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ISSUE 15

SPRING 2018

Inside This Issue Features: Fast Track European Citizenship Not all PEPs are created equal TheD esire for Second Citizenship: Not So Niche? City Focus: London Mumbai

Country Spotlights: Antigua and Barbuda

Ireland

St Kitts & Nevis

Canada

Latvia

Saint Lucia

Cyprus

Luxemburg

UK

The Commonwealth of Dominica

Malta

USA

Grenada

Portugal

www.citizenshipinvestment.org

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Contents Spring 2018 City Focus London .............................................................................................................................................................. 06 Mumbai ............................................................................................................................................................ 08 Features In a time of increased restrictions on immigration, residence and citizenship planning can open doors ........................................................................................ 10 Fast Track European Citizenship under the Bulgarian Investment Immigration Program ..........................................................................................12 The Truth About Bulgarian Citizenship by Investment – An Expert Panel Comments ...............................................................................................................14 Not all PEPs are created equal ............................................................................... 17 The Desire for Second Citizenship: Not So Niche? ...............................................24 Pacesetters: How the Caribbean is Creating Opportunity Out of Adversity......... 26

Country Spotlights Antigua and Barbuda .......................................................................................................................... 28 Canada .............................................................................................................................................................. 34 Cyprus ............................................................................................................................................................... 36 The Commonwealth of Dominica .......................................................................................... 40 Grenada .......................................................................................................................................................... 42 Ireland .............................................................................................................................................................. 44 Latvia .................................................................................................................................................................. 48 Luxemburg ................................................................................................................................................... 50 Malta .................................................................................................................................................................. 55 Portugal ........................................................................................................................................................... 64 Saint Lucia...................................................................................................................................................... 68 St Kitts & Nevis ......................................................................................................................................... 70 UK ......................................................................................................................................................................... 72 USA ..................................................................................................................................................................... 78 Sponsored by

Sponsored by

Editor’s Note: Orsolya Balogh

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elcome to the first edition of Citizenship by Investment 2018 – your resource for citizenship and residency options. After a successful event in Abu Dhabi, we are happy to announce that CBI is being launched in Mumbai, India at the Global Investment Immigration Summit. Throughout this edition, we aim to evaluate the various citizenship and residency options in order to provide you with the most up to date and relevant information available. Further to this, we review the logistical and practical considerations the UHNWI, HNWI and families should be aware of before choosing a citizenship or residency program. We begin this edition with news alerts on the latest updates to citizenship and residency permits around the world. In our city spotlights section, we are proud to represent Mumbai and London this time. Besides our Country Spotlights, we have a new country to introduce: Latvia. CBI covers all the crucial information needed about the investment hotspots of Europe, the Caribbean and the US. These spotlights discuss the main features of the countries, ranging from the demographics of the country to its history and economic future. For further information and updates please visit our website: www. citizenshipinvestment.org Follow us on Twitter@CitizenbyInvest. Thank you for reading – we hope you enjoy the latest edition of Citizenship by Investment, and we hope to see you at the Global Investment Immigration Summit.

BLS Media are contract publishers of high quality media for prestigious organisations, event organisers, governments and trade associations both in the United Kingdom and internationally. Our experienced publishing team will develop your publication from initial concept through to completion. Our services include: creative design, PR, advertising sales, sales training, editorial and distribution. Published by BLS Media Ltd, info@blsmedia.co.uk www.blsmedia.co.uk Unit 5, ‘Hiltongrove N1’, 14 Southgate Road London N1 3LY

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Whilst every care has been taken in compiling this publication and the statements contained herein are believed to be correct, the publishers and the promoters will not accept responsibility for any inaccuracies. Reproduction of any part of this publication without permission is strictly forbidden. BLS Media make no recommendation in respect of any of the advertisers and no recommendation may be implied by way of the presence of their advertisements. Advertising: For advertising enquiries in future editions of contact Sam Hussain info@blsmedia.co.uk | www.blsmedia.co.uk

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Features: Introduction Citizenship by Investment welcomes its readers to the Spring edition, distributed in Mumbai, India. This issue will be focusing on a variety of topics which have made an impact upon global citizenship and residency program. Being launched at the Global Immigration Investment Summit www.events.citizenshipinvestment.org

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tarting this edition with exciting features, our authors will explain increased restrictions on immigration, reflecting on residence and citizenship planning. There are more changes to the UK’s domestic immigration system due to Brexit impact. Mischon de Reya will focus on the current rights of the EEA citizens and their family members to reside in the UK, focusing on various restrictive facts. Although the USA is one of the most popular countries in the world, traditional lawful immigration routes have become increasingly difficult. In this feature our worldwide known attorney Mona Shah will explain why is a Grenadian passport a solution for E-2 treaty visa requirements. Citizenship-by-investment programs attract HNW individuals, who often have

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some level of political exposure. This includes family connections, involvement in certain industries, employment by government or government controlled entities or the countries in which they do business. Thomas Anthony, Global Head, at Exiger with Matthew McDonald, CAMS- Research Manager at Exiger Diligence reflect on the challenge of assessing risk of political exposure in high-net-worth individuals. BLS Global is proud to announce that it will be hosting the Global Immigration Summit (GIIS 18) to take place in London UK, in April 2018. If you are a HNWI and are interested in learning more about the various opportunities through gaining secondary citizenships via investment or residency, feel free to view our dedicated website www.citizenshipinvestment.org, or visit our Events Page on https://events. citizenshipinvestment.org/

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City Focus: London

London is the capital of the United Kingdom by standing on the River Thames. Funded by the romans, the globally oriented city London is not only an economic hub for the United Kingdom, but also for Europe.

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istorically split between Essex, Surrey, Middlesex, Kent and Hertfordshire, which today largely makes up Greater London, a region governed by the Mayor of London and the London Assembly. London became the leading metropolis in the fashion, finance, arts, commerce, education, entertainment, healthcare, media, research and development, tourism, transportation and professional services. The capital is the world’s largest financial centre and has the fifth- or sixth-largest metropolitan area GDP in the world. London is one of the most visited city measured by international arrivals, and it has the largest city airport system measured by passenger traffic. It is also popular

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for international students, as there are 103,000 international students are living and learning in the city. In 2012, London became the first city to have hosted the modern Summer Olympic Games three times.

metropolitan area is the most populous in the EU with 14,040,163 inhabitants in 2016, while the Greater London Authority states the population of the city-region (covering a large part of the south east) as 22.7 million. London was the world’s most populous city from around 1831 to 1925.*

There are a diverse range of people and cultures and in the capital there are more than 300 languages are spoken. It’s estimated mid-2016 municipal population (corresponding to Greater London) was 8,787,892, the largest of any city in the European Union and accounting for 13.4% of the UK population. London’s urban area is the second most populous in the EU, after Paris, with 9,787,426 inhabitants at the 2011 census. The city ’s

The city has four World Heritage Sites: the Tower of London; Kew Gardens; the site comprising the Palace of Westminster, Westminster Abbey, and St Margaret’s Church; and the historic settlement of Greenwich (in which the Royal Observatory, Greenwich defines the Prime Meridian, 0° longitude, and GMT). Other landmarks include Buckingham Palace, the London Eye, Piccadilly Circus, St Paul’s Cathedral, Tower Bridge, Trafalgar Square and The Shard.**

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Numerous museums, libraries, galleries, sporting events and other cultural institutions take place in London, including the British Museum, British Library, National Gallery, Natural History Museum, Tate Modern, and West End theatres. The London Underground is the oldest underground railway network in the world. London, UK the perfect time and location, as millions of EU citizens who currently live in the UK – and the brits living in Europe, face uncertainly. 89% of Britons want dual citizenship after leaving EU. *Source: Wikipedia Citizenship By Investment

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City Focus: Mumbai In 2008, Mumbai was named an alpha world city. It is also the wealthiest city in India, and has the highest number of millionaires and billionaires among all cities in India

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umbai, (also known as Bombay, the official name until 1995) is the capital city of the Indian state of Maharashtra. It is the most populous city in India with an estimated city proper population of 12.4 million as of 2011. Along with the neighbouring regions of the Mumbai Metropolitan Region, it is second most populous metropolitan area in India, with a population of 21.3 million as of 2016. Mumbai lies on the Konkan on the west coast of India and has a deep natural harbour. In 2008, Mumbai was named an alpha world city. It is also the wealthiest city in India, and has the highest number of millionaires and billionaires among all cities in India. The seven islands that came to constitute Mumbai were home to communities of fishing colonies of the Koli people. For centuries, the islands were under the control of successive indigenous empires before being ceded to the Portuguese Empire and subsequently to the East India Company when in 1661 Charles II of England married Catherine of Braganza and as part of her dowry Charles received the ports of Tangier and Seven Islands of Bombay.

During the mid-18th century, Bombay was reshaped by the Hornby Vellard project, which undertook reclamation of the area between the seven islands from the sea. Along with construction of major roads and railways, the reclamation project, completed in 1845, transformed Bombay into a major seaport on the Arabian Sea. Bombay in the 19th century was characterised by economic and educational development. During the early 20th century it became a strong base for the Indian independence movement. Upon India’s independence in 1947 the city was incorporated into Bombay State. In 1960, following the Samyukta Maharashtra Movement, a new state of Maharashtra was created with Bombay as the capital. Mumbai is the financial, commercial and entertainment capital of India. It is also one of the world’s top ten centres of commerce in terms of global financial flow, generating 6.16% of India’s GDP and accounting for 25% of industrial output, 70% of maritime trade in India (Mumbai Port Trust and JNPT), and 70% of capital transactions to India’s economy. The city houses important financial institutions such as the Reserve Bank of India, the Bombay Stock Exchange, the National Stock Exchange of India, the SEBI and the corporate head-

quarters of numerous Indian companies and multinational corporations. It is also home to some of India’s premier scientific and nuclear institutes like Bhabha Atomic Research Centre, Nuclear Power Corporation of India, Indian Rare Earths, Tata Institute of Fundamental Research, Atomic Energy Regulatory Board, Atomic Energy Commission of India, and the Department of Atomic Energy. The city also houses India’s Hindi (Bollywood) and Marathi cinema industries. Mumbai’s business opportunities, as well as its potential to offer a higher standard of living, attract migrants from all over India, making the city a melting pot of many communities and cultures

In 2008, Mumbai was named an alpha world city. It is also the wealthiest city in India, and has the highest number of millionaires and billionaires among all cities in India. * Source: https://en.wikipedia.org/wiki/Mumbai Citizenship By Investment

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In a time of increased restrictions on immigration, residence and citizenship planning can open doors

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BY MARCO GANTENBEIN, MANAGING PARTNER, HENLEY & PARTNERS DUBAI, HEAD OF MIDDLE EAST 017 saw a number of ‘countryfirst’ agendas being promulgated around the world. In the US, for example, President Trump pulled out of a number of international treaties and agreements, including the TransPacific Partnership, the Paris climate accord, the UN Educational, Scientific, and Cultural Organization (UNESCO), and the UN Global Compact on Migration. The latter emerged out of the 2018 New York Declaration for Refugees and Migrants and aims to provide

collaborative, multinational support for migrating populations. Departing from the global community, the US asserted that commitment to such a program runs counter to its own immigration policies, which have become increasingly restrictive since Trump assumed office. The UK’s decision to withdraw from the EU represents the most well-known example of ‘country-first’ thinking in recent history, but the same trend has in fact taken root in several other developed countries. The

governments of Australia and New Zealand both took steps in 2017 to curb the number of skilled individuals coming into their countries by either scrapping popular visa programs or making the qualifying criteria more stringent. In the EU itself, antiimmigration policy has gained ground in countries such as Austria, Poland, Hungary, the Netherlands, and even Germany, where the alt-right party Alternative for Germany (AfD) won seats in the Bundestag for the first time last year.

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THE GLOBAL MOBILITY LANDSCAPE The Henley Passport Index, formerly known as the Henley & Partners Visa Restrictions Index, is a ranking of all the passports of the world according to the number of countries their holders can travel to visa-free. Launched on 9 January, the 2018 edition of the index provides a number of important insights into the contemporary mobility landscape, with a specific focus on travel freedom and passport strength. While travel and immigration seem, at first, to be separate categories, in reality they are mutually dependent. As Prof. Florian Trauner of the Vrije Universiteit Brussel explains, “the issue of short-term travel visas is often linked to migration concerns”. “Many irregular migrants have entered a country with a regular visa and subsequently overstayed,” Trauner writes on the Henley Passport Index website (henleypassportindex. com). “Visa liberalization is therefore a politically sensitive issue. It is sometimes portrayed as being lenient on migration and opening up new avenues for irregular migrants.” The result of this perceived connection between visa and immigration policy is that as border security tightens worldwide, travel freedom becomes more limited for nationalities on the receiving end.

SPOTLIGHT ON SOUTH ASIA The data behind the Henley Passport Index suggests that this pattern is already a reality for certain regions and jurisdictions — most notably South Asia (encompassing Afghanistan, Bangladesh, Bhutan, India, the Maldives, Nepal, Pakistan, and Sri Lanka). South Asian countries performed fairly well on the index year-on-year: five out of the eight countries in the region improved their global rank compared with 2017, and all eight countries maintained or improved their visa-free score (that is, the number of countries they can travel to without a visa). Viewed through a global lens, however, the South Asian picture is somewhat bleak. Other than the Maldives, which is ranked 58th globally, countries in South Asia fall between 83rd place (Bhutan) and 104th place (Afghanistan, the bottom-ranking country on the index). India is ranked 86th globally, with visa-free access to only 49 countries. Indian nationals are unable to access key international business, lifestyle, and career destinations such as the US, the UK, Hong Kong, China, Russia, the UAE, and Europe’s Schengen Area. South Asia has also fared the worst, on aggregate, of any region in the world over time on the Henley Passport Index. Every single country in the region has moved

down the ranking since 2008, which means that the strength of South Asian passports is declining relative to that of other passports. The Bangladeshi passport has shown the greatest historical decline, dropping 23 places on the index since 2008. India has fallen 11 places over the past ten years, while the Maldives and Bhutan have fallen seven places (the smallest regional drop). India is the poorest performer among the five BRICS member states (Brazil, the Russian Federation, India, China, and South Africa), trailing behind China, which climbed ten places in 2018 to claim 75th place on the index.

THE GLOBAL MOBILITY DIVIDE As Trauner points out, the current ‘global mobility divide’ makes it difficult for citizens of developing countries to travel outside their continent. Our observations indicate that, within the developing world, visa liberalization with the Schengen Area has been the main differentiator for countries that have performed well on the Henley Passport Index over time versus those that have not. The Caribbean region provides an interesting case in point. The countries that have improved their positions on the index since 2008 (Antigua and Barbuda, the Bahamas, Barbados, Dominica, Grenada, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, and Trinidad and Tobago) all signed short-stay visa-waiver agreements with the EU between 2009 and 2015. On the other hand, those countries that have not yet signed such visa-waiver agreements (Cuba, the Dominican Republic, Haiti, and Jamaica) have all lost ground on the index over time. The result is widely disparate levels of travel freedom for nationalities on different ends on the EU visa liberalization spectrum. For example, Barbados, the top performer in the Caribbean, has access to 146 countries, whereas Haiti, the poorest regional performer, has visa-free access to only 53 countries. The same pattern holds within the BRICS group: Brazil is the only BRICS member that has visa-free access to Schengen Area countries, and it is also the only member that falls within the top 20 of the index. (The runner-up, the Russia Federation, is ranked nearly 30 spots below Brazil, in 45th place.) South Asia-domiciled passports, then, have fared poorly on the Henley Passport Index and have seen their relative strength diminishing over the past decade, in part because they have not gained access to the 26 countries in the Schengen Area. Visa liberalization with the latter depends on a number of

preconditions that need to be met, including reinforced border controls, the introduction of biometric passports, low corruption levels, and strong protection of minority rights. It seems highly unlikely that South Asian countries will be able to overcome these barriers to entry in the near future.

OPENING DOORS BRICS countries such as India have experienced rapid economic growth and development in recent decades, but their citizens’ global mobility and access levels remain, for the most part, low. This discrepancy means that successful BRICS businesspeople who want to expand their business, career, and wealth opportunities globally are not automatically equipped with the means of doing so. For these individuals, investment migration becomes a crucial mechanism that allows them to enhance their current citizenship or residence with additional passports or residence permits in alternative jurisdictions. There is no a priori hierarchy between residence and citizenship programs. As Henley & Partners’ Global Residence and Citizenship Programs 2017–2018 publication makes clear, each type of program has its advantages, and each will meet the needs of particular individuals. Residence-byinvestment programs — for example, those offered by Thailand and Portugal — give high- and ultra-high-net-worth individuals the option of physically relocating to a favorable jurisdiction (either now or during retirement) and becoming tax residents of that jurisdiction. Residents of a country have full legal rights, including the right to live, work, study, and receive healthcare in that country. On the other hand, citizenship-byinvestment programs — such as those offered by Malta and Cyprus — provide wealthy individuals with the privilege of a second or third passport, which gives them to right to travel, trade, and settle in countries beyond their country of citizenship. Acquiring a second passport or residence permit is not simply about improved mobility, however. Global citizens who have assets, investments, and networks in multiple jurisdictions benefit from each country’s best practices and are less vulnerable to its risks and shortcomings. Moreover, they are able to participate in a progressive, globalized economy, where the borders between individuals matter less than the interests, goals, and concerns they share. Please note that the data presented in this editorial is as of 9 January 2018. Visit henleypassportindex. com for the latest figures and ranking. Citizenship By Investment 11

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Fast Track European Citizenship under the Bulgarian Investment Immigration Program

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epublic of Bulgaria is a EU member-state, located at the heart of the Balkan peninsula. Bulgaria is the oldest European state established during the 7th century south of the Danube delta. During its Golden age, it was where the Cyrillic script was developed but it’s also famous with its yogurt and the rose oil. Often described as “Heaven on Earth” thanks to its diversity of breathtaking landscapes, diverse nature and mild climate. Ski in some of Europe`s best resorts during the morning then spend a lovely afternoon gazing at the beautiful sunset on the beach,

or visit Bulgaria`s ancient secrets and enjoy a drink at the cozy city clubs, all within a single day. Bulgaria occupies the crossroads between East and the West, the link connecting Western Europe with the Middle East and North Africa. A 3 hour flight is all between you and most major destinations in Europe, Russia and the Mediterranean. Principles of freedom and often quoted as the most religion tolerant country in the EU, make the country a popular destination not only to tourists but also to serious newcomers willing to become EU citizens, in pursuit of the best deal.

Bulgaria enjoys a rapidly developing economy with its GDP growth topping 3,9% while unemployment remains at 5.8%, well below the EU average. The forecasted GDP for the first quarter of 2018 stands at a consensus of 8 320 USD per capital. During the 2009 recession Bulgaria was among the few member states that cushioned the shocks thanks to its very low debt to GDP, among the lowest in the EU. Contrary to the PIGS countries (Portugal, Ireland, Greece, Spain), the economy experienced only a mild deterioration of business conditions and quickly came back to strong growth figures.

