU. Both private banks and law firms the success of their Caribbean peers. A recent judicial inquiry identified report increased interest among The Cyprus Investment Programme, a “culture of impunity” within the clients seeking new citizenships previously popular amongst a higher echelons of government, and passports since the advent of Russian audience, appreciative of which had spread to regulatory the pandemic. Wealthy investors, their country’s huge influence in bodies. say commentators, only began to the coastal resorts of Larnaca and Both Malta and Cyprus had been appreciate mobility once it was Limassol, where Russian is widely criticised by European authorities. abruptly withdrawn due to Covid. spoken, has been withdrawn, Mr Errington says Malta in particular following infringement procedures raised the ire of EU neighbours OPENING UP from the European Commission in for going against the principles of Many popular CBI destinations 2020. membership of the economic bloc. are once again opening up to “The Maltese and Cypriot markets EU neighbours, critical of Malta’s international visitors. “The have trailed off, mainly due to highly lucrative scheme denigrating Caribbean islands remain popular scandals,” says Mr Errington. Until the traditional European freedom and are quite easy to work with,” recently, he says, Asian investors of movement concept, were left reveals John Errington, managing planning to extract their money “jealous and sceptical, if not hostile”. director of London-based CBI from home territory found Malta Despite this negative publicity, specialists Errington Bose attractive, due to an efficient most commentators believe there is Immigration Services. banking system, the relative speed of an inevitability of rival jurisdictions

4 AUGUST/SEPTEMBER 2021 INTRODUCTION SPECIAL REPORT

vying to attract wealth through CBI tax avoidance and lax vetting are On hold: the Cyprus industry is increased collaboration Investment schemes, particularly within the often seized on and amplified by Programme has been between competing centres, which realist, highly competitive political opposition movements, keen to withdrawn, following all share the aim of attracting climate facilitated by Covid-19. create a political backlash against infringement well-qualified, high net worth procedures from the “The more autocracy you have, CBI strategies. European entrepreneurs. the more you will see citizenship “This does not mean the policy is Commission in 2020 Promoters of investment for sale in the liberal jurisdictions,” wrong,” suggests Indian-American migration, including the likes of suggests Loretta Napoleoni, an academic Parag Khanna, founder Malta, Ireland, Singapore and Italian political commentator who of consultancy FutureMap and the United Arab Emirates, are analyses international finance and author of ‘Move: The forces uprooting establishing ‘Green Zone Networks’ security issues. us’, which plots future migration of states respecting each other’s “If you know where to go and you patterns. “When they get elected, standards of immigration control, have the money, then everything is the opposition typically follows health regulation and monitoring of for sale,” says Ms Napoleoni. the same policy, as fundamentally residency criteria. Mr Khanna also “The super-rich buy their way it’s not about politics or protecting believes technological innovation into countries and are welcomed an international reputation, but is correlated to openness and for their money. Most people in that demographics, which is a domestic, circulation of people. country think they will spend their fiscal issue.” money there and expect a trickle- For these smaller nations, CBI is JOINT INITIATIVES down effect. Public opinion is mostly vital to attract physical, tangible These emerging ‘clubs’ of nations only opposing immigration at lower investment, replacing burdensome are compared by Mr Khanna to levels, so I don’t see regulation sovereign debt with “sovereign modern-day re-incarnations of happening.” equity”, a concept which needs to be the Hanseatic League, a medieval Suggestions that criminal better communicated to voters. federation of trading states in individuals are benefiting from “I don’t believe that the half- the Baltic and North Seas, which second passports are often over- baked, politically-motivated advanced mutual commercial cooked, she believes. Organised pressures to clamp down on these interests of member hubs and criminals, she says, are more likely programmes will be sufficient to protected them against external to use covert ways to enter other suppress the demand side of the aggression. jurisdictions, rather than these equation from millions of people Improved due diligence of highly public channels. who want to move, and it’s an open applicants should result from such “Terrorist organisations do not use and shut case,” says Mr Khanna. joint initiatives. “We could have the mainstream of buying houses or “The force that wins is the one better background checks,” suggests making investments, they prefer to favouring mobility, not the force that Mr Khanna. lean on corrupt officials. If you are a favours suppression. The fact that “We should curb money known criminal, you would not go there are now 100 such programmes laundering and be careful about through an official channel,” insists tells that story very clearly.” who is allowed in simply as a mask, Ms Napoleoni. The most recent, overarching but we should not question the right In smaller countries, however, trend he has observed among to be able to live in a better place to these thorny issues of security, countries participating in the CBI cure the accident of birth.”

PWMNET.COM 5 CORPORATE STATEMENT THE CBI INDEX

The 2021 CBI Index

ow entering its fifth year, the end of 2020, while St Kitts and Nevis in last year’s CBI Index, Montenegro CBI Index provides a extended its limited-time offer on announced its CBI programme would not comprehensive, data-driven applications under the Sustainable Growth be extended beyond 2021. As the analysis of the world’s active Fund, from its original end date of Programme remains open for applications Ncitizenship by investment (CBI) 15 January 2021. until 31 December 2021, Montenegro will programmes and has become known as the New investment options have also been still be included in this year’s rankings. industry’s most reliable comparison tool for introduced since the 2020 CBI Index. While Malta discontinued its Individual CBI programmes. It also serves as a practical St Kitts and Nevis launched a private home Investor Programme, it unveiled an guide for individuals and entities wishing to option, under which applicants can altogether new CBI policy, which this year’s learn more about the CBI industry, the purchase a private home worth Index will assess, along with Egypt’s new issues that affect it, and its future direction. U$400,000, and an ‘alternative investment CBI Programme. North Macedonia is only Last year, prolonged disruption to option,’ under which applicants can invest now establishing the necessary frameworks worldwide travel resulting from the in local approved projects not necessarily for an international audience to fully Covid-19 pandemic forced many CBI linked to real estate or the tourism industry. engage with its CBI offering. As such, the programmes to adapt their processing Meanwhile, scrapped its CBI Index will continue to monitor its procedures and requirements. This year, government bond investment option, but progress as it transitions from its current programmes have continued to adjust. now offers a wide variety of qualifying phase to a fully operational programme. Antigua and Barbuda and Grenada, for investments, such as in undertakings for The 2021 CBI Index therefore examines example, made provisions for the virtual collective investment in transferable the CBI programmes of 14 countries, and administration of their oaths of allegiance in securities, alternative investment funds, evaluates them against nine pillars that February 2021 and November 2020 and a range of Bulgarian companies. reflect investor priorities. As always, data respectively, while Vanuatu’s travel Elsewhere in Europe, despite the was collated from relevant industry requirement remains suspended. promise of new CBI regulations in the sources, including legislation, government In the Caribbean, two limited-time summer of 2020, the Cypriot government circulars and memoranda, programme offers implemented in the wake of took the decision to abolish its Programme application forms and guidelines, official Covid-19 were extended to 31 December following mounting pressure from the media and statistics channels, and direct 2021. St Lucia extended its Covid-19 Relief European Commission. In another correspondence with governments and Bond option, originally due to expire at the unexpected exit, after its first appearance their authorised representatives.

A TIMELINE OF CITIZENSHIP BY INVESTMENT

1984 1985 1993 2009 2013 2016 St Kitts Austria Dominica Bulgaria Antigua St Lucia and Nevis and Barbuda Cambodia Grenada

6 AUGUST/SEPTEMBER 2021 LOOKING TO 2022 CORPORATE STATEMENT

Reflections and predictions for 2022

o far, 2021 has proved to be a well after the main applicant, questions have Visit pwmnet.com for Against the background of mounting remarkable year for citizenship been raised as to whether spouses in these an expanded version scrutiny by multilateral bodies and of the CBI Index, by investment (CBI), with both jurisdictions can count as true ‘dependants.’ including detailed international organisations, it is expected the implementation of new Indeed, this year’s CBI Index is more profiles of all 14 that increased emphasis on due diligence programmes and the closure of nuanced than in previous years, penalising citizenship by will continue into 2022, and there is hope S investment longstanding and infant programmes alike. countries where family members do not programmes that the industry may move closer to Trends have included family inclusiveness, receive citizenship with the main applicant. harmonised standards. More should be sustained emphasis on due diligence, and Some CBI nations have been enhancing done, however, by Middle Eastern nations. growing oversight of real estate projects their due diligence practices for many years. Although lower due diligence barriers to available for investment under certain Malta, for example, whose due diligence entry are often a feature of newer CBI CBI programmes. operations under the IIP already required a programmes, there is little to suggest that Family inclusiveness seems to have hefty €7500 fee from the investor, now improvements to applicant vetting and reached an apex in the Caribbean, where utilises two (and not merely one) external due diligence processes are being Grenada in 2019, Dominica and St Lucia in due diligence firms – requiring an even prioritised, even as their programmes early 2020, and St Kitts and Nevis and more substantial €15,000 fee. become better established. As Antigua and Barbuda in late 2020, Vanuatu is also upgrading its due demonstrated by the abolition of the expanded their definition of ‘dependant’ to diligence, having mandated in 2020 Cyprus Investment Programme, failure to include siblings. regulations that checks be carried out by implement comprehensive due diligence Malta’s Granting of Citizenship for an “international specialist firm” and processes in time can come with grave Exceptional Services Regulations were requiring an extra US$3000 per consequences, including permanent drafted to be wider than the regulations for application for its due diligence — a damage to a programme’s reputation. Malta’s Individual Investor Programme substantial addition to the the previous This year has seen growing awareness of (IIP), but only slightly, allowing adult US$2000. However, although Vanuatu the risks associated with, and consequent children to apply with their parent investor checks applicants against the databases of oversight of, real estate investment up to the age of 28, instead of 26. reputable due diligence firms, it does not options. In St Kitts and Nevis, for example, There have been some improvements in appear that the country is working with a as of March 2021, new and existing Bulgaria for spouses, but with Egypt also third-party firm to conduct stringent developers must submit a payment allowing spouses to only obtain citizenship on-the-ground checks of applicants. schedule to the St Kitts Investment Promotion Agency. This will govern the A TIMELINE OF CITIZENSHIP BY INVESTMENT way a project is financed, improving the administration of funds provided to real estate developments under the Programme and increasing the likelihood that developments will be completed 2017 2018 2019 2020 successfully and at pace. Turkey Jordan Montenegro Egypt Turkey also tightened its real estate rules. In March 2021, the country decided Vanuatu Malta that a property that has been used to obtain citizenship (whether through a title deed transfer or preliminary sales contract) could no longer be used in another CBI application. The change limits the risk that a real estate ‘bubble’ will form, and ensures property is not recycled by CBI applicants. Real estate controls are being applied in CBI jurisdictions across the globe and show no signs of being relaxed, and it is expected that CBI nations will continue to work to enhance the integrity of their real estate offerings.

PWMNET.COM 7 CBI frameworks without ‘operational’ programmes

OPERATIONAL PROGRAMMES BANGLADESH However, CBI in Bangladesh falls CBI in Bangladesh finds its roots in the short of offering a clear, formal Not all countries have operational Bangladesh Citizenship (Temporary framework and its application volume CBI programmes, despite sharing Provisions) Order, with Article 2B(2) is non-existent. some characteristics with those giving the government wide-ranging Unlike in many of the programmes that do. powers to “grant citizenship of the CBI Index assesses, there is no Bangladesh to any person who is a single government body tasked solely he 2021 CBI Index analyses citizen of any state of Europe or North with administering CBI in Bangladesh. countries with ‘operational’ America, or of any other state,” and Citizenship is broadly administered citizenship by investment Article 4 stating that “The government by various entities, ranging from (CBI) programmes. Such may, upon application made to it in this the Ministry of Home Affairs, to Tprogrammes are rooted in law, subject to behalf in the manner prescribed, grant the police and the Investment procedural rules and policies, readily citizenship to any person.” Development Authority. promoted abroad, and have, if Although documentation on the Further, highlighting the longstanding, processed a sizable number specific conditions for CBI in Bangladesh country’s unpopularity with investors, of applications over their lifetime. is difficult to access, the Central Bank of only two people who naturalised as Countries that lack one or more of Bangladesh states that citizenship may be citizens of Bangladesh obtained these elements fall outside of the remit granted to any person who invests in citizenship through the making of an of the CBI Index. Examples of such Bangladesh, including in a recognised investment between 1988 and 2016. countries include Bangladesh, Papua financial institution, and does not Both were granted citizenship in 1997, New Guinea, and Samoa. repatriate that investment. more than 20 years ago.

