CBI in Review: Q1 – Q3 of 2020 (Europe and Oceania)

The CBI industry has seen a number of developments in 2020 – many of which were catalysed by the onset of the Covid-19 pandemic. CBI programmes across the globe have implemented changes to investment thresholds, family eligibility, and documentary requirements, while some programmes underwent, or are set to undergo, complete overhauls.

This post maps some of the major changes introduced in Europe and Oceania in the first three quarters of 2020.

The Montenegro CBI Programme

The first major industry development of 2020 came in February when Montenegro issued the first application approval under its newly operational CBI Programme. Having issued the approval within 95 days of application submission, Montenegro joined the likes of Dominica, Grenada, St Kitts and Nevis, and St Lucia for its efficient processing, although it has yet to be seen whether Montenegro will continue to process at speed as more applications are submitted.

The Cyprus Investment Programme

In August, Cyprus gazetted new Regulations implementing a vast array of changes to the Cyprus Investment Programme (CIP). The changes were far-reaching and reportedly tied to anti-money laundering legislation to bolster the Programme’s credibility and integrity.

Major changes affecting applications made under the CIP included (1) the exclusion of applicants deemed ‘high risk,’ (2) changes to requirements under some investment routes, including an increase in the minimum donation amounts, (3) amended documentary requirements, and (4) the expansion of family eligibility.

Significant changes were also introduced affecting the nature of the CIP. These include increased regulation and oversight of registered service providers, as well as the establishment of a ‘CBI Unit-like’ entity to examine applications made under the CIP. Importantly, citizenship can now be revoked if any of the economic criteria or other CIP requirements are no longer met by applicants.

The Malta Individual Investor Programme

Also set to undergo a major overhaul is Malta’s Programme, which is nearing its cap of 1,800 successful main applicants. The Malta Individual Investor Programme Agency announced that citizenship applications will cease on 30 September 2020, after which time the Individual Investor Programme (IIP) will be replaced by an altogether new offering.

Malta’s Parliamentary Secretary for Citizenship and Communities, Alex Muscat, has stated that the new Regulations will address concerns that the European Commission levied against the IIP.

The Vanuatu Development Support Programme

Recent reports indicate that Vanuatu will become the first jurisdiction whose citizenship by investment programme will accept applications from stateless persons. Antigua and Barbuda had previously announced that it would be exploring the feasibility of accepting stateless applicants under its Citizenship by Investment Programme back in March – no further update has since been provided, however.

How can I find out more?

If you wish to receive tailored advice as to which CBI programme is suitable for you, please contact CS Global Partners.