Blog

 

Background

On 14 July 2014 P5+1 and Iran agreed the Joint Comprehensive Plan of Action (“JCPOA”) after marathon negotiations in Vienna. This historic deal was eventually to put an end to nuclear sanctions against Iran. This happened on 19 January 2016 which is known as the implementation day. This was the date when the IEA reported back to the UN General Council confirming that Iran had complied with the terms of the JCPOA.

 

The JCPOA and the scope of sanction relief

The aim of the JCPOA was “the comprehensive lifting of all UN National Security Council sanctions as well as multi-lateral and national sanctions relating to Iran’s nuclear programme”. Therefore, the result has been the lifting of the vast majority of EU sanctions, the delisting of many Iranian companies from the EU asset freeze list, the ceasing of US application of US secondary sanctions, the removal from the US sanction list of certain persons and entities and availability of licensing in respect of certain activities.

 

Important challenges and opportunities for HNW advisors

Since the lifting of the sanctions, there has been a marked improvement in the Iranian economy and various observers have noticed an influx of interest from Iranian parties investing in various asset classes within Europe.

Iran has increased its production of oil, there has been increasing interest in Iran as a consumer market and Iranian companies have had the opportunity to showcase products in areas as diverse as petro chemicals and high technology.

There is anecdotal evidence of increase in the number of Iranian HNW immigrants into Europe. This is considered as a new potential client source for various HNW advisors in the fields of immigration, tax, private client, property and the like.

 

Compliance and due diligence issues

HNW advisors are all too familiar with the compliance and due diligence challenges in relation to clients coming from different territories but given the recent lifting of sanctions and in relation to the Iranian HNW clients, there are some additional and complicated due diligence issues.

 

Sanctions specific issues

It will be very difficult for a US HNW advisory to deal with an Iranian client because as mentioned above, the JCPOA did not remove US sanctions prohibiting trading commerce between US entities and Iran.

On the other hand, it would be perfectly possible for European HNW advisors to deal with Iranian clients. This will of course have to be subject to ensuring that they go through a very strict due-diligence exercise which goes beyond checking the identity of individuals but is directed towards ensuring that the particular individual clients or any entities and companies they represent are not subject to any sanctions.

It is essential to ensure when dealing with an Iranian entity that they are not a listed individual or entity or that they do not represent one. The entities still listed by the United Nations, the EU and the United States can be found on the website www.iranwatch.org. The problems arise when dealing with individuals who have relationships with companies which are directly or indirectly linked to sanctioned entities or individuals. In those circumstances, it is important to carry out a strict due diligence process within Iran to make sure that the entities are properly checked.

This would require specific steps to be taken to establish the identity of the individuals or the ownerships and directorships of any companies included. Some of the information regarding companies is readily available in Iran but much of this information is not. Advisors cannot afford to take risks in this regard and it is essential that appropriate enquiries are made.

If the result of the search is inconclusive then the advisor should take time to explore the position further.

 

Different types of searches

Many of the potential individual clients will have corporate interests and it is critical that these are checked thoroughly.

An initial search of the public records could reveal the identity of the directors of such companies, the companies’ registration number, objects, identity of inspectors (when dealing with private joint stock companies), the type of company and some limited information about the companies’ shareholders.

In order to obtain more in depth information in relation to a corporate entity, one will have to use agents in order to obtain full details of shareholders.

When dealing with individuals or when wanting to find out more information about the company such as for example pending litigation etc. a level 3 search can be carried out. This would generally involve a media search and personal enquiries with the company or individual involved.

There are many agencies within Iran that carry out searches of individuals for credibility and reputations. It is however critical that appropriate providers of due-diligence advisors are chosen so that the information obtained is as accurate as possible.

 

Summary

There is no doubt that the recent lifting of the sanctions has created new opportunities for HNW advisors and there will now be many potential clients in that territory for such advisors. However given that many entities and individuals remain listed and given the risks attached to dealing with such entities, the advisors should be acutely aware of these risks and take steps to reduce them.

 

 

Author: Sharokh Koussari, Solicitor & Partner of DWFM Beckman
www.dwfmbeckman.com

 

 

 

 

 

 

With its efficient processing, rigorous due diligence, wide choice of investment options and the sheer physical attraction of the islands, the Antigua & Barbuda Citizenship-by-Investment Programme is fast becoming a jurisdiction of choice. In fact, according to the Henley & Partners Visa Restrictions Index 2016, Antigua and Barbuda is the “leading country in the Caribbean.”