CBI in Bangladesh is held back by the fact that there is no single government body overseeing the application process

8 AUGUST/SEPTEMBER 2021 OPERATIONAL PROGRAMMES CORPORATE STATEMENT

PAPUA NEW GUINEA character references from two Papua Samoa received a approved, the investor is granted a Over in Oceania, in 2016, Papua New New Guinean citizens who have known total of two CBI permanent resident permit valid for applications Guinea passed amendments to its them for at least two years. between 2017/2018 three years. The investor must reside in Constitution and Citizenship Act to make CBI stands as an interesting route to and 2019/2020, Samoa for at least 15 days per year provision for investors to obtain citizenship particularly for those who do with neither ending during the three-year period and comply in citizenship being citizenship of the country. not have links to the host country. granted with the investment plan to be able to Before being able to apply for Because Papua New Guinea insists on make the final application for citizenship. citizenship of Papua New Guinea, those links even for investors, and limits Compared to Bangladesh and Papua investors must make a K150,000 those who can access dual citizenship, it New Guinea, Samoa offers some of the (US$42,800) investment in a company suffers from a lack of industry same features as the more popular CBI or business in Papua New Guinea, and prominence, despite its low investment jurisdictions. It has, for example, a seek a position and work permit from the threshold. Citizenship Investment Committee, Department of Industrial Relations. application fees (albeit very expensive), They must then apply for an Entry SAMOA due diligence fees and provisions to Permit for Businesspersons/Investors. On 31 January 2017, Samoa’s Citizenship allow for an independent specialised Unlike some of the world’s most Investment Act and Citizenship third party to perform background popular CBI programmes, Papua New Investment Regulations entered into checks. Guinea’s rules are aimed at those who force and Samoa began accepting However, Samoa’s high investment already have ties to Papua New Guinea applications under its newly instated CBI threshold, minimum wealth requirement and wish to relocate to the country. This scheme. (a feature shared, but then dropped, by is because citizenship applicants must Investors are eligible to apply for CBI St Lucia), arduous investment plan intend to permanently reside in Papua in Samoa if they intend to make a requirement, and taxing physical New Guinea, and either renounce their minimum of WSt4m (US$1.55m) presence requirement, have had an citizenship of origin or apply to be ‘qualifying investment’ within three years overall negative impact on investor approved for dual citizenship. The latter of the date the application is granted, interest. According to MCIL’s past three option, however, is only available to and, at the time of application, have a annual reports, Samoa received a total of citizens of , Fiji, Germany, New minimum net worth of WSt2.5m two CBI applications between the years Zealand, Samoa, the UK, the US and (US$971,000). 2017/2018 and 2019/2020. Of these Vanuatu, severely reducing the pool of Applications must be accompanied applications, one was withdrawn by the prospective applicants. Additionally, by an investment plan for review by the applicant and the other was placed on when making an application for Ministry of Commerce, Industry and hold due to missing documentation and citizenship, investors must submit Labour (MCIL). If an application is unpaid due diligence fees.

PWMNET.COM 9 EU CBI: due diligence and lessons learnt

RESPONSIBILITY reputation of a host country and its PROGRAMME RESPONSES programme, and often have widespread Cyprus Governments that fail to take consequences for the entire industry. Having made several attempts to background checks seriously risk a Due diligence concerns linked to improve its due diligence over the years, premature end to their citizenship by European CBI programmes, for example, including by implementing a ban on investment programmes. have led to tensions between CBI nations ‘high-risk persons’ in 2019 and and the European Commission (EC). In a announcing new regulations tied to January 2019 report, the EC highlighted anti-money laundering legislation in June multi-layered due diligence concerns related to the security, money 2020, years of lax vetting procedures system is an essential laundering, tax evasion and corruption have come back to bite Cyprus. element of any successful risks it believed these programmes posed. In August 2020, an investigative series citizenship by investment In October 2020, it commenced by Al Jazeera revealed that Cyprus had (CBI)A programme, as it combines infringement procedures against Cyprus granted citizenship to more than 50 internal government checks with and Malta for granting economic high-risk or politically exposed persons research by specialist third-party due citizenship to individuals without a since the Programme’s inception. Further, diligence firms, and assessments by ‘genuine link’ to the two countries, and in October 2020, Al Jazeera published a regional and international bodies. again referenced the risks that it deemed video report, recorded one year prior, that Failures in due diligence harm the “inherent in such schemes.” seemingly evidenced the readiness of

The European Commission has raised concerns that CBI programmes pose security, money laundering, tax evasion and corruption risks

10 AUGUST/SEPTEMBER 2021 RESPONSIBILITY CORPORATE STATEMENT

certain government officials and mounting due diligence scandals. Indeed, The sun set on the 2021, confirming that the Bulgarian registered service providers to help in November 2020, Malta launched a Cypriot CBI Immigrant Investor Programme was programme as lax applicants obtain citizenship in wholly new CBI policy, enshrined in the due diligence checks alive and ready for remodelling. contravention of the Programme’s rules. Granting of Citizenship for Exceptional caused irreparable Traditionally one of Europe’s less This revelation, coupled with the EC’s Services Regulations. reputational damage popular CBI destinations, it will be move to open infringement proceedings, The policy aims at clarifying the interesting to observe whether the ultimately led to the abolition of the ‘genuine link’ between applicants and changes lead to an increase in Cyprus Investment Programme in Malta, requiring them to reside in Malta applications in the coming year. With February 2021. It is worth noting that for either 36 months or 12 months no external component to its vetting despite this, the EC issued a reasoned (depending on the investment made), procedures, Bulgaria would nonetheless opinion against Cyprus in June 2021, show physical presence in Malta, and do well to tighten its due diligence noting that although Cyprus is no longer build ‘connecting factors’. It also takes procedures and avoid the same pitfalls accepting new applications, it has steps to improve due diligence, requiring Cyprus was unable to address in time. continued to process pending applications applicant clearance from two external due and that the matter may be escalated to diligence providers. Montenegro the European Court of Justice. A June 2021 letter of formal notice In March 2021, Montenegro announced from the EC concerning Malta’s latest that its short-lived CBI programme would Malta policy only raised matters connected to be wound down by 31 December 2021 Like Cyprus, Malta has also ended its the ‘genuine link.’ — the Programme ostensibly causing a longstanding CBI programme, the barrier to Montenegro’s EU accession. ‘Individual Investor Programme’, in the Bulgaria It should be noted, however, that second half of 2020. However, unlike EU scrutiny does not seem to have Montenegro’s decision may equally be Cyprus, the Programme was closed deterred Bulgaria’s parliament from tied to low uptake, with only because it had reached its prescribed approving several amendments to 131 applications received, instead of the application cap, and not because of Bulgaria’s Citizenship Act in in February 2000 envisioned by the government.

PWMNET.COM 11 New horizons: the rise of digital nomadism

NOMAD VISAS citizenship and residence by investment Even countries with high immigration- industries. The Covid-19 pandemic and generated income relative to gross CBI jurisdictions stand to benefit the ascent of remote working, however, domestic product, such as some of the from the new work-from-home have led to the unveiling of a new, yet CBI nations featured in this Index, have normal, and from the employees comparable immigration system: the therefore begun to implement DNV who want to trade in office life for digital nomad visa (DNV). rules to find further ways of tapping Sometimes referred to as a remote- into the global mobility market. a chance to work overseas worker visa, this allows a person to live in a foreign country for an extended EXPLORING AVAILABLE period and work remotely for DIGITAL NOMAD VISAS or the countries implementing companies and individuals based Among European CBI jurisdictions, them, citizenship by elsewhere. The visa usually specifies Malta has introduced a one-year investment (CBI) programmes that the holder does not become ‘Nomad Residence Permit’ that costs bring several opportunities. subject to additional income tax €300 and allows workers to stay in, and FForemost among these is the ability to outside of that person’s normal country work remotely from, Malta for a year or provide a valuable framework in which of tax residence. DNVs allow for an less, depending on the length of their immigration rights are exchanged for extended stay compared to standard intended stay. To ensure that applicants non-tax revenue. For many years, this tourist visas, but also prevent the holder do not become a burden, the framework has been unique to the from undertaking local employment. government requires persons to have a

The Covid-19 pandemic has forced a radical rethink in how we work, with millions of people forced to make their home their new office

12 AUGUST/SEPTEMBER 2021 NOMAD VISAS CORPORATE STATEMENT

gross income threshold of €2700 per widely benefit from such a programme, Thanks to advances an expected minimum income of month, pass a background check, and particularly if it were to primarily target in communications US$50,000. The NDR visa is valid technology and possess health and travel insurance. regional workers from Australia, infrastructure, for two years from the date of arrival Evaluating the permit’s potential for New Zealand, and other countries many people can in Antigua and Barbuda, and visitors profitability, Malta’s parliamentary in Oceania. now work from are required to maintain their own almost anywhere secretary for citizenship, Alex Muscat, Perhaps the region that saw the in the world health insurance plan while staying in stated that Malta estimates that “a digital highest uptake in the implementation the country. nomad spends roughly €30,000 a year of DNVs, starting with Barbados in Dominica inaugurated its version of a in [the] country” — a sum “close to what June 2020, was the Caribbean, DNV, dubbed ‘Work in Nature’ (WIN), tourists spent […] in 2019” and equated including some of its CBI jurisdictions. earlier this year. The visa provides the yearly expenditure of one digital The island nation of Antigua and applicants with the opportunity to work nomad to “roughly what 260 tourists Barbuda was the first such CBI remotely for up to 18 months on the would spend in a day.” jurisdiction to announce a DNV island. Fees for the WIN visa are Meanwhile, as part of its Covid-19 programme. Named the ‘Nomad US$800 for individual applicants, and recovery plan, it is speculated that the Digital Residence (NDR)’ and US$1200 for families, with an additional Pacific island state of Vanuatu will launched in October 2020, the US$100 application cost. Businesses introduce a Remote Worker Visa for programme is for remote workers able may also apply for their employees, at a entrepreneurs, freelancers and to show both sufficient means to cost of US$800 for up to four teleworkers. As a secluded destination support themselves (along with any employees, plus US$500 for each with few Covid-19 cases, Vanuatu may family members joining them), and additional employee after the fourth.

PWMNET.COM 13 Cryptocurrency and CBI convergence

PAYMENTS CBI and cryptocurrency already have a storied history, but with the rise of decentralised finance, perhaps now is the time for jurisdictions to reconsider their stance on this new method of payment.

he economic and travel uncertainties originating from the Covid-19 crisis have led many to reconsider Tboth their personal priorities and their investment portfolios. Two beneficiaries of this re-evaluation process have been citizenship by investment (CBI) and cryptocurrency — owing to their shared capability to provide greater financial freedom and independence from a particular government’s decision-making. Perhaps not surprisingly, along with this surge has been increased discussion as to whether CBI programmes should accept cryptocurrency as a form of payment. It is unclear whether cryptocurrencies as payment for AN OLD DEBATE the benefits of citizenship. cryptocurrency use It is not the first time that questions will be deemed However, this is not to say that there Vanuatu was have been raised about the potential enough by CBI is no recognition of the growing appeal ties between CBI and cryptocurrency. governments to of cryptocurrency and of its underlying outweigh some of rumoured to have In 2017, Vanuatu was rumoured to have the challenges blockchain technology, as well as of become the first country with an active posed by it some of the arguments in favour of become the first CBI programme to accept bitcoin as a allowing cryptocurrency payments country with an form of payment for its citizenship; from prospective CBI investors. however, these reports were active CBI subsequently refuted by the nation’s LOWER TRANSACTION COSTS government. Similarly, in summer 2018, Cryptocurrency payments can lower programme to Antigua and Barbuda took steps to transactions costs for international integrate cryptocurrency in the nation’s payments through the elimination of accept bitcoin as a CBI Programme, only to later clarify banking fees while also allowing for form of payment for that payment must still be made in US greater transaction mobility. Moreover, dollars. Indeed, to date, no CBI the change would be easier to its citizenship in 2017 government accepts bitcoin or other implement following the digitisation of

14 AUGUST/SEPTEMBER 2021 CASE STUDY CORPORATE STATEMENT

CBI units and the Covid-19 cyber FIGHTING FINANCIAL CRIME BALANCING ACT acceleration witnessed in the last 18 Some reports suggest that the reality While cryptocurrency is likely to months. of cryptocurrency being a magnet for remain on investor radars for some financial crime is likely overstated, with time, it is unclear whether the benefits MORE EFFECTIVE DUE only 0.5% of total transactions of cryptocurrency use will be deemed DILIGENCE estimated to be used for illicit activity. enough by CBI governments to High-end due diligence is costly. An In the case of bitcoin, transactions are outweigh some of the challenges industry-wide, federated, permissioned public, traceable and permanently posed by it — the most obvious ones blockchain could streamline some of stored in the network, and users must being the reputational risk associated the vetting processes by allowing typically perform KYC and anti-money with digital currencies and their access to immutable know-your-client laundering requirements on reputable connection to illicit activity, as well as (KYC) data records on investors stored crypto exchanges. Rather than hinder a Owing to the huge cryptocurrencies’ volatility and the on the blockchain by financial actors. country’s source of funds analysis for popularity of dangers of being overexposed to cryptoassets such Ultimately, this could improve due the investor, blockchain’s immutable as bitcoin, them. What is certainly clear is that diligence in a manner that is cost ledgers could therefore help track the dedicated ATMs the industry, and investors, will effective and does not significantly source of funds and limit financial have started continue to watch this development appearing in some increase administrative burdens. crime exposure. countries closely.

