
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
Media mentions
Blog post
Senior Manager Zak Hynes explores the key factors businesses should consider when establishing a presence in the UAE—from operating model and visa requirements to banking, office needs and long-term growth plans—in our new blog. The right structure is the one that best supports your business strategy, not simply the lowest upfront cost.
Video
Partner Catherine Macris highlights key findings from Fragomen’s 2026 regional immigration overviews, including tighter compliance controls, digital border transformation and emerging pathways for global talent.
Media mentions
Partner Karolina Schiffter discusses how the EU's extension of temporary protection for Ukrainian citizens through 2028 will affect employers in Poland.
Fragomen news
Fragomen’s "Immigration Guide for the UK Tech Sector" introduces visa options available for those working and recruiting in the tech sector.
Blog post
Center for Strategy and Applied Insights Senior Director Leah Rogal examines how employers can use the J-1 Research Scholar visa to retain eligible global research talent, support long-term research initiatives and strengthen workforce and immigration planning.
Blog post
In this blog, Middle East and Africa Private Client Practice Director Nofi Mojidi-Bayna explores how evolving residency frameworks across the region are reshaping long-term mobility planning and examines the three global forces transforming immigration strategy for businesses, investors and internationally mobile families.
Blog post
In this blog, Associate Halil Kaya outlines the UK Visa Fees Reimbursement Scheme for Scale Ups, including eligibility requirements, available funding and key considerations for high-growth businesses recruiting international talent.
Media mentions
Blog post
Media mentions
Senior Associate Isabel Schnitzler outlines the key compliance considerations for employers with employees working across the EU.
Podcast
Associates Julia Manacher and Stephanie Weaver examine immigration issues emerging in a popular reality television series, including K-1 visa denials, consular non-reviewability, fraud findings and changing adjudication policies.
Media mentions
Blog post
Senior Manager Zak Hynes explores the key factors businesses should consider when establishing a presence in the UAE—from operating model and visa requirements to banking, office needs and long-term growth plans—in our new blog. The right structure is the one that best supports your business strategy, not simply the lowest upfront cost.
Video
Partner Catherine Macris highlights key findings from Fragomen’s 2026 regional immigration overviews, including tighter compliance controls, digital border transformation and emerging pathways for global talent.
Media mentions
Partner Karolina Schiffter discusses how the EU's extension of temporary protection for Ukrainian citizens through 2028 will affect employers in Poland.
Fragomen news
Fragomen’s "Immigration Guide for the UK Tech Sector" introduces visa options available for those working and recruiting in the tech sector.
Blog post
Center for Strategy and Applied Insights Senior Director Leah Rogal examines how employers can use the J-1 Research Scholar visa to retain eligible global research talent, support long-term research initiatives and strengthen workforce and immigration planning.
Blog post
In this blog, Middle East and Africa Private Client Practice Director Nofi Mojidi-Bayna explores how evolving residency frameworks across the region are reshaping long-term mobility planning and examines the three global forces transforming immigration strategy for businesses, investors and internationally mobile families.
Blog post
In this blog, Associate Halil Kaya outlines the UK Visa Fees Reimbursement Scheme for Scale Ups, including eligibility requirements, available funding and key considerations for high-growth businesses recruiting international talent.
Media mentions
Blog post
Media mentions
Senior Associate Isabel Schnitzler outlines the key compliance considerations for employers with employees working across the EU.
Podcast
Associates Julia Manacher and Stephanie Weaver examine immigration issues emerging in a popular reality television series, including K-1 visa denials, consular non-reviewability, fraud findings and changing adjudication policies.