 

Holders of an Antigua and Barbuda passport may now travel to 134 countries visa-free, including Canada, the UK and the European “Schengen” countries.

 

The Programme is managed by a dedicated Citizenship by Investment Unit (CIU), staffed by a team of professionals who are responsible for processing applications and recommending the approval of real estate and business investment options. The ultimate responsibility of the Programme rests with the Office of the Prime Minister.

 

To date, approximately 1,650 individuals have been granted citizenship by the CIU. For the first 6 months of 2016, the Unit received one hundred and forty-seven (147) applications.

 

-National Development Fund (NDF) – 114
-Real Estate – 20
-Investment in Business – 13

 

In addition, the Unit has recently afforded new citizens the opportunity to add dependants; minors under 18 years, spouse, parent or grandparent; after approval. There is also a no HIV test requirement for minors 0 – 11.

 

The following fees now apply for additions after approval:

-Processing fee – New Spouse  $75,000.00
-Processing fee – 0 – 11 years $25,000.00
-Processing fee – 12 – 17 years $25,000.00
-Processing fee – over 65 years $75,000.00
-Due Diligence fee – New Spouse $7,500.00
-Due diligence fee – 0 – 11 years $   N/A
-Due diligence fee – 12 – 17 years $2,000.00
-Due diligence fee – over 65 yrs  $4,000.00

 

The CIU has also recently created two National Development Fund (NDF) categories.

1. For a single applicant, or a family of 4 or less:

 

US$200,000 Contribution and processing fees of :

-Main applicant US$50,000
-Spouse US$50,000
-Up to two dependents pay no processing fees

 

2. Family of 5 or more:

US$250,000 Contribution and processing fees of :-

-Main applicant US$50,000
-Spouse US$50,000
-Up to three dependants pay no processing fees

 

Additionally, the Government of Antigua and Barbuda wishes to take this opportunity to apprise future citizens that biometric passports will be introduced as of January, 2017.

 

Despite being a relatively new entrant in the alternative citizenship space, Antigua and Barbuda’s Citizenship by Investment Programme is already proving very popular with investors. Speedy processing and the quality of real estate offerings, give the programme a serious competitive advantage.

 

From all accounts, Antigua and Barbuda seems destined to punch above its weight in the international arena as it strives, according to the Prime Minister, Hon. Gaston Browne, to “become the economic powerhouse of the Eastern Caribbean.”

 

 

Author: Antigua & Barbuda CIU
www.cip.gov.ag

 

 

 

As we head into autumn, 2016 already promises to leave behind a history of significant events. From Brexit to Schengen to global security challenges there is much ado in the world of High Net Worth Individual (HNWI) movement.

 

As the sun sets on Rio’s 2016 Olympics, we look at how Brazil fares against the rest of the world in HNWI growth and migration.

 

Compared to the growth of HNWI population in other parts of the world in 2015, Brazil performed poorly, losing 7.8 per cent of its HNWI population and 5.9 per cent of ultra-HNWI wealth (elsewhere ultra-HNWI wealth has gown more than the other wealth segments, both in 2015 and over the past four years)[1].

 

Regionally, however, Brazil has the highest number of HNWIs in Latin America and third highest among BRIC nations, and the growth of Brazil’s UHNWI population over the next decade is expected to outperform the global average, at 50 per cent[2]. WealthInsight forecasts that the number of Latin American HNWIs is expected to exceed 530,000 by 2019[3]. Brazil had the highest number of HNWIs with 198,000 in 2014, followed by Mexico with 148,000 individuals in the same year. Remarkably Latin American HNWIs held a higher proportion of their wealth outside of their home countries than the global average between 2010 and 2014, according to WealthInsight. Millionaires from Chile, Peru, Colombia and Argentina all held more than 33 per cent of their wealth outside their home country in 2014, while the global average was 20-30 per cent. Chilean HNWIs held the highest proportion of their investments outside their country at 38.4 per cent or USD100.5 billion in 2014, and it is one of the fastest growing in the region, recording a forecast compound annual growth rate of 4.8 per cent between 2015 and 2019.

 

Earlier in the year, it was reported that the downturn in Brazil’s local economy and rising crime rates are pushing many millionaires out of the country[4]. Key destinations for foreign investments include North America and Europe.