PWMNET.COM 15 Overview of the methodology

METHODOLOGY Arriving at an appropriate rating for PILLAR 1: FREEDOM OF the nine pillars involves a complex MOVEMENT The CBI Index is built around nine combination of benchmarking, Freedom of movement within and pillars, designed to measure global statistical analysis, and comparative between countries is of paramount citizenship programme features and investigation. importance to any individual seeking jurisdictional desirability Each of the nine pillars is scored out second citizenship. This holds true of a maximum of 10 points, calculated whether the individual wishes to travel on an averaging basis from the scores for work purposes, to visit family, or he CBI Index is a rating of composite indicators and for leisure. system designed to measure sub-indicators. The maximum score In the 2021 CBI Index, the Freedom of the performance and appeal attainable by a programme is 90, with Movement Pillar measures the relative of global citizenship by all final scores also expressed in terms strength of each country’s citizenship on Tinvestment (CBI) programmes across a of a percentage of the total points the basis of three equally weighted diverse range of indicators. Its purpose available. For example, a perfect factors: the number of destinations to is to provide a rigorous and systematic 90-point score would be expressed as which a country’s passport allows travel mechanism for appraising programmes, 100 per cent. without restriction, the number of prime to facilitate the decision-making It should be noted that, owing to the business hubs to which it provides process for individuals considering vast number of statistics, indicators and access, and the degree to which a given them, and to bring value to the sub-indicators available for analysis, no citizenship provides settlement rights in CBI industry. single approach exists for the rating of other nations. All countries with operational CBI CBI programmes. In framing the CBI It is assumed, for the purposes of this programmes are assessed by the Index, Index, however, reliance was placed on pillar, that the passport used for travel is which, in 2021, include the following 14 official sources and publications from an ordinary passport, and not a nations: Antigua and Barbuda, Austria, institutions of the highest international diplomatic or service passport. Bulgaria, Cambodia, Dominica, Egypt, standing, as well as on the specialised Emphasis was placed on the total Grenada, Jordan, Malta, Montenegro, input of industry experts, whose number of countries and territories that St Kitts and Nevis, St Lucia, Turkey, and contributions and responses were used may be visited without applying for a Vanuatu. After officially opening in to obtain and interpret both qualitative visa. This includes both visa-free and 2020, Egypt becomes the latest and quantitative data used in the visa-on-arrival destinations, as neither addition to the CBI Index, while Cyprus construction of the CBI Index. requires receipt of a visa in advance of is no longer included due to the It should further be noted that, travel. Government and other official Programme’s recent abolition. whenever possible, points were awarded sources, including data from the UN The primary methodological based on evidence from official sources World Tourism Organisation, were used objective of the CBI Index is to isolate and the letter of the law. Because to obtain up-to-date information on visa factors — or ‘pillars’ — that satisfactorily announcements of changes to CBI requirements for holders of each of the measure programme features and programmes are often made well in 14 passports under evaluation. jurisdictional desirability. The nine pillars advance of their actual implementation, As business travel is a prime that constitute this year’s CBI Index are: the CBI Index limits its evaluations to consideration for prospective global changes confirmed by governments citizens, a passport’s ability to provide 1. Freedom of Movement themselves and associated legal facts. access to the world’s leading economic 2. Standard of Living Finally, the 2021 CBI Index does not and financial centres was also evaluated. 3. Minimum Investment Outlay consider temporary measures resulting The World Bank’s Ease of Doing 4. Mandatory Travel or from the Covid-19 crisis, except in the Business Index, the Heritage Residence Certainty of Product Pillar, which takes Foundation’s Index of Economic 5. Citizenship Timeline into account a programme’s ability to Freedom, the World Economic Forum’s 6. Ease of Processing respond and adapt to present needs. Global Competitiveness Report, and 7. Due Diligence The more general impact of the Covid- other authoritative sources were used to 8. Family 19 pandemic on a nation’s wellbeing is arrive at a list of the top centres for 9. Certainty of Product factored in the Standard of Living Pillar. international business.

16 AUGUST/SEPTEMBER 2021 METHODOLOGY CORPORATE STATEMENT

For both of these indicators, points as a relative value, within the context of affordable was selected for evaluation. were awarded on a descending scale, with the other CBI countries. For example, Dominica offers a single the highest score received by the country Reliance was placed on the UN Human applicant the choice between a direct with visa-free or visa-on-arrival entry to Development Index for factors such as life contribution to the government and an the highest number of foreign countries expectancy, education, safety and income. investment in pre-approved real estate, or territories. Countries’ latest annual economic with the latter being the more expensive While the freedom to access a high performance statistics were used to alternative. The first option was therefore number of jurisdictions is of critical indicate present-day economic used to determine the minimum importance to the citizenship investor, circumstances, as well as growth potential investment outlay for the Dominica many also look at second citizenship as a — a particularly important indicator for CBI Programme. gateway to ensuring long-term security investors. Data was sourced from the This Pillar considers pure investment and stability for themselves and their World Bank’s Open Data Catalogue to requirements, exclusive of minor fees that families. The settlement rights measure ensure accuracy and consistency. This may also apply. These may include reflects this, making CBI countries that means that, for the 2021 CBI Index, application, processing or due diligence are part of broad free-movement regimes statistics from 2020 were used. The fees that do not significantly alter the cost more attractive. reader should thus be aware that this of a citizenship application. However, In order to assess settlement rights, year’s data sets were somewhat distorted where countries had sizeable additional value was placed both on the number of by the Covid-19 pandemic. fees amounting to US$15,000 or more, jurisdictions accessible within a given free- The Standard of Living Pillar also such fees were taken into account. movement regime and on the nature of examines a country’s ability to promote The highest number of points was the rights afforded to the citizen, with freedom, and to protect the rights of awarded to the country requiring the distinctions drawn for rights that are individuals to act and to express lowest minimum investment. conditional on a citizen undertaking work. themselves without undue constraints. The EU, the CARICOM Single Market Civil liberties and political rights within a PILLAR 4: MANDATORY TRAVEL and Economy, the Association of jurisdiction were rated as part of this OR RESIDENCE Southeast Asian Nations, the Community exercise, using sources such as Freedom The Mandatory Travel or Residence Pillar of Sahel-Saharan States, and the Common House’s Freedom in the World Index. examines the travel or residence Market for Eastern and Southern Africa conditions imposed on applicants both free-movement regimes were also PILLAR 3: MINIMUM before and after the granting of assessed against the total average UN INVESTMENT OUTLAY citizenship. Often busy with running a Human Development Index score of the The Minimum Investment Outlay Pillar business or with international travel of free-movement bloc under evaluation. measures one of the most practical and their own, citizens of the world have little foremost considerations of CBI: how much opportunity to fulfil minimum stay PILLAR 2: STANDARD OF LIVING capital is required for the investor to requirements. The Standard of Living Pillar is a measure become an eligible applicant for the A careful examination of the laws, of the quality of life offered by the 14 CBI programme of their choosing. regulations and policies pertaining to jurisdictions under assessment. This pillar is The cost of applying for CBI increases each CBI programme was undertaken. vital to those who yearn to relocate while with the number of dependants — or First, it was determined whether any such securing a prosperous and fulfilling qualifying family members — included in prerequisites applied. Second, post- lifestyle. Similarly, it is key to those wanting an application. In some jurisdictions, this citizenship requirements were examined, to take advantage of local business increase is proportional, while in others the as well as the consequences of failing to opportunities or needing to transfer and cost only increases following the inclusion fulfil them. Third, the extent of the travel safeguard their assets. of multiple dependants. To remain or residence requirements were analysed, For this Pillar, a wide range of official consistent across all jurisdictions, it was with physical visits for the purposes of indicators were considered to allow for an assumed that one applicant was applying attending an interview, swearing an oath accurate assessment. Consequently, for citizenship alone (i.e., the application of allegiance or giving biometric establishing an appropriate benchmark consisted of a single applicant). information all considered. was paramount, as a country’s score must Where a CBI programme offers It is important to note that physical, be viewed both as an absolute value and multiple investment options, the most rather than nominal, requirements were

PWMNET.COM 17

taken into consideration. layer of certainty for the applicant who is PILLAR 7: DUE DILIGENCE In line with previous pillars, scrutiny urgently in need of second citizenship. The Due Diligence Pillar focuses on focused on the main applicant, rather each nation’s commitment to ensuring than any dependants that may be PILLAR 6: EASE OF that their programme remains included in the citizenship application. PROCESSING transparent and effective at evaluating As having year-round freedom to The Ease of Processing Pillar measures potential candidates for citizenship. It is, travel is a highly valued liberty, the end-to-end complexity of the CBI therefore, a measure of each programmes that waived both residence application process. In some programme’s integrity. and travel requirements achieved the jurisdictions, the application process can The CBI Index focuses on the ability best score, followed by those with be a labour-intensive and painstaking of governments to obtain information minimal requirements. The lowest scores task that is time-consuming for the on and from applicants, such as by the were attained by programmes with applicant; in others, it is streamlined and performance of internal and external extensive requirements. the applicant receives clear directives on due diligence checks. Indicators The scoring system under the how to proceed. The overall comprise police certificate requirements Mandatory Travel or Residence Pillar effortlessness of the application process — including the number of nations from combines the subtotals for mandatory is a particularly important component which a certificate must be provided — travel requirements and residence and the promise of a smooth, hassle-free as well as requests for fingerprints or requirements to yield the total pillar process can generate readiness to biometric data. score. engage with a programme. Emphasis was also placed on a Multiple indicators were considered, country’s ability to gather evidence on PILLAR 5: CITIZENSHIP commencing with entry qualifications, the applicant’s source of funds, as this is TIMELINE such as previous business experience, a a core step in denying citizenship to The Citizenship Timeline Pillar looks at proven track record of achievement or those profiting from, or involved in, the the average time taken for citizenship to fluency in a language. Knowledge of financing of illicit activity. be secured by the applicant. local history or culture assessments and Increasingly, strict anti-terrorism and The speed at which application forms interview requirements were also anti-money laundering legislation has and supporting documentation are weighed. prompted some governments to processed, and the steps involved in By its very nature as a naturalisation exclude persons of certain nationalities approving an application, vary between process, CBI involves a significant from their programmes or to restrict programmes. Therefore, a thorough amount of paperwork, including both funds transferred from certain inspection of applicable laws, forms and supporting documents. jurisdictions, in order to ensure regulations, and policies was made to Having the support of an official compliance with international sanctions. determine the official processing times government website and of a dedicated These trends are included among this mandated by each jurisdiction. CBI body to seek and obtain clarification pillar’s indicators. Extensive reliance was also placed on was thus a factor in awarding points to a The greater a country’s ability to the first-hand experience of applicants, programme. perform background checks on agents and other stakeholders, whose Extensive communication with applicants, the higher the score attained. contributions proved to be an invaluable advisors and legal experts is required tool in ascertaining citizenship timelines. where a jurisdiction mandates the PILLAR 8: FAMILY One of the key merits of CBI purchase of real estate or other assets, The Family Pillar measures the extent to programmes is their ability to provide a and hefty paperwork must also be which investors can obtain citizenship rapid route to second citizenship; as submitted as evidence of that purchase. with their immediate and extended family. such, the highest scores were awarded to Therefore, countries with compulsory The CBI Index recognises that the rise the programmes with the shortest purchasing requirements were deemed of increasingly complex family turnaround times. to burden the application process. relationships is driving investors to seek Additional merit was given to Programmes with fewer demands programmes that allow for a more diverse programmes offering fast-track placed on the applicant, and with range of family members to be included processing options (even if at an relatively straightforward procedures, under a primary application. Indeed, while additional fee), as these provide an extra achieved higher scores for this pillar. the large majority of CBI programmes

18 AUGUST/SEPTEMBER 2021 METHODOLOGY CORPORATE STATEMENT

provide for the inclusion of spouses and investors with a means of differentiating a minor children, only a handful of programme’s relative robustness. THE RESEARCHER countries do so for adult children and ‘Longevity’ measures the age of a extended family. Introducing a further given programme. ‘Popularity and The CBI Index was created by James layer of nuance to its scoring system, this renown’ evaluates the number of McKay, a research consultant and year’s CBI Index also draws a distinction applications and naturalisations under the founder of McKay Research with between family members who are each programme per year, as well as a more than 14 years of experience in allowed to apply with, and obtain programme’s eminence in the industry. the design and execution of complex, citizenship at the same time as, the main As applicants and service providers data-driven research and analysis applicant, and those who obtain prize continuity throughout the projects. Having read psychology and citizenship at a later stage and as a application process and beyond, the statistics at University College London, consequence of the main applicant stability of each programme was also Mr KcKay provides strategic custom having already received citizenship. assessed. Here, importance was placed research and consulting solutions Multiple family member categories on whether any calls to end a particular across a wide range of sectors, and were considered, with points being programme have been made by actively works with some of the world’s awarded for adult children, parents, authorities within or external to the CBI biggest independent providers of grandparents and even siblings. jurisdiction. market intelligence across several Additional merit was also given to Additionally, countries with no cap on industries including investment, programmes with provisions for family the number of applications that can be technology, and manufacturing. members of the main applicant’s spouse. processed over the life of the programme Mr McKay, who used guidance Additionally, the degree of flexibility scored more highly than jurisdictions that from the OECD’s Handbook on within each of these categories can differ imposed a yearly maximum or a fixed Constructing Composite Indicators, radically from programme to programme. total over a given period. For example, employed a three-stage process In the adult children category, for Montenegro’s CBI programme is both to produce the latest version of example, programmes that allow for the time- and volume-limited, with the the CBI Index. The first phase inclusion of children aged over 18 years government planning to end the scheme involved comprehensive primary and with few restrictions achieved the most after 31 December 2021 and limiting the secondary research to chart all major points. Those that require proof of a high total number of investors to 2000. developments in the world of economic degree of dependency — for example The reputation of a programme was citizenship over the past 12 months. with a requirement that the child is in full- determined by the amount of negative The second phase comprised a detailed time education and fully supported by the press or the number of scandals it has exploration of official macroeconomic main applicant — achieved fewer points. been linked to, affecting investors’ and programme statistics to be used As inclusivity has become an issue of broader perceptions of a given country. in evaluating CBI Index country global importance and increasingly Just as important, however, is evidence performance. The third and final relevant to the CBI industry, a point was that programme funds are being utilised stage involved critically analysing and awarded to those programmes that make for social good. Points were awarded for a inputting all data collected throughout provision for dependents living with a jurisdiction’s transparent use of CBI funds, the research process, paying careful disability. for example for the development of attention to maintaining the statistical domestic healthcare, education, tourism continuity and integrity of the original PILLAR 9: CERTAINTY OF and other infrastructure. index architecture. PRODUCT Lastly, ‘adaptability’ reflects a After a comprehensive review The Certainty of Product Pillar programme’s ability to rapidly respond to, and methodological update for encompasses a range of factors that and sometimes even predict, the needs of the 2020 edition of the CBI Index, measure a programme’s certainty across applicants and the industry. More points the nine-pillar index architecture five different dimensions: longevity, were awarded to jurisdictions that have now provides investors with an popularity and renown, stability, shown capacity to communicate with enhanced toolset with which to reputation and adaptability. With the CBI applicants, prospective applicants and measure the performance and industry continuing its rapid growth, it is stakeholders, and to tweak their appeal of global citizenship by more important than ever to provide requirements accordingly. investment programmes.

