Talking Economic Impact and Opportunity

Investment migration has gotten plenty of public and media attention in recent years; however, the industry’s economic benefit has been largely kept on the sidelines. Bruno L’ecuyer, CEO of the Investment Migration Council (IMC), shares his thoughts and opinions on the challenges, opportunities and outlines the organisation’s plans and priorities for the future.

As Chief Executive of the IMC, what issues are currently high on your agenda?

Defining and setting common standards for investment migration continues to be one of our top priorities. We feel self-regulation can be an effective and efficient means of control for investment migration, which would definitely benefit from more harmonised practices, but is not as systemically risky as the financial services industry for example. We are of the opinion that improving standards and ensuring that our members adhere to the established standards will help the sector expand even further.

The growth of our own organisation is also very high on our agenda. The IMC currently has around 450 members and has established itself as a credible industry body. However, I believe we can grow our membership base further by engaging with professionals from around the world. We are also looking to diversifying our membership and are working on attracting other professionals that don’t necessarily focus on investment migration but facilitate talent and business migration – a segment that is seeing tremendous growth the world over. At the moment these professionals are a little bit outside our catchment area, but if we want to see growth, we need to diversify who we communicate to and work for as an organisation and give potential members reasons to join.

Supporting and facilitating the development of global investment migration rules has long been a priority of the IMC. What progress have you achieved thus far?

The launch of a code of ethics and professional conduct standards for the industry back in 2015 was one of our first initiatives, and we have subsequently launched an anti-bribery and corruption code. We strongly support the development of enhanced common due diligence standards to ensure only bona fide applicants are approved across all investment migration programmes. We have commissioned and published independent research into due diligence with a view of creating a common framework of guidelines for governments and agents to adopt.

Currently, we are working on a set of guidelines for the sales and promotion of investment migration programmes globally. We have established a working group made up of members from 10 different countries who are looking into how investment migration should be promoted. We are in talks with various governments on this too. In many cases they are providing us with their own frameworks, and we are taking a helicopter view of the all the different guidelines in order to develop a best practice document that outlines what to do and what to avoid when promoting investment migration programmes globally. I am hopeful that the draft document will be ready by the end of December 2020.

Investment migration appears to be facing an increasingly hostile environment, with several international institutions and organisations criticising the sector. How should the industry show that it’s serious about addressing these concerns?

Investment migration is a complex legal and technical phenomenon, and it’s the sovereign right of states to determine their national migration policy. Nonetheless, we are aware that some organisations have concerns that need to be addressed, and those are mostly relating to security, money laundering and financing of terrorism. However, out of those three, the only one that is really a risk is money laundering. The level of due diligence involved in investment migration is so high that it isn’t worth it for a terrorist to gain access to a country through this route. In fact, there isn’t a single reported case. In our opinion, investor migrants neither pose a security nor a terrorism threat.

From a money laundering perspective, the risk is still there even though it is very small. As an industry, we have to abide by the global Anti Money Laundering (AML) and Combatting the Financing of Terrorism (CFT) regulations to ensure that the people coming through are really fit and proper. Everybody in the industry needs to be aware of the rules, and there are no exceptions. Small agents dealing with two or three applications per year need to ensure they know the source of funds as much as governments handling hundreds of applications throughout the year need to properly investigate this matter. In addition to doing what is legally required from the industry, I think the fact that we have developed and published different guidelines and standards is showing that we are serious about addressing those concerns.

European Commission President Ursula von der Leyen recently referred to investment migration in her State of the Union address, pointing out that European values were not for sale. In October 2020, the Commission launched infringement procedures against Malta and Cyprus. What comments would you like to make about the EU’s attitude towards the industry?

I am completely in agreement with Ursula von der Leyen: European values should not be for sale. But if we are concerned about European values, why don’t we look at introducing a European values test? After all, citizenship tests are quite common. When investor migrants are coming through an investment migration pathway of an EU member state, they could be required to sit an online test on European values. We have thrown that idea around Brussels; it hasn’t picked up too much, but it’s one idea that could be explored and developed further.

Moreover, I am spending an increasing amount of time continuing our constructive discussions with the EU and other international institutions by providing them with information that is up to date, for instance about the so-called Cyprus Papers published by Al Jazeera. Cyprus’ decision to suspend its citizenship-by-investment programme following the damming and quite frankly shocking revelations is the right thing to do. A proper investigation needs to take place into the allegations that were made and the context. Our experience with media programmes like the one of Al Jazeera is that often they are twisted to achieve a specific goal, in this case to damage the reputation of Cyprus. In response to the infringement procedures initiated by the European Commission against Malta and Cyprus regarding their citizenship by investment programme, I like to point out that citizenship of EU member states remains a national competence. The division of competence between the EU and its member states is the central postulate on which the Union is based, and the latter can sovereignly decide which individuals and under what circumstances they should acquire their citizenship.

