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. 10

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