PWMNET.COM 19 Key findings: Caribbean nations remain on top

KEY FINDINGS arrival offering for the second year in a equals Austria’s expected years of row — perhaps heralding a better overall schooling with 16.1 on average. These The CBI Index’s Key Findings pillar score for 2022. All five Caribbean two nations’ historic accomplishments in present an evaluation of each jurisdictions are also members of the life expectancy, safety and the upholding country, both overall and within the Caricom Single Market and Economy of basic freedoms all contribute to their parameters of the nine pillars (CSME), which comprises 12 member high rankings despite the economic states and facilitates the right to work for damage caused by Covid-19 in 2020. certain categories of workers. In joint third position, with a score of he CBI Index is intended as a In the 2021 CBI Index, Vanuatu scores seven, are Bulgaria and Turkey. While practical tool, both for those five, as it does not belong to a free- both countries are fairly evenly matched who wish to compare movement regime and offers visa-free with respect to safety and GNI, each citizenship by investment access to 13 out of 20 CBI Index business outdoes the other in different key areas: T(CBI) programmes as a whole and for hubs. This year, Vanuatu joins Dominica Turkey outscores Bulgaria for life those who wish to compare specific with the highest overall increase in visa- expectancy, education and GDP aspects of each programme. These free and visa-on-arrival destinations out growth, while Bulgaria achieves a aspects are reflected by the CBI Index’s of all 14 jurisdictions under evaluation. significantly higher freedom score. nine pillars: Freedom of Movement, Once again, EU candidate Ranking fifth with six points are Standard of Living, Minimum Montenegro is followed in descending Antigua and Barbuda, Grenada, Investment Outlay, Mandatory Travel or order by Turkey and Cambodia, with Montenegro and St Lucia. All countries Residence, Citizenship Timeline, Ease of respective scores of four, three and two. in this tier exhibit similar scores across a Processing, Due Diligence, Family and Citizens of Montenegro can travel range of different measures, such as life Certainty of Product. without pre-applying for a visa to more expectancy and GNI, but some notable than double the number of nations than differences include Montenegro’s PILLAR 1: FREEDOM citizens of Cambodia, and nearly stronger performance in terms of OF MOVEMENT two-and-a-half times the number of relative safety and all three Caribbean Schengen Area countries Austria and business hubs than citizens of Turkey. countries presenting citizens with more Malta maintain their scores of 10 in this This year, the lowest score is shared rights and freedoms. For education, year’s Index, closely followed by the sole between Egypt and Jordan. Grenada is again the strongest remaining fellow EU member state in Unfortunately, Egypt’s membership of performer with 16.6 years of expected the Index, Bulgaria, with a score of nine. the Community of Sahel-Saharan States schooling on average — the highest of It is worth noting that Bulgaria, like and the Common Market for Eastern any of the 14 jurisdictions. While all Cyprus, Croatia and Romania, is not a and Southern Africa offers no relief for countries in this tier experienced sharp, Schengen state; however, like Austria the country, as free movement is yet to pandemic-fuelled GDP declines in and Malta, it offers citizens the right to be implemented throughout the 2020, the economies of Antigua and live and work in all 27 EU member states. member states of each regime. Barbuda and St Lucia were more Among the free movement regimes severely affected. assessed in this Index, the EU continues PILLAR 2: STANDARD In eighth position are a diverse group to provide the greatest opportunities for OF LIVING of countries comprising Dominica, human development. In 2021, Austria emerges as the leader in Egypt, Jordan, St Kitts and Nevis and Outside of the EU, citizenship of the the Standard of Living Pillar, with a total Vanuatu, all with a score of five. Here, Caribbean countries of Antigua and of nine points to Malta’s eight. Austria’s the Caribbean countries attain higher Barbuda, Grenada, St Kitts and Nevis gross national income (GNI) increase for freedom, GNI and life expectancy, and St Lucia offers the greatest mobility bolstered its performance, and the with Dominica in particular scoring with a score of seven, while Dominica country also marginally outperforms highly with a life expectancy of 78.2 scores six. Notwithstanding its lower Malta across gross domestic product years and with a perfect freedom score. number of visa-free or visa-on-arrival (GDP) growth, relative safety and Egypt recorded a 3.6 per cent GDP destinations, Dominica was the freedom metrics. As was the case in growth during this period, while Jordan Caribbean nation with the greatest 2020, however, Malta retains the edge saw its GDP shrink by 1.6 per cent — increase in its visa-free and visa-on- with respect to life expectancy and their larger, more diversified economies

20 AUGUST/SEPTEMBER 2021 KEY FINDINGS CORPORATE STATEMENT

THE CBI INDEX NINE PILLARS FINAL RESULTS Country Freedom Standard Min Inv Mandatory Ctznshp Ease of Due Family Certainty Total % of Mvmnt of Living Outlay Trv/Res Timeline Process Diligence of Product Points Antigua & Barbuda 7 6 9 6 6 10 9 10 7 69 77

Austria 10 9 1 8 2 4 4 4 5 47 52 Bulgaria 9 7 7 6 2 6 7 0 5 48 54 Cambodia 2 4 8 8 8 4 4 2 4 44 49 Dominica 6 5 10 10 9 10 10 10 10 80 89 Egypt 1 5 8 8 6 9 6 5 2 49 55 Grenada 7 6 9 10 9 10 10 10 7 78 86 Jordan 1 5 4 10 9 7 2 4 4 46 51 Malta 10 8 4 2 3 9 10 9 4 58 65 Montenegro 4 6 6 8 9 6 9 6 1 55 61 St Kitts & Nevis 7 5 9 10 10 10 10 10 9 80 89 St Lucia 7 6 10 10 9 10 7 9 6 74 82 Turkey 3 7 8 8 8 7 3 5 6 55 61 Vanuatu 5 5 9 8 9 10 7 7 7 66 73 weathering the Covid-19 storm more countries with a score of nine points, * Each country's €705,000 for those choosing to reside final score as easily than smaller island nations. Antigua and Barbuda and Vanuatu are displayed in the in Malta for 36 months or more. Additionally, Egypt and Jordan also the next most affordable options at above table is not Malta’s new threshold is made up of achieved top scores for safety. Although US$130,000. Despite a minimum an aggregation of a €600,000 Exceptional Direct rounded-up sub- Vanuatu appears at the bottom of the contribution amount of US$100,000, pillars but an overall Investment, €80,000 over five years of table for education and GNI, the South Antigua and Barbuda continues to levy a performance score rent, a €10,000 charitable donation and Pacific island’s respectable score is owed hefty government fee of US$30,000. a sizeable €15,000 due diligence fee to the continued high levels of freedom Grenada and St Kitts and Nevis’ (twice as high as under the Malta and security it offers its citizens. minimum contributions remain at Individual Investor Programme [IIP]). Cambodia shores up the final position US$150,000. Austria retains its place as the most for the Standard of Living Pillar — its In the 2021 CBI Index, newcomer expensive CBI nation. score of four points nonetheless Egypt joins Cambodia and Turkey with a reflecting how the country’s first score of eight. Egypt’s most affordable PILLAR 4: MANDATORY economic contraction in a decade was investment option is a US$250,000 TRAVEL OR RESIDENCE not as severe as the double-digit donation to the Central Bank of Egypt. With the exception of new entrant declines seen elsewhere, as well as its Having made several changes to its Egypt, the scores under the Mandatory robust performance in the realm of investment options in 2021, Bulgaria Travel or Residence Pillar remain personal safety. overtakes Montenegro, increasing its unchanged from the 2020 CBI Index. score from five to seven. Now that the Dominica, Grenada, St Kitts and Nevis, PILLAR 3: MINIMUM option to invest in government bonds St Lucia and Jordan maintain their INVESTMENT OUTLAY has been eliminated, applicants looking perfect scores as they require neither This year’s Index reflects the fact that for the most affordable route to travel nor residence on the part of several jurisdictions have altered their citizenship can invest in a Bulgarian applicants. minimum investment thresholds for company employing 10 or more Egypt makes its CBI Index debut with applicants. This has resulted in some Bulgarian nationals for a minimum of a score of eight, joining Austria, score changes under the Minimum €257,000. Cambodia, Montenegro, Turkey and Investment Outlay Pillar, which, Montenegro is followed by Malta and Vanuatu. All six of these nations require excluding the new entrant, had remained Jordan, both of which attain a score of applicants to make one trip to their new unchanged since the 2019 CBI Index. four. In December 2020, the Jordan country of citizenship. Egypt, for These changes, however, did not Investment Commission revealed that example, requires applicants to make at affect the Caribbean and Vanuatu, the country’s minimum investment least one trip to the country to complete which remain the top scorers under this amount had been reduced from US$1m the procedures to obtain a National ID Pillar. With a minimum contribution to US$750,000, resulting in Jordan’s Card. With respect to Vanuatu, it is amount of US$100,000, Dominica and score increasing by one point since last worth noting that although the St Lucia continue to offer the lowest year’s Index. Malta’s score remains requirement that applicants take the threshold of all 14 jurisdictions assessed, unchanged, despite its new offering oath of allegiance in front of a and receive a score of 10. Of the four having a lower minimum threshold of Commissioner for Oaths has been

PWMNET.COM 21 citizenship to investors in an average of 24 months.

PILLAR 6: EASE OF PROCESSING The Caribbean nations achieve scores temporarily suspended as a result of the route has an average processing time of Newcomer Egypt's of 10 in the Ease of Processing Pillar lack of an official, Covid-19 pandemic, the CBI Index does three months. Also offering decisions to working CBI Unit for their continued commitment to not consider temporary changes that are applicants in three months, with website held it back ensuring the CBI process is as liable to being quickly reverted. Grenada adhering to a 60-business day from a perfect straightforward as possible. The score in the Ease of Antigua and Barbuda and Bulgaria response time, Dominica, Grenada, Processing Pillar region’s CBI Units work to maintain follow with a score of six. Antigua and Jordan, Montenegro and St Lucia each accessible, up-to-date programme Barbuda requires applicants to travel to score nine. After issuing its first approval websites and applicants are not the country, or one of its embassies, to in 2020, Montenegro’s CBI Programme burdened with mandatory interviews, take the oath of allegiance and did not receive the high application examinations or requirements to implements a minimum physical volumes expected, so its processing demonstrate business acumen. Also presence requirement of five days within time remains largely unchanged from scoring 10 is Vanuatu, whose five years of the grant of citizenship. As last year. Development Support Programme with Vanuatu, it is important to note that Vanuatu also scores nine. Despite (DSP) adopts this same streamlined the residence requirement has been increasing investor demand, Vanuatu philosophy toward processing temporarily suspended due to ongoing maintains last year’s score and applications. Covid-19 restrictions and provision has continues to process applications at Concerns were however raised this been made for applicants to take the pace. This may change in the future, year with respect to Vanuatu because, oath of allegiance remotely; however, given Vanuatu’s ongoing efforts to while applicants are not, in practice, this change is expected to be short-lived. implement more stringent vetting asked to undertake a language test, the Like the Malta IIP, Malta’s new controls on applicants. nation’s Citizenship Act fails to exclude offering obtains a score of two. Similarly, in Turkey, rocketing DSP applicants from the requirement Prospective Maltese citizens must spend application numbers do not seem to to speak and understand English, a minimum of either 36 or 12 months in have impacted processing times in the French, Bislama or a vernacular of Malta, with the 12-month option country, resulting in Turkey maintaining Vanuatu. This conflict should be needing a higher overall investment its score of eight, along with Cambodia. resolved or clarified by local lawmakers outlay. Applicants must also make two Egypt’s CBI Programme enters the to ensure applicants continue to face trips to Malta, the first to provide running with a score of six, with between straightforward processing and to biometrics for the issuance of the six and nine months considered a reliable reduce programme uncertainty. residence card, and the second to take timeframe estimate. Antigua and Were it not for the fact that its the oath of allegiance within six months Barbuda, the Caribbean country with official CBI Unit website is still not of the letter of approval from the slowest processing times, also up-and-running, and therefore that Community Malta Agency. receives a score of six. official information is not made readily With three points, Malta finishes just available for prospective applicants, PILLAR 5: CITIZENSHIP above its European counterparts Austria Egypt would have also attained a TIMELINE and Bulgaria. In Malta, the best-case score of 10. Instead, it joins Malta’s St Kitts and Nevis once again leads the scenario for applicants is a processing new offering with a score of nine. Citizenship Timeline pillar by virtue of its time of 13 months, inclusive of both Malta’s score is a result of it requiring Accelerated Application Process, which application submission and minimum applicants to purchase real estate to offers citizenship to qualifying applicants residence requirements; while in obtain citizenship — a time- within a maximum of 60 days and, under Bulgaria, fast-track applicants obtain consuming, document-heavy process certain circumstances, as little as 45 days. citizenship after around 18 to 24 months, that CBI applicants can avoid, should For applicants who do not want to pay a inclusive of a 12-month nominal they wish to, in the Caribbean and premium, St Kitts and Nevis’ standard residence period. Austria grants Vanuatu.

