
Country / Territory
Related contacts

Managing Partner, United Kingdom
Related offices
Related contacts

Managing Partner, United Kingdom
Related offices
Related contacts

Managing Partner, United Kingdom
Related offices
By: Nadine Goldfoot
On Monday 5 March, the Organized Crime and Corruption Reporting Project and Transparency International launched a report on global investor migration programmes.
The report alleges that citizenship and residence through investment schemes are vulnerable to abuse and ‘undermine the fight against corruption in the European Union and neighbouring countries … selling access to the Schengen visa-free travel area, and even EU citizenship, to foreign investors with little scrutiny, transparency or due diligence. The report discusses programmes in a number of jurisdictions and calls on the European Commission to act.
The Commission is already active in this area and examining investor migration programmes across Europe. Nonetheless, the report serves as an important learning tool which the young and evolving industry takes very seriously, and is a warning of the absolute importance of enhanced due diligence throughout the application process for those offering such programmes or looking to move into this space. Globally, regulatory regimes are rightly tightening towards higher standards of compliance and increasing levels of diligence in all aspects. As restrictions tighten, the vast majority of investor migration clients are moving in synchronisation. They increasingly and rightly value best practice standards as the norm. The industry itself is demanding the highest internal standards and learning the lessons of controversy and, under the governance of the Investment Migration Council, the industry will continue to grow in best practice standards.
A balance of course must be struck between due diligence and due process, and whilst programmes must operate to the highest of ethical standards, applicants are also entitled to due process and to a fair determination of their applications. Malta is subject to criticism in the report, but it should be observed that applicants to the Individual Investor Program must submit to rigorous due diligence processes. Applicants must demonstrate a clean criminal record, with checks being conducted with the International Criminal Court, INTERPOL and various other authorities and sources. Police certificates are mandatory, as is increasingly the case across the globe. Most programmes will have grounds for exclusion that usually include individuals indicted before an International Criminal Court or who appeared at any time before an International Criminal Court; those who have at any time had pending charges related to crimes of terrorism, money laundering, funding of terrorism, crimes against humanity, war crimes, or crimes that infringe upon such protection of human rights and fundamental freedoms; those convicted of serious criminal activity and those whose assets have been frozen or blocked within the EU.
The report demonstrates that work is still to be done within the industry to achieve best practices, rigorous standards and reputational integrity – improvements can of course always be made and constructive dialogue will remain key.
Country / Territory
Related contacts

Managing Partner, United Kingdom
Related offices
Related contacts

Managing Partner, United Kingdom
Related offices
Related contacts

Managing Partner, United Kingdom
Related offices
Explore more at Fragomen
Video
Partner Diana Quintas outlines key early career visa pathways and practical considerations for employers and graduates navigating entry-level immigration options.
Fragomen news
The Montreal office has added Partner Julie Lessard and Counsel Elsa Agostinho and Sophia Khanzadian to strengthen its immigration services.
Blog post
Destination Services Director Christine Sperr examines how housing market reforms, rent stabilization measures and cost-of-living dynamics in Saudi Arabia are influencing workforce mobility, compensation planning and long-term settlement strategies under Vision 2030.
Blog post
Manager Dr Adela Schmidt and Senior Associate Isabel Schnitzler analyse the European Commission’s infringement proceedings against Germany concerning its Vander Elst visa requirements for third-country nationals providing short-term cross-border services and explain why current compliance obligations remain unchanged.
Blog post
Latin America & the Caribbean Managing Partner Leonor Echeverria, Senior Associates Sarah Blackmore and Sonya Cole and Senior Regional Knowledge Manager Laura Weingort examine renewed energy interest in Venezuela and outline key immigration pathways, procedural constraints and strategic considerations for compliant talent deployment.
Media mentions
Senior Manager Andreia Ghimis highlights how the EU’s new migration strategy could create opportunities for employers while increasing compliance requirements.
Awards
Partner Julia Onslow-Cole is recognised in the Spears 500 guide to leading private client advisers, reflecting her experience advising high-net-worth individuals, families and global businesses on complex UK and European immigration and mobility strategies.
Media mentions
Partner Abeer Al Husseini discusses increased scrutiny of Saudi business visas in AGBI, highlighting stricter review of short-term entry used for operational work and the implications for regional employers.
Awards
Australia and New Zealand Managing Partner Teresa Liu, Partner Charles Johanes, Practice Leaders Hedvika and Leader Ben Lear and Senior Associate Hannah Scanlan are recognized in the 2026 edition of Doyle’s Guide as leading immigration practitioners in Australia.
Awards
Fragomen is ranked Band 1 for Immigration: Business in the Chambers Global 2026 Guide, marking two decades of recognition since 2006. The firm is also the only firm ranked Band 1 in the Global: Multi-Jurisdictional Immigration category and receives additional individual recognitions in the USA: Business Immigration rankings.
Media mentions
Partner Rick Lamanna provides insight to Buffalo Toronto Public Media on potential IRCC processing challenges as Canada prepares for increased visa demand ahead of the 2026 FIFA World Cup.
Video
Partner Diana Quintas outlines key early career visa pathways and practical considerations for employers and graduates navigating entry-level immigration options.
Fragomen news
The Montreal office has added Partner Julie Lessard and Counsel Elsa Agostinho and Sophia Khanzadian to strengthen its immigration services.
Blog post
Destination Services Director Christine Sperr examines how housing market reforms, rent stabilization measures and cost-of-living dynamics in Saudi Arabia are influencing workforce mobility, compensation planning and long-term settlement strategies under Vision 2030.
Blog post
Manager Dr Adela Schmidt and Senior Associate Isabel Schnitzler analyse the European Commission’s infringement proceedings against Germany concerning its Vander Elst visa requirements for third-country nationals providing short-term cross-border services and explain why current compliance obligations remain unchanged.
Blog post
Latin America & the Caribbean Managing Partner Leonor Echeverria, Senior Associates Sarah Blackmore and Sonya Cole and Senior Regional Knowledge Manager Laura Weingort examine renewed energy interest in Venezuela and outline key immigration pathways, procedural constraints and strategic considerations for compliant talent deployment.
Media mentions
Senior Manager Andreia Ghimis highlights how the EU’s new migration strategy could create opportunities for employers while increasing compliance requirements.
Awards
Partner Julia Onslow-Cole is recognised in the Spears 500 guide to leading private client advisers, reflecting her experience advising high-net-worth individuals, families and global businesses on complex UK and European immigration and mobility strategies.
Media mentions
Partner Abeer Al Husseini discusses increased scrutiny of Saudi business visas in AGBI, highlighting stricter review of short-term entry used for operational work and the implications for regional employers.
Awards
Australia and New Zealand Managing Partner Teresa Liu, Partner Charles Johanes, Practice Leaders Hedvika and Leader Ben Lear and Senior Associate Hannah Scanlan are recognized in the 2026 edition of Doyle’s Guide as leading immigration practitioners in Australia.
Awards
Fragomen is ranked Band 1 for Immigration: Business in the Chambers Global 2026 Guide, marking two decades of recognition since 2006. The firm is also the only firm ranked Band 1 in the Global: Multi-Jurisdictional Immigration category and receives additional individual recognitions in the USA: Business Immigration rankings.
Media mentions
Partner Rick Lamanna provides insight to Buffalo Toronto Public Media on potential IRCC processing challenges as Canada prepares for increased visa demand ahead of the 2026 FIFA World Cup.

