
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
Visas
Senior Business Immigration Manager Vicente Duque outlines key immigration considerations for international visitors traveling to Mexico for the 2026 FIFA World Cup, including visa eligibility, entry documentation and travel between host countries.
Blog post
Counsel Susan Steger examines how wage-driven selection mechanisms in programs such as the H-1B lottery and PERM can create incentives for artificial wage inflation and introduce new compliance and workforce planning challenges for employers.
Media mentions
Director Gemma Hyslop examines how collaboration across the global mobility sector can help strengthen legal pathways and support for migrant women experiencing abuse.
Media mentions
Partner Abeer Al Husseini discussed immigration and duty-of-care challenges for employers amid Middle East travel disruptions.
Awards
Partner Sarah K. Peterson is recognized by the Minneapolis/St. Paul Business Journal as a 2026 Women in Business honoree for her professional achievements and contributions to the Twin Cities business community.
Media mentions
Immigration Manager Alice Heron explains how HR teams can navigate Irish immigration law and manage international talent effectively.
Media mentions
Associate Ilaria Iovieno and Immigration Consultant Devina Sanghera outline what the proposed expansion of the UK Right to Work Scheme means for housebuilders.
Awards
Partner Cynthia Shearn is recognized by Crain’s Chicago Business in its 2026 Notable Women in Law list, honoring her leadership in immigration and global mobility and her impact within the legal community.
Media mentions
Partner Emily Allen says the new H-1B lottery is driving earlier planning and more detailed preparation.
Blog post
Senior Business Immigration Consultant Ryaihanny Sahrom and Business Immigration Consultant II Fahimah Muhammad examine Indonesia’s newly launched Global Citizenship of Indonesia (GCI) program and its introduction of long-term and indefinite permanent residence pathways for members of the Indonesian diaspora.
Media mentions
Senior Immigration Manager Jonathan Hill notes that tighter UK visa compliance rules and new rating measures create additional challenges for universities.
Video
Partner Diana Quintas outlines key early career visa pathways and practical considerations for employers and graduates navigating entry-level immigration options.
Visas
Senior Business Immigration Manager Vicente Duque outlines key immigration considerations for international visitors traveling to Mexico for the 2026 FIFA World Cup, including visa eligibility, entry documentation and travel between host countries.
Blog post
Counsel Susan Steger examines how wage-driven selection mechanisms in programs such as the H-1B lottery and PERM can create incentives for artificial wage inflation and introduce new compliance and workforce planning challenges for employers.
Media mentions
Director Gemma Hyslop examines how collaboration across the global mobility sector can help strengthen legal pathways and support for migrant women experiencing abuse.
Media mentions
Partner Abeer Al Husseini discussed immigration and duty-of-care challenges for employers amid Middle East travel disruptions.
Awards
Partner Sarah K. Peterson is recognized by the Minneapolis/St. Paul Business Journal as a 2026 Women in Business honoree for her professional achievements and contributions to the Twin Cities business community.
Media mentions
Immigration Manager Alice Heron explains how HR teams can navigate Irish immigration law and manage international talent effectively.
Media mentions
Associate Ilaria Iovieno and Immigration Consultant Devina Sanghera outline what the proposed expansion of the UK Right to Work Scheme means for housebuilders.
Awards
Partner Cynthia Shearn is recognized by Crain’s Chicago Business in its 2026 Notable Women in Law list, honoring her leadership in immigration and global mobility and her impact within the legal community.
Media mentions
Partner Emily Allen says the new H-1B lottery is driving earlier planning and more detailed preparation.
Blog post
Senior Business Immigration Consultant Ryaihanny Sahrom and Business Immigration Consultant II Fahimah Muhammad examine Indonesia’s newly launched Global Citizenship of Indonesia (GCI) program and its introduction of long-term and indefinite permanent residence pathways for members of the Indonesian diaspora.
Media mentions
Senior Immigration Manager Jonathan Hill notes that tighter UK visa compliance rules and new rating measures create additional challenges for universities.
Video
Partner Diana Quintas outlines key early career visa pathways and practical considerations for employers and graduates navigating entry-level immigration options.