22 AUGUST/SEPTEMBER 20202021 KEY FINDINGS CORPORATE STATEMENT

Jordan and Turkey receive a score of THE FINAL SCORES internal checks are conducted by three seven. Neither tests applicants’ business government agencies. Country rank Total Points Percentage acumen, language skills or knowledge of Similarly, in Austria and Cambodia, local culture, but both should seek to 1 Dominica 80 89 on-the-ground checks are not establish dedicated entities and an performed. Austria and Cambodia’s online presence for the running of their 1 St Kitts & Nevis 80 89 score of four reflects this, as well as their programmes. 3 Grenada 78 86 lower standard of due diligence when it Bulgaria and Montenegro achieve a 4 St Lucia 74 82 comes to police certificate requirements score of six. Not only do these countries and source of funds checks. In 5 Antigua & Barbuda 69 77 lack a dedicated entity to manage and Cambodia, for example, it is not clear oversee their programmes, they also 6 Vanuatu 66 73 whether any checks are performed on an require the making of complex 7 Malta 58 65 applicant’s source of funds. investments. Although Montenegro’s 8 Montenegro 55 61 Turkey finishes one point above CBI Programme has an official website, 8 Turkey 55 61 Jordan with a score of two, with neither the domain has been inaccessible since country looking set to meet the standard 10 Egypt 49 55 the 2020 edition of the CBI Index. of due diligence that is expected of Austria and Cambodia remain at the 11 Bulgaria 48 54 more circumspect CBI nations, despite bottom and were dealt scores of four for 12 Austria 47 52 their programmes becoming more their more gruelling applicant 13 Jordan 46 51 established in the industry. requirements, with Austria being the only 14 Cambodia 44 49 country to require a proven track record PILLAR 8: FAMILY of business achievement and Cambodia Joining Dominica and Grenada with a being the only country to implement a score of 10, Antigua and Barbuda and language and history and culture test. This year, Vanuatu joins Bulgaria and St Kitts and Nevis also occupy the top St Lucia with a score of seven for due spot in the Family Pillar this year. PILLAR 7: DUE DILIGENCE diligence. For Vanuatu, this is an Antigua and Barbuda’s two-point Once again, Dominica, Grenada, Malta increase of one point since the 2020 increase is a result of changes in and St Kitts and Nevis earn top scores in CBI Index, owing to new requirements November 2020 that reduced the Due Diligence Pillar. Since the CBI for applicants to submit bank restrictions on children over 18 years Index’s introduction in 2017, this has been statements showing six months of and allowed siblings of the main a consistent outcome for Dominica, transaction history. As Vanuatu seeks to applicant or spouse to be included in an Malta and St Kitts and Nevis, while enhance its external due diligence application, if unmarried. St Kitts and Grenada has attained a perfect score component, next year’s CBI Index could Nevis also widened its definition of every year since 2019. Malta’s new see further improvements for the Pacific dependant to include siblings of the offering is no exception, with applicants island-nation. However, St Lucia main applicant or spouse if 30 years or having to undergo multiple layers of remains the lowest-scoring Caribbean under, unmarried, childless and vetting, including external checks by two nation. It has not imposed fingerprinting financially dependent on the main reputable due diligence firms. or biometric requirements since last applicant. Antigua and Barbuda and year, and it could do more to St Lucia retains its score of nine, Montenegro form the second tranche of authenticate source of funds. falling short of the top spot as it is the countries, both scoring nine. Although Newcomer Egypt enters the ranking only Caribbean nation that does not they have biometric requirements, with six points. Despite requiring allow grandparents to form part of an restrict applications from citizens of applicants to provide biometrics and application. Malta’s new offering also at-risk nations, and use independent due requiring the submission of a clean scores nine, reflecting the fact that, diligence firms for on-the-ground police certificate from both an although siblings are ineligible, children checks, there is room for improvement applicant’s country of citizenship and over 18 are permitted with few with respect to ascertaining criminal residence, Egypt does not employ a restrictions, as are dependent parents activity for the former and source of third-party specialist firm to provide an and grandparents of the main applicant funds for the latter. extra layer of vetting. Instead, desktop or spouse over the age of 55.

PWMNET.COM 23 estimated to have increased by 325%, demonstrating that Turkey’s popularity shows no signs of abating. Both Austria and Bulgaria obtain a score of five, a one-point increase Vanuatu scores seven and Montenegro PILLAR 9: CERTAINTY OF St Kitts and Nevis compared to the 2020 CBI Index. When follows with six. In both countries, children has moved into joint the European Commission (EC) initiated PRODUCT first place overall over 18 years can be included. Vanuatu, For the second year, Dominica achieves for the first time infringement proceedings against Cyprus however, requires a higher degree of a score of 10 in the Certainty of Product since the inception and Malta last October and sent a letter of the CBI Index dependency to be shown as adult Pillar — a result of its transparent and in 2017 to Bulgaria, Austria was notably absent children must be residing with or highly renowned programme. At 28 from the firing line. This suggests that dependent upon the main applicant or years old and with a track record of good Austria’s Programme is one of the most spouse and attending full-time education. governance, the Dominica CBI stable in the EU. Bulgaria’s increase is due On the other hand, while Vanuatu allows Programme has led the way in providing to recent sweeping changes to parents of the main applicant or spouse to clarity as to how CBI funds are used, this investment options under the be included, Montenegro does not allow year earmarking US$370m for the Programme, demonstrating a higher level the inclusion of extended family, and the construction of an international airport. of adaptability and putting to bed any family tie for all dependants must be with Furthermore, 2215 applications were rumours of the Programme’s closure. the main applicant. approved in the 2019/2020 fiscal year Cambodia, Jordan and Malta are next Egypt enters the running with a score (which runs from 1 July to 30 June) — with scores of four. Having been of five, level with Turkey. While Egypt showing strong interest even amid the established at the tail end of 2020, and Turkey both make provision for Covid-19 pandemic. Malta’s new offering loses points for children over the age of 18, Turkey only The industry’s most longstanding longevity. Further, in June 2021 a letter allows adult children to be included if programme, that of St Kitts and Nevis, of formal notice was sent from the EC rendered dependent as a result of a scores nine. This score also reflects St concerning Malta’s new policy, despite medical condition. In the 2021 CBI Index, Kitts and Nevis’ ability to adapt to present more stringent residence requirements. countries are only awarded points in the need and to attract high numbers of Having had longer to establish itself in Family Pillar if a particular family member investors. St Kitts and Nevis could, the industry and having made receives citizenship at the same time as however, provide more guidance on its amendments to its minimum investment the main applicant. In Egypt, spouses of new investment options, in particular the outlay, Jordan’s score increases by two the main applicant can only obtain ‘Alternative Investment Option’. from last year. Cambodia’s increase of citizenship two years after the main Antigua and Barbuda, Grenada and one point is a result of reports from applicant, and Egypt therefore receives Vanuatu each receive seven points. Cambodia’s Ministry of Interior that no point for spouse dependants. Antigua and Barbuda lost a point in this suggest 700 foreign nationals applied Austria and Jordan retain scores of year’s CBI Index for its reduced for Cambodian citizenship between four, with neither country allowing family application volume in 2020. Grenada also 2000 and 2013. members of the main applicant’s spouse lost a point owing to reputational Egypt enters the race towards the to be included in an application. implications arising from the developer of bottom of the table, having had little Cambodia is next with a lowly score of Grenada’s CBI-approved Kimpton time to establish a reputation, while two, allowing only a spouse or minor child Kawana Bay Resort seeking international Montenegro drops to last place, owing of the main applicant to obtain arbitration against Grenada. In Vanuatu, largely to the fact that the Programme citizenship with the main applicant. however, growing application numbers will be closing at the end of 2021. Bulgaria takes last place this year due to and more efforts to improve due the 2021 CBI Index not considering diligence and promote the DSP FINAL SCORES: THE HIGHEST- family members who cannot obtain internationally led to a two-point increase. RANKING PROGRAMMES citizenship at the same time as the main St Lucia and Turkey retain scores of six, For the first time in the history of the applicant. Bulgaria only facilitates with neither programme suffering any CBI Index, St Kitts and Nevis joins citizenship for spouses and children after major setbacks in the last year. In 2020, Dominica in first place overall, making citizenship is obtained. approvals under Turkey’s Programme are Dominica and St Kitts and Nevis the

24 AUGUST/SEPTEMBER 2021 KEY FINDINGS CORPORATE STATEMENT

best CBI programmes the industry has the Caribbean. A renewed focus on due premieres with commendable scores for to offer in 2021. diligence, with applicants now being its relatively low minimum investment For Dominica, first place has been a asked to provide six-month bank outlay, low travel and residence consistent result for five consecutive statements, and a better reputation requirements, and straightforward years. Maintaining a perfect score in six helped Vanuatu increase its overall score programme — missing out on a perfect out of the nine pillars assessed, by two points. Efforts to improve score in the Ease of Processing Pillar due Dominica once again promises, among applicant vetting in the country are to the Programme’s official website other things, an affordable minimum ongoing and a confirmed system of being inaccessible. The CBI Index will investment outlay, a streamlined on-the-ground checks would see continue to chart the Programme’s application process, and certainty to Vanuatu continue on its upward development in the coming year and investors. However, the hit taken to trajectory. monitor investor interest. Dominica’s economy as a result of Malta’s brand-new offering debuts in In eleventh place, Bulgaria increases Covid-19 ultimately lowered Dominica’s seventh place, maintaining the same its percentage score this year. Changes overall score. position as its predecessor. Like the IIP to investment options in early 2021 led St Kitts and Nevis remains the CBI before it, the new policy performs to a lower minimum investment amount nation with the fastest processing time respectably in five pillars, with a well- and demonstrated that Bulgaria can and is the Caribbean country with the deserved perfect score in the Freedom adapt to meet investor demand. largest visa-free or visa-on-arrival of Movement and Due Diligence Pillars. Burdensome travel requirements, a lack offering. This year, St Kitts and Nevis Malta is, however, the country with the of official government guidance, and also achieves a perfect score in the most arduous travel and residence one of the longest citizenship timelines Family Pillar, thanks to changes allowing requirements, and a 13-month in the industry, however, continue to siblings to be included in an application. citizenship timeline is the best possible prevent Bulgaria from climbing up the Some level of uncertainty was recorded outcome for applicants. Malta’s certainty table. Fellow EU member state Austria this year, primarily due to the of product continues to falter as pressure follows, having done little to de-mystify introduction of two new investment from the EC shows no sign of letting up. its procedures for applicants and being options, the full workings of which Placing eighth, Montenegro’s overall both the slowest and most expensive require greater clarity. score is three points lower than last year programme in the CBI industry. In third place, Grenada continues to — putting it on par with Turkey in the Finishing above Cambodia for the first offer investors an efficient application 2021 CBI Index. Despite a respectable time since 2018, Jordan’s overall score process, takes a thorough approach to result underpinned by no residence increases by five points, primarily due to vetting and ensures wide family requirements and a speedy processing its CBI Programme’s growing popularity eligibility. Closing some of the gap time, investor interest in Montenegro’s and reductions in threshold amounts between itself and Grenada, St Lucia is Programme remains low, resulting in it across investment options. As Jordan the only nation whose Standard of Living being slated for cancellation at the end refines its offering, it would do well to score is displayed as one point higher in of 2021. uphold higher due diligence standards, this year’s CBI Index, as the impact of Even with this year’s addition of including mandating the use of external the pandemic was offset by increases in Egypt, Turkey remains the best- firms to perform on-the-ground checks GNI and relative safety. performing CBI programme in the and ensuring the authentication of Finishing below St Lucia for the third Middle East and North Africa owing to applicants’ source of funds. year, Antigua and Barbuda maintains its its undeniable popularity with investors, In last place for 2021 is Cambodia. percentage score of 77, despite efforts to higher standard of living, and access to The country’s visa-free and visa-on- become more family friendly. Greater more than double the number of arrival offering leaves much to be application volumes, a re-think of its destinations and five times more desired, and it offers the lowest standard five-day residence requirement and an business hubs than Egypt and Jordan. of living of all 14 programmes assessed. improved citizenship timeline would As Turkey’s popularity increases, it is If Cambodia wishes to raise its profile in help Antigua and Barbuda increase its essential that the Programme’s lacklustre the industry, significant strides must be score in future editions of the CBI Index. due diligence procedures be overhauled. made with respect to improving In sixth place, Vanuatu finishes as the Newcomer Egypt enters the running transparency and simplifying processes best scoring CBI programme outside of one point above Bulgaria. Egypt for applicants.