 

Turning towards developments in Europe, the full impact of Brexit remains uncertain. EU citizens residing in the UK are looking to cement their status through permanent residence and naturalisation applications for those eligible[5]. The UK remains attractive to HNWI, and UK’s Tier 1 Investor route may become increasingly popular for those who were planning to establish themselves in the UK through citizenship programs elsewhere in the EU.

 

Meanwhile, elsewhere in the region challenges have arisen for Tukey’s economy, with the fall of the Lira following the attempted coup on 15 July 2016. Turkey’s economy had been expanding year-on-year at the fastest pace since the third quarter of 2011 (while fixed investment was the main driver of growth, private consumption expanded at a slower pace and public spending shrank).

 

According to New World Wealth data, of the 100,200 HNWIs in Turkey with assets of USD 1 million or more, 5,200 HNWI have net assets of over USD 10 million. The HNWI number in Turkey has grown by 145 percent since 2000 and by 90 percent since 2005. Turkey’s HNWI numbers have been boosted by inflows from the rest of the Middle East and North Africa. There are 28 billionaires in the country with a population of 78 million; .Turkey is followed by the United Arab Emirates, which counts 72,100 HNWIs among its population. Israel has 71,700 HNWIs and Saudi Arabia has 59,000.

 

Prior to the events in July, the Turkish HNWI population was forecast to grow by 19.4 per cent, to reach 119,226 in 2020, while HNWI wealth has been projected to grow by 31.2 per cent to reach USD 768.2 billion[6].

 

The import of any political insecurity, an important driver of HNWI movement, on Turkey’s sizeable HNWI population will be one to watch in terms of outflows, with no capital controls currently in force, but also to see the impact on inflows and alternative destinations for those HNWI from the Middle East and North Africa previously moving into Turkey.

 

 

Author: Nadine Goldfoot, Partner, Fragomen Worldwide
www.fragomen.com

 

 

[1] https://www.worldwealthreport.com/Global-HNWI-Population-and-Wealth-Expanded

[2] https://www.knightfrank.com/wealthreport/2015/wealth-distribution/uhnwi-growth

[3] https://www.wealthadviser.co/2015/12/22/235007/wealthinsight-predicts-positive-future-outlook-latin-american-wealth-management-ma

[4] https://big.assets.huffingtonpost.com/millionaire-erevna.pdf

[5] See Migration Observatory’s Report on this for some interesting statistics: https://www.migrationobservatory.ox.ac.uk/commentary/here-today-gone-tomorrow-status-eu-citizens-already-living-uk

[6] https://www.businesswire.com/news/home/20160725005934/en/Turkey-Wealth-Report-2016—96768-HNWIs

 

 

On 23 June 2016 more than 30 million people in the United Kingdom took part in a referendum to decide the UK’s future within the European Union, with 52% of people voting to leave the EU. What followed has been described as the Brexit (Britain’s exit from the EU) ‘earthquake’.  The aftershocks were felt worldwide, resulting in significant uncertainty for EEA nationals, their families, businesses based in the UK and for British citizens residing elsewhere in the EU; with many already looking at the options available to them.

 

However, whilst politically and symbolically significant, it is important to note that the referendum result has no immediate legal effect; the UK continues to be a member of the EU. This will remain the case if and until the UK formally leaves the EU, once the UK government triggers Article 50 of the Treaty on European Union (TEU) indicating their intention to leave and thereafter a minimum notice period of two years served. It will be during these two years that the UK will negotiate its terms of withdrawal from the EU and the full impact of Brexit will not be known until the negotiations have reached a settlement.

 

Amidst the ambiguity and in the short term, EEA nationals and their family members are already taking steps to protect their positions and avoid uncertainty. In addition, the Government has provided assurances that ‘when we do leave the EU, we fully expect that the legal status of EU nationals living in the UK, and that of UK nationals in EU member states, will be properly protected.’[1]

 

Whilst it is likely that EEA nationals currently in the UK, and British expatriates abroad, will be accommodated in one form or another, the position for those not exercising treaty rights and those arriving post referendum is less clear and will ultimately depend on the final trading position. The key will be whether our newly negotiated relationship with the EU includes reciprocal free movement arrangements. If EU free movement comes to an end, EEA nationals and their family members may face visa restrictions.