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BULGARIAN INVESTMENT IMMIGRATION PROGRAM Since December 2013, the Bulgarian legislation has provided for an accelerated procedure should high-net-worth foreign investors and their families become interested in the benefits of the Bulgarian/European/ citizenship. The procedure is under the control of the Government. It has two stages

STAGE ONE: PERMANENT RESIDENCY

• Invest at least EUR 512 000 under law regulated investment assets • Visa D application & acquisition • Permanent Residency acquired in 4 to 6 months • Family members start their PRC procedure

STAGE TWO: FAST TRACK CITIZENSHIP

• Increase the investment to at least EUR 1,024,000 under the same legal provisions after one year of holding the PRC • File the application for Bulgarian citizenship • Receive citizenship within 6 months from application • Hold the investment for a period of 24 months from receiving Bulgarian citizenship

YOUR SECOND PASSPORT COMES WITH:

“Becoming a citizen has never been easier” Contact VISA FREE EUROPE now and start your applications

• Visa Free travel to 166 countries • Low tax burden • No language proficiency requirements • No physical residence required • No need to relinquish of current citizenship • Each application extends to the Investor, spouse and children under age of 18

is a local leader in the field of investment immigration consulting services. VFE is represented in Vietnam and Dubai and maintains long-standing relations with allied companies in UAE, China, Saudi Arabia, Austria, the UK, Russia, Georgia, Moldova, and Kazakhstan. VFE provides independent advice and custom tailored solutions to HNWI interested to acquire European citizenship while taking on profitable investments. Together with leading and reputable partners we deliver professional custom tailored solutions to our discerning clients. Our application success rate stands at 100%. Our projects have delivered quality returns to our investor base with real estate outperforming considerably most EU member states. VFE develops attractive investment options, in accordance with the Bulgarian legislation, aimed at delivering quality returns to our investor base. Investment in Government Bonds The investor purchases fixed interest portfolio comprised entirely of Government bonds. The compulsory term of the investment is 5 years. The full invested amount is to be repaid to the Investor at the end of the fifth year, inclusive of any coupon payments due. Investments in sovereign bonds usually bear the lowest risk of all known assets as they are backed by the taxing power of the Bulgarian state. Investment in equity of a Bulgarian public company, listed on the Bulgarian Stock Exchange – Sofia The investors can choose and acquire shares of a Bulgarian public company, whose shares trade on the Bulgarian Stock Exchange-Sofia (BSE-Sofia). During the 5-year compulsory term of the investment Visa Free Europe helps the investor to administer the investment portfolio. The investment is secured by an ownership of shares and at the end of the fifth year, the investor is allowed to sell the shares. The SOFIX Index was among the best performing European indices during the last 5 years with annualized return of 17%. Investment under a Trust Agreement The investor deposits his/her investment from outside Bulgaria in a Bulgarian bank under a trust agreement with a 5 year term. Visa Free Europe assists the investor to choose a portfolio of tangible assets: real estates, land, etc., and facilitate the transformation of the investment. The investment is then secured by the ownership of properties. At the end of the 5-year compulsory term, the investor is free to sell all the assets and cash in the profits generated from capital gains and rental income. Website: E-mail: Telephone: Address:

www.visafreeeurope.eu office@visafreeeurope.eu +359 2 448 6021 193 A “G. S. Rakovski” Sofia 1142, Bulgaria Citizenship By Investment 13

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The Truth About Bulgarian Citizenship by Investment – An Expert Panel Comments There’s contention among citizenship by investment practitioners regarding the residence/citizenship by investment program in Bulgaria. Many reputable firms market the program as a CIP, others as a residency program, and others yet stay away from it entirely.

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IN DISCUSSIONS ABOUT THE PROGRAM, A NUMBER OF QUESTIONS TEND TO COME UP: Does it have a sound legal basis? Are there any cases of investors successfully obtaining citizenship in Bulgaria through the advertised route? Is it correct to define it as a citizenship by investment program, as many service providers do? Does it have official sanction from the government of Bulgaria, which is to say, is it a legitimate citizenship by investment program? Investment Migration Insider asked four experts to weigh in on the matter. Their views on the Bulgarian program differ widely. The Bulgarian program is a two-stage procedure, explains Raia Petkova of Visa-Free Europe, a Sofia-based investment migration firm: “The first stage is a permanent residency card application, subject to an investment of minimum 512,000 euros. The second stage is the citizenship application. The investor is eligible to apply for Bulgarian citizenship if he has held a permanent residency card – which can be obtained in 4-6 months – for 12 months and has doubled the initial investment. Applicants under the program are not required to prove proficiency of Bulgarian language to apply for citizenship and there is no requirement to reside in Bulgaria.” The terms of the program are clearly defined by Bulgarian law, adds Petkova. “The Investment Immigration opportunities in Bulgaria are regulated by Bulgarian law: The Foreigners in the Republic of Bulgaria Act, the Bulgarian Citizenship Act, and the Investment Promotion Act.”

mostly to private sector companies. “Bulgaria’s Investor Programme for Residence and Citizenship was introduced in 2009 and modified in 2013. The naturalization period is two to six years, depending on the size of the investment. InvestBulgaria Agency is the only governmental body authorized to market and supervise the programme,” says Vladimir Kolev, vice president of Arton Capital in Bulgaria. The official website of InvestBulgaria Agency makes no mention of a program as such but does display a legal guide and the legal notices that form the basis of investor migration solutions on offer in Bulgaria. Unlike Malta, Cyprus and the Caribbean CIPs, Bulgaria’s investor migration program does not have an official website. “Bulgaria offers a residence program that could lead to citizenship. It may, technically, not be right to call it a citizenship by investment program. However, we often read and hear about improper marketing of such programs by some companies,” says Dr. Hussain Farooq, President of HF Corporation, a CBI consultancy. But Bulgaria, he explains, is not alone in being incorrectly marketed as a citizenship program. He points to Austria, Ireland, and Portugal as other examples. “Austria doesn’t have, and never had, a citizenship by investment program. Article 10 (6) of the Citizenship Act of Austria doesn’t define any investment criteria for naturalization of foreign individuals on the basis of extraordinary achievements.” See also: Alleged Scam Company Announces €25,000 Citizenship by Investment in Georgia Farooq added that his firm “sometimes receive emails from developers and service providers from countries like Portugal or Ireland who pitch their countries’ programs as citizenship programs, while we know that these are both residence by investment programs, or immigrant investor programs, also referred to as Golden Visa, that may lead to citizenship upon fulfilment of the criteria.”

“The Investment Immigration opportunities in Bulgaria are regulated by Bulgarian law: The Foreigners in the Republic of Bulgaria Act, the Bulgarian Citizenship Act, and the Investment Promotion Act.” The legal basis of investor naturalization in Bulgaria appears to be sound, but that does not a CIP make. While top government officials from the Caribbean and Mediterranean CIPcountries regularly make public statements and actively work to promote investor migration to their jurisdictions, Bulgarian officialdom appears to be leaving the marketing of their solution to

Head of an investment migration firm based in Europe who prefers not to be named says “I saw many advertisements of the Bulgarian citizenship program in 2014 and 2015, and have not heard about any successful cases where clients gained citizenship in 2 years. In fact, I have heard only about refused cases instead of successful ones. The law provides the possibility

but there is no guarantee whatsoever that citizenship will be provided. Also, why would any country in the EU be giving away citizenship just by someone investing in government bonds for €500,000? What is the advantage of such possibility for the country?” But Petkova and Kolev both disagree. ‘With regard to successful cases, several investors have obtained Bulgarian citizenship under the BIIP regulations,” says Petkova. “I cannot be more precise, because there is no public information about how many foreigners are granted citizenships through investment. The lack of information is due to the fact that the President’s Office is not reporting these particular cases separately from the other cases of foreigners who obtain citizenship”. Petkova explained that her firm, Visa Free Europe, will see their first client successfully obtaining citizenship through investment in Bulgaria this January, a process she says took about two years from initial investment. Kolev states that the number of successful citizenship applications through the program amounts to “more than ten”.

DOES BULGARIA HAVE A CITIZENSHIP BY INVESTMENT PROGRAM? Here’s a simple matrix to help determine whether a program is a CIP or not. You may disagree with the methodology and, if so, please leave a comment on Linkedin. The answer to whether Bulgaria has a CIP is that it depends on how we define a CIP. Several dozen countries have provisions in their laws that would allow for the naturalization of someone who makes a “significant contribution” to the country, and fulfillment of this condition is necessary but not sufficient to qualify as a CIP. Is it correct to call it a program if there is no official structure or procedure that predictably leads to citizenship, nor any government officials actively engaged in its promotion? One might call it a citizenship by investment opportunity, but calling it a program is inaccurate. There’s also the question of a residency period. How long of a minimum residence period can a citizenship program have before it becomes more appropriate to call it a residence program? Portugal’s Golden Visa, for example, may lead to a citizenship after five years of residence, but we wouldn’t refer to it as a CIP. But we do refer to Malta’s IIP as a CIP, and it does have a 12-month residence period. So what’s the cut-off? 12 months? 24? Investment Migration Insider’s conclusion is that Bulgaria’s program is a hybrid CIP. But so is Malta’s. And Austria is definitely not a CIP. Citizenship By Investment 15

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NOT ALL PEPs ARE CREATED EQUAL. is an AI-powered automated due diligence solution that efficiently evaluates applicants – including Politically Exposed Persons (PEPs).

To see how DDIQ can enhance your due diligence efforts, contact Karen Kelly at kakelly@exiger.com For more information, visit us at exiger.com 16 Citizenship By Investment

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Not all PEPs are created equal The challenge of assessing risk of political exposure in high-net-worth individuals THOMAS ANTHONY GLOBAL HEAD ICV PRACTICE, EXIGER DILIGENCE

MATTHEW MCDONALD, CAMS RESEARCH MANAGER, EXIGER DILIGENCE

Politically-exposed persons (“PEPs”) can be a sophisticated and sometimes elaborate group to evaluate. By nature, citizenship-by-investment (CBI) programs attract high-net-worth (HNW) and ultra-high net worth (UHNW) individuals, who often have some level of political exposure. This exposure includes family connections, involvement in certain industries, employment by government or government controlled entities or the countries in which they do business.

CBI programs are faced with the challenge of performing proper due diligence on these individuals to determine whether their PEP status represents sufficient risk to deny citizenship , and also doing it in a timely, and efficient manner. The expression “politically-exposed persons,” coined by the Financial Action Task Force (“FATF”), was intended to be a blanket term to describe a broad subset of individuals in a vast array of situations and jurisdictions. While this is useful for setting up a standard global definition, it also means that determining an individual’s level of political exposure, and level of associated risk, can be fuzzy at times. PEPs, and especially HNW PEPs, are considered riskier clients due to their positions of power and influence, which may make them more susceptible to corruption and graft. However, not all PEPs are created equal, and thus not all PEPs are as high-risk as others. The approach to determining whether to move forward with a PEP client should thus be risk-based. Citizenship By Investment 17

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Determining whether or not an individual is a PEP can range from fairly simple when, for example, a client discloses accurate and easily-verifiable information as part of an onboarding questionnaire, to complex and iterative when no such information is provided and names need to be researched and analyzed by subject matter experts. According to FATF’s definition, a PEP is “an individual who is or has been entrusted with a prominent public function,” as well as close relations and associates of such individuals. This might seem straightforward, but much depends on what one considers “prominent.” A city mayor in the United States is certainly entrusted with a prominent public function; but could the same be said for a project manager in the mayor’s office? Is risk aligned with prominence, or with the potential for corruption in a particular role? If the project manager in the mayor’s office handles all procurement activities and bids, the risk may be higher with this position. The matter is further complicated if you are assessing an official of a foreign government and have limited knowledge of how prominent that individual’s role is in that society. FATF advises that foreign PEPs – who, for CBI programs, constitute much of the clientele – “are always considered high risk and require the application of enhanced due diligence measures” [Source: “FATF Guidance: Politically Exposed Persons Recommendations 12 & 22”]. The industry simply does not have the option to rule out these clients based on inherent risk alone. When faced with the choice of ruling them out or conducting enhanced due diligence, the obvious answer is to perform enhanced due diligence.

APPLYING LOCAL SUBJECT MATTER EXPERTISE TO ASSESS FOREIGN PEPs Evaluating a PEP for risk means taking into account a number of factors that make up the profile of a risky client. Is the applicant’s declared wealth in line with their history of employment and asset ownership? Does it appear that the applicant’s political exposure (or that of their relations) contributed to their wealth (or indirectly, did it contribute to their employment and asset ownership)? Is the applicant or are their relations connected to a corrupt regime? Would the applicant’s position or political exposure make them susceptible to corruption and bribery? Answering these questions requires more than simply identifying a PEP on a list or running a simple web search on the name. Many CBI program clients come from jurisdictions considered high-risk for corruption,

Gaining the proper context for a PEP requires a synthesis of information about the individual, including the individual’s business, the nature of his or her political exposure, and relevant background information about their country of origin. money laundering, human rights abuses, or terrorist financing. In countries of the former Soviet Union, such as Russia, for example, one should look at how political exposure is linked to business, especially in specific industries such as resource extraction or banking. Wealth accumulation in Russia is often attained in lockstep with political access. Experts at the Commission on Security and Cooperation in Europe have asserted that businesses in Russia do not act independently of the state; rather, their “operations depend on the Kremlin’s approval” [Source: The Commission on Security and Cooperation in Europe]. To a certain degree, all wealth in Russia is subject to government oversight. An added layer of complexity is that wealth in Russia can be difficult to trace. It sometimes takes looking back several decades to understand how a HNW individual accumulated their fortune. The assets themselves can also be hidden behind layers of corporate vehicles, trusts and shell companies across multiple countries.

USING TECHNOLOGY TO DRIVE EFFICIENT AND COST-EFFECTIVE DUE DILIGENCE Obtaining this type of background knowledge is essential to creating a comprehensive, nuanced profile of potential PEP applicants and correctly assessing their risk. Arriving at this

full picture can take time. However, the range of solutions available to CBI programs and their service providers is growing, and the process is becoming more efficient with new technologies. For example, with natural language processing and cognitive computing, one can gain a better understanding of political exposure and related risk in an efficient and cost-effective manner. Manually conducting all the searches required to fully assess the risk of a low-profile foreign PEP – and creating a comprehensive audit trail for these searches – is time-consuming and requires significant manpower. But artificial intelligenceempowered due diligence can identify risk factors from thousands of sources in multiple languages and classify them in minutes while helping to eliminate false positives and duplication. Perhaps more importantly, these technology solutions are scalable and produce auditable results every time. The excuses for missing key information and letting high-risk, reputationally dangerous PEPs into a CBI program are wearing thinner in light of the growing availability and affordability of new technology solutions. And of course, the other advantage is that these improvements will not only help keep out risky applicants, but will also make it easier and faster for PEP clientele who pose little risk to be fairly adjudicated in the shortest possible time. Ultimately, improving our understanding of the nuances of PEP risk and making the processes for conducting the necessary risk assessment more efficient will make the immigrant investor industry a safer place for all parties involved. And a program will be able to decide quickly and confidently whether a given PEP should be accepted or rejected.

THOMAS ANTHONY is the Global Head of Exiger Diligence’s Immigration, Citizenship and Visa (ICV) practice, advising government agencies and their approved agents on the development and implementation of sound, riskbased policies and procedures for Citizenship by Investment programs. Thomas previously served as Deputy Chief Executive Officer and Acting CEO of Antigua and Barbuda’s Citizenship by Investment Unit.

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Greece is offering the most affordable Golden Visa Program in Europe.

Under the Greek Immigration Law, residence permits could be granted to third-country nationals and their family members who proceed to purchase property in Greece valued at a minimum of 250,000 euros.

Risvas & Associates is a leading Law Firm based in Athens Greece with over 35 years of experience advising international investors and private clients on every aspect of law. Our Firm is specializing in Immigration Law with reference to Residency and Citizenship by either acquisition of property or investment programs according to the Law 4251/2014 of the Greek Parliament, providing legal support and assistance to non-European citizens and their family members in receiving a permanent Greek (EU) residency permit (Golden Visa).

Risvas & Associates Law Firm Athens OfďŹ ce: 91, Alexandras Avenue , 11474 Athens, Greece Tel: +30 210 6462352 | Fax: +30 210 6462248 email: info@risvaslaw.gr | www.risvaslaw.gr Citizenship By Investment 19

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Residency and Citizenship Expo in Abu Dhabi, 2-4th November 2017-A Successful Event

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ighly experienced immigration consultants assisted dual citizenship aspirants in the complex decision-making, documentation and application process for a second citizenship and residency option from across different countries. The 3 day exhibition with more than 300 projects from hundreds of exhibitors helped to look at a wide spectrum of properties available, different investment options, financing sources, consultations and sorting out legal queries. BLS Media is proud to announce that

the company has successfully attended the International Investment & Real estate Show in Abu Dhabi in November 2017, which was an excellent opportunity to distribute the Arabic version of Citizenship by Investment magazine.

THE PRE EVENT RECEPTION Anichi Resort & Spa, the developer behind Silver Beach Resort & Spa – a luxury resort included in Dominica’s Citizenship by Investment Programme, has acquired a new name and a new brand. In 2019, the company,

now called Anichi Development, will debut Anichi Resort & Spa as an Autograph Collection Hotel – an independent brand under the world’s largest hotel company, Marriott International. In honour of its new brand, Anichi Development with BLS Global hosted a special reception on November 1st in Abu Dhabi, to introduce the new project and outline Dominica’s Citizenship Programme. The pleasant cocktail party was a perfect opportunity to network with the show exhibitors and speakers one day before the IREIS show.

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THE SHOW For the first time the USA EB5 took centre stage at this inaugural event. The Residency and Citizenship Expo in Abu Dhabi has featured a dedicated pavilion to help expatriates aspiring for dual citizenship opportunities gain the right advice and information from leading immigration experts in November 2017. Many of BLS’s well known contributors answered questions on the stage eg. Mona Shah at Mona Shah & Associates, Nima Korpivaara at David Hirson & Partners, LLP or Kristal Ozmun at Miller Mayer’s Immigration Practice Group. The next opportunity to network and sponsor is the Global Investment Immigration Summit in Mumbai, 27-28th February. We hope to see you there. Citizenship By Investment 21

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The leading trade and invest migration event! The Global Immigration Summit 2018 (GIS18) brings together direct investors, investors seeking immigration, immigration agents, global mobility managers, project developers, and regional centers together with international immigration citizenship experts from the USA, the Caribbean, the UK/Ireland, the Mediterranean and other key target regions.

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ondon is the ideal venue. One of its leading attributes is because of its central location; the city is within a six-hour flight of three continents. Not only is the city accessible, but it also possesses a time-zone advantage for doing business with Africa, the Middle East and Asia. A globally oriented city, London is not only an economic hub for the United Kingdom, but also for Europe. 40% of the world’s equities are traded here – more than the figure in New York. Finally, in London there are an approximately 103,000 international students that are living and learning in the city. London, UK the perfect time and location, as millions of EU citizens who currently live

in the UK - and the Brits living in Europe, face uncertainty. 89% of Britons want dual citizenship after leaving EU.

THE GIS18 EVENT: Over the course of two session-packed days, this event will provide up-to-date information and key contact networking opportunities for HNWIs (high net worth individuals) from Markets such as MENA (Middle-East North Africa), India, pan-Asian region Russia and Europe, attendees wishing to invest through immigration programs such as the American EB-5 Program to attain US permanent residency. With fluid changes across the global landscape impacting the US EB-5 and other national immigration programs, GIS18 will provide attendees with:

• The very latest solutions, expert insight knowledge and information learning through conferencing and networking sessions – leading towards successful citizenship investment applications • Avenues for direct equity • Collaborations from international leading immigration/migration experts and strategists This conference will provide information on best-strategy and citizenship/residency application investment opportunities and introductions to approved agents and experts.

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EVENT PROGRAMME TOPICS AND INVITED SPEAKERS

ABOUT BLS GLOBAL AND CITIZENSHIP BY INVESTMENT

The confirmed dates, venue and full programme with confirmed speakers will be published shortly.

About BLS Global and Citizenship by Investment London-based BLS Global is a highly specialised and established international media and communications company – they are the leading media experts within the investment-citizenship sector. BLS Media’s experience and expertise in this sector is underpinned through their industry partnerships and as official publishers of CBI (Citizen By Investment Magazine) and Trade & Invest in America The EB-5 Gateway. This is a unique publication catering to the Middle-Eastern, North African and Persian Gulf readership for EB-5 Program trade and investment into the USA. Additionally, BLS are the exclusive agents for the forthcoming USA and UK pavilions at IREIS’ Residency & Citizenship Expo (November 2018 in Abu Dhabi) which brings together government bodies, approved consultants, official agencies, legal entities, property developers, consultants and all the other associated entities. This event has created a unique platform for the regional prospects to select citizenship and residency options across the world harnessing opportunities available through the American EB-5 investment immigration program to UHNWIs (ultra high net worth individuals) from MENA (Middle-East North Africa), India and pan-Asian regions.

GIS18 will feature an Opening VIP Address, Keynote Address, Plenary Conference Sessions, Interactive Panel Discussions, Workshops together with VIP Networking opportunities and an extensive exhibitor area. Highlights to the programme include the following: • VIP networking opportunities with leading US EB-5 and other global experts and approved immigration/citizenship agents. • Information and knowledge insight learning and sharing from the two-day conference sessions and interactive in-depth panel discussions and workshops. • Expert national sessions presented by the USA, the Caribbean, the UK/Ireland, the Mediterranean, France and other key target investment regions. • Opportunities to present and leverage your business to leading experts and professionals in the investment immigration sector. • Full access to the exhibitor showcase area for all attendees. • Proactive and accelerated engagement into the rapidly expanding and highly lucrative EB-5/citizenship and global investment markets.

