Important Updates
Important Updates
December 19, 2025 | GuatemalaGuatemala: Immigration Rules Overhauled to Introduce Remote Work Pathways, Simplify Family Processing and Strengthen Compliance
December 19, 2025 | BulgariaBulgaria: Digital Nomad Residence Permit Introduced
December 19, 2025 | United StatesBusiness Insider: New H-1B Visa Rules Upgrade Some Lottery Applicants — and Squeeze Out Others
December 19, 2025 | DenmarkDenmark: Work Permit Exemption for Business Events, Conferences, Trade Fairs
December 19, 2025 | FinlandFinland: Permanent Residence Eligibility Restrictions Forthcoming
December 19, 2025 | GuatemalaGuatemala: Immigration Rules Overhauled to Introduce Remote Work Pathways, Simplify Family Processing and Strengthen Compliance
December 19, 2025 | BulgariaBulgaria: Digital Nomad Residence Permit Introduced
December 19, 2025 | United StatesBusiness Insider: New H-1B Visa Rules Upgrade Some Lottery Applicants — and Squeeze Out Others
December 19, 2025 | DenmarkDenmark: Work Permit Exemption for Business Events, Conferences, Trade Fairs
December 19, 2025 | FinlandFinland: Permanent Residence Eligibility Restrictions Forthcoming
December 19, 2025 | GuatemalaGuatemala: Immigration Rules Overhauled to Introduce Remote Work Pathways, Simplify Family Processing and Strengthen Compliance
Subscribe
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Navigating Immigration Under the Second Trump AdministrationFragomen Consulting EuropeImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsVietnamese ImmigrationView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Navigating Immigration Under the Second Trump Administration
  • Fragomen Consulting Europe
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • Vietnamese Immigration
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
  • Insights

Tier 1 Investors in Spotlight in the UK

April 6, 2018

Nadine Goldfoot

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Nadine Goldfoot

Nadine Goldfoot

Managing Partner, United Kingdom

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9156

Related offices

  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Nadine Goldfoot

Nadine Goldfoot

Managing Partner, United Kingdom

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9156

Related offices

  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Nadine Goldfoot

Nadine Goldfoot

Managing Partner, United Kingdom

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9156

Related offices

  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

By: Nadine Goldfoot

On 27 March 2018, the Prime Minister gave oral evidence before the Commons Liaison Committee on Russia and the aftermath of the Salisbury incident, during which she was questioned on the grant of Tier 1 (Investor) visas to around 700 Russian nationals between 2008 and 2015.

Yvette Cooper MP asked if the Home Office intended to do a retrospective source of money check on these granted applications. The Prime Minister did not promise such an investigation into these specific cases but advised that a more general review of the Tier 1 (Investor) scheme was underway by Home Secretary, Amber Rudd MP. The review goes beyond the specific Russia issue, and the Prime Minister stated, “It is right that we look generally to see whether this is a part of our visa regime that is being used properly or whether there are loopholes in it for people to be able to use it as access to the UK when otherwise we would not be granting them access” (see question 6).When pressed upon the issue of whether the review would or should look at individual cases where finances were in question, the Prime Minister advised that she would “ask the Home Office to provide further information”.

The scope of the review is not fully known but the investor scheme has already seen significant tightening of regulatory regimes around it. As is commonly known applicants must of course now open UK bank accounts prior to applying. In order to do so they must satisfy UK regulated financial institutions due diligence processes. New civil powers also came into force on 31 January 2018 enabling the High Court to grant an Unexplained Wealth Order (“UWO”) on satisfaction of a number of tests. It is effectively an investigative tool.

A UWO requires a person who is reasonably suspected of involvement in, or of being connected to a person involved in, serious crime to explain the nature and extent of their interest in particular property, and to explain how the property was obtained, where there are reasonable grounds to suspect that the respondent’s known lawfully obtained income would be insufficient to allow the respondent to obtain the property. The test for involvement with serious crime is by reference to Part 1 of the Serious Crime Act 2007. A UWO can also be applied to politicians or officials from outside the European Economic Area (EEA), or those associated with them i.e. Politically Exposed Persons (PEPs). A UWO made in relation to a non-EEA PEP would not require suspicion of serious criminality.

