stays in the EU since 2014, introduced an investor citizenship scheme in 2018119. Some third
countries, or the contractors supporting them, have explicitly marketed their citizenship with
the argument that it gives visa-free access to the European Union. Investors interested in such
schemes are often wealthy nationals of visa-required countries, who could use such schemes
to bypass the regular Schengen visa procedure and the in-depth assessment of individual
migratory and security risks it entails, including a possible evasion of measures to prevent
money laundering and financing of terrorism.
While the European Union respects the right of sovereign countries to decide on their own
naturalisation procedures, visa-free access to the Union should not be used as a tool for
leveraging individual investment in return for citizenship120. The implementation of such
schemes will be duly taken into account when assessing third countries that could be
considered for a visa-free regime with the European Union. Moreover, third countries that
already enjoy visa-free status must carry out security and background checks of applicants for
citizenship schemes to the highest possible standards; any failures in this regard could be
grounds for re-imposing a visa requirement and suspending or terminating visa waiver
agreements.
The Commission will monitor the impact of investor citizenship schemes implemented by
visa-free countries as part of the visa-suspension mechanism.
6. Conclusions
Investor citizenship and residence schemes pose risks for the Member States and the Union as
a whole, including in terms of security, money laundering, corruption, circumvention of EU
rules and tax evasion.
The abovementioned risks are further accentuated by shortcomings in the transparency and
governance of such schemes. The study commissioned by the Commission shows that the
information available on both investor citizenship and residence schemes operated by
Member States is incomplete. For instance, clear statistics on applications received, accepted
and rejected are missing or insufficient. Furthermore, there are no mechanisms to ensure
cooperation between the Member States on investor citizenship schemes, notably on security
checks. The Commission has concerns about the risks inherent in investor citizenship and
residence schemes and about the fact that the risks are not always sufficiently mitigated by the
measures taken by Member States.
The Commission will monitor the steps taken by Member States to ensure transparency and
good governance in the implementation of the schemes, with a view to address, in particular
risks of infiltration of non-EU organised crime groups in the economy, money laundering,
corruption and tax evasion. With a view to Member States improving the transparency and
governance of the schemes, the Commission will establish a group of experts to further
address matters of transparency, governance and security.
119
120
The Moldova Citizenship-by-Investment (MCBI) programme is governed by the Law No. 1024 of June 2,
2000 “on the citizenship of the Republic of Moldova” and the Government Decision No. 786 of October 4,
2017 “on acquiring citizenship by investment”. On 6 November, the Moldovan Citizenship-by-Investment
program was officially launched at the 12th Global Residence and Citizenship Conference, held in Dubai.
See for instance: https://vic.vu/citizenship/ (“Key benefits of Vanuatu Citizenship”).
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