HOSTED BY BLS GLOBAL: GIS18 is organised by BLS Media who are assembling a selection of industry experts to contribute leadership, insight and strategy to harness available opportunities for residency/ citizenship. GIS18 is the must-attend event for investors/agents wishing to learn about EB-5 opportunities and other global investment citizenship programs.

WHO SHOULD ATTEND?

HOW TO GET INVOLVED If you are provisionally ready to register your place call our team on +44 (0) 207 241 1589 and they will be happy to assist you.

SPONSORSHIP, EXHIBITOR AND SPEAKER OPPORTUNITIES A strictly limited number of sponsorship, exhibitor and speaker opportunities are available for GIS18 London. For all sponsorship, exhibitor and speaker opportunities please contact our team today by phone at +44 (0) 207 241 1589 or email at sam@blsmedia.co.uk.

• Investors

Hold my place, I’m awaiting funding...

• Government bodies

If you are currently awaiting additional funding you can request us to hold your place today to ensure you do not miss out.

• Approved/accredited consultants

CONTACT US

• Senior-level EB-5 Experts

BLS Global Events Team

• Legal entities/expert legislators/attorneys

London Office: Unit 5, Hiltongrove N1, 14 Southgate Rd London N1 3LY, United Kingdom

• HNWIs (High net worth individuals) • Relevant Embassy Officials

• International foreign intermediaries • Official agencies

• Immigration/migration service providers Agents

• EU Citizens in UK • Developers

…and all the other associated entities and agents

Tel: +44 (0) 207 241 1589 Email: sam@blsmedia.co.uk Website: www.blsmedia.co.uk

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The Desire for Second Citizenship: Not So Niche? CS GLOBAL PARTNERS

Although the concept of citizenship by investment, also known as economic citizenship, is often perceived as specific to high net worth individuals from a handful of nations, the desire to invest in a country to obtain an alternative citizenship is one that is spreading rapidly, and on a global scale.

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ountries continue to jostle over their place in the world. Britain’s ongoing negotiations with the European Union to reach an agreement over Brexit, Donald Trump’s tough stance on immigration, and Qatar’s loss of diplomatic ties with several previous allies in the Middle East, are just some of the issues compelling nations to consider their place in the world. As a consequence, the question of an individual’s sense of self, effected by this complex web of uncertainty, is brought to light. We

surveyed people around the world to gauge their opinions on second citizenship and how it can be accessed, and the challenges they face in living a more global life. The desire for a safer, more secure lifestyle is a significant factor for those looking to obtain a second citizenship, and, with its promise of a speedy route to the permanent status of ‘citizen,’ economic citizenship has long provided a strong solution. In a survey conducted in South Africa, half of the respondents cited increased security as a motivator to gain a second citizenship. 96% said they would

like to own a second passport. More than a fifth went as far as to declare that they would invest one quarter of their annual salary to pursue a second citizenship. Politics and the economy dominated respondents’ fears for the future, with two thirds confessing they were worried about turbulence at home. The survey was conducted shortly after President Zuma was challenged with a no confidence vote at the National Assembly. A year on from Brexit, a similar survey was conducted in the United Kingdom to gauge the public’s thoughts on second

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...following Britain’s decision to leave the European Union. 89% of respondents said they would like to have a second citizenship... citizenship, and whether this had changed following Britain’s decision to leave the European Union. 89% of respondents said they would like to have a second

citizenship, with 15% willing to donate at least half their annual salary to the cause, and 58% confessed that they had researched citizenship by investment following the Brexit decision. Threequarters of those surveyed related holding a passport to the notion of ‘freedom,’ and, indeed, the highest motivator for obtaining a second citizenship was freedom and human rights. These statistics suggest that shifts in the relationships between countries, particularly when the direction of those shifts remains unclear, play a role in broadening the importance people place

on second citizenship. But political change is not the only factor that motivates individuals to become ‘multi-national.’ Economic challenges and the ripple effects these have on local business opportunities also play a significant role, encouraging many to look abroad to maximise their business and investment prospects. 32% of South African respondents said they desired a second citizenship for better business and career opportunities. More than one third said that they would very likely move abroad if they held a second citizenship, suggesting pursuit of a more inspiring and encouraging environment. Mobility, whether for business or pleasure, is a growing necessity in an ever-globalising, interconnected world. Additional research quantifying the challenges of the typical Middle Eastern businessperson revealed many were unsatisfied and frustrated by their limited ability to travel and access new markets – something they increasingly felt they had to do. Unsurprisingly, nearly half of Middle Eastern participants admitted to having to travel at least every six months for work purposes. However, the desire to live a life of greater mobility was a prevalent theme in all the research conducted. Over a quarter of surveyed UK participants said they would like a second citizenship to increase travel opportunities, and more than 51% of South African nationals said the same. For some, second citizenship is about improved quality of life and access to services, ranging from better healthcare to top education, both for themselves and for their family. 22% of South African respondents pinpointed education opportunities as a reason to research alternative citizenship paths. That Australia was ranked highly by South African and British respondents in possible destinations for relocation is no surprise given the country ’s strong focus on education. The interest in citizenship by investment – a once niche industry – is growing faster than ever before. Being a citizen of multiple countries is increasingly seen as an important step towards ‘insuring’ against unpredictability – whether political, economic, or social. Equally, holding multiple citizenships is a means of securing greater freedom, mobility, and lifestyle benefits. Alongside the shifting political and economic landscape, people are considering their next move and whether second citizenship is the missing piece of the puzzle. Citizenship By Investment 25

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Pacesetters: How the Caribbean is Creating Opportunity Out of Adversity BY MICHA-ROSE EMMETT

Amid one of the most challenging hurricane seasons the world has ever faced, hurricanes Maria and Irma also created distinct ripples through the citizenship by investment industry, causing many countries to re-evaluate their approach and accordingly adjust to the new needs of their respective communities.

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he Commonwealth of Dominica, and the Federation of St Kitts and Nevis, were among a number of islandnations impacted by the adverse weather. But adversity brought with it opportunity, and both countries embraced the chance to introduce new elements to their citizenship by investment programmes and re-assert their reputation as pace-setters in the industry. St Kitts and Nevis’ Citizenship by Investment Programme responded quickly

to the chaos caused by the adverse weather events, creating an opportunity to rise above the challenges. A demonstration of innovation, the Programme swiftly introduced the Hurricane Relief Fund – a temporary funding module to ensure the country received direct foreign investment to protect its paradise. Once again exemplifying their reputation as the Platinum Standard in the industry, this forward-thinking approach was applauded on an international scale. Shortly after the inception of the new fund, the Programme

“an investment in your future is one in ours.” was awarded the World’s Most Innovative Investment Immigration Programme at the Global Citizen Awards Ceremony in Russia. That St Kitts and Nevis was quick to respond to a pressing need to assure its future speaks volumes about the country’s ability to think about the big picture and make adjustments accordingly. As pioneers, the Programme identified a need

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‘Global Community’ – a banner that better embodies the warmth and inclusivity of the island and its people.

for economic citizenship well before the industry materialised. The Hurricane Relief Fund gets to the very root of the win-win philosophy, engaging the market as if to say “an investment in your future is one in ours.” While protecting the future of their paradise, they are simultaneously providing a sanctuary to those who require one. Available strictly over a period of six months, the Hurricane Relief Fund has allowed foreign investment to flow directly into improving roads and buildings, as well as repairing damage sustained in the

agricultural sector. At the frontline of last year’s weather event, the Commonwealth of Dominica captured the hearts and minds of the world during its response to Hurricane Maria. Images of people working together to support the weak, rebuild communities, and restore hope flooded the media. The Citizenship by Investment Unit (CBIU) was part of this picture – back up and running, and processing applications to bring much-needed funds to Dominica within a week of the event. The camaraderie

and compassion of the country, as well as of the CBIU, was on display to the world. To better encapsulate these two attributes to the prospective applicant for Dominican citizenship, the Unit has now launched the ‘Global Community’ – a banner that better embodies the warmth and inclusivity of the island and its people. Dominica’s Global Community transcends the traditional framework of economic citizenship, encouraging those who seek a second citizenship to feel that they belong to an international network of Dominicans, regardless of geography. After all, those seeking second citizenship share similar motivations for doing so. They are looking for security and a way of life that is missing in their country of origin – an environment that offers opportunity for growth, development, and business. Similar to the industry’s legacy programme in St Kitts and Nevis, Dominica’s Citizenship by Investment Programme has a long and trusted track record of delivery. Like the people of Dominica, the Programme is resilient and resourceful in approach. From a practical standpoint, this has translated to the Unit adopting an online case management system to better process applications. It has also meant a streamlining of procedures and an intensification of applicant scrutiny by the constant improvement of its due diligence measures. Dominica is proud of its Global Community, and, to safeguard its reputation, it has prioritised its screening procedures, ensuring that only genuine applicants who fit the profile of what Dominica’s Global Community represents, need apply. Though very different approaches, both Dominica, and St Kitts and Nevis have demonstrated a resolve to conquer the chaos and destruction caused by last year’s hurricane events, and respond in a way that brings new dimensions to the economic citizenship industry. With the inception of Dominica’s Global Community, and St Kitts and Nevis’ Hurricane Relief Fund, both programmes have found intelligent solutions to complex problems. And like the discerning applicant who is challenged by the limitations of their birthplace, they too are finding ways to turn adversity into opportunity. Citizenship By Investment 27

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Country Spotlight

Antigua and Barbuda – The Number One Choice for Second Citizenship

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ubbed the “heart” or “gem” of the Caribbean because of its strategic location in the middle of the Leeward island chain, the independent Commonwealth state of Antigua and Barbuda comes very close to many people’s idea of paradise. This ideal geographic positioning makes the tropical twin-island jewel a regional travel hub, with excellent air links to North America and Europe. Home to over 100,000 people and blessed with 365 powder-white sand beaches, the country is revered as one of the most beautiful places in the world. Historically, as a result of tourism and real estate, Antigua and Barbuda has experienced continuous growth in Foreign Direct Investment (FDI). However, more recently, financial services, tertiary education and e-commerce, have become significant contributors. Bolstered by generous government incentives, foreign investment has contributed to the rapid development of the economy, resulting in the country having one of the highest Gross Domestic Product (GDP) per capita in the sub-region. Antigua and Barbuda, along with seven other states, is a member of the Eastern Caribbean Currency Union (ECCU), a development of the Organization of Eastern Caribbean States (OECS), which uses the

Eastern Caribbean dollar (EC) as its currency. The EC has been pegged to the United States dollar for the last 40 years, contributing to long-term financial stability.

WHY WAS THE ANTIGUA AND BARBUDA PROGRAMME ESTABLISHED? Like many countries around the world, Antigua and Barbuda was adversely affected by the 2008 economic crisis. Tourism, the main driver of the economy, began to experience a decline in visitors from the country’s source markets, namely Europe, the United Kingdom and the United States. After considering various options to jumpstart the economy, the government saw the Citizenship by Investment Programme (CIP) as the most effective way to re-attract FDIs, renew interest in the real estate market and spur investment in the general economy. Just a few months shy of its fifth birthday, the Antigua and Barbuda CIP is still a relatively new entrant into the economic investment arena. However, it has become very popular with investors owing to its straightforward and transparent application process, fast turnaround time and the quality of real estate offerings. The reduction in processing fees

in August 2017, gives the Programme an additional competitive advantage. After the devastation of Barbuda, the smaller, lesser-populated of the two islands by Hurricane Irma in September 2017, a further decision was taken by the government to decrease the National Development Fund (NDF) contribution for a limited time period*. This, the government feels, will allow for the allocation of the estimated US$200 Million urgently needed to rebuild a stronger, greener Barbuda, and simultaneously reducing carbon footprints.

WHEN WAS THE PROGRAMME ESTABLISHED? The Antigua and Barbuda CIP Act was passed in April of 2013. The Citizenship by Investment Unit (CIU), a creature of the legislation, was staffed on August 26, 2013 and opened for business on October 10, 2013. The first application was received in November of that year and the first citizenship granted in February of 2014. The Act allows for anyone 18 years and older and/or his family, who commits to making an investment under one of three options, to apply for citizenship.

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Peace Peace of mind. Piece paradise. Peaceof ofmind. mind.Piece Pieceofof ofparadise. paradise. We’ve We’ve got you covered. We’vegot gotyou youcovered. covered. For over 30 years, Global Bank of Commerce, Antigua’s For 30 Global Antigua’s Forover over 30years, years, GlobalBank BankofofCommerce, Commerce, oldest institution providing international financial Antigua’s services, oldest institution providing international fi nancial services, oldest institution international financial has offered its clientsproviding the perfect balance of world class services, has off ered its clients the perfect balance of world class has offered its clients the perfect balance of world class banking, security and convenience.

banking, banking,security securityand andconvenience. convenience.

Antigua is an independent and sovereign jurisdiction Antigua isisan and jurisdiction Antigua anindependent independent andsovereign sovereign jurisdiction since 1981, and is well positioned as a safe harbour for the since 1981, isiswell positioned aasafe more investor, may alsoasasqualify toharbour obtainfor sinceselective 1981,and and wellwho positioned safeharbour forthe the more selective investor, who may also qualify to obtain citizenship via a regulated process. more selective investor, who may also qualify to obtain

citizenship via a regulated process.

citizenship via learn a regulated Contact us and how weprocess. can support your financial Contact us and learn goals, todayusand Contact andtomorrow. learnhow howwe wecan cansupport supportyour yourfifinancial nancial goals, goals,today todayand andtomorrow. tomorrow.

Personal Banking Services

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Personal Banking Services Wealth Management Global Commerce Centre Old Parham Road Global Commerce Centre GlobalP.O. Commerce Centre Box W1803 Old Parham Road Old Parham St. John’s, Antigua,Road West Indies

P.O. Box W1803 P.O. Box W1803 St. John’s, West Indies Tel:Antigua, (268) 480-2240 St. John’s, Antigua, West Indies Fax: (268) 462-1831 Tel: (268) 480-2240 email: Tel:customer.service@gbc.ag (268) 480-2240 Fax: (268) 462-1831 www.globalbankofcommerce.com Fax: (268) 462-1831 email: customer.service@gbc.ag email: customer.service@gbc.ag www.globalbankofcommerce.com www.globalbankofcommerce.com

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Wealth Management

Wealth Management Commercial Banking Services Commercial Retail Banking Services International Banking Solutions Commercial Banking Services International Retail Banking Solutions Escrow Services International Retail Banking Solutions Escrow Services Citizenship by Investment Programme Escrow Services Citizenship by Investment Programme Online Banking Card Services Citizenship by and Investment Programme Online Banking and Card Services Online Banking and Card Services

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WHAT ARE THE BENEFITS OF ANTIGUA AND BARBUDA?

WHAT ARE THE THREE OPTIONS OFFERED UNDER THE CIP?

• Visa free access to over 135 countries, including the United Kingdom, the Schengen area, Hong Kong and Singapore

THE NATIONAL DEVELOPMENT FUN (NDF)

•Decision rendered in 60-90 days on most files •No restrictions on dual nationality

Processing Fees

$25,000

$25,000 for a family of up to 4 persons

$50,000 for a family of up to 4 persons with incremental payments of $15,000 for each additional dependent.

•Citizenship for life, once residency requirement is met

Contribution

$100,000

$100,000

$125,00

•Straightforward application process, no minimum net worth requirement or previous business experience

Due Diligence

$7,500

$7,500 + $7,500 for spouse, $2,000 per dependent 12-17, $4,000 per dependent 18 and over

$7,500 + $7,500 for spouse, $2,000 per dependent 12-17, $4,000 per dependent 18 and over

•No tax on worldwide income, inheritance, capital gains or investment returns •History of a stable currency US$1 = EC$2.70 since 1976 •Antigua and Barbuda is a stable Westminster-style democracy

* Other fees payable include passport fees. These fees are subject to change. * All fees quoted are in US dollars

THE REAL ESTATE AND BUSINESS INVESTMENT OPTIONS

•Well-established legal and regulatory framework, supporting civil and commercial relationships •Well-educated work force, skills and abilities for modern workplace •Active and committed member of international community *NDF Limited Time Offer: November 1, 2017 to October 31, 2018 In addition to visa free travel to over 135 countries, eligible investors have the right to reside permanently on the islands. The recent elimination of personal income tax makes it even more attractive. Applicants must submit to a rigorous due diligence (DD) or background check process. The only residency stipulation is that new citizens spend at least five days on Antigua and Barbuda in the five years following the granting of citizenship.

$50,000 for a family of up to 4 persons

$50,000 for a family of up to 4 persons with incremental payments of $15,000 for each additional dependent.

Minimum Investment

$400,000

$400,000

Due Diligence

$7,500 + $7,500 for spouse, $2,000 per dependent 12-17, $4,000 per dependent 18 and over

$7,500 + $7,500 for spouse, $2,000 per dependent 12-17, $4,000 per dependent 18 and over

Processing fees

$50,000

$7,500

* Other fees payable include passport fees. These fees are subject to change. * All fees quoted are in US dollars

As far as innovation is concerned, Antigua and Barbuda was the first Caribbean nation to permit investment in approved businesses, an initiative that other jurisdictions are now copying.

Additionally, new citizens can add new dependents after approval and there is no HIV test requirement for minors under 11.

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WHAT IS THE FUNCTION OF THE CIU? The CIU is responsible for processing applications and for recommending the approval of real estate and business investment options. There are a few factors that contribute to the rapid success of the Programme, which include the Unit’s highly competent staff, comprising mostly of private sector individuals. With a turnaround time of about 60 days, the CIU quickly became one of, if not the most efficient Unit in the region, surpassing countries that had been in the industry for far longer or just prior to its entry. Secondly, the fact that Antigua and Barbuda has maintained a strong presence in the highend tourism sector for more than four decades and already had certain infrastructure in place, the country quickly became an attractive portal for those seeking to invest in real estate and business Thirdly, the twin-island state had the opportunity to learn from the already established programmes and model its real estate offerings and escrow arrangements accordingly. In order to give investors the confidence that developers will deliver on their promise, the Unit exerts some control over the management of escrow accounts. Lastly, the CIU has been very visible in the international community by attending and presenting at various industry conferences and establishing a strong presence in a number of high-quality publications. This visibility, along with a culture of efficiency, a robust due diligence process, transparency and accountability, made residence and citizenship industry experts, Henley & Partners, rank the Programme number one in the region and number four globally.

In addition to visa free travel to over 135 countries, eligible investors have the right to reside permanently on the islands. The recent elimination of personal income tax makes it even more attractive.

WHAT ARE SOME OF THE REASONS PEOPLE MAY DESIRE A SECOND-CITIZENSHIP? Unfortunately, the politics of one’s home country generally dictates the freedom of movement of many people. A second citizenship gives this demographic the opportunity to become a global citizen; an opportunity that should be afforded every individual by virtue of them being a resident of planet Earth. In addition to mobility, citizenship and residency investment programmes allow families greater security, access to education, quality of life, stability and diversification of wealth.

DOES THE PROGRAMME ACCEPT APPLICATIONS FROM ANY COUNTRY, OR ARE THERE EXCEPTIONS? There is a “Restricted Country List” comprising Afghanistan, Iran, Iraq, North Korea, Somalia, Yemen and Sudan. Nationals of the countries listed are eligible to apply for citizenship in Antigua and Barbuda under the Citizenship by Investment Programme after having met the following criteria: • Individuals born in these restricted countries but who migrated before the age of majority and/or have maintained permanent residence in Canada, the United Kingdom, the United States of America, Australia, New Zealand, Saudi Arabia and the United Arab Emirates, for a period of not less than 10 years and maintain no economic ties to any restricted country.

HOW ARE APPLICANTS VETTED? All applicants must apply through a locally licensed agent ** and are subject to processing and Due Diligence (DD)/background check fees, depending on the ages of the members of the family. The DD process is an extremely involved and stringent procedure. The CIU employs a multi-tiered process which involves, but is not limited to, searches in global sanctions and embargo lists, alerts and watch lists issued by financial regulators, law enforcement and other government agencies worldwide. These lists contain the profiles of high risk and “potentially” high risk individuals and entities, Politically Exposed Persons (PEPs) and their relatives and close associates, highprofile criminals and blacklisted entities. The Unit engages the services of international DD providers to conduct extensive research on all members of the family in every place they would have lived for more than six months during the past 10 years. The Unit also focuses on ruling out direct or indirect involvement in terrorism, international investigations or cross border money laundering

activities when assessing eligibility. Where derogatory information is discovered at any of these stages, the applicant is denied.