 

As a result of Brexit, a new trend is emerging of high net worth British expatriates living in the EU seeking second passports, most notably from European countries such as Cyprus and Malta, where citizenship can be obtained in a relatively short period of time. This trend is driven by a desire to ensure they retain the rights of free movement afforded to them as European nationals, post Brexit. Correspondingly, for those who were using European citizenship programmes as a gateway to the UK, these programmes have lost a significant part of their attraction. For those in this position it is likely they will return to the more traditional entry route to the UK under the Tier 1 (Investor) programme, which previously saw a huge decline in applications when the investment amount was increased to £2 million in November 2014.

 

Whilst a lot remains uncertain and it will take time for the rubble to clear, there are steps that individuals can take to protect their positions, for example, applying for EEA registration certificates and permanent residence where possible. From a UK perspective, the Government has made clear their commitment to attracting ‘talented individuals to live in the UK who will help to contribute to the success of this country by investing here and creating jobs’[2] and this is likely to continue in a post-Brexit world.

 

Although we do not know yet what form any changes will take it is important to remember that the UK government has a long history of consulting with business and it is likely that future changes will be published well in advance of any implementation to allow sufficient time for individuals and business to react. Now is the time when individuals and the business community need to form part of the debate so that the best results can be achieved during the negotiation period.

 

 

Author: Julia Onslow-Cole, Partner, Legal Markets Leader & Head of Global Immigration, PricewaterhouseCoopers Legal LLP
www.pwclegal.co.uk

 

 

[1] Statement on the status of EU Nationals in the UK, 11 July 2016: https://www.gov.uk/government/news/statement-the-status-of-eu-nationals-in-the-uk

 

[2] Government’s Consultation on Reforms to the taxation of non-domiciles, 30 September 2015: https://www.gov.uk/government/consultations/reforms-to-the-taxation-of-non-domiciles/reforms-to-the-taxation-of-non-domiciles

 

 

 

Traditionally, the majority of the world’s wealthy elite have hailed from those parts of the world with advanced Western economies; most notably from Europe and North America. However, this trend is shifting east as Asia now mints more new high net worth and ultra high net worth individuals than any other part of the world. At the end of 2015, there were 5.1 million high net worth individuals (HNWIs) in Asia Pacific with a combined wealth of USD 17.4 trillion.[1]

 

A growing trend amongst these wealthy individuals is the desire to obtain an alternative or second citizenship. As demand drives supply, the number of Economic Citizenship programs (also known as citizenship-by-investment programs) available to HNWIs and their families has steadily increased over the last few years and is expected to continue to do so.

 

In exchange for a significant financial contribution or investment to the domestic economy, citizenship-by-investment programs offer the world’s wealthy elite with the opportunity to obtain citizenship and in so doing provide them with something that is less tangible and more desirable than any material object – the ability to transcend into a ‘global citizen’ with access to all the benefits which that affords.

 

There are a multitude of reasons why wealthy people apply to these programs. In Asia, it has primarily been driven by the poor travel-ability of the majority of Asia-domiciled passports. The biggest market being motivated by the ability to achieve greater mobility is China, whose nationals hold a passport that allows visa-free access to just 50 countries around the world. Other key markets include Thailand (71), the Philippines (61), Indonesia (58), Vietnam (47) and Bangladesh (39).[2] HNWIs in these countries therefore look to the citizenship-by-investment programs of Antigua and Barbuda[3], Dominica, Grenada[4], and St. Kitts and Nevis which provide wealthy foreign nationals who invest into these countries with visa-free access to up to 134 countries including those in the European Union (EU).

 

As more and more HNWIs surface around the Asian region, the need to ensure financial safety by protecting their personal assets and diversifying investments for themselves and their families continues to be a primary driving factor for the significant demand for these programs. The implementation of the Common Reporting Standard calling on jurisdictions to obtain information from their financial institutions and automatically exchange that information with other jurisdictions on an annual basis beginning in 2017/2018 has led to an increased focus on this aspect of economic citizenship. Although citizenship doesn’t have a direct impact on the automatic exchange of information as it is based on tax residency, the citizenship-by-investment programs in Malta and Cyprus can be particularly attractive given that they provide holders of EU passports the right to settle in all 28 member states of the EU which effectively provides 28 tax residency options.

