
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
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
Assistant Business Immigration Manager Shirley Kock and Senior Business Immigration Consultant Eunice Leo examine why applying early for Singapore permanent residency can strengthen long-term outcomes for foreign professionals and their families amid increasing competition and evolving immigration policies.
Blog post
UK Government Affairs Strategy Director Shuyeb Muquit outlines key passport and documentation considerations for British and Irish dual nationals as the UK’s Electronic Travel Authorisation (ETA) scheme moves into full enforcement from 25 February 2026, warning that failure to carry proof of British or Irish citizenship may result in boarding delays or refusal.
Media mentions
Senior Manager Géraldine Renaudière highlights how evolving policies and growing talent visa programs are shaping France’s immigration landscape.
Video
Senior Immigration Consultant Adriana Martinez Garro outlines the main visa and residency options available in Costa Rica, offering a practical overview for visitors, remote workers, retirees, investors and families exploring short- or long-term pathways.
Awards
Managing Partner Nadine Goldfoot and Senior Counsel David Crawford are recognized in Uglobal Immigration Magazine’s 2025 Top 25 Global Migration Attorneys list.
Media mentions
Partner Karolina Schiffter addresses the rise in Polish citizenship refusals and the impact of automated decision-making on individual cases.
Blog post
Manager Adam Hickling, Senior Associate Veronica Ciocea and Immigration Consultant Daisy Dale analyse the UK government’s A Fairer Pathway to Settlement consultation and its potential implications for the aviation sector, including proposed changes to Indefinite Leave to Remain, settlement timelines and dependant eligibility.
Media mentions
Partner Parisa Karaahmet discusses how recent US immigration policy changes, including potential impacts on the H-1B lottery, are shaping employer planning.
Media mentions
Media mentions
Partners Isha Atassi and Rahul Soni discuss US investment-based immigration options for Middle Eastern investors.
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
Assistant Business Immigration Manager Shirley Kock and Senior Business Immigration Consultant Eunice Leo examine why applying early for Singapore permanent residency can strengthen long-term outcomes for foreign professionals and their families amid increasing competition and evolving immigration policies.
Blog post
UK Government Affairs Strategy Director Shuyeb Muquit outlines key passport and documentation considerations for British and Irish dual nationals as the UK’s Electronic Travel Authorisation (ETA) scheme moves into full enforcement from 25 February 2026, warning that failure to carry proof of British or Irish citizenship may result in boarding delays or refusal.
Media mentions
Senior Manager Géraldine Renaudière highlights how evolving policies and growing talent visa programs are shaping France’s immigration landscape.
Video
Senior Immigration Consultant Adriana Martinez Garro outlines the main visa and residency options available in Costa Rica, offering a practical overview for visitors, remote workers, retirees, investors and families exploring short- or long-term pathways.
Awards
Managing Partner Nadine Goldfoot and Senior Counsel David Crawford are recognized in Uglobal Immigration Magazine’s 2025 Top 25 Global Migration Attorneys list.
Media mentions
Partner Karolina Schiffter addresses the rise in Polish citizenship refusals and the impact of automated decision-making on individual cases.
Blog post
Manager Adam Hickling, Senior Associate Veronica Ciocea and Immigration Consultant Daisy Dale analyse the UK government’s A Fairer Pathway to Settlement consultation and its potential implications for the aviation sector, including proposed changes to Indefinite Leave to Remain, settlement timelines and dependant eligibility.
Media mentions
Partner Parisa Karaahmet discusses how recent US immigration policy changes, including potential impacts on the H-1B lottery, are shaping employer planning.
Media mentions
Media mentions
Partners Isha Atassi and Rahul Soni discuss US investment-based immigration options for Middle Eastern investors.