…a culture of efficiency, a robust due diligence process, transparency and accountability, made residence and citizenship industry experts, Henley & Partners, rank the Programme number one in the region and number four globally. WHAT ARE SOME OF THE BENEFITS THAT HAVE BEEN DERIVED FROM THE PROGRAMME? Over the life of the Programme, Antigua and Barbuda has seen a resurgence in the country’s real estate sector and renewed interest in the hotel sector. This economic boost has allowed for environmentally responsible projects such as solar energy and reverse osmosis to be developed. The local populace has also benefited from direct contributions to social development schemes. Additionally, the construction boom expected as a result of the Programme will create more employment opportunities and other spillover benefits, to improve the economic livelihood of normal Antiguans and Barbudans. **A Locally Licensed Agent is a natural person who is a citizen of Antigua and Barbuda or who is lawfully ordinarily resident for a period of not less than seven years.

Looking to the future, the country anticipates that the revenue flows from CIP will assist in fostering cottage industries such as agroprocessing, improve the agricultural sector and support the creation of new industries, thereby, ensuring diversification of the economy. With its efficient processing, rigorous due diligence, wide choice of investment options and the sheer physical attraction of the islands, the Antigua and Barbuda CIP is fast becoming a second citizenship programme of choice. For more information about the Antigua and Barbuda Citizenship by Investment Programme, visit: www.cip.gov.ag or email: info@cip.gov.ag.

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Canada Country Spotlight

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anada is a country located in the northern part of North America and is the second largest country by total area and the fourth by land area. Its border with the United States of America is also the world’s longest land border. Despite its gargantuan size, Canada is relatively sparsely populated and approximately four fifths of Canada’s 35 million citizens can be found living near the southern border. This is because the northern parts of Canada are largely covered by forest, tundra and the Rocky Mountains, with a severely cold winter climate. Although cold in the winter also, the southern more inhabited parts of the country do experience more warmth in the summer periods. Canada is one of the world’s most ethnically diverse and multicultural nations, so UHNWI looking to visit should feel welcome. It also boasts the world’s eleventh largest economy in the world, for which it attributes much of its wealth to its plentiful natural resources and

highly connected international trade networks. It has the tenth highest nominal per capita income on a global scale, and ranks ninth in the Human Development Index. Canada holds firmly steadfast to principles of government transparency, civil liberties, quality of life, economic freedom, and education, making it a desirable location for UHNWI who want to invest in a culture with more liberal leanings. With the world’s largest proportion of fresh water lakes, Canada is only second in overall size to the behemoth that is Russia. Canada stretches from the Atlantic Ocean in the east to the Pacific Ocean in the west; to the north lies the Arctic Ocean. It also has the longest coastline in the world, with a total length of 243,042 kilometres (151,019 mi). It is also geologically active, having many earthquakes and potentially active volcanoes: notably Mount Meager, Mount Garibaldi, Mount Cayley, and the Mount Edziza volcanic complex.

Canada is one of the world’s most ethnically diverse and multicultural nations, so UHNWI looking to visit should feel welcome. It also boasts the world’s eleventh largest economy in the world...

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For the UHNWI with children considering a permanent relocation to Canada, they will be pleased to hear that Canada is the most educated country in the world with the highest number of adults having a tertiary education...

are looking to trade in both the US and Asia, Canada is a potentially great location in which to operate.For the UHNWI with children considering a permanent relocation to Canada, they will be pleased to hear that Canada is the most educated country in the world with the highest number of adults having a tertiary education and over 50% of adults obtaining at least an undergraduate college or university degree. Canadian educational bodies are taught in both English and French. The citizens of Canada place high importance on equality and inclusiveness for all its people and is famous for its welcoming approach to new citizens. Multiculturalism is a corner stone of the country and its people. There is also a large passionate following for ice hockey and lacrosse which are Canada’s national sports.

CANADIAN CITIZENSHIP BY INVESTMENT Although Canada does not offer a direct citizenship by investment program as it closed in 2014, it does offer a fast track scheme for investors who can acquire their citizenships faster through the process of naturalisation. The two programs on offer are as follows:

CANADA BUSINESS INVESTOR FAST TRACK PROGRAM If you are a UHNWI operating their own business, then setting up a branch of your business in Canada can be a path toward achieving faster Canadian citizenship. Your business must be reasonably successful and therefore you setting up a branch in Canada will benefit the Canadian economy and provide new jobs for its citizens. The total cost of the move and paperwork should amount to approximately USD 130,000. If this is a possibility for you and you can see some benefit to branching your business out to Canada other than acquiring a fast track to Canadian citizenship then this is the best option available. Politically, Canada operates a parliamentary system with a constitutional monarchy led by Queen Elizabeth II. The current Prime Minister of Canada is Justin Trudeau whose office is one of the most powerful in government: most legislation is initiated from this office and sent to Parliament for approval. There is also a Leader of Her Majesty’s Loyal Opposition who is usually the person leading the party who gained the second most seats and they are then used to monitor and criticise the current government where necessary to keep them in check. Economically, Canada is the world’s eleventh largest economy and one of the world’s top ten trading nations, with a highly globalized economy. It prides itself on its relatively low level of income disparity which again reflects on the principle of civil liberties and quality of life it cherishes. The country’s average household disposable

income per capita is over USD 23,900 higher than the OECD average. In terms of stock exchange, the Toronto Stock Exchange is the seventh largest stock exchange in the world by market capitalization and lists over 1,500 companies with a collective market capitalization of over US$2 trillion. Exports equalled over C$528 billion, while its imported goods were valued at over $523 billion, of which approximately $349 billion originated from the United States, $49 billion from the European Union, and $35 billion from China. After the recession in 2008, Canada has recovered well and continues to grow steadily and securely, although there is still some volatility with oil prices and higher than normal unemployment rates. Other than the USA who is its number one exporter, Canada has seen an increasing amount of exports to Asia which is now its second largest exporter. For UHNWI who

QUEBEC IMMIGRANT Investor Program The other alternative is the Quebec Immigrant Investor Program. In order to qualify, the UHWNI needs to make a donation of approximately USD 650,000 which has to be invested on fully guaranteed interest free government term deposit for 5 years. However, the payment does not have to be made up front and financing options can be considered: for example, there are payment schemes in which an initial down payment of USD 170,000 could be considered. Completion and acceptance from either of these programs will afford the UHNWI permanent residency in Canada. From this point, after a further two years permanent residency and one other year in total of general residency (three years total), you can apply to become a Canadian citizen via the naturalisation process. Citizenship By Investment 35

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Cyprus Country Spotlight

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yprus is the third most populous country in the Mediterranean. Home to over a million citizens, the island is the world’s 80th largest by area. Close neighbouring countries include Turkey, which lies a mere 70 kilometres to the north, and Lebanon, which is located approximately 108 kilometres to the east. It is also west of Syria, northwest of Israel and north of Egypt. The landscapes vary dramatically; with the Troodos mountains, famed beaches and the Pedieos River, Cyprus is home to varied scenery and breathtaking backdrops. With a sub-tropical climate, it experiences very mild winters and summers can be extremely warm. With an average temperature along its coast of 24 degrees Celsius, Cyprus boasts one of the warmest climates in the Mediterranean and as a result it is a popular tourist destination known for its beautiful beaches and archaeological sites relating to the cult of Aphrodite, including ruins of palaces, tombs and mosaic-adorned villas.

EDUCATION Cyprus boasts a highly developed educational system and offers exceptional facilities, both public and private. The brilliant standard of Cypriot education can be attributed to its government prioritising it highly, in fact Cyprus is one of the top

three spenders for education in the EU, with nearly 7% of its GDP devoted to educating its citizens. Its only rivals in Europe are Sweden and Denmark, and the quality of its public schools are comparable with many of other European countries’ private schools. Indicative of its high quality, Cyprus currently has the highest percentage of citizens of working age who have higher-level education in the EU at 30% which is ahead of Finland's 29.5%. In addition, 47% of its population aged 25–34 have tertiary education, which is the highest in the EU.

COMMUNICATION With an advanced, high-income economy and a very high Human Development Index, Cyprus is a key figure in the European Union and although a great destination for tourists, it is also much more than that. Boasting a rich and divisive history which dates back as far as 10 million BC, it generally follows European standards and for English speakers, communication will be easy as English is widely spoken and recognised by its citizens. Cyprus is so much more than just a beachtime resort; the island is multi-layered, like its history, with a compelling culture, lifestyle and landscape, overseen by warm,

hospitable people who are pleased to accept foreign trade and to do commence business relations with citizens and cultures of all kinds and creeds. The two most popular spoken languages in Cyprus are Greek and Turkish, although for those who speak English there is little to fear - English is widely understood and many road signs, public notices, advertisements etc. are also translated into English.

POLITICS Politically, Cyprus utilises a multi-party system but of course ultimate power is attributed to the President, who is both chief of state and head of government. The current President, Nicos Anastasiades, has been in power since February of 2013 and currently has a council of eleven ministers who operate underneath him, each one presiding over various categories, e.g. education, defence, health, etc. The Cypriot constitution, conceived in 1960, codifies the principle of separation of powers and, as such, the executive, legislative and judicial branches are all independent of one another in order to avoid abuse of power. The legislative branch consists of a House of Representatives who are represented by 59 members who get elected for a five year term. The three main parties in Cyprus

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Citizenship by Investment Summer 2017

CYPRUS CITIZENSHIP BY INVESTMENT Cyprus, a member of the European Union since 2004 provides one of the most attractive, quick and straight forward investment immigration programs to wealth individuals non EU citizens and is the only EU country that offers both options of Permanent Residency or Citizenship without the requirement of residency. Most importantly both programs are based on investment and the investment need only be kept for 3 years, after that period the investor can dispose of the investment as opposed to a donation to the government that applies to most of the other Countries’ programs. Both programs are offered through a fast track procedure enabling the applicant to receive an EU passport within 3 months or a permanent residency permit within 2 months.

Conditions / Criteria • Invest in Cyprus, an amount of at least €2.0m • Have a residential property in Cyprus of no less than €0.5m • Clear criminal record.

Benefits • EU citizenship; • EU passport; • Granted within 3 months; • No residency requirement; • No language requirement; • Investment can be disposed of after 3 years; • Visa-free travel to more than 157 countries. Quickly and cost efectively obtain visas for other countries, such as the USA; • A secure investment, rather than a donation like in many countries; Access to the best education and healthcare institutes; Children have the right to much lower tuition fees in European Union countries because they are nationals of a European Union country; • Insurance policy against political instability; • EU passport holders are entitled to enter, reside, study and work in the European Economic Area (European Union, Iceland, Liechtenstein, and Norway) and Switzerland without a visa. • Wonderful holiday destination; • Low crime rate; • Property(ies) acquired can be rented; • There is no inheritance tax; • One of the lowest property taxes in the world

• The applicant’s spouse and any dependants up to the age of 28 are eligible to apply along with the investor without the need of satisfying further economic criteria.

Benefits of Cyprus Permanent Residency • Fast track procedure allowing for the issuance of Permanent Residence Permit within two months; • Permit covers the whole family; • Acquire property of €300.000 in Cyprus • No physical residence requirements during or after the application procedure (the applicant, his/her spouse and any dependants need only visit Cyprus once every 2 (two years); • No language requirements; • A secure investment, rather than a donation like in many countries; • Insurance policy against political instability; • Children have the right to much lower tuition fees in European Union countries because they will be considered permanent residents of a European Union country; • Closest EU country to the Middle East ; • Wonderful holiday destination; • Low crime rate; • Well known and established financial and tax planning jurisdiction; • The property acquired will be freehold; • No inheritance tax; • Property acquired can be rented; • One of the lowest property taxes in the world;

www.stalworthpro.com | info@stalworthpro.com | +35 722 270 803 88 Arch. Makariou III, 2nd Floor, Office 203 2224 Latsia, Nicosia, Cyprus

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...The Cypriot citizenship program will continue to claim the European CBI crown and further increase investors’ interest in the country. include that of the current President, DISY, who was elected with 45% of the vote in the first round of the 2013 election and finally 57% of the vote in the second round. The other two prominent parties are the AKEL, who received 27% of the vote in the first round, and EDEK, who received 25% of the vote in the first round.

RELIGION According to Eurobarometer 2005, Cyprus is the second most religious state in the European Union, falling slightly short of Malta. Approximately 94% of its citizens follow Eastern Orthodox Christianity, while small, but significant, Muslim and Jewish communities also reside on the island. Cyprus is also the home ground of the Hala Sultan Tekke, which can be found close to the Larnaca Salt Lake, and is considered by many to be the third holiest site in Sunni Islam. Both Muslims and Christians have been known to visit the site as part of their pilgrimage.

ECONOMY In the early 21st century the Cypriot economy diversified massively and Cyprus became far more prosperous due to this diversification. However, in 2012 it became affected by the Eurozone financial and banking crisis. In June 2012, the Cypriot government announced it would need EUR 1.8 billion in foreign aid to support the Cyprus Popular Bank, and this was followed by Fitch downgrading Cyprus's credit rating to junk status. Fitch said Cyprus would need an additional EUR 4 billion to support its banks and the downgrade was mainly due to the exposure of Bank of Cyprus, Cyprus Popular Bank and Hellenic Bank - Cyprus's three largest banks - to the Greek financial crisis.

However, after a three and a half year recession, Cyprus’ economy began to recover well. In the first quarter of 2015, there was marked growth in the economy, and the country ’s credit was upgraded. The Cypriot economy continued to blossom; growth of 2.9% was reported in the third quarter of 2016, securing a markedly positive start to 2017.

CITIZENSHIP BY INVESTMENT IN CYPRUS Many wish to gain a Cypriot passport. Possession of one is an invaluable asset; with access to as many as 159 countries without visa and the right to live and work in all EU member states, a Cypriot citizenship has the ability to open many doors. This month has seen significant changes to Cyprus’ Citizenship by Investment program which will undoubtedly make citizenships even more accessible to investors. As before, the Cypriot programme will remain the fastest in Europe, with eligible investors achieving citizenship approval within three months. The Cypriot Cabinet have now also approved alterations that will lower the amount that single investors are required to invest in the country from €5 million to €2.5 million. This amount can be invested in real estate, government bonds or through creation of a business based in the Republic. Furthermore, groups will also no longer have to number five or more investors, and citizenships can be secured for the applicants’ parents alongside their own applications.

BACKGROUND Since the launch of the Cypriot CBI program, investors have consistently been attracted to Cyprus due to the country ’s highly sought after geographical location and mediterranean climate. The program is currently the highest listed of any European country in the Arton index of global citizen programs. News outlets have praised the newly simplified process, as the changes will improve the program’s accessibility and will further cater for the family of investors. The tweaks to the program will undoubtedly ensure that the Cypriot citizenship program will continue to claim the European CBI crown and further increase investors’ interest in the country.

HOW TO QUALIFY Investment and Donation You can qualify for Cypriot citizenship by: • Investing at least €2m in shares and/ or bonds of the Cyprus State Investment Company and • Donating at least €0.5m to the Cypriot Research and Technology Fund Investment You can qualify by investing at least €5m in Cyprus. The following types of investments qualify: • Property (but not undeveloped land) • Cypriot businesses or companies • Bonds, securities, debentures • Investment or participation in public works If a) to c) above, the investments have to be maintained for three years. Where the investment is in shares or bonds, the value of the investment must stay above €5m for the entire three years. Bank Deposits You can qualify by depositing at least €5m in a Cypriot bank for three years on fixed terms. The investment can be reduced down after 3 tears to just €500,000.

BUSINESS ACTIVITIES IN CYPRUS You can qualify by owning, or owning part of, a company which has paid taxes and other fees to the Cypriot government and which employs people in Cyprus. The amount of tax that must be paid varies according to the number of people your business employs in Cyprus. The minimum qualifying tax payments are as follows: • If the company employs ten or more people in Cyprus, it must have paid taxes of €200,000 in each of the last three years • If the company employs between five and ten people in Cyprus, it must have paid taxes and other payments of at least €300,000 in each of the last three years • If the company employs fewer than five people, it must have paid taxes and other fees of at least €500,000 in each of the last three years.

BENEFITS • Fastest Citizenship by Investment program in Europe. • Citizenship only necessitates one visit every seven years. • Provided their Cypriot property value totals or exceeds £500,000, or parents own a share in a £500,000 property (+VAT), parents also qualify for citizenship. • No language requirements • Excellent and strategic location

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• Can retain current nationality

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The Commonwealth of Dominica C  ountry Spotlight

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iscovery of the Commonwealth of Dominica is sure to yield a Caribbean experience unlike any other. Its breathtaking landscape reveals rainforests, rivers and waterfalls. It comes as no surprise that Dominica is affectionately known as “Nature’s Island”, as citizens of Dominica share their home with many rare species of plants, animals and birds. The rugged terrain offers adventurous visitors the chance to canyon, bike or swing from new heights. For those with a love of nature, Dominica is the perfect bird watching destination. Additionally, the botanical gardens house the Sisserou Parrot is named after the country’s national bird, which can only be found on the island.

Dominica is known for its spectacular reefs which visitors can explore whilst diving or snorkeling. Keen divers should certainly visit the signature Champagne Reef. For a less active visitor, there is the always the option to join a boating tour. From a catamaran, visitors can enjoy dolphin watching. Looking out onto the Caribbean Sea, the mountainous green sides are dotted with exotic tropical flowers, banana plantations and coconut trees. The Boiling Lake is the perfect place to soul search and discover yourself as its renowned healing properties are considered legendary. Dominica has the honour of being nominated as one of the happiest places to live on Earth. Simplicity is key here, whether

you want to walk barefoot through the pristine shore, wander down any number of green jungle trails or chill out on the beach looking onto the ocean, Dominica is a place where concerns are replaced by an overwhelming sense of peace and oneness.

BENEFITS OF CITIZENSHIP IN DOMINICA One of the main benefits of a Dominican citizenship for the potential applicant would be the access it provides. Dominica itself is a safe and enjoyable place to live, with a high quality of life and English is the official language so business transactions should run without language complications. Dominica has a progressive a stable economy and fosters an

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investor friendly environment. Citizenship also comes with free movement of capital, dividends and profits made outside of the island and no capital gains, estate or death taxes making it a prime location for those looking to protect their wealth. Dominica’s Government has frequent dealings with the private sector and other foreign investors in order to facilitate growth. There are a number of flexible and tailored projects available for the investor, as many international companies are targeting Dominica to develop agricultural opportunities, alternative energy projects, manufacturing concerns, hotel resort developments and even investment in the film industry. The soil is perfect for producing a variety of fruits, produce and plants due to its rich volcanic content. The landscape is also a prime candidate for real estate development and there are a number of opportunities to work together with joint venture investments and private landowners.

an ultimate goal of national development for Dominica. Generated funds are utilised for public and private sector projects where a need is identified. Public sector projects identified for financing under the Programme include (1) building of schools, (2) renovation of the hospital, (3) building of a national sports stadium and (4) promotion of the offshore sector. With respect to private sector projects, Government emphasis is on the tourism, information technology and agricultural sectors. To qualify for citizenship under this investment option, there are four investment categories with different contribution amounts, based on the number of dependents included in the application, which are as follows:

CITIZENSHIP BY INVESTMENT REQUIREMENTS

3. Main Applicant with up to three qualifying dependents. A non-refundable contribution of USD 200,000

Dominica offers applicants the option of becoming citizens in return for a qualifying investment, which includes either a donation to Dominica’s Economic Diversification Fund, or the purchase of pre-approved real estate.

ECONOMIC DIVERSIFICATION FUND

1. Single Applicant: a non-refundable contribution of USD 100,000 is required 2. Main Applicant and Spouse: a non-refundable contribution of USD 175,000 is required

4. Addititinal qualifying dependants USD 25,000

REAL ESTATE To qualify for citizenship of Dominica under the real estate option under the Citizenship by Investment Programme, an applicant must purchase authorised real estate to the minimum value of USD 200,000. Following approval of a real estate investment application, the following Government Fees are payable: • USD $25,000 for single applicant USD $35,000 for main applicant + spouse • USD 35,000 for family up to 4 persons, including the main applicant • USD 50,000 for family up to 6 persons, including the main applicant • USD 70,000 Family of 7 or more. Given that the application procedure under this option entails the purchase of real estate, this may extend the processing time, which is subject to the chosen property.

The Commonwealth of Dominica has the honour of being nominated as one of the happiest places to live on earth.