 

Beyond the desire for easier travel and financial safety, the deteriorating geopolitical climate and recent terror attacks around the world has seen a greater emphasis on physical safety and security motivating HNWIs to explore Economic Citizenship in order to have a safe haven to move to should local conditions deteriorate further.

 

The surge in interest in citizenship-by-investment programs from Asian-based HNWIs reflects a combination of the growing wealth in these emerging markets as well as the evolving motivations for HNWIs to further enhance their ability to become global citizens.

 

 

Author: Dominic Volek, Managing Director Henley & Partners Singapore, Head South East Asia
www.henleyglobal.com

 

 

[1] Source: World Wealth Report 2016, Capgemini and RBC Wealth Management

[2] Source: The Henley & Partners Visa Restrictions Index 2016

[3] Amongst the Caribbean programs, only citizens of Antigua and Barbuda enjoy visa-free access to Canada

[4] Amongst the Caribbean programs, only citizens of Grenada enjoy visa-free access to China

 

The UK immigration landscape continues to be dominated by Brexit. The questions of ‘when’, ‘how’ and ‘what’ remain unanswered and some commentators are even starting to question ‘if’ Brexit will actually take place, although this may be wishful thinking. Whilst focusing on the possibility that Brexit might not actually happen may provide some comfort to many immigration practitioners, it is simply not an effective solution for the 3.6million EU citizens currently residing in the UK.

 

So what does Brexit look like now?

The initial assertions from the Brexit camp that Article 50 would be triggered immediately have cooled both by the passing of time and more measured comments delivered away from the rhetoric and furore of the referendum debate. The touted date for Brexit has been pushed further and further into the distance, and the latest timeframe appears to indicate that Article 50 will be triggered in 2017 ahead of Brexit in early 2019, however not many would bet against that date being pushed back further.

 

Reported statements from the UK government suggest that the current plan for the Brexit discussions are to harness the spirit of Britain’s Olympic ‘world-beaters’ to draw up a blueprint for Brexit.  If ever there was a clear indication that no plan is in place – this is it. The referendum took place two months ago, and it appears that still nobody knows what Brexit will actually mean.

 

So what does this mean for EEA nationals?

Uncertainty is rarely a positive, but for EEA nationals the delays and confusion provide an opportunity to cement their position. There are two categories of EEA national who will be affected by Brexit, as follows:

 

1. EEA nationals considering moving to the UK

 

It is unclear whether the government will set a back-dated cut-off date from which EEA nationals will cease to be protected by free movement provisions.  However, the message from Westminster thus far is that those EEA nationals currently in the UK should be protected – both in the interests of fairness, and also as a safeguard to ensure that the status of British citizens living elsewhere in the EEA is not affected. The delays in triggering Article 50 alongside this reluctance to punish EEA nationals currently in the UK, would appear to give those considering the move to the UK an opportunity to do so as well as time to cement their position in the UK prior to any changes to free movement being made.

 

2. EEA nationals currently resident in the UK

 

At Mishcon de Reya, our advice to all EEA clients is to seek to formalise their position in the UK.  Those who have exercised Treaty Rights for the five year qualifying period should apply for Permanent Residence, whilst those who cannot satisfy the requirements to acquire Permanent Residence in the UK are advised to apply for a Registration Certificate in order to place them in the UK prior to any future changes regarding free movement.

 

How Brexit will pan out, no one knows, but from an immigration perspective, the current delays mean that EEA nationals should not panic and should take the time to ensure that they are doing all they can to protect their position.

 

 

Authors: Maria Patsalos, Partner & David Deane, Associate – Mishcon de Reya
www.mishcon.com

 

The EB-5 Regional Center Program (the “Program”) is responsible for tens of billions of dollars in capital investments and tens of thousands of American jobs. It is critical for lawmakers to understand the detrimental consequences to the U.S. economy if they allow EB-5 to lapse or expire.

 

From 2005 to 2015, over $15 billion in foreign direct investment (“FDI”) flowed into the U.S. from across the world thanks to the EB-5 Regional Center Program. During this time, and especially in the years that followed the Great Recession, the Program became a potent economic development tool for diverse communities and industries across the country. More than $14 billion of the $15-plus billion (or 93%) in EB-5 capital was invested in the U.S. in the years following the financial crisis of 2008.