PWMNET.COM 25 CORPORATE STATEMENT NINE PILLARS

OVERALL RESULTS The nine pillars of 89% 1. Dominica 1 2 3 4

89% FREEDOM OF STANDARD MINIMUM MANDATORY MOVEMENT OF LIVING INVESTMENT TRAVEL OR 1. St Kitts & Nevis OUTLAY RESIDENCE 86% 3. Grenada

82% 4. St Lucia AUSTRIA, AUSTRIA DOMINICA, DOMINICA, MALTA ST LUCIA GRENADA, JORDAN, ST 77% These two countries Austria receives a US$100,000 KITTS AND 5. Antigua & Barbuda are members of the EU perfect score in life FOR A SINGLE NEVIS, ST LUCIA and of the Schengen expectancy, safety, APPLICANT Area, providing citizens gross national income Dominica and St Lucia No travel or residence 73% with both extensive and freedom continue to provide the requirements 6. Vanuatu settlement rights and most affordable option travel opportunities for citizenship 65% 7. Malta TWO TRIPS 61% REAL GDP Although Bulgaria’s GROWTH residence requirement 8. Montenegro Owing to the effect of does not equate to BIGGEST MOVER Covid-19, Egypt and LARGE FEE physical presence, Dominica and Vanuatu Turkey are the only COMPONENTS applicants must travel 61% saw the greatest countries with a positive Antigua and Barbuda to Bulgaria twice before 8. Turkey increase in visa-free and real gross domestic levies a fee of citizenship is granted. visa-on-arrival offerings product growth rate out US$30,000 under all Malta also requires since 2020 of all countries assessed investment options. applicants to make at 55% Both Malta and least two trips 10. Egypt Montenegro also implement a fee of €15,000 — Malta 54% for due diligence 11. Bulgaria and Montenegro for POSITIVE processing MOVER 52% AT LEAST 12 St Lucia is the only MONTHS 12. Austria country whose Standard of Living score is Before applying for displayed as one point citizenship of Malta, 51% higher than last year applicants must have 13. Jordan resided in the country MOST for either 36 months or, IMPROVED in exchange for a higher 49% Bulgaria, followed investment amount, at 14. Cambodia by Jordan least 12 months

26 AUGUST/SEPTEMBER 2021 the 2021 CBI Index

5 6 7 8 9

CITIZENSHIP EASE OF DUE FAMILY CERTAINTY OF TIMELINE PROCESSING DILIGENCE PRODUCT

ST KITTS AND CARIBBEAN, DOMINICA, ANTIGUA AND DOMINICA NEVIS VANUATU GRENADA, BARBUDA, MALTA, ST KITTS DOMINICA, St Kitts and Nevis AND NEVIS GRENADA, ST is the only country KITTS AND with a guaranteed NEVIS fast-track process, the 60-day Accelerated TEST Application Process Cambodia remains the LONGEST CBI only programme that PROGRAMME implements mandatory BANNED St Kitts and Nevis, language and history or NATIONALITIES since 1984 culture exams In the Caribbean, Cambodia, Malta, Montenegro and SIBLINGS Vanuatu, certain All Caribbean DOMINICA, nationalities are citizenship by investment nations now GRENADA, excluded from applying allow siblings to be JORDAN, INTERVIEW, as a result of due CALLS TO END included in an MONTENEGRO, MINIMUM diligence concerns European nations are application, subject to BUSINESS often subject to ST LUCIA, meeting specified EXPERIENCE pressure to close their VANUATU requirements Austria provides the programmes by the Continuing its trend only programme where European Commission, towards improving applicants must both sit although Austria has processing times, a mandatory interview been exempt from such calls Grenada is adhering to and demonstrate a a citizenship timeline of minimum level of 60 business days business experience POLICE CERTIFICATE DELAY REQUIREMENTS In Egypt, spouses of the main applicant can only Police certificates are obtain citizenship two key to understanding CAPS years after the main a person’s criminal Jordan, Malta and SLOWEST applicant. In Bulgaria, DEDICATED background, and Montenegro all Austria, followed by all eligible family ENTITY Bulgaria should be requested members obtain impose caps on The Caribbean, Egypt, from more than one citizenship after the application numbers, Malta and Vanuatu jurisdiction, including main applicant and Montenegro’s are the only nations that of citizenship Programme will be with a dedicated and residence coming to an end on 31 processing body where different December 2021

PWMNET.COM 27 Programme profiles

PROGRAMMES The final option — introduced in nation or to one of its embassies or October 2018, but modified significantly consulates. A closer look at the 14 citizenship by in May 2020 — applies to families of at Changes to the Programme in late investment programmes that make up least six persons who invest US$150,000 2020 made Antigua and Barbuda one of the 2021 CBI Index into the University of the West Indies the most family friendly jurisdictions in the Fund (UWIF). In addition to receiving Caribbean, allowing many family citizenship, one member of the family will members, including unmarried siblings of THE ANTIGUA AND BARBUDA also be entitled to a one-year, tuition-only any age, to join the main applicant’s CITIZENSHIP BY INVESTMENT scholarship. journey to second citizenship. PROGRAMME Government fees apply for three of the Antigua and Barbuda accepts dual The Antigua and Barbuda Citizenship by four options and due diligence fees apply nationality. Investment (CBI) Programme was to all. Government fees of US$30,000 established by the Antigua and Barbuda apply for any family of up to four persons, CITIZENSHIP BY INVESTMENT Citizenship by Investment Act, 2013. and increase by US$15,000 with each IN AUSTRIA Antigua and Barbuda offers four additional person included in an The particulars of Austria’s CBI investment options for successful application. The only exception to this procedures are not clearly codified in the applicants. rule is the UWIF option, where no nation’s laws. Rather, the scheme draws The first allows single applicants or government fee is due for families of six broad legitimacy from Article 10(6) of the families of up to four persons to make a persons. In all cases, 10 per cent of the 1985 Nationality Act, which gives leave to minimum contribution of US$100,000 to government fees are due upon submission the federal government to grant the National Development Fund, a not- of the application and are deemed non- citizenship where a person displays actual for-profit organisation created to run both refundable. or expected outstanding achievements. public and private projects, as well as In 2021, application processing by the The federal government may, by an charitable initiatives, such as improving CBI Unit, the government body order, lay down specific stipulations access to healthcare and education. This responsible for reviewing all applications regarding the grant of nationality under contribution threshold was proposed under the Programme, remains relatively Article 10(6). Its failure to fully do so has under a limited-time offer that was slow. Due diligence procedures in Antigua made the Austrian scheme one of the indefinitely extended in October 2019. and Barbuda are generally strict, and all least transparent processes in the The second option, the minimum economic citizens hold e-passports. economic citizenship arena. threshold for which was introduced in Several nationalities are excluded outright The outstanding achievement March 2020, requires the applicant to from the application process. underlined in Austria’s laws can be make an investment of at least There is no mandated interview or economic and can cover those whose US$200,000 into a government- knowledge-based test, but Antigua and investments in Austria are sufficient to approved real estate project for a period Barbuda requires applicants to travel to trigger the provision. of five years. Additionally, an applicant the nation, or to an embassy or consulate, Exclusive and limited to those who can with no more than three additional family to sign an oath of allegiance. Furthermore, guarantee a positive attitude towards members may make a joint investment once awarded, citizenship is conditional Austria, and who do not pose a danger to with a ‘related party,’ with both the on the applicant spending five days on law and order, public safety or other applicant and the related party making a Antiguan or Barbudan soil within five public interests, the scheme has operated minimum investment of US$200,000 years of obtaining citizenship. This intermittently and only rarely are aspiring each. A related party is one with the same requirement is waived for children until applicants successful. Indeed, between Licenced Agent as the applicant. after they reach the age of majority at 18. 1985 and 2020, only 1436 persons were The third option entails an investment Due to Covid-19 travel restrictions, naturalised under Article 10(6). of US$1.5m into an eligible government- Antigua and Barbuda’s residence The scheme is also mindful of Austria’s approved business project. Applicants requirement was suspended until summer — and the applicant’s — associations with can apply as joint investors so long as 2021. The CBI Unit has, in the interim, other states, barring persons whose each applicant makes a minimum been allowing economic citizens to take relations with foreign states would be investment of US$400,000 into a project the oath of allegiance virtually, if satisfied detrimental to Austria, or who, upon worth at least US$5m. that travel restrictions prevent travel to the becoming Austrian nationals, would

28 AUGUST/SEPTEMBER 2021 PROGRAMME PROFILES CORPORATE STATEMENT

damage the country’s international relations. A person is also barred if they hold certain criminal convictions, immigration orders or affiliations with extremism. The two-year process involves filing the application in person (unless the applicant is incompetent to act) and significant communication with various government representatives. Article 10(a) (2) exempts prospective economic physical residence in the nation is not Bulgaria is home to The BGIIP is only available to non-EU citizens from having to demonstrate compulsory. diverse terrain, from nationals who must make two formal trips the Black Sea coast sufficient knowledge of the German After amendments passed in February to its mountainous to Bulgaria: once to file for permanent language and basic knowledge of 2021 (and now in force), there are several interiors residence, and once to register permanent Austria’s history and democratic system. investment options under the BGIIP. residence and receive the relevant identity An applicant who lives outside of Austria Applicants can invest €1,024,000 in documents, at which point biometrics are must, however, travel to the relevant stocks traded in Bulgaria; €512,000 in also taken. Permanent residence can be Austrian diplomatic or consular authority undertakings for collective investment in obtained within six to nine months of to give the oath of allegiance (with some transferable securities; €512,000 in submission; citizenship rests on the option exceptions for those who cannot alternative investment funds (partly selected by the applicant, but can be reasonably be expected to appear to focused on Bulgaria); €1,024,000 in a expected within 18 to 24 months under the deliver the oath). Bulgarian company carrying on a Certified fast-track option. Although Austria generally disallows Priority Investment Project; participate in Family members are unable to apply dual nationality, Article 10(6) specifies that and invest €257,000 in a Bulgarian with the main applicant. Instead, they can applicants are permitted to retain their company employing 10 or more Bulgarian apply for citizenship only after the main original citizenship, bringing the scheme in nationals; participate in and invest applicant has naturalised. line with those of other jurisdictions €3,075,000 in a Bulgarian private In 2019, in response to concerns offering economic citizenship. Benefits of company; or invest in a Certified regarding due diligence, Bulgaria began Austrian citizenship include the right to Investment Project, with the investment to demand criminal records from both an live and work in any country in the amount depending on the project in applicant’s home country and country of European Economic Area (EEA) and question. These investments and permanent residence. Further concerns , as well as facilitated travel to thresholds allow an applicant to obtain led to various announcements that the US and . citizenship after five years. However, Bulgaria would end the BGIIP, yet such applicants can fast-track their route to claims were put to bed with the 2021 THE BULGARIAN IMMIGRANT citizenship after one year by raising their amendments. INVESTOR PROGRAMME investment. The benefits of Bulgarian citizenship The Bulgarian Immigrant Investor Applications under the BGIIP are first include free movement rights throughout Programme (BGIIP) was created in 2009 submitted to a local Bulgarian consulate, all EU member states. Starting 1 and finds its legal basis in Article 25(1) of which redirects them to the Ministry of December 2017, citizens of Bulgaria were the Foreigners in the Republic of Bulgaria Foreign Affairs and issues a first-stage visa granted the right to visa-free travel to Act and Article 14a of the Citizenship Act. for the applicant to enter Bulgaria and file Canada for up to six months, provided Designed as a quick route to citizenship for permanent residence. Thereafter, they obtain an Electronic Travel via a period of nominal permanent processing is conducted by the Ministry of Authorisation. Bulgaria has yet to join the residence in Bulgaria, the BGIIP does not Foreign Affairs. These entities do not test Schengen Area, although it is taking steps require the investor to physically spend applicants on their knowledge of the towards membership. Persons wishing to time in Bulgaria while waiting for Bulgarian language or local culture, and obtain citizenship of Bulgaria must usually citizenship to be issued. This makes the applicants need not sit a mandatory renounce any other nationality they hold; BGIIP one of a handful of European interview during the residence or however, exceptions exist for native citizenship programmes where prior citizenship application stages. Bulgarians, citizens of the EU, EEA and

PWMNET.COM 29 Switzerland, along with spouses of behaviour, police and health certificates, The Caribbean may purchase real estate in the country — Bulgarian citizens and, under Article 14a of as well as to sign the relevant citizenship island of Dominica a privilege exclusive to Cambodians. offers sun, sea, sand the Citizenship Act, economic citizens. oath. Applicants who choose the and some truly investment option must register a breathtaking views THE DOMINICA CITIZENSHIP CITIZENSHIP BY INVESTMENT residence in Cambodia at the time of the BY INVESTMENT PROGRAMME IN CAMBODIA application, although they need not live Dominica’s CBI Programme was launched As early as 1996, provisions were made in there. This requirement is waived for in 1993, and is known for being one of the Cambodia’s Law on Nationality to allow applicants who choose to donate. world’s most efficient and transparent foreigners to naturalise following an Applications are reviewed by the options for economic citizenship. It plays a investment in the country. These were Ministry of the Interior, although major role in promoting social and further outlined, in their most recent citizenship may only be granted by the environmental causes, particularly form, by Sub-decree 287 of 2013. On 11 King by royal decree. The entire process sustainable development. June 2018, the Cambodian senate can take between three and six months to The Programme was reshaped by the approved a draft law aimed at modifying complete, with some evidence that Commonwealth of Dominica Citizenship Cambodia’s economic citizenship speedier processing may be possible. In by Investment Regulations, 2014, to landscape and, in particular, raising 2013, it was reported by the Cambodian include diverse investment options and investment thresholds. The draft law, Ministry of Interior that 700 foreign even stricter regulation processes. however, has yet to reach the final stages nationals had applied for Cambodian Changes to the Programme in 2020 of approval. citizenship since 2000. modified investment thresholds and fees, Cambodia, therefore, continues to Citizenship of Cambodia brings visa- and significantly expanded the scope of afford economic citizenship to persons free travel rights to more than 50 eligible dependants and post-citizenship who invest 1.25bn riels into the nation. countries and territories, the majority of additions. The investment must be approved either which are located in southeast Asia. As a The Programme offers two investment by the Cambodian Development member of the Association of Southeast opportunities: a one-time contribution to Council or by the royal government. Asian Nations, Cambodia affords the government, commonly known as the Citizenship is also available to those who opportunities for facilitated trade and Economic Diversification Fund (EDF) donate 1bn riels for the restoration and greater mobility among member states option, or an investment in government- rebuilding of Cambodia’s economy. for certain professionals. For those approved real estate. Funds transferred to Knowledge of Khmer history and wishing to retain their citizenship of birth, the EDF have been instrumental in language is required, and applicants must Cambodia allows dual citizenship. Finally, Dominica’s national development, travel to Cambodia to obtain good as Khmer citizens, successful applicants particularly through the reconstruction of