The Economic Diversification Fund (EDF) was established through the Citizenship by Investment Programme as one component of a national capital mobilisation portfolio towards Citizenship By Investment 41

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Grenada C  ountry Spotlight

The best things in life come in threes, and the tri-island state of Grenada is no exception. Consisting of Grenada, Petite Martinique and Carriacou, the picturesque islands offer plentiful opportunities for both adventure lovers and those seeking rest and relaxation. Due to its lushfertile landscapes and award winning white sandy beaches, visitors may find themselves wishing that they could extend their stay.

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enowned for its high exports of nutmeg and mace, Grenada is sometimes dubbed the “Island of Spice” as it is reputed that travellers can taste a faint flavour in the air. Spices aren’t the only natural bounty that Grenada shares with its guests; cocoa beans, bananas and avocados are also grown in abundance throughout the land. Grenada is famed for its unspoilt scenery. Its natural beauty remains largely untouched by industrialisation – between the cobalt blues of the ocean and the rich greens of its vegetation, the eye is spoilt for choice. It is the perfect getaway destination for those seeking adventure in wildlife, suntans and spas or a romantic break with a partner. With its white sand and invitingly clear waters, the Grand Anse beach is regularly noted as one of the most beautiful in the world.

For those who enjoy active adventure, a trek to the cascading waters of the Seven Sisters Falls will lead you through the rainforest and to unforgettable memories. Visitors to the island are likely to encounter some of the friendliest people in the Caribbean, as Grenada is renowned for its hospitable attitude toward both tourists and new citizens alike. Grenadian culture is expressed through largely creative means: with music, poetry, pageantry, theatre, dance and sports all celebrating past times. Other means of socialising come in the form of organised celebrations and festivities. Lots of time is dedicated toward cooking, with food another activity that Grenadian people like to share with others. The nation is fully English speaking, so there should be little trouble acclimatising and integrating into the community.

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CITIZENSHIP OF GRENADA The Grenada Citizenship by Investment Committee is the main Governmentappointed body tasked with the responsibility of overseeing the processing of applications for Grenadian citizenship by investment. The Committee assesses applications in accordance with the Grenada Citizenship by Investment Act, after which recommendations are made to the Minister, who makes the final decision to deny, approve or delay granting Grenadian citizenship. At present, citizenship in Grenada through the Grenada Citizenship by Investment Programme can be achieved through: 1) A contribution to Grenada’s National Transformation Fund or 2) The purchase of pre-approved real estate Minimum contribution of USD 150,000 to the NTF Contribution to Grenada’s NTF of a minimum of USD 150,000 The non-refundable contribution to the NTF is the fastest and more straightforward route to obtaining citizenship of Grenada. This option is available for USD 200,000 for a family of up to 4 people. In addition to the contribution, application, processing, and due diligence fees apply.

Investment of a minimum of USD 350,000 in an approved real estate project The investment is subject to a minimum holding period of three years. The investment does not include application, processing, and due diligence fees. The minimum investment required is USD 350,000. Families who wish to invest larger amounts in custom private homes or in other businesses should discuss this directly with their relevant approved real estate developer or International Marketing Agent. The Government is welcoming of investors and generous concessions may be made in special circumstances. The Citizenship by Investment Programme in Grenada was conceived for unique global citizens who demand exclusivity and prompt personal service. It has been developed to have some distinct advantages over other citizenship options in the Caribbean – whilst the benefit to Grenada is manifested through inward investment, the creation of sustainable long term employment opportunities for Grenadians, training and the wider benefit directly and indirectly to the Grenadian economy. The broadening of skills, the creation of jobs and the economic benefits derived from new foreign investment will immeasurably strengthen Grenada.

More specifically, the benefits that Grenada’s Programme offers over the citizenship programmes of other Caribbean states include: Efficiency: The application process is quick. The law mandates that a decision will be made within 60business days of submission, followed by the issuance of Certificate of Registration. The application cannot be approved until after the background checks have been cleared. Family friendly: By not charging exorbitant application, processing, and due diligence fees for spouses, and family members, Grenada is an attractive option for international businessmen looking for security and travel options for their families. Good visa-free travel: The Grenada passport allows visa-free travel to more than 120 countries, including China. Grenadian citizens also have the opportunity to apply for the USA E-2 visa. There is no requirement to visit Grenada in order to qualify for citizenship.

The benefits to the applicant / new investor are as follows: 1) Ability to include one's family to one's application 2) The opportunity to own freehold prime real estate in an approved project The real estate owned by the investor may produce a modest annual income and may be enjoyed by the investor along with friends and family. Citizenship By Investment 43

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Ireland stepping up as an investment immigration destination

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reland’s population is similar to that of a large district in Beijing or Shanghai at just over 4.5 million people1. When you are speaking about a country of that size to investors in China, it is not uncommon to be met with questions like ‘where?’  Irelands profile as an investment destination, however, is increasing amongst Chinese investors. Large scale deals such as HNA’s $2.5 billion acquisition of Ireland aircraft lessor Avalon last year attracted a lot of press both domestically and internationally. Ireland also became the only EU country to have its ban on beef imports lifted2 and more recently the country increased its promotion of its Immigrant Investor Program (IIP).

IRELAND’S BUSINESS RELATIONSHIP WITH CHINA Ireland and China’s economic relationship has been gathering momentum in recent years. With annual trade approaching $10 billion3 a year, both governments have stated intentions to proactively build upon

BY JAMES HARTSHORN this in the coming years. Strong connections continue to form and Chinese businesses have begun to take advantage of Ireland’s inviting tax structure, educated work force and proximity to Europe. Leading Chinese companies such as ZTE, Huawei, Tencent and many of China’s largest banks now have major operations in Ireland.  Ireland - China relations far exceed trade, interestingly, both economies share a unique link as the Chinese plan for the Shenzhen Economic Zone was closely modelled on Ireland’s Shannon Free trade Zone (SFZ)4, after a group of Chinese officials, which included future president Jiang Zemin, visited the SFZ while searching for economic models to incorporate into Deng Xiaoping’s reform period. The model was a massive success and was replicated across the country, contributing most likely to China’s economic advances of the past 40 years. 

In 1957, the Irish Minister for Foreign Affairs, Frank Aiken, decided to vote for a debate on the representation of China at the United Nations5, which ultimately resulted in the body’s recognition of P.R.C over Taiwan. Since P.R.C’s inclusion in 1971, Ireland has never voted against China in the United Nations. It was an Irishman, named Michael Morris, who used his position as head of the International Olympic Committee to ensure China’s fair admission and membership in the games, resulting in China and Taiwan both participating in the games6.

IRELAND IN THE GLOBAL MARKET Despite Ireland’s significant gains in China it still has a long way to go to catch up with its largest foreign direct investment contributor, America. Many of the readers might not be aware that the value of American investment in Ireland, at $165 billion7, is actually greater than the corresponding American investment into

Brazil, Russia, India and China, combined.  With an education system that ranks in the top ten globally8, there is a very strong

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argument for career development in Ireland. For a small city, Dublin has one of the highest concentrations of Fortune 500 companies in the world. All of these companies have excellent graduate programs and active recruitment campaigns. Some employers rank graduates from Ireland number one in Europe.  It is also expected that there might be a large relocation of many financial institution from London to Dublin as a result of Brexit. This windfall of business relocation has already begun with JPMorgan Chase’s acquisition of a 12,000-square-meter office in Dublin9, capable of housing over 1,000 employees.  Ireland has been the best preforming economy for the past three years in a row, with a growth rate of 5.2 percent last year10, GDP growth is forecast at 3.8 percent in 2017 and 3.6 percent in 2018. Unemployment is expected to average more than 6 percent in 2017 and more than 5 percent in 201811, down from almost 15 percent during the recession.

IRELAND’S EDUCATIONAL SYSTEM In addition to its economic performance, the quality of the Irish education system is a big contributor to the increased demand of immigration investment to Ireland. Every child in Ireland currently on a Stamp 412 visa is entitled to free, state-run primary and postprimary education.  According to the 2016 Global Competitiveness Report, released by the

World Economic Forum, the Irish School system ranks 6th in the world. Its Education system overall ranks 9th globally and all Irish Universities rank in the top 5 percent globally. Trinity College Dublin is Ireland’s premier University and was founded in 1592. Trinity College is modelled after the collegiate universities of Cambridge and Oxford in England, and is also one of the Seven Ancient

Universities of Britain and Ireland.  All of these factors add considerably to Ireland’s attractiveness as a destination for immigration investment. This is very much evidenced in the sharp rise in demand in 2016, where the applications number soared by 500 percent, rising to 329 from 66 the year before with Chinese nationals making up 313 of those applications13.

HOW IRELAND’S PROGRAM WORKS The program itself is straightforward and designed in a way to mitigate risk for investors. One of the strongest points is that an investor will actually have their application approved before they are required to make their investment14.  The purpose of the Immigrant Investor Program is to enable non-EEA nationals and their families who commit to an approved investment in Ireland to acquire permanent residency (Stamp 4 Visa) in Ireland. The Irish government set up the program in 2012. It

estimates that last year the program generated

about €140 million for the Irish economy.  There are essentially two components to an IIP application, the person and the investment. The personal criteria relate to the good character of the individual, their net worth and the providence of the funds to be invested. The investment component relates to the nature of the proposed investment.  Individuals can apply to the IIP without committing any investment funds.  An individual must choose one of four eligible investments and once the application has been approved, the investment may then proceed, and once the funds have been invested the individual and their family will be issued with permission to reside in Ireland.

IRISH RESIDENCY Successful applicants receive residence permission for 5 years. An initial permission will be granted for two years, and following a review at that point to ensure the investment is still in place, the investor will be granted another period of 3 years.  After this initial 5-year period, the investor will be free to apply for residence indefinitely in 5-year periods. The residency requirements for the program are only one day per year, which is very convenient for those applicants wishing to maintain their businesses in China, or elsewhere, while still being able to maintain Irish residence. Citizenship By Investment 45

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ELIGIBLE INVESTMENTS Enterprise Investment A minimum of €1 million invested in either a single Irish enterprise or spread over a number of enterprises for a minimum of three years. The enterprise can be a start-up or existing business but must be registered and headquartered in Ireland and the investment must support the creation or maintenance of employment.  The investment must be made in the name of the individual seeking residence. A business plan must also be submitted for all businesses, indicating how the investment will help create or maintain employment. Despite the reference to jobs there is no specific number of jobs that need to be created, as with the ten-job metric in EB5 program for example.

WHO IS ELIGBLE? The program is open to non-EEA nationals with a net worth of over €2 million. Individuals must be of good character and not convicted of a criminal offence in any jurisdiction. The funds used for the investment must be the individual’s own funds, they cannot be borrowed.

ELIGIBLE FAMILY MEMBERS Residency under the program is also available to spouses/partners and children under 18 years of age for whom the applicant and/or their spouse or partner has legal guardianship. Children between the ages of 18 and 24 will be considered where they are unmarried and are financially dependent on their parents.

INCREASED INVESTMENT THRESHOLD

Investment Fund A minimum of €1 million invested in an approved investment fund. The investment must be held for a minimum period of three years. The funds and fund managers must be regulated by the Central Bank. There are a number of funds in Ireland that have been set up specifically with IIP investors in mind.

The program saw exponential growth in 2016, which led to an increase in the investment amount from €500,000 to €1,000,000. Many in the industry have been critical of this move, as it has led to a significant decreased demand for the program, and have begun lobbying to have

Real Estate Investment Trust (“REIT”) A minimum of €2 million invested in any Irish REIT that is listed on the Irish Stock Exchange. The full investment must be held for a minimum period of three years. During this period the number of shares approved must be retained even if their value rises above the original €2 million investment. After three years the investor may divest up to 50 percent of the shares purchased for the IIP, and after four years the investor may divest no more than a further 25 percent. After five years there are no retention obligations.

The financial crisis all but decimated the Irish banks and with them all of the significant developers. This meant for a period of around eight years there was no money for projects and nobody with the skillset to develop them. This lack of spending on infrastructure during the recession has created huge potential for investment. It is most acutely evident in chronic shortages of housing, healthcare and energy facilities throughout the country.  Two areas requiring significant capital expenditure are Social Housing and the Healthcare sector. The Social housing requirement is particular significant as the government have committed to the construction of over 110,000 houses. The estimated capital cost of this would be in the region of €22 billion, which would need to be raised privately due to borrowing restrictions imposed by the EU following the 2008 financial crisis.  Given their strategic importance to the government, both are qualifying investment types under the IIP.  This opportunity is not lost on the global investment community either. Since 201, there have been many funds flooding into Ireland to explore opportunities in

Endowment A minimum endowment of €500,000 is required in a project of public benefit in the arts, sport, health, cultural or educational field. It will be regarded as a philanthropic contribution and investors will receive no financial return. Where a group of five or more investors wish to combine their philanthropic endowments to contribute to an appropriate project, a minimum investment of €400,000 per investor will qualify under the program.

this price increase addressed. 

THE OPPORTUNITY

real estate created by the financial crisis. Blackstone, Hines, Colony NorthStar and Kennedy Wilson, to name just a few. Incidentally, Kennedy Wilson in part developed the aforementioned JPMorgan

chase office in Dublin.  As with any new territory, it’s crucial to partner with the right people who know what they are doing. A great way to see this is to just look at what they have previously done in Ireland. A great benefit of Ireland’s size is that the business community is quite small and all of the reputable players will know each other. A good test is to walk into one of the big four and mention the name of the company you are thinking about working with, if they don’t know them, that’s a bad sign.  One need not look past Tom Barracks wisdom, that ‘the Jungle is a safer place with professionals than a paved road with amateurs’. That is as true in Ireland as it is in any other jurisdiction.

JAMES HARTSHORN is the Asia director of Bartra Wealth Advisors Limited. He works in the industries of real estate and investment immigration, having successfully established and implemented investment immigration programmes in foreign markets.

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Latvia Country Spotlight

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L

atvia is a member state of the European Union, laying in Northern Europe with borders to Belarus, Russia, Estonia and Lithuania. It also shares a maritime border with Sweden. The country is a member state of the European Union (EU), NATO and Schengen Zone. It is an active participant in World Trade Organisation enjoying all benefits of free and open trade in global markets. Latvia offers an Immigration Investment Program, which provides the opportunity to citizens from outside of Europe to receive a Residence Permit. It enables these citizens and their families to live in Latvia or any other European Country including unconditional travel freedom within the Schengen Area.

Country

Latvia

Investment

50’000

Portugal

PROGRAMME SUMMARY Latvia offers a European Residence Status for Investors, by becoming a shareholder of a local registered and established Company. In regards to receive Residency in Latvia, it has to be €50’000 invested into share capital of a local established company. The Temporary Residence Permit (TRP) is valid for 5 years with a long term Schengen Visa. It can be renewed for unlimited times as long as the applicant maintains its shares in the company. 5 years after there is an opportunity to apply for a Permanent Residence Permit with the possibility of EU Citizenship.

Cyprus

500’000

2’000’000

Greece

Malta 1’250’000

250’000

Timescale (months)

1-3

2-3

2-3

2-3

2-3

Residency

Yes

Yes

Yes

Yes

Yes

Donation to Government

10’000 Family included

5’173 Family not included

500’000 Family included

650’000 Family not included

10’000 Family included

Citizenship

Yes

Yes

Yes

Yes

Yes

10’000

Costs Additional Family member costs (Wife, children)

No Wife and children included

Annual renewal costs per Applicant

80

19’000 Yes 5’173 per Family member 2’586

37’000

60’000

0’000

No Wife and children included

Yes 25’000 per Family member

Included

Included

No Wife and children included 500

PROCESS

SAFE HAVEN

Residence Permit Application is based on being a Shareholder of a Latvian Company. The Investment into shares has to be made before applying for the TRP. Money is held in special Transaction Accounts and only released to the Company after successful Temporary Residence application.

Europe is one of the top regions worldwide in terms of democratically elected Governments, medical support, safety and education.

FAMILY

Some clients plan to live permanently in Europe and have the wish to allow their children to where to benefit from either the state or private education system. A European Education paired a Residency or Citizenship does not only look good, it opens doors into international business.

The Temporary Residence Permit (TRP) covers the whole family. It includes the Investor, wife all children under the age of 18.

SUMMARY Already your Temporary Residence Permit gives you a European Residence Status for a Permanent Residence Permit which allows you to reside and travel freely within the entire European Schengen Area.

LIVING To keep your Residency valid you do not need to live in Latvia. However, it is your choice to reside just sometimes, permanently or just a part of the year.

EDUCATION SYSTEM

RESIDENCY THROUGH INVESTMENT To qualify for Residency by Investment in the Republic of Latvia you have the possibility to become a shareholder in one of our Latvian registered Joint Stock Companies. The minimum Investment into Company shares is set by the Government at an amount of €50’000. Being a shareholder entitles you to apply for a Residence Permit which includes a Schengen Visa for the same time. Citizenship By Investment 49

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Residence in Luxembourg - your family’s path to stability, flexibility in Europe, privacy and one of the best nationalities in the world

S

mart families are increasingly looking for a better balance between wealth protection, privacy, health, community, and overall quality of life instead of the traditional “tax haven”. Your strategic decision to obtain residence in Luxembourg is the key to your Family’s happiness and longevity.

ABOUT THE GRAND-DUCHY OF LUXEMBOURG Luxembourg is the richest country in the western world – as per IMF (2016), even when adjusting for purchasing power parity. For comparison, the Consumer Prices

and Groceries Prices in Switzerland are respectively 57.01% and 83.75% higher than in Luxembourg. Just as impressive, according to the U.S. firm Mercer (2016) and the London-based Legatum Institute (2017), as well as being the safest country on Earth, Luxembourg features the world's best healthcare and social security systems. What is more, Luxembourg is a global leader in terms of the rule of Law, education opportunities, environment cleanliness, average life expectancy, and satisfaction with life. Once in Luxembourg, you shall feel at home since most of the population speaks at least three languages and 46% are from abroad. As an expat, you can choose among many international communities and a range

of excellent international schools for your children. Located in the heart of Europe, life in Luxembourg is rarely just about Luxembourg. Cross-border living and business is a breeze; your family will enjoy the freedom to study and spend time in secondary residences in Schengen area without any further approval. With best-in-class tax planning possibilities (exemption of wealth tax and undistributed profits taxation and a vast double tax treaty agreement network), no restrictions on property purchase (unlike other places, e.g., Switzerland), banking secrecy for residents, privacy, ease of cross-border living and overall excellent quality of life, Luxembourg is surely your best decision!

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GMS+ LUXEMBOURG FAMILY OFFICE Founded by Jean-Luc Jourdan in 1999, GMS+ is a Multi-Family Office based in Luxembourg City. GMS+ are chartered accountants, auditors, tax consultants, trust services providers as well as court-witnessed financial and economic experts. The goal of the services provided by GMS+ is the optimisation of your life’s assets. Our services begin with a frank analysis of your current situation in terms of:

• Asset protection • Investment performance • Legal compliance • Discretion • Tax efficiency • Complexity • Cost Each client situation is unique, but the services we generally offer to fine-tune our client’s situation are:

• Consulting and Structuring • Wealth Management & Investment Opportunities • Accounting, Tax & Economic Expertise and Services • Project Management (business venture, litigation…) • Corporate Finance & Fundraising • Consulting, Analytics, Marketing • Administrative, Secretarial and Business Centre Services • Private Concierge services for personal/ family tasks such as major purchases, immigration, relocation, education etc.

At GMS+ , our essence is to allow you to concentrate your focus on your core business and your family. With our earned trust will come the possibility to delegate all kinds of important but time consuming tasks and projects to GMS+.

MOVING TO LUXEMBOURG FOUR SIMPLE STEPS:

1. Our team of experts including an immigration attorney as well as tax, finance and relocation specialists devises a strategy tailored to your Family’s specific circumstances. 2. We execute the strategy that involves close mediation with Luxembourg banks and/or corporate structuring.

3. By now, different specialists have

come together to complete the necessary groundwork. We next submit your case to the Ministry of Foreign Affairs for approval. It typically takes 3 to 6 months.

4. Following the immigration permit

PERMIT DURATION AND NATIONALITY Depending on residency category, either one-year or three-year permits can be initially obtained. By the end of 5 years of residency, you may request a permanent resident status, or even citizenship - as per the 2017 law.

START YOUR LUXEMBOURG RESIDENCY PROJECT Our experts understand the exacting requirements of a UHNW clientele. Whilst subject to Luxembourg’s stringent privacy laws, the privacy of our clients is further assured by enforcing strict data management policies as well as providing our clients with a secure, private communication and project management app.

issuance, you need to relocate to Luxembourg within 6 months. Once arrived, our experts help you pass any outstanding formalities within 1-2 weeks, thereby completing the migration process!

