• 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

Blog post

Moving Talent, Moving Families: Navigating Family Reunification in Europe

Senior Manager Andreia Ghimis and Senior Immigration Consultant Louise Farren explore how family reunification rules across Europe can affect international moves and why employers should assess family eligibility, immigration requirements and likely timelines alongside an employee’s work authorization.

Learn more

Media mentions

Business Insider: How Would the $70,000 Fee on International Students Working in the US Impact Schools and Grads? 2 Lawyers Break It Down.

Partner Aaron Blumberg discusses how a proposed $70,000 fee for international students seeking US work authorization could affect students, universities and employers.

Learn more

Blog post

How to Qualify for Permanent Residence and Polish Citizenship

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek outline the principal pathways to permanent residence and Polish citizenship, including key residence, language and income considerations and potential future reforms.

Learn more

Fragomen news

Comment on USCIS Mandatory Electronic Filing RuleLearn more

Fragomen news

Fragomen Collaboration Selected as 2026 European Labour Authority Good Practice

Fragomen, together with SICPA and Deutsche Rentenversicherung Bund, has been selected by the European Labour Authority as a 2026 Good Practice for an EU-funded WE BUILD use case exploring how digital identity solutions could help transform PD A1 processes and support cross-border labour mobility in Europe.

Learn more

Media mentions

The Caterer: Right to Work Scheme: Have You Carried Out Checks on Temporary Staff?

Senior Manager Louise Senior highlights how expanded UK right to work requirements will affect hospitality businesses using temporary and contingent workers.

Learn more

Media mentions

Citeline: The People Behind The Pipeline: How The Global Race For Talent Is Reshaping Pharma

Partners Rajiv Naik and Hyla Kaplan Rosenberg explore how global talent policies are reshaping the biopharma industry.

Learn more

Video

Healthcare Horizons: Open Enrollment - a J-1 Trap? | #MobilityMinute

Counsel Christopher L. Wendt discusses why J-1 exchange visitors should carefully evaluate health insurance options during open enrollment and how a proposed Department of State rule could increase the consequences of selecting coverage that does not meet applicable requirements.

Learn more

Fragomen news

2026 年9月アメリカ移民法ダイジェストLearn more

Media mentions

Scottish Legal News: Scotland Needs Immigration Rules Built for Scotland’s Economy

Director Kelly Hardman examines proposals for a more tailored immigration framework in Scotland that reflects the country’s economic, workforce and demographic needs.

Learn more

Media mentions

Veranda: Want to Get a Second Passport? Here Are the 3 Universal Rules You Need to Know

Practice Leader Olga Nechita outlines common pathways to obtaining a second passport and key considerations for prospective applicants.

Learn more

Blog post

Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Director Isobel Neilson and Manager Sophie Jo Wasson examine how Malta’s Citizenship by Merit framework considers exceptional achievement and contribution alongside the country’s long-term priorities under Vision 2050, and what applicants should consider when developing a credible case.

Learn more

Blog post

Moving Talent, Moving Families: Navigating Family Reunification in Europe

Senior Manager Andreia Ghimis and Senior Immigration Consultant Louise Farren explore how family reunification rules across Europe can affect international moves and why employers should assess family eligibility, immigration requirements and likely timelines alongside an employee’s work authorization.

Learn more

Media mentions

Business Insider: How Would the $70,000 Fee on International Students Working in the US Impact Schools and Grads? 2 Lawyers Break It Down.

Partner Aaron Blumberg discusses how a proposed $70,000 fee for international students seeking US work authorization could affect students, universities and employers.

Learn more

Blog post

How to Qualify for Permanent Residence and Polish Citizenship

Poland Immigration Strategy Director Tomasz Rogala and Senior Associate Tomasz Rdzanek outline the principal pathways to permanent residence and Polish citizenship, including key residence, language and income considerations and potential future reforms.

Learn more

Fragomen news

Comment on USCIS Mandatory Electronic Filing RuleLearn more

Fragomen news

Fragomen Collaboration Selected as 2026 European Labour Authority Good Practice

Fragomen, together with SICPA and Deutsche Rentenversicherung Bund, has been selected by the European Labour Authority as a 2026 Good Practice for an EU-funded WE BUILD use case exploring how digital identity solutions could help transform PD A1 processes and support cross-border labour mobility in Europe.

Learn more

Media mentions

The Caterer: Right to Work Scheme: Have You Carried Out Checks on Temporary Staff?

Senior Manager Louise Senior highlights how expanded UK right to work requirements will affect hospitality businesses using temporary and contingent workers.

Learn more

Media mentions

Citeline: The People Behind The Pipeline: How The Global Race For Talent Is Reshaping Pharma

Partners Rajiv Naik and Hyla Kaplan Rosenberg explore how global talent policies are reshaping the biopharma industry.

Learn more

Video

Healthcare Horizons: Open Enrollment - a J-1 Trap? | #MobilityMinute

Counsel Christopher L. Wendt discusses why J-1 exchange visitors should carefully evaluate health insurance options during open enrollment and how a proposed Department of State rule could increase the consequences of selecting coverage that does not meet applicable requirements.

Learn more

Fragomen news

2026 年9月アメリカ移民法ダイジェストLearn more

Media mentions

Scottish Legal News: Scotland Needs Immigration Rules Built for Scotland’s Economy

Director Kelly Hardman examines proposals for a more tailored immigration framework in Scotland that reflects the country’s economic, workforce and demographic needs.

Learn more

Media mentions

Veranda: Want to Get a Second Passport? Here Are the 3 Universal Rules You Need to Know

Practice Leader Olga Nechita outlines common pathways to obtaining a second passport and key considerations for prospective applicants.

Learn more

Blog post

Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Director Isobel Neilson and Manager Sophie Jo Wasson examine how Malta’s Citizenship by Merit framework considers exceptional achievement and contribution alongside the country’s long-term priorities under Vision 2050, and what applicants should consider when developing a credible case.

Learn more
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
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsView 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

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • 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
Important Updates
Important Updates
October 13, 2026 | United StatesUnited States: What Employers Need to Know About the Government’s New PERM Investigations and Program Suspensions
October 14, 2026 | KuwaitKuwait: New Wage Payment and Protection System Launched
October 13, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
October 13, 2026 | United StatesUnited States: Trump Administration Again Proposes Elimination of Deference to Prior Approvals of Immigration Petitions
October 13, 2026 | United StatesUnited States: USCIS Reaffirms Regulation Eliminating Maximum 540-Day EAD Auto-Extension
October 13, 2026 | United StatesUnited States: What Employers Need to Know About the Government’s New PERM Investigations and Program Suspensions
October 14, 2026 | KuwaitKuwait: New Wage Payment and Protection System Launched
October 13, 2026 | 🌐Middle East - The Latest News on Mobility and Travel Considerations
October 13, 2026 | United StatesUnited States: Trump Administration Again Proposes Elimination of Deference to Prior Approvals of Immigration Petitions
October 13, 2026 | United StatesUnited States: USCIS Reaffirms Regulation Eliminating Maximum 540-Day EAD Auto-Extension
October 13, 2026 | United StatesUnited States: What Employers Need to Know About the Government’s New PERM Investigations and Program Suspensions
Subscribe

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
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

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

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

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

© 2026 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.