30 AUGUST/SEPTEMBER 2021 PROGRAMME PROFILES CORPORATE STATEMENT

key infrastructure, sustainable housing CITIZENSHIP BY INVESTMENT and the agricultural sector. IN EGYPT The EDF option requires a In 2019, Egypt passed Parliament Law No. contribution of US$100,000 for a single 190, which detailed conditions for the grant It should be noted applicant — a value that increases as of citizenship to foreign nationals in family members are added to an exchange for investments or donations that spouses will application. The real estate option without the need to undergo a period of not obtain requires an investment of at least residence. The law was published in March US$200,000, to which a single applicant 2020, giving the go-ahead for Egypt’s first citizenship of must add a US$25,000 real estate CBI Programme. government fee. The real estate must be There are four routes to citizenship Egypt until two held for a period of three years, which under the Programme. First, the purchase increases to five years if the future of one or more government-owned years after the purchaser is also an applicant for CBI. properties or government-owned land, main applicant Other applicable fees include due for at least US$500,000, to be held for a diligence, minor processing and period of five years. Second, the becomes a citizen Certificate of Naturalisation fees. acquisition of a minimum 40 per cent The CBI Unit is the government stake in either a new or previously authority tasked with managing and established Egyptian company, in which not take part in a formal interview, nor processing applications for economic the total invested capital must be a undergo mandatory testing, but they citizenship. To qualify for Dominica’s CBI minimum of US$400,000. Third, a bank must make one visit to Egypt to obtain a Programme, applicants must have a clean deposit of either US$750,000 to be National ID Card before the grant of criminal record and prove they are of returned after five years or US$1m to be citizenship. Biometrics are taken as part of good character through a series of returned after three years — both at zero this process. extensive due diligence checks, including per cent interest. Finally, a non- Main applicants may also include regarding source of funds. refundable contribution of US$250,000 certain family members in an application By regulation, the Unit must respond to the CBI Unit account at the Central for citizenship. Any official spouse of the to an application within three months of Bank of Egypt. Applicants need not make main applicant, for example, can be its submission, helping it maintain one of the contribution or investment until after included in an application. However, it the fastest processing times in the CBI their application has been approved. should be noted that such spouses will industry. A CBI Unit has been set up within the not obtain citizenship of Egypt until two The application process in Dominica is office of the prime minister to oversee the years after the main applicant becomes a straightforward, with no interview, travel application process. As part of their citizen. The main applicant can also or residence requirements, either before application, applicants are required to pay include unmarried children below the age or after the citizenship process. a non-refundable US$10,000 of 21 in an application for citizenship, but Applicants need not learn English, nor government fee and submit several unlike spouses, children receive Egyptian show a minimum level of education or documents, including clean criminal citizenship at the same time as the main business experience. records from an applicant’s country of applicant. Benefits of citizenship of Dominica citizenship and residence, and documents Other benefits of Egyptian citizenship include visa-free travel to more than 140 evidencing employment or company include eligibility to apply for an E-2 visa foreign destinations, dual citizenship and ownership. to the US and the ability to retain dual the opportunity to experience an eco- Due diligence is performed by the citizenship. friendly lifestyle in a lush environment. General Intelligence Service, the Military There is no cap or expiry date on Several family members can join the main Intelligence and Reconnaissance Egypt’s CBI Programme. applicant and become citizens Administration, and the Financial themselves, including, as of summer Regulatory Authority. There are no THE GRENADA CITIZENSHIP BY 2020, siblings of the main applicant or banned nationalities under Egypt’s CBI INVESTMENT PROGRAMME their spouse up to the age of 25, subject Programme. Created in 2013 by the Grenada to conditions. As part of the process, applicants need Citizenship by Investment Act, Grenada’s

PWMNET.COM 31 CBI Programme supports the nation’s approved tourism developments to which if less desirable, for persons to obtain renewable and sustainable development the developer has already committed 20 citizenship under Article 5, although such initiatives, and stimulates foreign per cent of the total expected cost. All persons must relinquish all other investment to promote tourism, applicants who purchase real estate nationalities. No more than 500 persons construction, agriculture and under the CBI Programme must hold it are accepted for economic citizenship manufacturing. The Grenada CBI for five years. per year. Programme has gained recognition and Any application lodged by up to four Applicants have five investment trust thanks to its due diligence processes. family members requires payment of an options, the thresholds and hold periods The Grenada CBI Programme offers additional US$50,000 government fee for which were reduced in a cabinet applicants two investment options. The where the real estate option is selected. decision made in December 2019. First, first option is a contribution to the Additional moneys are required, however, applicants can decide to invest National Transformation Fund (NTF) — when parents or grandparents under the US$750,000 in Jordanian small and a government institution responsible for age of 55 and siblings are included in an medium-sized enterprises, and must hold locating and financing alternative, application. Applicants under either that investment for a period of at least economy-stimulating investments for the option are responsible for paying three years. Second, they can deposit country. A single applicant must make a associated application, processing and US$1m in a non-interest-bearing account US$150,000 minimum donation to the due diligence fees. at the Central Bank of Jordan for a period NTF — an amount that increases as Despite delays in 2018, the speed of of at least three years. Third, they can family members are added to an application review has improved invest in treasury bonds worth US$1m, to application. significantly over the past three years, be held for at least six years at an interest The second option is an investment in with the country now approving rate determined by the Central Bank of a government-approved real estate successful applications in 60 business Jordan. Fourth, they can purchase project, which itself presents two choices. days. Grenada does not require securities from an active investment Applicants can invest US$350,000 in any applicants to sit an interview, demonstrate portfolio priced at US$1m. Fifth, they can pre-approved project. Alternatively, they business experience or proficiency in the invest US$1.5m in any project across the can jointly invest US$220,000 in pre- English language, or fulfil travel or country (or US$1m in projects that are residence requirements. located in governorates outside of Grenadian citizenship can benefit Amman) that create a minimum of 20 successful applicants by providing them local jobs and that remain active for no with options for global mobility, including less than three years. to China, with which Grenada has an Applications for citizenship are lodged extradition treaty formalised in October with the Jordan Investment Commission, Successful 2018. Grenadian citizens are eligible to an entity established in 2014 to succeed apply for a renewable E-2 visa for the US. the Jordan Investment Board, which was applications in Dual nationality is allowed. first founded in 1995. Its role is to promote investment in Jordan and respond to Jordan must be CITIZENSHIP BY INVESTMENT emerging trends in the international and IN JORDAN domestic economic environment. approved by the Jordan announced the commencement Successful applications must be approved Council of of its economic citizenship programme in by the Council of Ministers and the February 2018, finding legal basis in the monarch, in a process that takes around Ministers and the provisions of the Jordanian Nationality three months. Law, 1954 (No. 6 of 1954). Article 13(2) Naturalised Jordanians are barred from monarch, in a removes the residence requirement for political or diplomatic positions, from any process that takes persons whose naturalisation is in the public office prescribed by the Council of public interest or who are ‘Arab’ — that is, Ministers, and from becoming members around three persons whose father was of Arab origin of the state council for a period of ten and who are nationals of a member of the years from the grant of citizenship. They months. League of Arab States. It is also possible, are also excluded from participation in

32 AUGUST/SEPTEMBER 2021 PROGRAMME PROFILES CORPORATE STATEMENT

municipal or village councils for a period Persons wishing to apply for citizenship Maltese architecture €16,000 per annum. In both instances, of five years from obtaining citizenship. under the Regulations must first draws from its they must hold the real estate for a succession of Loss of citizenship for naturalised complete a residence requirement of different rulers over period of five years from the date of issue persons is considered if a person commits either 36 months or, for a higher the centuries, from of the Certificate of Naturalisation. the romans to the or attempts to commit an act to endanger investment amount, 12 months. During French and British Furthermore, the property must be Jordan’s peace and security, or if a person the residence period, applicants apply for adequate and suitable for main is found to have misrepresented evidence an eligibility assessment and, if successful, applicants and any dependants to live in. during the naturalisation process. may apply for citizenship upon Finally, applicants must make a Revocation of citizenship is also possible completion of the residence requirement. €10,000 donation to a registered in certain instances where a person enters Under Malta’s offering, therefore, philanthropic, cultural, sport, scientific, foreign military or civil service, or the citizenship is at best a 13-month animal welfare, or artistic non- service of an enemy state. endeavour. During this time, applicants governmental organisation or society, or are expected to live in Malta and build as otherwise approved by the MALTA’S GRANTING OF ‘connecting factors’ to the country. Community Malta Agency. CITIZENSHIP FOR All applicants under the Regulations As well as completing the three-part EXCEPTIONAL SERVICES must complete three forms of investment, applicants must also pay REGULATIONS investment. hefty due diligence and administrative Following the discontinuation of the First, they must make either a fees. Individual Investor Programme in €600,000 or a €750,000 exceptional Maltese citizenship brings several September 2020, Malta’s new citizenship direct investment, depending on the benefits, including the ability to retain by investment offering is moulded in its length of their stay in Malta. €10,000 of dual nationality, which was allowed in current form by the Granting of this must be remitted as a non- 2000. Successful applicants under the Citizenship for Exceptional Services refundable deposit upon submission of policy can expect their names to be Regulations, 2020. Malta’s new offering is the initial residence application. published in Malta’s Gazette, and to be subject to a cap of 400 Certificates of Second, they must either purchase real identified as recipients of Maltese Naturalisation per annum and 1500 in estate in Malta, valued at €700,000 or citizenship within 12 months of obtaining total, excluding dependants. more, or rent property at a cost of at least their citizenship.

PWMNET.COM 33 THE MONTENEGRO a €100,000 donation to be used by the Federation of St Kitts and Nevis has a CITIZENSHIP BY INVESTMENT government to assist underdeveloped more than 35-year history of leading the PROGRAMME communities in Montenegro. field of economic citizenship. Indeed, its Montenegro’s CBI Programme was In addition to the required investment, CBI Programme has earned multiple launched on the basis of the Decision on hefty processing fees apply, starting at awards and a reputation as the ‘platinum criteria, method and procedure for €15,000 for a single applicant. Due standard’ of CBI. selection of persons who may acquire diligence fees also apply, reflecting the To qualify for economic citizenship, Montenegrin citizenship by admission fact that due diligence is performed applicants now have four investment for the purpose of implementation of both by agents and third-party due options to choose from, following the special investment programme of diligence firms. introduction of two new investment particular importance for the business In December 2019, an important options in March 2021. Due diligence and economic interest of Montenegro. change to Montenegro’s Programme was fees apply under all options, as do minor The Decision was adopted on 22 implemented after issues surfaced with processing and Certificate of November 2018, and entered into effect respect to dependants. Article 12 of the Registration fees. The country’s first- on 1 January 2019 before the country Montenegrin Citizenship Act makes ever option for economic citizenship — a began accepting applications under its provision for ‘a person over 18 years of donation to the Sugar Industry CBI Programme in October 2019. age’ to obtain Montenegrin citizenship to Diversification Foundation — remains in The Programme is limited both by the benefit of the state, thereby existence in relevant regulations, but has, application volume and time, being precluding minor dependants obtaining in practice, been superseded by the capped at 2000 applications and slated to economic citizenship. To rectify this, the Sustainable Growth Fund (SGF). run until 31 December 2021. In March government issued a decree specifying The SGF is a permanent feature of 2021, the Montenegrin government that dependants may be included in a CBI the Programme that was established in announced that the Montenegro CBI application. As a result, Montenegro March 2018. The SGF substituted the Programme would not be extended past permits the inclusion of a spouse, minor temporary Hurricane Relief Fund its expiration date. children and adult children who are (HRF), whose establishment in 2017 Despite a promising start, issuing its dependent on the main applicant. resulted in elevated application first application approval in February 2020 Under the Programme, applicants need numbers. Under the SGF, a single within three months of submission and not fulfil any mandatory residence applicant must make a minimum entering the market with one of the world’s requirements before or after the grant of donation of US$150,000. This option is fastest application processing times, citizenship. However, applicants must also attractive for families, and, under a Montenegro failed to secure investor travel to Montenegro to receive their final limited-time offer set to expire on 31 interest. As of March 2021, it had issued decision and supply biometrics. December 2021, families of up to four only 37 approvals. Montenegro is an attractive destination persons (excluding siblings) can obtain The investment structure in for second citizenship, with one of the citizenship under the SGF for the same Montenegro consists of two tiers, with fastest growing economies in the Balkans cost as a single applicant. applicants being required to make a non- and the prospect of becoming an EU The second option is an investment in refundable donation and choose between member state in 2025. Montenegro is also pre-authorised real estate, of which two real estate options. Under the first party to an E-2 visa treaty with the US, there are two branches. Under the first option, applicants must invest €250,000 allowing Montenegrin citizens to obtain branch, the applicant must buy property in government-approved development E-2 visas to work in the US. worth at least US$400,000 and keep it projects in tourism, agriculture or Successful applicants are exempt from for five years. Under the second branch, processing, located in northern and Montenegro’s restrictions on dual the applicant must make a joint central Montenegro. Under the second nationality. investment with another applicant, with option, applicants must invest €450,000 each investment worth at least in government-approved development THE ST KITTS AND NEVIS US$200,000. The joint investment must projects in any of the same three CITIZENSHIP BY INVESTMENT be retained for a period of seven years. industries, located in Podgorica or along PROGRAMME Under the third option, which is only the coastline. Regardless of the real estate Home to the world’s most longstanding available until 1 November 2022, option chosen, applicants must also make economic citizenship programme, the applicants can purchase a private home