At GMS+ Luxembourg Family Office , our clients are glad to know first hand the value of entrusting their private projects such as relocation to us.

In preparation and upon your arrival in Luxembourg, we help you pick the right housing, recruit domestic staff, register your vehicles, obtain the Luxembourgish driving licence, as well as secure utility, telephone, internet, and insurance services. Accordingly, we help you settle in your new home and take care of your day-to-day lifestyle demands.

You too can find out more about the advantages of doing business with GMS+ . Whatever project you have in mind feel free to message us right now via Telegram or What’sApp at +352621324923 , call us at +352 44 55 101 , e-mail us at info@ gms.plus or chat with us on our website at www.gms.plus.

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Excellence in Contract Publishing BLS Media is an innovative, progressive and creative media company with traditional attention to detail, led by experienced professionals. The EB-5 Gateway covers many different topics related to trade and investment in the US. This unique publication presents information regarding the EB-5 program that caters to a Middle-Eastern, North-African and Persian Gulf readership, giving advertisers an opportunity to reach this largely untouched market. CBI is an ultimate guide for Arab HNWIs looking to invest for residency/citizenship purposes. With an editorial focus on finance and investment, real estate, issues that face HNWI’s relocating, legislation around citizenship/residency and dedicated country spotlights among much more, CBI magazine has become the ultimate guide for Global Citizens looking to invest for citizenship purposes.

BLS Media Unit 5, Hiltongrove N1

+44 (0) 20 7241 1589

14 Southgate Rd

+44 (0) 871 314 0213

London N1 3LY

info@blsmedia.co.uk

www.blsmedia.co.uk

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A leading specialist in Residence and Citizenship Programmes.

The Integritas Group is a multi-disciplinary firm with extensive experience in providing corporate, trust, residence and citizenship services to its clients. The services provided include the incorporation and maintenance of companies, set up of trusts, provision of trustee and fiduciary services and assistance in the participation to the various residence programmes in Malta and in other jurisdictions; as well as the Individual Investor Programme (IIP), Malta’s popular citizenship programme. As a boutique firm, the Integritas Group provides a bespoke service and has a personalised relationship with its clients.

114/3, The Strand, Gzira GZR 1027 - Malta Phone: +356 23 850611 • Fax: +356 21 334405 Email: info@integritas-trustees.com • www.integritas-trustees.com

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Integritas Trustees Ltd (C 22574) is authorised by the Malta Financial Services Authority under the Trusts & Trustees Act. Integritas Consulting Ltd (C 52711) and Integritas Corporate-Services Ltd (C 52395) are licenced by the MFSA to act as Corporate Service Providers.

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Malta C  ountry Spotlight

T

his archipelago in the centre of the Mediterranean is rich in history, culture and natural beauty. The country offers a leisurely European lifestyle, in a divine Mediterranean setting. The cluster of islands is home to pristine beaches, fantastical lagoons, blissful architecture and invigorating entertainment. Malta was once a tall mountain joined to Italy by land. Over 10,000 years ago the sea level rose up and transformed Malta into a collection of small islands. The country was first cultivated by immigrants from Sicily in 5,200 BC and has since been host to a long succession of invaders and colonizers: from the Roman Empire to the Arabs, to the Turks, the French and then the British. Malta finally gained independence in 1964 and in 2004 joined the European Union. Such a convoluted history has resulted in a cultural identity blended with characteristics from all over the world. The Maltese climate is similar to that of its Mediterranean neighbours, with mild winters and hot dry summers. In summer there is an average of 12 hours of sunlight or five to six hours of sunlight in winter. Such a climate is ideal for making the most of everything Malta has to offer.

HARRIET PRENDERGAST Cuisine in Malta is based around the seasons. Winter brings with it rich bowls of minestra, a thick vegetable soup, as summer approaches Lampuki pie is served with fresh fish from the region. The gastronomy has been heavily influenced by the blended European culture in Malta and in some ways is considered to be the first ever fusion cuisine. The food picks up some of the best aspects of Sicilian, British, French and Mediterranean cuisines. This country is packed with entertainment opportunities for everyone in the family. The coastline of the islands present idyllic Mediterranean beaches from which to bask in the sun or sail around the archipelago. Water sports are also popular for the more adventurous, with the beaches offering prime locations for jet and water skiing, snorkelling and parasailing. The Blue Lagoon is the most prominent tourist attraction in Malta, considered one of the most luxurious spots in Europe with crystal clear, azure waters and a pristine beach. Despite being the smallest member of the European Union, Maltese architecture has graced the big screen as a set in the films

Troy, Gladiator and most recently as Kings Landing in the television series Game of Thrones. Ancient architecture paired with the Mediterranean climate make it an ideal, picturesque setting. The architectural landmarks on the islands are the grand Baroque churches and prehistoric temples. Baroque influences can be seen throughout the city landscapes. The capital city Valletta has been declared a UNESCO world heritage site for its buildings by the Knights of St John. While away an afternoon wandering the streets of the city and gazing at the architectural features of Malta, just as you would in a Baroquian art gallery. The cities and villages across the country host festivals of art, history, food and beer. The most famous being, the Medieval Mdina festival, during which the streets are transformed to recreate life in the middle ages. The social calendar is brimming with year round events; spring brings with it the carnival festival, followed by the Easter festival, then the fireworks, fashion, arts and jazz festivals, to name but a few. Each of these events create magical days of strolling around market stalls, feasting on delicious food and drink, revelling in fantastic entertainment and even better company. Citizenship By Investment 55

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ECONOMY

ELIGIBILITY

THINGS TO CONSIDER

The Maltese economy is one of the few in Europe to be recording positive growth. The country has experienced economic growth over the last three years, which is forecast to continue. The real GDP growth is predicted to remain strong and unemployment is at an all time low. The main sources of income in Malta lie in foreign industry, manufacturing and tourism. With a budget in surplus, Malta presents a strong, stable economic environment for immigrants.

To be eligible for citizenship by investment, applicants must: • Be over 18 • Be in good health • Have a clean criminal record • The main applicant is required to contribute €650,00 to Malta, plus 50,000 for every adult family member and 25,000 for under 18 • Spouses and children are required to contribute €25,000 each • Unmarried children between 18 an 25 and dependant parents are required to contribute €50,000 each (these contributions can be made after application approval) • Applicants are required to invest at least €350,000 in property or enter a rental property agreement for a at least €16,000 p.a. both on five year contracts • Applicants are required to invest €150,000 in bonds or shares. The investments must be in Stock sanctioned by the Maltese government • Applications can be supported by a genuine link to Malta through residence

Citizenship by investment entitles the holder to visa free travel to more than 166 countries and gives the right to live, work and study in any country in the European Union. The Maltese tax system is based on domicile and residence, rather than citizenship. Tax is only due on income and capital gains arising in Malta. After a period of five years property can be sold in Malta completely tax free, so long as it was the resident’s sole residence for at least three years. If selling the property before three years of residence a tax of 12% is charged on the selling price. In addition, there are no inheritance or death taxes, no net worth or wealth taxes, no municipal taxes, rates or real estate taxes and no estate duty. With tax benefits such as these, a stable economic climate and banks ranked as some of the most stable in the world, investment in Malta is a sound way to gain citizenship.

CITIZENSHIP BY INVESTMENT Gaining citizenship in Malta via investment is a simple, quick process which can allow the entire family to immigrate with ease. Citizenship is typically approved after just four months processing time. Family eligibility extends to parents of the applicant and spouse, minor children and unmarried adult children under 27. Descendants gain citizenship automatically.

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Malta: the expats’ choice In a world of ever-increasing global mobility with countless options, why does Malta consistently stand out as a destination of choice?

BY SIMON XUEREB

MALTA’S EXPATRIATE POPULATION HAS EXPLODED OVER RECENT YEARS AND SHOWS NO SIGNS OF SLOWING DOWN, TO WHAT WOULD YOU ATTRIBUTE THIS SUCCESS? This success can be attributed to an interlinked convergence of various factors which have led to increased economic growth with positive spill over effects. Malta’s friendly business environment and tax efficiency is underpinned by an economic growth that remains amongst the strongest of the Eurozone. GDP for 2017 Q3 increased by 7.2% in annual terms, slightly below the 7.9% in the previous year, but impressive nonetheless. Growth was mainly driven by increased government consumption coupled with robust growth in household consumption, reinforced by higher wages. Official statistics show that the 2017 budget swayed from a deficit to a slight surplus for the January to October period compared to the previous year. The

resultant surplus is the outcome of growth in annual revenue, particularly from VAT and income taxes, which outperformed expenditure. Economic growth was accompanied by a strong upsurge in employment, unemployment continued on its downward trend in October 2017 and both tourist inflows and expenditure continued to increase at more than 10% year-on-year. It is also important to bear in mind that the tourism and digital gaming industries, among others, are projected to continue to expand. This economic environment coupled with historic low levels of unemployment, mean that existing Maltese employers and employers relocating operations to Malta are recruiting from the rest of the EU (and sometimes further afield), which has resulted in the dramatic growth of Malta’s expatriate population. Coupled with this, we are also experiencing an unprecedented influx of High Net Worth Individuals seeking to relocate to Malta both for

personal reasons (i.e. safety and security, stability and a favourable tax environment) as well as to establish or relocate their business operations to Malta.

WHAT ARE THE KEY CATEGORIES OF PEOPLE CHOOSING TO RELOCATE TO MALTA AND WHY? In general terms, one can classify the majority of expatriates who relocate to Malta into three main categories. Firstly, those who relocate to Malta seeking job opportunities here in view of the Islands’ continued growth and success. This, notwithstanding the economic turbulence afflicting not only neighbouring countries but the international community over the last few years. Secondly, we are witnessing a constant and progressive increase of business owners who are relocating their businesses or parts thereof to Malta, in view of Malta’s business friendly environment and corporate tax system. Thirdly, High-Net Worth Individuals are

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Economic growth was accompanied by a strong upsurge in employment, unemployment continued on its downward trend in October 2017 and both tourist inows and expenditure continued to increase at more than 10% year-on-year.

combining the relocation of their business to Malta with their personal relocation to Malta, or are otherwise attracted to Malta for personal reasons, choosing to take up residence and/or citizenship in Malta through the various progammes which Malta offers in this space.

WHAT ARE THE KEY ROUTES TO TAKING UP RESIDENCE / CITIZENSHIP IN MALTA? Depending upon one’s nationality and the purpose behind one’s relocation to Malta, there are a number of different routes to taking up residence. As a starting point, EU Nationals of course benefit from free movement and can take up residence in Malta subject to few limitations. However, EU Nationals may still benefit from programmes such as the Residence Programme Rules which, subject to certain conditions, provide for a flat 15% tax rate upon certain types of qualifying income, depending upon which programme is taken up i.e. the Residence Programme Rules

which provides for a flat 15% tax rate upon foreign source income which is received / remitted to Malta. This, coupled with the standard remittance basis rules which only bring to charge to Maltese tax foreign source income to the extent that this is received in Malta (i.e. foreign source income not received in Malta would not be subject to Maltese tax) and provides a highly attractive tax environment for relocating expats with significant income arising outside of Malta. In addition, other programmes such as the qualifying employment in aviation rules, the highly qualified persons rules and the qualifying employment in innovation and creativity rules provide for a flat 15% rate of Maltese tax upon the employment income derived from qualifying employments for a set period following relocation to Malta, provide attractive tax rules for employees relocating to work in Malta for a defined period. Similar programmes also exist for 3rd country nationals, who may take up residence in Malta on the basis of either

their employment (subject to a work permit), in terms of such a tax status with the related benefits thereof; in terms of a significant investment into their own business in Malta (entrepreneur work permit); or in terms of one of the pure immigration statuses offered: the Malta residence and Visa Programme or the Malta Individual Investor Programme. The Malta Residence and Visa programme would provide a beneficiary with a Maltese residence card which allows for residence in Malta and VISA free travel through the Schengen area (subject to a rolling 3 month travel restriction), subject to the fulfilment of various conditions, namely an investment of EUR250,000 in Malta government bonds and the acquisition by way of purchase or rent of an appropriate property in Malta. The Malta Individual Investor Programme (MIIP), offers applicants who satisfy industry leading due diligence and who have effected significant qualifying investment into Malta, the opportunity to acquire Maltese citizenship with all the concordant benefits of EU citizenship. Citizenship By Investment 59

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Malta: There’s Power in Property Investment With rental investments that secure a 5% annual return and property prices that continue to go up, it’s no wonder that the international community has set its sight on property in Malta. Here we consider why this Mediterranean haven has become a hotspot for those keen to expand their property portfolio.

W

ho could have imagined the sheer potential of a tiny island in the middle of the Mediterranean?

In just the span of a couple of decades, Malta has gone from being a holiday spot purely popular for sun-and-sea breaks, to a destination that attracts luxury travellers, global companies and eager business investors – all of whom want a piece of what this petite island nation has to offer. As a result, the property industry has exploded. More and more international visitors and expats are choosing to buy here, whether as a home, a place to get away to, or a rental investment. The limited supply of land has meant the property costs have continued to rise, and prices here remained steady, even during the Europewide property crash. Property prices have shown consistent growth over recent years. This has given investors an excellent return, whether they bought their home to live in and sell at a later date, or to rent. Naturally, the Maltese lifestyle is a huge draw in itself. It may sound cliché to say that the island has something for everyone but it really does, with a dynamic history, culture and way of life that enthrals its visitors. Once here, visitors get to experience the very best that the Mediterranean has to offer

from world-class restaurants, international cuisines and sophisticated bars, to undiscovered coves on the coast that make for a dreamy afternoon getaway. In fact, it is this balance of modern living and stark natural landscape, as well as the fabulous mix of old and new, that continues to make Malta such an exciting and dynamic place to live and invest in. The range of properties also provides thrilling prospects for investors. You can choose from large apartments with unobstructed sea views and historic character houses in tiny villages, to sprawling villas with pools and plenty of outdoor space for entertaining. There are unconverted properties with oodles of potential and ‘ready-made’ homes in chic contemporary developments – both of which delight investors keen on adding something different to their portfolios. With a population of just over 400,000, there’s also an eclectic mix of people in Malta. There’s now an established, and constantly-growing, expat community with individuals from all over the world. Many have been drawn here for business reasons and to make the most of the many incentives for start-ups and companies in the iGaming and financial services sectors. Others have chosen Malta as the perfect place to retire to or retreat to. The island is also a safe haven for families

to raise their children, with excellent healthcare and education systems that mirror the best European and US models. The English-speaking population makes it easy to settle in, while the close proximity to the rest or Europe and the umpteen flights in and out of the Malta everyday, make it easy for people to work in and commute to. In addition to all these, there are also several incentives to encourage individuals and companies to invest in Malta. The island’s economy remains one of the better performing ones within the Eurozone, while preferential taxation rates exist for high net-worth individuals and those keen to invest. Special Designated Areas – modern developments ideal for expat living and as rental investments – have also been created to facilitate international buyers. Altogether this creates an appealing mix that fulfils so many diverse criteria. Finally, Malta is also a place where people can really make the most of their work-life balance: time seems to go slower in Malta, and it’s so easy to travel around the island that you can be on the beach or by the pool just minutes after leaving the office. So, if you have ever imagined owning a little piece of paradise, then this may really be the place to find it and make it your own – whether as a wonderful home or an excellent real estate investment. Citizenship By Investment 61

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MALTA RESIDENCE AND VISA PROGRAMME Non-EU Nationals interested in taking up permanent residence in Malta can now avail themselves of the Malta Residence and Visa Programme. This programme follows on the success of the Malta Individual Investor Programme (Citizenship) and allows the beneficiaries together with their registered dependents to reside, settle or stay indefinitely in Malta.

Eligibility to the Malta Residence and Visa Programme requires applicants to satisfy a three-tier investment, including: • A non-refundable initial contribution of €30,000, in the manner as requested by Identity Malta • A qualifying investment in a form determined by Identity Malta having an initial value of €250,000. This investment ought to be held for a minimum period of 5 years from the date of issue of the Malta Residence and Visa Programme certificate; • Hold title to a qualifying property, be it through outright purchase or long term lease, which must be held for a minimum period of 5 years from the date of issue of the certificate.

• Either ownership of an immovable property purchased for not less than €320,000 for a property situated in Malta, or €270,000 for a property situated in Gozo or in the South of Malta; OR • Leasing of an immovable property for a rental value of not less than €12,000 per annum in the case of property situated in Malta or €10,000 per annum in the case of propErty situated in Gozo or in the South of Malta. More information about this programme can be found on www.franksalt.com.mt

GLOBAL RESIDENCE PROGRAMME In June 2013, the Global Residence Programme was launched for non-EU foreigners, offering great advantages and favourable thresholds. Under the Global Residence Programme, the value of the immovable property bought in Malta by foreigners has to be at least €275,000. However, when the property is in the south of Malta or in Gozo, the minimum value can be €220,000. • Applicants will also be eligible if they rent property on an annual basis of €9,600 in Malta and €8,750 in Gozo or in the South of Malta.

• Residents under this Programme and their dependents, have to be covered by health insurance. They will not be entitled to free state health services. • The new Residence Programme for Foreigners replaces the High Net Worth Individuals Scheme for non-EU foreigners. • A standard application processing fee of €6,000 is applicable if a property is purchased in Malta and €5,500 if the property is bought in Gozo or South of Malta. • There are no minimum stay requirements. More information about this programme can be found on www.franksalt.com.mt

Frank Salt Real Estate Malta T: + 356 2379 4794 E: fs@franksalt.com.mt www.franksalt.com.mt

• Minimum tax to be paid in advance reduced to €15,000 on income derived in Malta, with further income charged at 15%.

914109

036999

036331

318020

Beautifully laid out, furnished 3-bedroom, corner APARTMENT in one of the best blocks within this prestigious complex. Entrance leads onto a well-lit, split-level open-plan kitchen, living and dining area with fantastic views of the marina and beyond. A large terrace can accommodate al fresco dining. A wide corridor houses a washroom/laundry, guest toilet, main bathroom and 3 bedrooms (two with en suite) and each with their own balcony/ terrace. The main bedroom is a lavish 60sqm with walk-through wardrobe, study area, en suite, lounge area and a jacuzzi. All bedrooms command views of Balluta Bay. Further complementing this property is a car space.

An amazing seafront APARTMENT finished to very high standards enjoying scenic views of the marina, Valletta Bastions, Sa Mason Creek and beyond. The layout consists of an entrance hall, a 68sqm open plan comprising of the living/dining/ kitchen area leading onto a sizable terrace with space for entertainment, 3 double bedrooms (all with en-suite facilities), 2 having terraces, guest toilet, laundry room and study. Further complementing this apartment is a car space.

Superb seafront APARTMENT located in the prestigious marina complex of Portomaso. Recently refurbished, 270sqm layout consisting of a wide entrance hall, fitted kitchen, dining/lounge area leading to a large front terrace with great marina views ideal for entertaining, three double bedrooms (all enjoying an en suite and the main set to the front of the property with direct access to the large terrace). The terrace itself can be fully enclosed by a glass curtain which runs through the entire width of the property.

Expertly converted designer finished HOUSE OF CHARACTER in one of the prettiest streets in Naxxar. Finished to very high standards whilst also adorned with many of its original features, this property comprises traditional Maltese Entrance (Remissa), double volume living area, separate dining room, fully equipped kitchen with breakfast area all leading into a large pretty central courtyard, guest toilet, four double bedrooms (all served with en suite shower), main bedroom with walk-in wardrobe and en suite bathroom, store room and laundry room with own roof. This beautiful house is also equipped with a lift to facilitate access to all floors.

