Member States and for the Union as a whole: in particular, risks to security, including the
possibility of infiltration of non-EU organised crime groups, as well as risks of money
laundering, corruption and tax evasion. Such risks are exacerbated by the cross-border rights
associated with citizenship of the Union or residence in a Member State.
There is also a concern around lack of transparency and governance of the schemes. Both
citizenship and residence schemes have come under close public scrutiny following
allegations of abuse and corruption linked to them in some Member States58. Enhancing
transparency and putting in place adequate risk management, control systems and oversight
mechanisms could help mitigate as far as possible some of these concerns.
4.1. Risks posed by Investor citizenship and residence schemes
4.1.1. Security
Over the past years, the Commission has presented different initiatives aimed at strengthening
the security of the EU and creating a Security Union59. The three main centralised information
systems developed by the EU and used for security checks are (i) the Schengen Information
System (SIS)60 with a broad spectrum of alerts on persons and objects, (ii) the Visa
Information System (VIS)61 with data on short-stay visas, and (iii) the Eurodac system62 with
fingerprint data of asylum applicants and third-country nationals who have crossed the
external borders irregularly. These three systems are complementary, and – with the exception
of SIS – primarily targeted at third-country nationals.
In addition, new IT systems like the Entry/Exit System (EES) 63 and the Electronic Travel
Information and Authorisation System (ETIAS)64 are being established and the reinforcement
of the VIS65 and the extension of the European Criminal Records Information System to Third
58
59
60
61
62
63
64
65
A detailed account of reports of abuse or misuse of the schemes is set out in the Study Overview, ibid, note
4, pp. 23 & 75.
See for examples the measures adopted by the Commission on 17 April 2018, including the Report on
progress towards an effective and genuine Security Union, http://europa.eu/rapid/press-release_IP-183301_en.htm
https://ec.europa.eu/home-affairs/what-we-do/policies/borders-and-visas/schengen-information-system_en
https://ec.europa.eu/home-affairs/what-we-do/policies/borders-and-visas/visa-information-system_en
https://ec.europa.eu/home-affairs/what-we-do/policies/asylum/identification-of-applicants_en
Regulation of the European Parliament and of the Council establishing an Entry/Exit System (EES) to
register entry and exit data and refusal of entry data of third-country nationals crossing the external borders
of the Member States and determining the conditions for access to the EES for law enforcement purposes,
and amending the Convention implementing the Schengen Agreement and Regulations (EC) No 767/2008
and (EU) No 1077/2011 and Regulation of the European Parliament and of the Council amending
Regulation (EU) 2016/399 as regards the use of the Entry/Exit System.
Regulation of the European Parliament and of the Council establishing a European Travel Information and
Authorisation System (ETIAS) and amending Regulations (EU) No 1077/2011, (EU) No 515/2014, (EU)
2016/399, (EU) 2016/1624 and (EU) 2017/2226.
Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EC) No
767/2008, Regulation (EC) No 810/2009, Regulation (EU) 2017/2226, Regulation (EU) 2016/399,
Regulation XX/2018 [Interoperability Regulation], and Decision 2004/512/EC and repealing Council
Decision 2008/633/JHA (COM/2018/302 final). On 19 December 2018, the Council adopted its negotiation
mandate. The European Parliament is in the process of adopting its mandate.
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