How do you believe the dialogue with supranational institutions, including the EU, OECD and World Bank will evolve? And what role does the IMC aim to play in establishing a better relationship?

I’d like to point out that we weren’t established as an advocacy group, but as a membership body. Our primary aim was and is to bring the investment migration community together, introducing certain common standards and ensuring that governments from around the world have a platform to talk about this kind of legal migration. We have been talking to the EU and other policy bodies for about a year and a half now. Our motivation was to let everybody in the policy circles know that the investment migration industry is represented by our organisation – a non-profit Swiss organisation – and that we are here to act as a bridge of communication between the industry and policymakers who need information about the sector so that they can make informed decisions.

In many ways, we have been highly successful. We have published many policy papers, we have been cited by the European Parliamentary Research Service, and the OECD monitors our work. We have morphed a little bit into a think tank, at least on the reporting side. In the past, we focused on the legal side of what investment migration is, now we are emphasising the economic value of investment migration. Recently, we’ve published a report looking at the UN Sustainable Development Goals and how investment migration contributes to many of the 17 important goals.

When the news broke about covid-19, you quickly realised this pandemic would jeopardise the Investment Migration Forum. How did you stay in touch with the industry during this challenging and uncertain time and are you planning a Forum for 2021?

In March 2020, when the pandemic brought travel to a standstill, we quickly transformed the way we communicated and launched the IMC Streaming Service ‘Crossing Borders’ on YouTube. To date, we’ve hosted close to 70 Crossing Borders programmes, which have welcomed more than 200 speakers and attracted some 2,700 delegates from 60+ countries. The programme has been quite successful and is now a permanent fixture in our events calendar with a monthly broadcast. All of the previous broadcasts are available free to view on our YouTube channel.

Nonetheless, we feel the need of the industry to meet face to face again and are planning to host the Investment Migration Forum between the 14th and 17th June 2021 in Brussels, Belgium. We are excited to bring the Forum to Brussels for the first time. We had wonderful four years in Geneva, Switzerland, but a lot of our regular attendees expressed the wish to discover another European city. Given the increasing amount of time that we spend in Brussels nowadays, Brussels was a natural choice. Besides, we are hoping to increase the participation of European policymakers by bringing this high-calibre event to their doorstep, which would allow them to fit the Forum in their busy schedules. Without the need to travel, it will offer them an opportunity to learn more about the sector and meet the people who are involved. As an industry, we often get accused of being secretive and not very transparent. This was perhaps true in the past, but the sector has changed and evolved a lot. We are very welcoming and want to advance the dialogue with European institutions.

What new membership initiatives do you have in the pipeline, and what else can the industry expect from the IMC in the coming 12 to 24 months?

Covid-19 has accelerated our digitalisation programme. We had a 12-18 months programme aimed at digitalizing many of our services for our members. This has now been fast-tracked, and we are working on a new website, which is focused on the user experience. Our members will be able to manage their profile, get in touch with the community and the IMC, as well as accessing information, facts and figures about the sector in a much more user-friendly way.

We will also be launching IMC Fellow membership, the highest level of membership. It is open to any individual who has been a professional member of the IMC for 5 consecutive years and has 10+ years of working experience with 3 years at senior level. We are planning to launch the IMC Fellow membership at the same time as the website towards the end of 2020.

The IMC’s Education and Training division (IMCET) has also been busy and will be launching two new bespoke courses shortly. We are also restructuring the Certification in Investment Migration and are planning to offer students the opportunity to choose individual modules of this very successful course. These bite-sized learning options are great news for both employees and employers.

What final message would you like to share with the investment migration community?

Migration is always going to be a divisive issue that will elicit a lot of discussion and various viewpoints, no matter what category of migrants it is. We need to raise awareness about the contribution that investor migrants make in their communities. Often, their contributions go well beyond the financial investment that is required as part of an investment migration programme. There are many examples around the world, unfortunately, the media often ignores those positives as they are not newsworthy. Take, for example, the late Thai entrepreneur Mr Vichai Srivaddhanprabha. He was predominantly famous for investing in Leicester Football club – at least that is what media focused on. However, he was a lot more than that. He was an investment migrant in the UK who, throughout his stay in Leicester city, gave away £2m in donations towards a new children’s hospital, and a £1m gift to the city’s university medical department. I think as an industry, we have a unique opportunity to address economic and societal disparities and bring about positive and impactful change – and we need to recognise the importance of effectively communicating how we are creating value for all stakeholders.

Interview with Bruno L’ecuyer, Chief Executive of the Investment Migration Council
Source: IM Yearbook 2020/2021

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