34 AUGUST/SEPTEMBER 2021 PROGRAMME PROFILES CORPORATE STATEMENT

worth at least US$400,000 (not under the Alternative Investment St Lucia is well THE ST LUCIA CITIZENSHIP BY including the value of the land on which Option. known for its abundance of INVESTMENT PROGRAMME the home sits). Limitations exist with The CBI Unit, which processes all CBI nature, from its Inaugurated in January 2016, St Lucia’s respect to the type of property that can applications, normally issues approvals mountains and CBI Programme is the Caribbean’s be used under this option, as the private or denials within three months. The live volcano to its beaches and newest economic citizenship programme. home must be sold as a single unit and Accelerated Application Process, hiking trails The Programme has four investment not divided into apartments or available at a premium fee, allows options. The fastest option is a condominiums. Property purchased successful applicants to receive contribution to St Lucia’s National under this option cannot be re-used in a citizenship within 60 days of applying. Economic Fund (NEF). subsequent application for CBI and is Currently, St Kitts and Nevis is the only Moneys deposited into the NEF are subject to a hold period of five years. CBI nation to offer a secure, guaranteed intended for progressive local Finally, the ‘Alternative Investment fast-track route. There is no interview, development projects selected by the Option’ allows applicants to invest either language, education or business Minister of Finance with the approval of in an approved infrastructural project or requirement applicable to any of the parliament. Originally set at a other approved development project. options chosen. Travel to the twin- US$200,000 contribution, the The cost of the investment varies islands is not obligatory, and no government reduced the minimum according to whether St Kitts and Nevis minimum residence stays apply either threshold to US$100,000 inJanuary 2017. owns the project at the end of the prior to or after citizenship is obtained. The second option under the agreement, in which case the minimum Due diligence procedures remain Programme asks applicants to make a investment amount is US$175,000, or among the industry’s most robust and minimum investment of US$300,000 whether the project is privately owned, are expected to be further strengthened into a government-approved real estate in which case the minimum investment by upcoming processes focusing on project. To date, the government has amount is US$200,000. fingerprinting and biometrics. designated two real estate projects for A US$35,000 government fee is Benefits of citizenship of St Kitts and selection under this option, which, upon applicable for single applicants under Nevis include visa-free travel to a purchase, must be held for a period of the pre-approved real estate and private growing number of worldwide five years. home options, while a government fee destinations — the highest of any CBI Applicants may also acquire of US$50,000 applies for single country in the Caribbean. Citizens are government bonds. A limited-time offer, applicants and families of up to four allowed to hold multiple nationalities. in place until 31 December 2021, allows a

PWMNET.COM 35 single applicant (or a main applicant with lifestyle and global access to more than acknowledged by the Ministry of Family, up to four dependants) to purchase 145 countries and territories. St Lucia has Labour, and Social Security. Applicants bonds worth US$200,000 to be held for no restrictions on holding dual nationality. who purchase property may not re-sell between five to seven years, depending Despite these benefits, there remain that property to someone for use in a on the family structure. There are also concerns linked to calls for past future CBI application. opportunities for an applicant to purchase amendments to the Programme “to be Application processing remains steady bonds worth more, but with reduced repealed” and for a “policy decision” on despite record application numbers, hold-period constraints. Outside the whether the country should retain the taking between three to six months on limited-time offer, single applicants are Programme. average. There is no requirement for required to purchase bonds worth at least applicants to learn Turkish or to attend a US$500,000 and to hold them for five CITIZENSHIP BY INVESTMENT mandatory interview. There is also no years. Qualifying government bonds IN TURKEY requirement to establish residence by cannot return a rate of interest. Turkey’s economic citizenship physical presence. However, the applicant Under the Programme’s final option, programme was launched in January will need to obtain an investor residence applicants can make a minimum 2017. It finds its basis in Turkey’s card and provide biometrics. investment of US$3.5m into a Citizenship Law, Act No. 5901 and in There are no restrictions on an government-approved enterprise project. Regulation 2016/9601, passed by the applicant’s country of origin, making the Projects, which may be initiated by council of ministers on 12 December Turkish CBI route a popular option for applicants themselves, can range from the 2016. Article 12 of the Act specifies that a those who are banned from partaking in building of a port to the establishment of a person may obtain Turkish citizenship for the programmes of other nations. university, and must result in the creation of “outstanding service in the social or While the ultimate decision on the at least three permanent jobs. Applicants economic arena”, provided this creates no grant of economic citizenship originally may partner with others to launch a joint obstacle to “national security and public rested with the council of ministers, venture, so long as a total minimum order.” Regulation 2016/9601 was following the 2018 amendments it is now investment of US$6m is made, with each amended by Regulation 2018/30540 and in the hands of Turkey’s president. investor contributing no less than US$1m. Presidential Decree 106, made on 18 Turkey allows dual nationality and is At least six permanent jobs must be September 2018 and gazetted a day later. considered a moderate country within generated as a result of the joint venture. It was further amended by Regulation the context of the Middle East. Despite Due diligence fees are always levied. 2018/418, made in December 2018. various attempts at obtaining visa-free Processing fees apply under all options, Applicants interested in obtaining travel to the Schengen Area, including except for investments in real estate and citizenship of Turkey may do so by by the making of an agreement with the government bonds limited-time offer, choosing one of five routes. The first the EU on the flow of refugees, Turkish while administration fees apply only to the three each entail retention of the nationals must obtain visas to enter the real estate, government bonds and investment for a period of three years. Schengen member states. They must enterprise project options. The latter start They are purchasing property valued at also apply for visas to Canada and at US$30,000 for real estate investors, US$250,000, depositing US$500,000 in the US. and at US$50,000 for single applicants a Turkish bank, or investing US$500,000 choosing the government bond or in government bonds. The applicant THE VANUATU DEVELOPMENT enterprise project routes. must ensure recognition of the SUPPORT PROGRAMME Applications are processed by the CBI investment by either the Ministry of Vanuatu currently has two concurrent Unit and are usually returned with an Environment and Urbanisation, the CBI programmes: the Development approval or denial within three months of Council of Bank Audit and Regulation, or Support Programme (DSP) and the submission. There is no need for the Ministry of Treasury and Finance, Vanuatu Contribution Programme applicants to learn English, or to prove depending on the chosen investment. (VCP). In April 2021, the Vanuatu any business skills or education. The remaining two routes to citizenship government also approved a bill that Applicants need not attend an interview, are an investment of US$500,000 in fixed would instate a third programme, the reside in St Lucia, nor travel to the island. capital, to be acknowledged by the Real Estate Option Programme. Citizenship of St Lucia offers a viable Ministry of Industry and Technology, or Until 2018, the DSP had been limited alternative for anyone seeking a relaxing the creation of 50 jobs in Turkey, to be in scope, offering honorary citizenship.

36 AUGUST/SEPTEMBER 2021 PROGRAMME PROFILES CORPORATE STATEMENT

This changed with the Citizenship per cent of this value prior to the Port Vila, the capital Citizenship certificates may be received of Vanuatu, has a (Amendment) Act (No. 34 of 2018). application being considered and in the population of just by a designated agent and do not The DSP was further enhanced by the knowledge that this amount would be 45,000 people require additional travelling. Citizenship (Development Support lost should the applicant fail to pass Limitations also exist with respect to Programme) Regulations Order No. 33 scrutiny. Due diligence, application and the applicant’s choice of designated of 2019, which improved the certificate fees apply, with due diligence agent, as applicants cannot decide to programme’s competitiveness, bringing fees having been increased to US$5000 change their representative agent unless applicant costs in line with the VCP per application by the Citizenship their application is progressing at an while also enabling participation by (Development Support Program) unreasonably slow pace (defined as in Ni-Vanuatu designated agents with an (Amendment) Regulations Order No. excess of six months). office registered in Port Vila. 39 of 2020. This amendment also In practice, applicants benefit from The VCP, on the other hand, remains mandated the use of an international the government not imposing a the purview of a single agent and its specialist firm to perform due diligence language test, which could otherwise affiliated exclusive marketing agent, checks. Despite this new requirement, it require mastering any of Vanuatu’s three based in Hong Kong. There has been seems Vanuatu currently only makes use official languages (English, French, and some indication, however, that Vanuatu’s of third-party firms to conduct desktop Bislama) or a vernacular of Vanuatu. new administration is looking to reform checks, rather than comprehensive Applicants also need not sit an the current structure as, in May 2020, on-the-ground due diligence. interview, nor study the culture or the sole agent for the VCP was issued Applications are processed rapidly, history of the island. with a three-month notice for the although slowdowns are sometimes There is a close rapport between termination of its contract with Vanuatu. recorded as a result of the oath of Vanuatu and China, something that Applications under the DSP are allegiance procedure having to be made headlines in June 2019 when processed by the Citizenship Office and completed in the physical presence of a certain Chinese-born DSP citizens were Commission, an entity established under Commissioner for Oaths located in repatriated — allegedly without due the Vanuatu Citizenship Act. Vanuatu, Dubai, Hong Kong or process. Despite this, citizens of The minimum sale price for a single Singapore. With the onset of Covid-19, Vanuatu cannot access China visa-free. applicant under the DSP is US$130,000, however, temporary provision was made They can, however, travel without a visa of which the government retains for applicants to take the oath of to Hong Kong, Russia, the Schengen US$80,000. Applicants must commit 25 allegiance via video conference link. Area and the UK.

PWMNET.COM 37 CORPORATE STATEMENT DATA

Country snapshots

ANTIGUA AND BARBUDA F.O.M. S.O.L. CAPITAL CITY St John’s M.I.O. M.T.R. POPULATION (2020)* 97,930 C.T. E.P. OFFICIAL LANGUAGE English D.D. F. CURRENCY Eastern Caribbean dollar C.P. 77% 0246810

AUSTRIA F.O.M. S.O.L. CAPITAL CITY Vienna M.I.O. M.T.R. POPULATION (2020)* 8,917,200 C.T. E.P. OFFICIAL LANGUAGE German D.D. F. CURRENCY Euro C.P. 52% 0246810

BULGARIA F.O.M. S.O.L. CAPITAL CITY Sofia M.I.O. M.T.R. POPULATION (2020)* 6,927,290 C.T. E.P. OFFICIAL LANGUAGE Bulgarian D.D. F. CURRENCY Bulgarian lev C.P. 54% 0246810

CAMBODIA F.O.M. S.O.L. CAPITAL CITY Phnom Penh M.I.O. M.T.R. POPULATION (2020)* 16,718,970 C.T. E.P. OFFICIAL LANGUAGE Khmer D.D. F. CURRENCY Cambodian riel C.P. 49% 0246810

DOMINICA F.O.M. S.O.L. CAPITAL CITY Roseau M.I.O. M.T.R. POPULATION (2020)* 71,990 C.T. E.P. OFFICIAL LANGUAGE English D.D. F. CURRENCY Eastern Caribbean dollar C.P. 89% 0246810

EGYPT F.O.M. S.O.L. CAPITAL CITY Cairo M.I.O. M.T.R. POPULATION (2020)* 102,334,400 C.T. E.P. OFFICIAL LANGUAGE Arabic D.D. F. CURRENCY Egyptian pound C.P. 55% 0246810

GRENADA F.O.M. S.O.L. CAPITAL CITY St George's M.I.O. M.T.R. POPULATION (2020)* 112,520 C.T. E.P. OFFICIAL LANGUAGE English D.D. F. CURRENCY Eastern Caribbean dollar C.P. 86% 0246810

38 AUGUST/SEPTEMBER 2021 * Source: the World Bank Data Bank; last accessed 06/07/2021

JORDAN F.O.M. S.O.L. CAPITAL CITY Amman M.I.O. M.T.R. POPULATION (2020)* 10,203,140 C.T. E.P. OFFICIAL LANGUAGE Arabic D.D. F. CURRENCY Jordanian dinar C.P. 51% 0246810

MALTA F.O.M. S.O.L. CAPITAL CITY Valletta M.I.O. M.T.R. POPULATION (2020)* 525,280 C.T. E.P. OFFICIAL LANGUAGE Maltese, English D.D. F. CURRENCY Euro C.P. 65% 0246810

MONTENEGRO F.O.M. S.O.L. CAPITAL CITY Podgorica M.I.O. M.T.R. POPULATION (2020)* 621,720 C.T. E.P. OFFICIAL LANGUAGE Montenegrin D.D. F. CURRENCY Euro C.P. 61% 0246810

ST KITTS & NEVIS F.O.M. S.O.L. CAPITAL CITY Basseterre M.I.O. M.T.R. POPULATION (2020)* 53,190 C.T. E.P. OFFICIAL LANGUAGE English D.D. F. CURRENCY Eastern Caribbean dollar C.P. 89% 0246810

ST LUCIA F.O.M. S.O.L. CAPITAL CITY Castries M.I.O. M.T.R. POPULATION (2020)* 183,630 C.T. E.P. OFFICIAL LANGUAGE English D.D. F. CURRENCY Eastern Caribbean dollar C.P. 82% 0246810

TURKEY F.O.M. S.O.L. CAPITAL CITY Ankara M.I.O. M.T.R. POPULATION (2020)* 84,339,070 C.T. E.P. OFFICIAL LANGUAGE Turkish D.D. F. CURRENCY Turkish lira C.P. 61% 0246810

VANUATU F.O.M. S.O.L. CAPITAL CITY Port Vila M.I.O. M.T.R. POPULATION (2020)* 307,150 C.T. E.P. OFFICIAL LANGUAGE English, French, Bislama D.D. F. CURRENCY Vanuatu vatu C.P. 73% 0246810

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