The Year 2022 has turned out to be a twisting year for the investment migration industry, specifically with citizenship and residence by investment programs. The EU is committed to end all citizenship by investment programs by 2025 and has asked member states and third countries to gradually phase them out.

The Russia’s invasion of Ukraine has led to important developments restricting golden citizenship and residence schemes.

Let us take a look at the some of the most important developments.

  • Russians are banned from applying for All CBI and Golden visa programs due to escalating Russia-Ukraine tensions. Economic sanctions has been imposed on russian companies and banks cutting of from SWIFT financial system.
  • Greece has suspended golden visas for Russians. The renewal and issuance of residence permits are suspended for russians.
  • SEF Portugal has suspended applications for ARI golden visa from russian nationals.
  • EU has suspended visa waiver with Vanuatu passport holders entering schengen area. The application of the Agreement between the European Union and the Republic of Vanuatu on the short-stay visa waiver is hereby suspended as from 4 May 2022 as regards citizens of Vanuatu holding an ordinary passport issued by Vanuatu as of 25 May 2015.
  • Malta has suspended processing of  residence and citizenship by investment applications from nationals of Russia/Belarus until further notice.
  • The European commission has proposed to end Golden passport (CBI) programs by 2025 and further tightening rules for RBI programs.
  • The European Union has imposed partial visa suspension on all Vanuatu citizens due to poor security checks of the Vanuatu CBI program
  • Bulgaria has voted to scrap its citizenship by investment program amidst EU pressure.
  • Latvia to shut down golden visa program.
  • Antigua, Dominica, Grenada, St Lucia and St Kitts have announced temporary suspension of applications from Russia, Ukraine and Belarus because of the ongoing war and inability of providers to conduct due diligence and banking transactions there.
  • UK has shut down its tier1 investor visa route effective immediately preventing corrupt elites and oligarchs accessing the UK.
  • St Lucia has extended issuing government bonds for citizenship until end of 2022. New CEO also appointed for CIP unit.

Golden Residence programs

The European Commission has proposals to regulate various aspects of RBI schemes with the aim of harmonising standards and procedures and strengthening them..

  • Increased due diligence and rigorous background checks of the applicants and, where necessary, their family members, including the sources of their funds, mandatory checks against the Union large-scale justice and home affairs IT systems and vetting procedures in third countries;
  • The regulation, proper certification and scrutiny of intermediaries as well as limitation of their activities and, in the case of CBI schemes, the cessation of their services;
  • harmonised rules and obligations on Member States to report to the Commission regarding their RBI schemes and applications thereunder
  • minimum physical residence requirements and minimum active involvement in the investment, quality of investment, added value and contribution to the economy as conditions for acquiring residence under RBI scheme
  • a monitoring mechanism for the ex post control of successful applicants’ continued compliance with the legal requirements of RBI schemes;