The ability to apply for a UWO is limited to those agencies defined as an “enforcement authority”, which does not include the Home Office currently but does include Her Majesty’s Revenue and Customs. Although the Home Office cannot apply directly for an Order, agencies, including the enforcement authorities, will be required to consider their legal powers and abilities to share information. This is both when referring information to each other either to support an application for a UWO, or to consider civil or criminal action in regards to the information obtained in UWO.

Of course also, the European Union’s Fourth Anti-Money Laundering Directive came into force on 26th June 2017. The Directive includes some fundamental changes to the anti-money laundering procedures, rules on PEPs, including changes to CDD, a central register for beneficial owners and a focus on risk assessments.

It remains to be seen whether the Home Office review will find that sufficient checks are now in place or whether further restrictions are to be introduced for Tier 1 (Investors).

Learn more about Nadine Goldfoot.

Country / Territory

  • United KingdomUnited Kingdom

Related contacts

Nadine Goldfoot

Nadine Goldfoot

Managing Partner, United Kingdom

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9156

Related offices

  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Nadine Goldfoot

Nadine Goldfoot

Managing Partner, United Kingdom

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9156

Related offices

  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Related contacts

Nadine Goldfoot

Nadine Goldfoot

Managing Partner, United Kingdom

London, United Kingdom

Email

[email protected]

T:+44 (0) 20 7090 9156

Related offices

  • London

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Media mentions

Business Insider: New H-1B Visa Rules Upgrade Some Lottery Applicants — and Squeeze Out Others

Partner K. Edward Raleigh on how the $100K H‑1B fee factors into hiring international talent.

Learn more

Media mentions

Konfederacja Lewiatan: Procedura legalizacji zatrudnienia cudzoziemców w Polsce po zmianach w 2025 r.

Poland Immigration Strategy Director Tomasz Rogala contributes to Konfederacja Lewiatan’s analysis on 2025 changes to work permits and foreign employment in Poland.

Learn more

Blog post

F and J Visa Updates: Social Media Checks Begin as DHS Proposes New Limits

Associate Alejandro Hernandez analyses new F and J visa screening practices, including social media vetting by US consulates and proposed DHS changes that could significantly alter admission periods for students and exchange visitors.

Learn more

Awards

Fragomen Ireland Awarded the KeepWell Mark by IBEC

Fragomen Ireland is accredited with IBEC’s KeepWell Mark™, recognizing the practice’s commitment to wellbeing, inclusion and responsible business.

Learn more

Media mentions

The Scotsman: UK Offshore Immigration Crackdown Risks Stifling Growth Unless Policy Meets Reality

Director Kelly Hardman discusses how UK offshore immigration rules are creating challenges for energy and maritime operations.

Learn more

Media mentions

HR Headquarters: Irish Immigration Changes: What Employers Need To Know Now And Into 2026

Partner Ángel Bello Cortés outlines upcoming changes to Ireland’s immigration rules and their implications for employers.

Learn more

Media mentions

ABC7: CA, Other States Sue Trump Admin Over New $100K Fee for H-1B Visas

Partner Chad Ellsworth discussed the new $100,000 H-1B visa fee and ongoing demand for specialized talent across the US tech industry.

Learn more

Media mentions

Caring Times: Home Office Scrutiny Intensifies

Senior Manager Kate Hooper and Associate Naomi Nyamaah explain the importance of maintaining sponsor licences for care providers in the UK.

Learn more

Media mentions

CBC: What We Know About US Proposal to Demand 5 Years of Social Media History From Certain Visitors

Counsel Brian Hunt outlines how the US could scan social media as part of proposed entry requirements for travellers applying through ESTA.

