Investment Migration Council Responds to Comments made by the EU Justice Commissioner on Citizenship-by-Investment

The European Commissioner for Justice, Věra Jourová has announced her intentions to bring forward a report on Citizenship-by-Investment from December to the Autumn, which will seek to issue new, more stringent guidelines – believing that the granting of citizenship poses a serious security risk.

The Investment Migration Council (IMC), which represents the investor immigration and citizenship by investment industry, welcomes the opportunity to respond to comments made by European Commissioner for Justice Vera Jourova on Citizenship by Investment, as reported across European media:

Bruno L’ecuyer, the Chief Executive of the IMC, comments: “IMC members are compliant to a comprehensive Code of Ethics and Professional Conduct, that addresses any issue pertaining to security. As a consequence, significant time and capital is spent by professional firms and governments to ensure the tightest levels of security and background checks are carried out by European and global security agencies. Likewise, Citizenship-by-Investment applications are also vetted against current EU anti-money-laundering and financing of terrorism legislation, and must adhere to legal and regulatory obligations that individual EU states have adopted in line with EU law. It ensures the highest levels of corporate governance and due diligence is in place to prevent any security concerns.

The IMC shares and understands the Commissioner’s concerns in respect of the security of EU citizens. Nevertheless, we believe that the governance, due diligence and transparency of applicants under the Citizenship-by-Investment provisions in Austria, Malta and Cyprus – the three most active countries in the EU in this field – are not a security threat to the EU, given that very strict due diligence procedures and background checks on applicants are in place in those countries.

The Citizenship-by-Investment programmes run by EU sovereign states process a very small number of applications – approximately 700 to 1,000 per year. By comparison, according to Eurostat, in 2016 a total of 994,800 people obtained citizenship of an EU-28 Member State. Citizenship-by-Investment applicants therefore account for about 0.1% of the total of new EU citizenships granted each year.

The concerns of the Commissioner and the EU are of paramount importance and shared by both the IMC and our members, as well as the sovereign states which offer Citizenship-by-Investment in Europe.

We welcome a meeting with Commissioner Jourová to discuss her concerns and have the opportunity to demonstrate our confidence in the security measures in place and highlight the societal impact the industry has on local economies and their citizens.”

Peter S. Vincent, Assistant Director General for International Policy at BORDERPOL and former Legal Counsel at the US Department of Justice and US Department of Homeland Security, also responds: “I can understand and sympathize with the EU Commissioner’s concerns. However, having been exposed to the industry for a few years now, I can honestly say that as a former security and counterterrorism professional, the citizenship by investment programs of the EU are not a security threat to the European Union. In terms of commitment to governance, the very robust application process in Malta could even become the standard industry model, not just for the European Union but globally”.

Mr Vincent states that, as a result of consulting with the IMC and the industry, and seeing first-hand how governments manage their programs effectively, he has “increasing confidence with the degree of safeguards that are in place in order to minimize and mitigate risks to the global infrastructure, and certainly within a European Union context.”

Bruno L’ecuyer concludes; “Residence and citizenship by investment programs raise valuable capital for sovereign states around the world, including also in the European Union. This permits governments, particularly of smaller countries, to reduce deficits and reliance on external funding partners and invest in vital infrastructure to diversify and future proof their economies.”


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