APARTMENT IN PORTOMASO €1,800,000

FINISHED APARTMENT IN TA’ XBIEX €1,500,000

FINISHED APARTMENT IN PORTOMASO €1,495,000

HOUSE OF CHARACTER IN NAXXAR €800,000

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Portugal C  ountry Spotlight

P

ortugal calls itself home to over 10.5 million of its citizens and can be found on the Iberian Peninsula, bordering Spain and the Atlantic Ocean. The capital city is named Lisbon and has a population of 552,700. The fact that the country faces ocean side has influenced many aspects of its culture – its beautiful beaches prove to be a very popular tourist destination and in fact much of the countries architecture is rooted in its rich history which harkens back to as early as the 1500s when Portugal had a maritime empire. Culturally, Portugal is extremely refined, and features a unique mixture of tradition and modernity which you will struggle to find in any other location. Its breath taking landscape, fine cuisine and even finer wines are the perfect medicine for all holiday goers suffering from the dreariness of everyday life. The climate could be described as mild, but the 3000 hours of sunshine a year and 850kms of beaches that these sun rays visit are great for those looking for an increase in Vitamin D. Although Portugal is great for some mindless relaxation, do not mistake it for a

country without substance. It’s history is one of ups and downs, as in in the 15th and 16th centuries is grew to become what was the first global empire, becoming one of the world’s major economic, political and military powers and expanding Western influence across the globe. However, as with all great empires, it was met with many setbacks and finally with the destruction of its capital city, Lisbon, in 1755 at the hands of an earthquake, Portugal lost much of its power. Perhaps this history can be reflected in the spirit of the Portugal’s people who are known to celebrate what they have as they know that at any moment, life can throw a curveball and everything can be taken away. There is a real communal sense that one should live for today and it leads to a very pleasant atmosphere which is infectious – it is difficult to worry when you are in the company of Portuguese citizens. A large majority of Portugal’s citizens are Roman Catholic but it is home to a large number of small communities representing different faiths and so it gives off a welcoming impression to all who grace its borders. The official language of the natives is Portuguese and it derives itself from early Latin. Although

if Portuguese is not your first language, you should not fear as according to International English Proficiency Index, Portugal has a high proficiency level in English, proficiency higher than in countries like Italy, France or Greece.

CITIZENSHIP BY INVESTMENT IN PORTUGAL Many people, after spending time in Portugal, come to the conclusion that they would like to live there permanently. To these people, there is some good news, citizenship by investment is entirely possible in Portugal, but you will need to invest a minimum of EURO 500,000 in order to qualify for a “golden visa”. Once you have acquired a golden visa, it is then possible to apply to become a citizen of Portugal after six years. In comparison to other some other EU countries, the minimum cost of investment is a little higher, but there are many benefits to Portuguese citizenship, including low tax rates, low minimum stay periods and, of course, the benefits of a climate and culture that are in-line with each other – easy going, with hot periods.

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ROUTES TO CBI IN PORTUGAL • Property Investments: - Acquisition of property above EUR 500,000. - Acquisition of property above EUR 350,000 - for properties more than 30 years old or located in areas of urban renovation. • Capital Investments: - Transfer of Funds above EUR 1,000,000. - Transfer of Funds above EUR 350,000 for research activities. - Transfer of Funds above EUR 250,000 for artistic or cultural activities. - Transfer of Funds above EUR 500,000 for capitalization of small and medium size companies. • Job creation: - Creation of a minimum of 10 jobs. It should be noted that only investments effectively made after 8th October 2012 are eligible for the Golden Visa programme. Once issued, the Golden Visa will be valid for an initial period of 1 (one) year and then will be renewed for subsequent periods of 2 (two) years. The simplicity of the Golden Visa Programme implies an extremely reduced amount of requirements being asked from the investor. The Golden Visa Programme sets out that the investor must comply with general requirements applicable to all types of qualifying investments and also with the

specific requirements of each type of qualifying investment. In general, all investors have to comply with the following requirements: • Keep the investment for a minimum period of 5 years • Funds for investment should come from abroad • Entry in Portugal with a valid Schengen visa • Absence of references in the Portuguese Immigration and the Schengen services • Absence of conviction of relevant crime • Minimum stay in Portugal: 7 (seven) days during the first year and 14 (fourteen) days during each subsequent period of two years

PORTUGAL IN SUMMARY While being a more expensive option than some of its neighbours, Portugal offers investors a warm and friendly climate, gorgeous coastlines and vibrant cities in which to seek residence. Diverse, beautiful and culturally arresting, Portugal, in many ways, offers bits of the best of all of Europe.

Portugal is extremely refined and features a unique mixture of tradition and modernity which you will struggle to find in any other location. Citizenship By Investment 65

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Saint Lucia Country Spotlight

S

aint Lucia is a small part of paradise located in the Eastern Caribbean Sea. The varied landscape has something to offer all visitors: from the vast expanses of sandy beaches to the awe inspiring Piton mountains, Saint Lucia makes for a sensational setting. Citizenship in Saint Lucia is the opportunity to escape to a tropical life surrounded by nature’s finest creations. The island hosts a variety of possible activities for its visitors and residents, with world class dining and luxurious spas being just two of the possibilities.

GEOGRAPHY Saint Lucia is located on the boundary between the Eastern Caribbean Sea and the Atlantic Ocean. The island lies northeast of Saint Vincent, northwest of Barbados and to the south of Martinique. The capital city of Saint Lucia is Castries, which houses 60,263 Saint Lucians (32.4% of the population). In total, the island covers a land area of 617 km sq. Saint Lucia is the only country in the world to have been named after a woman. The local climate of the island is tropical. The year typically features a dry season from December until the end of May, and a wet season from June until the end of November. The average daytime temperature is an

estimated 29 degrees; as the island is located near to the equator, the temperature does not vary greatly throughout the year. From 1663 until 1979, Saint Lucia was in both French and British control. Between 1667 and 1814, control switched between French and British hands a total of 14 times. Due to the development of the sugar industry, Saint Lucia was considered an attractive colony to hold. In 1814, Saint Lucia was firmly under British control until it became an independent state of the Commonwealth of Nations associated with the United Kingdom in 1979. The official language of Saint Lucia is English, however Saint Lucian Creole French are considered vernacular languages of the island.

POLITICS Saint Lucia is a two party parliamentary democracy, and a Commonwealth nation. Queen Elizabeth II is the Head of State, and her presence is represented by a Governor-General. The Prime Minister is usually the head of the party that commands a majority in the House of Assembly. There are 17 seats in the House of Assembly, and 11 seats in the second chamber of Parliament, the Senate. As well as being a member of the Commonwealth, Saint Lucia is a member of CARICOM (the Caribbean community) and the Organisation of Eastern Caribbean States. It maintains friendly relations with all of the active

major powers in the Caribbean - the United States of America, Canada, France and the United Kingdom.

BACKGROUND Saint Lucia Citizenship by Investment Program was founded in 2015 under the regulations of the Citizenship by Investment Bill 2015 making it the newest programme to join the other Citizenship by Investment Programs (CIP) in the Caribbean region. The Saint Lucia Citizenship By Investment Program was launched at the Bay Gardens Beach Resort on December 29th, 2015. The program officially began accepting applications on January 1st, 2016.

BENEFITS • Applications, including those with dependents, will be processed within 3 months • No residency requirements • Passport allows for visa-free movement to 120+ countries, including UK, Hong Kong, and 28 EU countries within the Schengen Area • Application process does not include interview or visit to Saint Lucia • Education and managerial experience are not required • Global income is not taxed

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HOW TO QUALIFY

REAL ESTATE PROJECTS

Those wishing to secure a Saint Lucian passport through Citizenship By Investment Programme must be at least 18 years of age, have no criminal record, and be in good health. Furthermore, in order to qualify for Citizenship in Saint Lucia, investors must fulfil one of the four following investment options.

The Cabinet of Ministers will evaluate proposed real estate projects for the possibility of citizenship. Approved real estate projects can come under two categories:

SAINT LUCIA NATIONAL ECONOMIC FUND (NEF) Saint Lucia National Economic Fund is a fund established to receive investments of cash from the citizenship program that will be used in the funding of government sponsored projects. The Finance Minister must seek approval from Parliament for the allocation of funds for his chosen purposes. Once an application for citizenship through investment in the Saint Lucia National Economic Fund has been approved, an investment as follows is required: • Single applicant: US$100,000 • Main Applicant plus Spouse: US$165,000 • Applicant applying with spouse and up to two other qualifying dependants: US$190,000 • Each extra qualifying dependant, of any age: US$25,000

• Luxury branded hotels and resorts • Luxury boutique properties The applicant must enter into a binding purchase and sales agreement for an investment in an approved real estate project. Investments, totalling the agreed purchase price, are deposited in an escrow account managed both by the property developer as well as the Saint Lucia based Citizenship by Investment Unit. • Minimum investment required: US $300,000

ENTERPRISE PROJECTS The Cabinet will evaluate enterprise projects to appear on the approved list for the Citizenship by Investment Programme. Approved enterprise projects come under seven categories: • Specialty Restaurants • Cruise ports and marinas • Agro-processing plants • Pharmaceutical products • Ports, bridges, roads and highways • Research institutions and facilities - Offshore universities

Once approved the enterprise project becomes available for further investments from other applicants for citizenship by investment. The following minimum investment is required: Option 1 – A sole applicant. • A minimum investment of US$3,500,000 Option 2 – More than one applicant (joint venture). • A minimum investment of US$ 6,000,000 with each applicant contributing no less than US$1,000,000

GOVERNMENT BONDS Citizenship by investment may be made through the purchase of non-interest-bearing Government bonds. These bonds must be registered and remain in the name of the applicant for a five (5) year holding period from the date of first issue and not attract a rate of interest. Once an application for citizenship by means of an investment in government bonds has been approved, the following minimum investment is required: • Sole applicant: US$500,000 • Couple (Applicant and spouse): US$535,000 • Applicant applying with spouse and up to two dependants: US$550,000 • Each extra dependant: US$25,000

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St Kitts & Nevis C  ountry Spotlight

S

t Kitts & Nevis can be found in the northern Leeward Islands of the Caribbean, tucked away and brimming with beautiful nature and a lengthy and rich cultural history. It has something for everyone, whether your preferred activities are fishing, water sports, golfing, sailing, going for a nice meal, or simply relaxing on the sandy, palm fringed beaches. Although small, Nevis is an unspoiled playground with empty beaches that stretch as far as the eye can see. If you are looking for a place to escape the hustle and bustle of everyday Western life and to find some tranquility, Nevis may be the perfect place for you. There’s also ample opportunity to lose yourself in fishing, diving and a number of other water based activities. There are a plethora of wrecks, caves, walls and pristine reefs just waiting to be explored.

CITIZENSHIP OF ST KITTS & NEVIS The Government of St Kitts & Nevis has introduced extensive legislation to attract financial services businesses to the island.

The Citizenship by Investment Programme has also been in operation since 1984, allowing foreign investors to acquire citizenship under certain conditions. This makes it the oldest existing citizenship programme in the world, as well as the most reputable citizenship programme in existence. One can invest in designated real estate or contribute to the Sugar Industry Diversification Foundation (SIDF).

USD 400,000 – in one of the approved real estate developments in addition to paying Government fees, due diligence fees and taxes – or a contribution to the Sugar Industry Diversification Foundation (SIDF) to the amount of USD 250,000 (for a single applicant). SIDF contributions do not require the payment of Government fees, but small diligence fees still apply.

St Kitts & Nevis citizenship is highly regarded. As a result, St Kitts & Nevis citizens enjoy a passport with an excellent reputation and very good visa-free travel, including to all of the EU’s Schengen Area, Hong Kong, Switzerland, and other countries. Accordingly, the St Kitts & Nevis Citizenship by Investment Programme is an attractive option if one is looking to acquire a second citizenship through investment without prior residence requirements.

BENEFITS

The Citizenship Programme of St Kitts & Nevis requires applicants to make an economic contribution to the country. In exchange, they are granted full citizenship. To qualify for citizenship, the applicant must make either an investment of at least

When you acquire citizenship under the St Kitts & Nevis Citizenship Programme, you and your family enjoy full citizenship for life, which can be passed on to future generations by descent. As a citizen of St Kitts & Nevis, you have the right to take up residence in St Kitts & Nevis at any time and for any length of time. You will not be taxed on foreign income, capital gains, gift, wealth, or inheritance tax so this may complement your current wealth protection and tax planning strategies.

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REQUIREMENTS AND PROCEDURES Real Estate Option To qualify for citizenship of St Kitts and Nevis under the real estate option of its Citizenship by Investment Programme, the applicant must make an investment in designated real estate with a value of at least USD 400,000. St Kitts and Nevis Launches Hurricane Relief Fund, Reducing CBI Fees The Citizenship by Investment Unit has launched the Hurricane Relief Fund (HRF) Investment Contribution to assist the Government with repairs to public infrastructure and private property damaged during the 2017 Hurricane season. The HRF option will be available for a six (6) months period ending on March 30th 2018. The HRF will assist with Hurricane Relief efforts not only in St Kitts and Nevis but it is envisioned that these efforts can be extended to support neighbouring countries in the Caribbean who have been affected this hurricane season. The CIU Hurricane Relief Fund Investment Contribution • Single applicant: US$150,000 • Main applicant with up to 3 dependents: US$150,000 • Additional dependents, regardless of Age: US$25,000

ON APPROVAL IN PRINCIPLE OF AN APPLICATION UNDER THE REAL ESTATE INVESTMENT OPTION THE FOLLOWING FEES ARE PAYABLE TO THE GOVERNMENT OF ST KITTS AND NEVIS: • USD 50,000.00 for the main applicant. • USD 25,000.00 for the spouse of the main applicant • USD 25,000.00 for each child of the main applicant under the age of 18 other than the spouse. • USD 50,000.00 for each qualified dependant of the main applicant above the age of 18 other than spouse • Qualifying dependants include children over 18 years but below 30 who are in a dependency relationship with their parents. In addition, they include parents and grandparents aged 55 or over living with and dependent on the main applicant. Additionally to these fees, real-estate buyers should be aware that there are also purchase costs (mainly compulsory insurance fund contribution and conveyance fees) of approximately 4–5% of the purchase price. Only villas and condominium units from an approved developer will qualify for citizenship.

Upon submission of an application, non-refundable due diligence and processing fees must be also paid. These fees amount to US$7,500 for the main applicant, and US$4,000 for each dependent of the main application. Unmarried dependent children who are older than 18 but younger than 30 can also be included in the application. Similarly, dependent parents aged 55 or above may also be included. SIDF Contribution To qualify for citizenship of St Kitts and Nevis under the SIDF option, the Government requires a contribution to the St Kitts and Nevis Sugar Industry Diversification Foundation, a public charity. Under this option, there are several alternatives available: 1. Single Applicant: a non-refundable contribution of USD 250,000 is required. 2. Applicant with up to three family members, for example one spouse and two dependants irrespective of age: a non-refundable contribution of USD 300,000 is required. 3. Any additional dependant, regardless of age: USD 25,000 In each of these categories, the above amounts include all government fees with the exception of due diligence fees. Children aged 30 or under and parents or grandparents aged at least 55 may also be included in the application if they fulfil certain terms. USD 7,500.00 for due diligence for the main applicant. USD 4,000.00 for due diligence for each dependant over 16 years. Citizenship By Investment 71

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Brexit and Investment Migration to the UK MISHCON DE REYA

T

he UK has a long history of welcoming talent and investment from overseas. This practice has led to the creation of a diverse and culturally rich society which appeals to those seeking not only tax efficiency, but political stability, excellent educational opportunities and the benefits that flow from the UK’s tradition of upholding the rule of law. However, immigration policy in the UK is currently in a state of flux, and there is uncertainty surrounding the future landscape of migration to this country. This uncertainty emanates, most notably, from the Referendum decision of 23 June 2016, in which the UK public voted to leave the European Union (the ‘EU’).

Immigration was at the centre of the debate surrounding the UK’s continued membership of the EU, and the UK government has come under increasing pressure to reduce the numbers of individuals migrating to its shores. Britain once had an open door policy when it came to immigration but since the late 20th century, rising immigration in the UK has triggered a debate about immigration controls. As part of its Brexit agenda, the UK government has pledged to introduce new migration controls for European Economic Area (EEA) nationals and their family members, and is also expected to introduce changes to the UK’s domestic immigration system. Such changes will inevitably impact the ways in which both non-EEA and EEA

individuals, including those with the capacity to invest, seek to come to this country.

THE END OF FREE MOVEMENT? With the UK set to leave the EU in March 2019, the detail concerning the future relationship between the UK and the EU, including trading and immigration arrangements (amongst many other matters), remains unknown. The UK Prime Minister, Theresa May, has given several speeches on the topic of Brexit, but the landscape of postBrexit Britain is still up for negotiation. On 17 January 2017, Theresa May announced her priorities for the government’s Brexit negotiations in her much-anticipated Lancaster House keynote

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speech. Her priorities included the “control” of migration between the UK and the EU: the Prime Minister confirmed that the government intends to impose restrictions on EEA nationals and their family members entering the UK after Brexit. Clearly, the imposition of such controls would represent a seismic shift in the landscape of UK immigration policy. Currently, qualifying citizens of EEA countries, and certain non-EEA family members, have the right to live in the UK without a visa by virtue of EU free movement law. However, after Brexit, this is likely to change, and the current rights of EEA citizens and their family members to reside in the UK are expected to become more restrictive. At present, those who have resided in the

UK for five years or more under European law may qualify for permanent residence and potentially British citizenship, subject to meeting the relevant rules. EEA nationals who have resided in the UK for less than five years may qualify for a registration certificate. Similarly, the non-European family members of EEA nationals, such as spouses/ civil-partners, children or other dependants, may also be able to apply for an EEA family permit, residence card or permanent residence card to formalise their status. It is a common misconception that all EEA nationals have the right to formal residence in the UK (by way of an immigration document issued by the Home Office, such as a permanent residence card). In reality, only those who meet certain qualifying conditions are eligible to have

their right of residence recognised. For example, if you are a student or a selfsufficient person and wish to have your right of residence in the UK recognised by the Home Office, you (and any family members who you wish to include in your application) are required to hold ‘’comprehensive sickness insurance’’ (CSI). Those who wish to apply for permanent residence must be able to show that they have held CSI for a full five year period. What constitutes CSI is unclear. The Home Office’s policy guidance tells caseworkers that CSI is that which covers ‘’the costs of the majority of medical treatment [the applicant] may receive in the UK...’’ The government has also stated that CSI means ‘’full health insurance’’, although it does not define what ‘’full’’ means. Clearly, students and self-sufficient persons, who may have resided in the UK for a large part of their lives, will be adversely affected and unable to obtain a permanent right of residence in the UK if they were unaware (as many are) of the CSI requirement. This is also counter-intuitive as many high net worth applicants have more than sufficient funds never to require CSI, since they have ample means to meet the cost of the best health care available. This argument, however, has not been accepted by the UK immigration authorities, leaving the very people the UK seeks to attract in limbo. A study by the Institute for Government in the UK (IFG) states that two million of the three million EEA nationals currently in the UK have resided here for five years or more, and could therefore qualify for permanent residence. Many of the remaining one million would qualify in 2019, by the time the UK is expected to leave the EU. The IFG’s report notes that in order to process the applications of all those currently eligible for a residence document by the time the UK leaves the EU, the Home Office would need to make approximately 3,600 decisions per day. Currently, the Home Office is making approximately 650 decisions per day. At the Home Office’s current rate, it would therefore take 11 years to process the millions of applications from EEA nationals residing in this country. The UK government has remained silent on how it will address this issue. Clearly, there will be changes to the current rights of EEA nationals to reside in the UK as a result of Brexit, and the UK government’s reassurances in this regard have fallen far short of what EU campaigners and the EU27 desire. In a leaked Home Office document concerning the future of immigration policy in the UK, it appears that the government plans to dramatically reduce the numbers of low-skilled migrants coming to the UK’s shores. It also describes plans to place tougher restrictions on the rights of EEA nationals to settle in the UK, and in particular on their right to bring in family members. The impact of such measures on both the UK economy and population as a whole could be huge. There are numerous questions which will need to be addressed in light of the UK’s exit from the EU from an immigration perspective. For example, will existing EEA Citizenship By Investment 73

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residents who are in the UK on a certain date have their rights preserved? If so, how would this be practically enforced? How will the UK ensure that it attracts and retains talent in this country? The answers to such questions, and to many others, remain to be seen. By seeking to set laws at a national level, the UK has implied that it will have the ability to forge new arrangements with nonEEA countries after Brexit. For example, on a recent trade visit to India in November, Theresa May said the 33-strong delegation had sealed deals worth £1billion, laying the groundwork for more than 1,300 jobs in the UK. However, YK Sinha, India’s High Commissioner to the UK, has warned that after Brexit it may take up to a decade for the two countries to negotiate a free trade deal, and that the “freer movement of people and professionals” would be a crucial component of any deal. In other words, Britain must accept higher levels of immigration from India if it hopes to sign a free trade agreement after Brexit. Similar views have been expressed by other non-EEA countries with whom the UK could potentially create agreements, such as Australia. Currently, whilst EEA nationals may enter the UK to work without a visa, non-EEA nationals who wish to work in the UK are usually required to apply for sponsorship under Tier 2 of the Points Based System, which obliges them to meet minimum skill and salary levels. There is a monthly cap on the number of workers who may enter the UK in this capacity, and such a cap was reached in both December 2017 and January 2018, meaning that many workers with valuable skills were unable to make visa applications in December 2017 and January 2018. After Brexit, it is likely that the UK will need to

…one notable outcome of the Brexit vote from a high net worth immigration perspective has been a significant rise in Tier 1 (Investor) applications overhaul its current immigration system in order to accommodate the numbers of individuals applying for visas to work in this country. Whether specific deals will be struck to facilitate the movement of workers from certain countries such as India remains to be seen. Whilst the impact of Brexit on economic migration to the UK is likely to be huge, it is also likely to have ramifications for those wishing to invest in the country.

