European Commission Report on Investor Citizenship and Residence Schemes in the European Union

We welcome the Commission’s report. It represents progress towards the establishment of a rigorous, fair and formalised system for investment migration (IM) with standards that will mitigate risks of abuse. The IMC has shared these values and objectives since our foundation.

We support enhanced transparency by putting in place better risk management, control systems and oversight mechanisms, as well as calls for greater cooperation on information-sharing about applicants for citizenship and residency; the IMC stands ready to cooperate with legislators as other industry bodies do.

In fact, we are proactively working with our industry members and countries to conduct research into the following areas we independently have identified as priorities: National Security and Investment Migration (IM); Societal Benefits of IM; Financial Crimes and IM.

These study areas will augment our ongoing research initiatives into: Due Diligence in IM, Setting Global Standards for Professional Firms and finally providing an evidence-driven approach to demonstrating the financial inflow into a country of IM programmes. We will be sharing these research reports and findings with the European Commission, European Parliament, OECD and IMF to proactively enhance cooperation and information-sharing in this area.

Consequently, we ask for better balance in this report and in future work in this area. For example, this report does not present or reflect in any manner the fundamental societal and economic benefits that these investment programmes bring. This is not constructive to policy-making or debate formation.

These programs create genuine societal advantage not just through increased government revenue, employment creation and enhanced infrastructure spending, but through the generation of new opportunities across all levels of society. National statistics of Malta, Greece, Latvia, Spain and Portugal reflect the contribution made through foreign direct investment.

Good policy-making is built on solid cooperation and consultation with industry but also across European Institutions – e.g. the work of the European Parliament’s Research Services entitled “Citizenship by Investment (CBI) and Residency by Investment (RBI) schemes in the EU: State of play, issues and impacts” which in itself demonstrated the contributions of these programmes to small countries on the periphery of the European economy was not cited nor included in the European Commission report. It is important such contributions are taken on board by the European Commission both from a factual and balance perspective.

Therefore in order for workable solutions to be found and progress to be made it is essential that industry and the work of the IMC are included within future European Commission Communications and initiatives. We have sought this level of cooperative engagement for some time now and we are committed to seeking from the European Commission inclusion in their future policy development process.

We look forward to achieving more enhanced cooperation with the European Commission in order to help deliver our common objective of a rigorous, fair and formalised system for investment migration (IM).

SUBMITTED

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