Learn more

Video

Minimum Annual Remuneration Threshold Increases for Employment Permits in Ireland | #MobilityMinute

In the Mobility Minute, Practice Leader Colm Collins outlines upcoming changes to Ireland’s employment permit qualifying criteria and the steps employers should take ahead of the 1 March 2026 implementation.

Learn more

Media mentions

Leading Britain's Conversation: The US Wants to Review Your Instagram Stories - Just in Time for the World Cup

Partner Charlotte Slocombe discusses what travellers to the US under the Visa Waiver Program need to disclose and consider before travelling.

Learn more

Media mentions

Newstalk ZB: Explained: Do Prospective Kiwi Tourists to the US Need to Be Careful?

Counsel Brian Hunt discussed US Customs and Border Protection's proposed changes to the ESTA application process regarding social media and additional personal information.

Learn more

Media mentions

Business Insider: New H-1B Visa Rules Upgrade Some Lottery Applicants — and Squeeze Out Others

Partner K. Edward Raleigh on how the $100K H‑1B fee factors into hiring international talent.

Learn more

Media mentions

Konfederacja Lewiatan: Procedura legalizacji zatrudnienia cudzoziemców w Polsce po zmianach w 2025 r.

Poland Immigration Strategy Director Tomasz Rogala contributes to Konfederacja Lewiatan’s analysis on 2025 changes to work permits and foreign employment in Poland.

Learn more

Blog post

F and J Visa Updates: Social Media Checks Begin as DHS Proposes New Limits

Associate Alejandro Hernandez analyses new F and J visa screening practices, including social media vetting by US consulates and proposed DHS changes that could significantly alter admission periods for students and exchange visitors.

Learn more

Awards

Fragomen Ireland Awarded the KeepWell Mark by IBEC

Fragomen Ireland is accredited with IBEC’s KeepWell Mark™, recognizing the practice’s commitment to wellbeing, inclusion and responsible business.

Learn more

Media mentions

The Scotsman: UK Offshore Immigration Crackdown Risks Stifling Growth Unless Policy Meets Reality

Director Kelly Hardman discusses how UK offshore immigration rules are creating challenges for energy and maritime operations.

Learn more

Media mentions

HR Headquarters: Irish Immigration Changes: What Employers Need To Know Now And Into 2026

Partner Ángel Bello Cortés outlines upcoming changes to Ireland’s immigration rules and their implications for employers.

Learn more

Media mentions

ABC7: CA, Other States Sue Trump Admin Over New $100K Fee for H-1B Visas

Partner Chad Ellsworth discussed the new $100,000 H-1B visa fee and ongoing demand for specialized talent across the US tech industry.

Learn more

Media mentions

Caring Times: Home Office Scrutiny Intensifies

Senior Manager Kate Hooper and Associate Naomi Nyamaah explain the importance of maintaining sponsor licences for care providers in the UK.

Learn more

Media mentions

CBC: What We Know About US Proposal to Demand 5 Years of Social Media History From Certain Visitors

Counsel Brian Hunt outlines how the US could scan social media as part of proposed entry requirements for travellers applying through ESTA.

Learn more

Video

Minimum Annual Remuneration Threshold Increases for Employment Permits in Ireland | #MobilityMinute

In the Mobility Minute, Practice Leader Colm Collins outlines upcoming changes to Ireland’s employment permit qualifying criteria and the steps employers should take ahead of the 1 March 2026 implementation.

Learn more

Media mentions

Leading Britain's Conversation: The US Wants to Review Your Instagram Stories - Just in Time for the World Cup

Partner Charlotte Slocombe discusses what travellers to the US under the Visa Waiver Program need to disclose and consider before travelling.

Learn more

Media mentions

Newstalk ZB: Explained: Do Prospective Kiwi Tourists to the US Need to Be Careful?

Counsel Brian Hunt discussed US Customs and Border Protection's proposed changes to the ESTA application process regarding social media and additional personal information.

Learn more

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • Twitter

© 2025 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.