IMPACT ON THE TIER 1 (INVESTOR) VISA What long-term impact the UK’s exit from the EU will have on high net worth migration to the UK is difficult to predict before Brexit. However, in the short-term it appears that, despite the political and economic uncertainty triggered by Brexit, the UK is continuing to attract overseas investors

to its shores. Indeed, one notable outcome of the Brexit vote from a high net worth immigration perspective has been a significant rise in Tier 1 (Investor) applications. The Tier 1 (Investor) visa is a fantastic option for those with the capacity to invest in the UK. It allows a high degree of flexibility and allows the main applicant and their qualifying family members to live, work, study and set-up a business in the UK without restriction. The visa is aimed at those with access to at least £2million to invest in UK government bonds, UK equities or loan capital in active UK registered companies (excluding those principally engaged in property investment). Applicants can also bring their partner and minor children with them to the UK, who can all live, work, study or establish a business in this country throughout the validity of their visas. The initial visa is usually granted for three years, with the possibility to extend for an

additional two. Having spent five years in the UK on this visa - or less, depending on the level of investment - the investor can become eligible to settle in the UK permanently. Once permanent residence (known as Indefinite Leave to Remain in the UK) is achieved, applicants may withdraw their investments. Those who invest at least £5million can become eligible to settle after three years, and those investing at least £10million can become eligible after just two years. Those who have spent five years in the UK (in compliance with the relevant requirement of their immigration status) can then apply for British citizenship and a British passport. Before the Referendum decision of June 2016, the number of individuals applying for Tier 1 (Investor) visas had been on the decline. Data from the Office of National Statistics in the UK showed that the number of Tier 1 (Investor) visas granted by the UK fell from nearly 3000 in 2014, to 708 in

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2015, and only 217 in the first half of 2016. The decline can be attributed in part to the doubling of the minimum level of investment from £1million to £2million in November 2014. However, it is not only the greater level of investment that has presented difficulties for potential applicants. Following the change to the Investor visa rules in November 2014, the investor is now also required to have opened a bank account in the UK prior to applying for the visa, and must therefore have passed the bank’s stringent scrutiny regulations. This of course poses significant difficulties for nationals of certain countries, such as Iran, who often struggle to open a UK account in a timely manner as a result of the bank’s interpretation of their regulatory obligations and/or international sanctions. Furthermore, those who come to the UK on an Investor visa and who wish to acquire settlement rights are required to adhere to strict residence requirements which many

struggle to meet. To qualify for settlement, investors should reside in the UK for at least 180 days of any 12 month period. To qualify for citizenship, which is often the ultimate aim, the investor should not spend more than 450 days outside of the UK over a minimum five-year period. For the vast majority of clients, adhering to these requirements is impossible. Finally, although the category offers an accelerated settlement route for those wishing to invest more, this is no longer an option for the investor’s dependants. The dependants of a £5million or £10million investor are still required to wait at least five years to acquire settlement rights. They therefore cannot settle in line with their investor family member, thus falling short of the ultimate goal of many families. On 11 January 2018 the Home Office announced further changes to the settlement rules which have a significant impact on Investors. For any visa granted on or after 11 January 2018, dependant partners of

Point Based System migrants, including Tier 1 (Investors), must (in addition to the main applicant) also not be absent from the UK for more than 180 days in any 12-month period if they wish to qualify for settlement. Before this change in the rules, the absences of partners were not scrutinised and partners of Investor migrants (who were often the wealth generators) could travel freely. The Home Office now expects both the main applicant and their partner to meet the residence requirements if they wish to apply for settlement. This change in the rules will have a huge impact on the partners of Investor migrants, as well as on their children because, in general, the children of Tier 1 (Investors) can only obtain settlement if both parents also obtain settlement. Moreover, the way in which absences from the UK will be calculated has also changed. The Home Office will now calculate absences on a rolling basis, and can assess absences in ‘’any 12 -month period’’ they chose to look at, rather than looking at a defined 12-month period. This means that it is much harder for clients to manage their travel and to seek to ensure compliance with the rules for settlement. When faced with these restrictions, the options being offered elsewhere can appear more attractive to clients desiring UK residence, and who have the capacity to invest. For example, for a minimum investment of EUR 2million in the Republic of Cyprus, applicants can acquire a Cypriot passport, and with it the full rights and entitlements of European citizenship, within six months. Holding a Cypriot passport has enabled the individual to live and work freely in the UK by exercising EU Treaty rights. The Maltese Individual Investor Programme is similarly attractive and allows applicants to acquire Maltese citizenship and, thus, has enabled them to live and work in the UK under European law within a year, for an investment of around £1million. Moreover, both these programmes allow the applicant to invest in property, which is now prohibited under the UK Investor rules. The fact that high net worth individuals are prepared to obtain citizenship of another EEA country in order to reside in the UK is indicative of the continuing appeal of the UK within the high net worth community. The option of acquiring a second passport in order to facilitate residence in another country is however of course only open to individuals whose current nationality and personal and political circumstances make this permissible. However, the anticipated withdrawal of freedom of movement rights for the UK after Brexit would dramatically affect the appeal of citizenship by investment programmes being offered by other EEA countries for those wishing to obtain an EEA passport in order to reside in the UK. High net worth individuals wishing to reside in the UK would therefore have to revert to domestic UK immigration routes. Indeed, following the outcome of the Referendum vote, a marked resurgence in Tier 1 (Investor) applications has already been seen. Citizenship By Investment 75

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RESURGENCE OF THE TIER 1 (INVESTOR) VISA Prior to the Referendum vote, the UK had seen a marked decline in Tier 1 (Investor) visa applications. However, on 1 December 2016, the Office of National Statistics released figures on the number of Tier 1 (Investor) visas granted in the third quarter of 2016. The figures revealed that the number of Tier 1 (Investors) entering the UK in the third quarter of 2016 was the highest number granted since the required investment threshold increased from £1million to £2million in November 2014. In the third quarter of 2016, the number of Tier 1 (Investor) visas granted by the UK rose from 40 in the previous quarter, to 72: a staggering 80% increase. When compared to the same quarter in 2015, the third quarter of 2016 shows an increase of 56%. The number of applicants has continued to rise, with 75 applications in the first quarter of 2017 and 85 applications in the second quarter of 2017. Chinese and Russian nationals are currently the biggest contributors by number. The data also highlights increasing applications from Turkey and India, two countries which previously have not shown significant numbers of applicants. The reasons for the rise in Tier 1 (Investor) applications are likely to be threefold: 1. The drop in the value of the pound following the EU referendum; 2. It is possible that citizenship by investment programmes offered by EEA countries (as described above) are becoming less attractive to foreign nationals hoping to obtain an EEA nationality to live in the UK, due to the

uncertainty surrounding the continuance of freedom of movement rights under EU law; and 3. Many fear that the UK government will tighten immigration rules in the aftermath of Brexit and so are pre-emptively seeking to secure their status before any adverse changes come into force. Although the rise in the number of Tier 1 (Investor) visas granted in the second quarter of 2017 does not yet match the pre-November 2014 levels, it represents a significant increase and indicates that, despite the pejorative press surrounding the UK’s increasingly restrictive attitude towards immigration, the UK may be set to regain its position as a destination of choice for high net worth investors.

COMPETITION FOR HNWS Competition for the world’s millionaires and the many economic contributions they bring, both in terms of direct investment and indirect spending, is fierce. Despite the uncertainty brought about by the outcome of the EU Referendum, the UK environment is continuing to maintain its foreign appeal. In the aftermath of the Referendum decision, the UK government has a window of opportunity to revisit its high net worth migration offering and to put in place a framework which more adequately attracts and enables international investment in this country, and allows the UK to reap the reciprocal benefits brought to it by such investment.

“…the UK environment is continuing to maintain its foreign appeal.”

IF YOU HAVE ANY QUESTIONS ARISING FROM THIS, PLEASE CONTACT:

Kamal Rahman Partner E: kamal.rahman@mishcon.com T: +44 20 3321 7143

Fran Rance Associate E: fran.rance@mishcon.com T: +44 20 3321 6036

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LONDON The leading trade and invest migration event!

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Creating Jobs Through EB-5 Investment

C

ongress created the EB-­5 program in 1990 to benefit the U.S. economy by attracting investments from qualified foreign investors. Under the program, each investor is required to demonstrate that at least 10 new jobs were created or saved as a result of the EB-­ 5 investment, which must be a minimum of $1 million, or $500,000 if the funds are invested in certain high-­unemployment or rural areas. Since the 2008 economic crisis, access to capital has been constricted and municipal budgets continue to face significant shortfalls. EB-­5 investments have filled the funding gap, providing a new, vital source of capital for local economic development projects that revitalize communities, create and supporte jobs, infrastructure and services. A comprehensive peer-reviewed economic study found that during fiscal 2014-2105, an estimated

$11.23 billion in capital investment was invested in 355 Regional Center projects representing nearly 2% of all foreign direct investment into the U.S. over that two year period. The report also indicated that EB-5 investments over those two years supported 184,700 jobs for U.S. workers with more than 54,000 American jobs created in the contruction industry alone. More than 25 countries, including Australia and the United Kingdom, use similar programs to attract foreign investments. The American program is more stringent than many others, requiring substantial risk for investors in terms of both their financial investment and immigration status. • Investments made through the U.S. EB-­5 program must be “at risk” in the same way that investments in stocks or equity

funds carry an inherent risk. There is no guaranteed financial return. • If their application is approved by USCIS, EB-­5 investors receive a conditional visa that is valid for two years. In order to receive a permanent visa, these investors must demonstrate that the legally required economic benefits flowing from their investments have been achieved. Annually, the EB-­5 Program accounts for less than 1% of the visas issued by the U.S. Throughout the process, EB-­5 investors are subject to the same background checks and national security screenings as applicants in any other visa category, and their ability to eventually apply for citizenship is subject to the same criteria as other visa holders. Like any other investment vehicle, EB-­5 investment funds are subject to U.S. securities and anti-­ fraud laws and regulations.

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securities laws, enforced by state securities regulators and the U.S. Securities & Exchange Commission.

EXAMPLES OF SUCCESSFUL PROJECTS Capital investments made by EB-­5 Regional Centers have supported successful economic development projects, including: • Redevelopment of a closed Air Force base in Southern California into a vital commercial area including a distribution center and regional airport • Development of assisted and retirement living communities in Washington State, creating 800 jobs and serving approximately 130 seniors; • The transformation of the a closed Navy yard in Philadelphia into a dynamic, multi-­use development now home to 130 companies and 10,000 employees • Restoration of the historic “Alaska Club” building in Seattle, creating a modern hotel that employs almost 100 people and serving over 100,000 hotel guests annually • Rehabilitation of a 100 year old building into a hotel that created of 161 jobs while kick--- starting the revitalization of an historic Dallas neighborhood

SUPPORT FOR THE EB-­5 REGIONAL CENTER PROGRAM The EB-­5 Regional Center program is supported by mayors and local economic development officials who see the value of the program first-­hand. • The U.S. Conference of Mayors recently endorsed permanent authorization of the regional center program, noting that EB-­5 has become a vital source of urban redevelopment funds.

ABOUT THE EB-­5 REGIONAL CENTER PROGRAM In 1992, Congress enhanced the economic impact of the EB-­5 program by permitting the designation of Regional Centers to pool EB-­5 capital from multiple foreign investors for investment in USCIS-­approved economic development projects within a defined geographic region. Today, 95 percent of all EB-­5 capital is raised and invested by Regional Centers. Regional Centers maximize the program’s job creation benefits by facilitating the investment of significant amounts of capital in large-­scale projects – often in coordination with regional economic development agencies – which use the EB-­5 funds to leverage additional capital. Regional Centers use economic analysis models, including those developed by the U.S. Department of

Commerce, to demonstrate that job creation targets required by law have been achieved. For investments made through Regional Centers, at least 10 direct, indirect or induced jobs must be created. Existing federally-­designated Regional Centers include entities that are publicly owned and operated by state economic development agencies as well as public-­private partnerships and private sector investment companies. A Regional Center obtains its designation by submitting a detailed application to USCIS. The application must state the kinds of businesses that will receive capital from investors, the jobs that will be created directly or indirectly as a result of the investment of capital, and the other positive economic impacts that will result from the investment of capital. All investment offerings made by EB-­ 5 Regional Centers are subject to U.S.

• Dallas Mayor Michael Rawlings said, “The EB-­5 Program enables regional centers to be a key economic driver in their communities, creating desperately needed jobs in a tough economic environment.” • Mark Jaffe, president of the Greater New York Chamber of Commerce, has called EB-­5 “a common sense job creator that is straightforward with no cost to U.S. taxpayers,” and cited the program as “an important ingredient” in the success of “large-­scale, public/private real estate projects that create much needed jobs in areas of high unemployment.” Prepared by Invest in the USA

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Not eligible for a U.S. E-2 Treaty Visa? Try using a Grenadian passport! BY MONA SHAH, ESQ.

W

hether it is for business, education or investment, the USA remains one of the most popular countries in the world, even though traditional lawful immigration routes have become increasingly difficult. The popular EB-5 Investment Visa has become a victim of its own success with adjudication delays reaching almost 18 months. Aspiring investors and businessmen intent upon a speedier entry are looking for alternative strategies into the US. The E-2 non-immigrant treaty visa, able to be adjudicated within 3 weeks, has emerged as a viable alternative to waiting. However, a major caveat to this option is that only citizens of certain selected treaty countries are able to use this visa option. Citizens of India and China, for example, are not eligible to file under the E-2 treaty visa. Is there a solution? Yes, apply for a Grenadian passport!

IS E-2 THE ULTIMATE GOAL FOR A PERSON SEEKING TO UTILIZE GRENADA’S CBI PROGRAM? The US has E-2 trade treaties with fewer than 100 countries. The list of eligible countries (which includes Grenada, Taiwan, Kazakhstan, Pakistan, Jordan, Germany, France, Poland, Mexico, and Canada, just to name a few) is available at the Department of State’s E-2 and E-1 treaty page*. The investor must be a national of one of the enumerated countries to qualify for the E-2 visa. This requirement cannot be waived or excused for any reason. This option to utilize Grenada’s CBI program has become very attractive as an investor can become a citizen of Grenada and apply for an E-2 visa to enter the US, without ever traveling to Grenada. The entire process can be completed from abroad, processing the application for citizenship can take as little as three to

four months, and there are no permanent residency or biometric requirements. Adding to the desirability of this option is the fact that a Grenadian passport holder can travel visa-free to 121 countries, including the UK, the UAE, Russia and China. Although participants looking to obtain a Grenadian passport can choose between a donation to the Government of USD$200,000 or an investment into a real estate project of approximately USD$350,000; should the Investor Immigrant’s ultimate goal be eligibility for an E-2 visa into the US, then the more expensive real estate option must be chosen. Purchasing real estate demonstrates a physical nexus to Grenada. The investment into a real estate project comes with a tax ID, a title deed and permanent residence, all of which are not offered by the donation route. Attempts to satisfy the residency clause for E-2 visas, by

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buybacks. The investor is advised to look closely at the quality of documentation on such assurances. Such guarantees are only possible when the amount in question is controlled by an impartial fiduciary in an escrow account Investors are required to hold their assets for three years from the time citizenship is granted.

E-2 TO EB-5 (THE IMMIGRANT INVESTMENT VISA) An E-2 visa is ideal for people who only require business access to the U.S. rather than permanent stay; avoiding worldwide taxes and for those who are merely testing the waters, unsure as to whether the U.S. is their final destination. For an investor who ultimately intends on obtaining lawful residency in the US, the advantage an E-2 visa brings is a faster entry into the U.S. This is particularly pertinent if the EB-5 petitioner is also an entrepreneur, intending to control and develop his own business or investments. Strategizing a person’s immigration journey does not end here! The E-2 business can eventually be transferred into an EB-5 petition. The transition from E-2 to EB-5 is not an easy one and often requires cleverly crafting from an early stage. The E-2 capital investment may be counted towards the EB-5 requirement however, retained earnings or revenue generated by the E-2 investment may not be counted toward EB-5. Certainly, it should not be forgotten that the E-2 investment, like the EB-5, must place lawfully acquired, owned, and controlled capital at commercial risk with a profit objective, and be subject to loss if the investment fails.

ABOUT THE AUTHOR: MONA SHAH, ESQ.

renting property have been unsuccessful. The real estate option also allows for the possibility of a return on capital, as an investor would be buying an equity stake, although this all depends upon the project chosen. The return could be a 1-4% annual return on the investment, with the possibility of resale. If an investor is considering the possibility of a buyout after the three-year period, he/she should invest in a project that is already under construction and will be delivered in a timely fashion.

FINDING THE RIGHT GRENADIAN PROJECT: As with all private projects, investors should be wary and definitely conduct due diligence. Presently, there are approximately 16 approved projects in Grenada, but not all will reach completion

and subsequent viability. Developers must have both deep pockets and a great deal of passion in order to bring a project to fruition. It is worth noting that banks will not lend against greenfield, hospitality or citizenship-type products in the Caribbean. Private equity is also not available to greenfield Caribbean projects, except for purchase of distressed assets in the Caribbean. Investors should be wary of novice developers who have simply owned the land for decades through family heritage without any applicable development experience. Further, Grenadian projects that depend solely on capital obtained through the Citizenship by Investment program are highly likely to fail, because investor funds are slow to come by and do not arrive in regular intervals. Investors should also be wary of citizenship products that offer guaranteed returns and/or

UK born, Mona, a dual licensed attorney, was formerly a Government Prosecutor with the British Crown Prosecution Service. Mona has extensive knowledge of all facets of U.S. immigration law; her expertise ranges from specialist business law to complicated, multiissue federal deportation litigation before the US Courts of Appeal. Recognized as an industry leader in EB-5, Mona has received many accolades for her work, including voted top 25 EB-5 attorney in the US 4 years in a row; Top Lawyer by Who’s Who International, ‘Top Attorney of North America’. Mona, is also an adjunct professor at Baruch College, CUNY University. She has authored numerous articles, a published book for investors, co-edited EB-5 Gateway (BLS) and is a recommended author with Lexis Practice Advisor. Mona is regularly invited to speak worldwide, has been interviewed by mainstream news channels, including Fox Business News, Al Jazeera and quoted in major newspapers, including the New York Times. Mona also hosts the first podcast series on EB-5, with over 55 podcast episodes. * https://travel.state.gov/content/travel/en/us-visas/visainformation-resources/fees/treaty.html

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Our Experience Sets Us Apart TOP 25 EB-5 ATTORNEYS — INDUSTRY LEADERS — INTERNATIONALLY RENOWNED — PUBLISHED AUTHORS — HIGHLY EXPERIENCED IN EB-5 AND U.S. IMMIGRATION LAW — EXPERIENCED IN CORPORATE, SEC AND DIRECT INVESTMENTS — ADJUNCT PROFESSOR AT CITY UNIVERSITY OF NEW YORK

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© 2018 KPMG, a Maltese Civil Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. CBI-India 2018.indd 83

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TI N

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E NT TH ME ER T D S N E U NV D YI VE P B RO HI PP S A EN IZ IT

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wake up to paradise

T

amarind Hills is one of Antiguans premier real estate developments within the Antiguan Citizenship by Investment Programme. This five star resort development is located between two of the finest beaches in Antigua, and five minutes from a great variety of bars, restaurants, shops, golf and marina. There are a wide range of luxury modern villas available for sale, all of which qualify the buyer to apply for Antiguan Citizenship.

• One to four bedroom freehold whole ownership properties from US$450,000 • Completed properties available with proven rental income • Antigua has visa free access to over 130 countries including the UK and Schengen countries • Tax advantages for first times buyers • No personal or worldwide income tax in Antigua

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CBI Issue 15 - Spring 2018  
CBI Issue 15 - Spring 2018  
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