 
Today, the EB-5 regional center industry needs to lead the stakeholder community in educating the government, media, and public about the important work going on across the country due to the Program—creating vital American jobs at no cost to taxpayers.  It is essential that the EB-5 regional center industry work toward reform, improvement and reauthorization of the Program to achieve a more efficient and sustainable program for the future and to ensure it can continue, without a lapse, to provide investment and jobs to American communities, both big and small.
Thanks to our shared success in building this multi-billion dollar EB-5 capital market, regional centers will play an integral role in the U.S. economy for years to come.

 
$18 Billion Reasons EB-5 Must Continue

As the EB-5 regional center industry debates reform measures to include in reauthorization legislation, it is important that we understand the real world consequences of letting the Program expire, something some key lawmakers have publicly stated should happen. The industry knows that any outcome that results in a program lapse or expiration would be a disaster for the U.S. economy with lingering and irreversible damage.

 
A lapse in the Program would mean that more than $18 billion in FDI (12% of U.S. FDI in 2015) that is already injected or waiting to be injected into the economy through EB-5 projects would be thrown into chaos—along with tens of billions of dollars in other project financing that is leveraged and reliant on the finance structure of EB-5 capital projects. Based on guidance from the federal government, investors with petitions already in the process would no longer have statutory basis for adjudication under the rules that governed the Program at the time of filing.
Without the Program, investors will have no grounds for I-829 adjudication and will be left hanging in the balance, their petitions suspended in bureaucratic purgatory. Funding for affected projects would be halted and the U.S. would watch litigation destroy the potential for EB-5 capital to support hundreds of thousands of American jobs.

 
Actions to Improve EB-5 Program Integrity

Program integrity is a priority for Congress, as seen in various bipartisan bills. Some measures include background checks for regional center owners, banning participation by certain convicted criminals, forbidding foreign ownership of a regional center and addressing national security concerns related to EB-5. Overwhelmingly, the entire industry supports improved integrity measures to weed out the fraudsters, cheats and criminals while allowing the rest of the industry to contribute to the American economy through job creation and economic development. EB-5 is on the White House’s “unified regulatory agenda” to update the Program’s regulations for the first time since the early 1990s and this will occur as USCIS enhances its capabilities protecting program integrity.

 
In the last few years, IIUSA has worked tirelessly to develop meaningful self-regulatory processes that hold its members and the industry to the highest standards of ethical business practices. IIUSA has a long history of supporting reforms that would improve program integrity, including those proposed by the legislative and executive branches. Following a process of constructive engagement and comprise, legislation that includes integrity measures are now under consideration as a single and broadly supported reform and reauthorization bill.

 
Code of Ethics and Best Practices

Since 2014, IIUSA’s membership has approved five new and updated several other best practices documents that strive to hold its members and the industry to the highest standards possible. This includes the Code of Ethics and Standards for Professional Conduct, which was approved along with an enforcement procedures process which include a vehicle to file complaints against bad actors. IIUSA also has recommended best practices for regional centers, anti-money laundering/know your customer efforts, engaging with sales intermediaries, and a securities law white paper. These, combined with the Code of Ethics and enforcement procedures, set a high bar for how the industry is expected to operate. Lastly, IIUSA keeps the industry informed of essential intelligence on compliance, market dynamics, and ever-evolving best practices through various education offerings.  Long story short, EB-5 is not a spectator sport.

 

‘Mend It, Not End It’

The pieces of the puzzle are on the table and many of them are already in place for EB-5 reauthorization and reform.  As many supporters in the Senate stated in an EB-5 hearing earlier this year, Congress must “mend it, not end it.” During this hearing, we learned about the implications of even a short lapse in program authorization, something that would cost the U.S. economy billions of dollars—a shock the financial system cannot afford and one that would launch a litigation frenzy in which everyone loses. The onus is on the industry to use our collective voice to spur Congress to reform and reauthorize this vital part of the post-recession economy in the U.S.
Years of success, advocacy, experience and relationship building have led us to this moment. The EB-5 industry and Congress are in an optimal place to negotiate durable reform that results in a stronger, more efficient EB-5 program.  The message for all of us to carry is simple: the EB-5 regional center program must be reauthorized without a lapse or countless communities, regional centers, and investors will face desperate times and years of protracted, expensive court proceedings.

 
Author: Peter D. Joseph, Executive Director, IIUSA
www.iiusa.org