Everything You Need to Know About North Macedonia’s New Citizenship Program

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IMI reached out to some of the major stakeholders of the new North Macedonian citizenship by investment program to clarify questions regarding the program’s structure, pricing, and requirements, as well as about the selection of agents, the North Macedonian government’s decision process, and more.

Responding to our questions were Cyrus Arman of Asara Group, the Master Agent, Jean-François Harvey of Harvey Law Group, the Master Compliance Agent for Asia, and Sam Bayat of Bayat Legal Services, one of the program’s appointed agents for the MENA region.

You can skip directly to a question by clicking it in the list below:

• Considering the wide variety of unofficial investment migration “programs” circulating in the market, how can investors be confident that this is a bona fide, government-sanctioned CIP?
• Can we expect an official announcement on the matter from the government?
• Was there a public tender for this program?
• Who can become agents of the program? Is it open to anyone?
• Will there be a CIU or other type of dedicated processing unit within the government?
• Harvey Law Group is listed as the program but also the “master compliance agent” for Asia. What does that title imply?
• Can we expect the introduction of further investment options, beyond business investment and fund contributions, such as real estate, for example?
• When will the program open to applications and what does the process look like?
• What is the cost structure for investments and applications?
• Which documents are required for application?
• What will the funds invest in?

Considering the wide variety of unofficial investment migration “programs” circulating in the market, how can investors be confident that this is a bona fide, government-sanctioned CIP?

Cyrus Arman: Let me begin by pointing out that, since 2016, North Macedonia (then Macedonia) has had a citizenship by investment program that’s fully sanctioned and approved by the government. This is a matter of public record and, indeed, provided for in the country’s nationality laws. For the last four years, investors have been able to obtain citizenship through a EUR 400,000 business investment, the contribution of which to the North Macedonian economy they needed to demonstrate to the government, who would then approve citizenship on a discretionary basis.

What’s new this time is, first of all, that we have introduced two investment contribution funds that are not only fully vetted and pre-approved as qualifying investments by the government but also fully controlled by the government. This provides investors with additional levels of predictability; it removes any questions as to the eligibility of the investment vehicle and gives a precise timeline for qualification.

The program is under the direct (and close) supervision of the Ministry of Interior Affairs.

Can we expect an official announcement on the matter from the government?

Cyrus Arman: When the program was first approved in 2016, the government made a number of announcements, though mostly in the local media and not in English. The program was subject to extensive political debate at the time. For the moment, we understand that the government will not be proactively promoting the program in the way you might expect to see in a Caribbean CIP country, leaving such promotion instead to private firms. You can, however, expect an official government page for the program in English within the coming weeks.

Was there a public tender for this program?

Cyrus Arman: The government decided quite early on not to engage third-parties to design or implement the program, opting instead to craft the program on its own. It did, however, consult extensively with both private organizations and the governments of other countries during the planning stages. I am not at liberty to say exactly with which organizations and countries they consulted, but I can say that they were the types of entities that have experience in this field.

Who can become agents of the program? Is it open to anyone?

Cyrus Arman: Prospective agents for the investment contribution fund route can visit that route’s official website to learn more about qualifying as agents. Although the program is open to letting more agents qualify, it will not be as open as many other programs, partly because of the high degree of selectivity the government is committed to, both for its agents and applicants.

Will there be a CIU or other type of dedicated processing unit within the government?

Cyrus Arman: As mentioned previously, the program operates under the auspices of the Ministry of Interior Affairs and, within that Ministry, the Citizenship Division. An English-language website for this division is forthcoming. It is this office that will be in charge of processing applications that come in through the investment contribution fund route. This team already has several years of experience vetting applications for citizenship by investment through the business investment option and operate with the highest standards of due diligence.

This division is also responsible for collecting and collating program statistics, which it has signaled it will be open to sharing publicly upon request.

Harvey Law Group is listed on your website as not only an agent for the program but also the “master compliance agent” for Asia. What does that title imply?

Cyrus Arman: Harvey Law Group, in addition to being a normal agent for the program, is authorized to appoint sub-agents for the program. The government judged that, due to the size of the Asian market and the sheer number of small-scale immigration agents and firms on that continent, it would be more practical to have a single, experienced firm with an extensive office presence in the region be responsible for assuring the quality of applications arising from that part of the world. Rather than having hundreds of smaller firms engaging with Skopje directly, they will engage with HLG, who will be responsible for the quality of applications submitted by sub-agents. In other words, as far as program authorities are concerned, it is better for them to have a single point of contact and source for Asia-based applications, all of which will be funneled through that firm.

HLG will have to conduct their own due diligence on its sub-agents, providing an additional layer of vetting prior to the vetting that takes place at the government-level in North Macedonia.

Jean-François Harvey: Because the government prescribes the minimum and maximum fees agents may charge applicants at the retail level (from EUR 30,000 to EUR 50,000, depending on family size), part of our mandate is to not only recruit agents in Asia or provide our own clients for the program but also to ensure everyone respects the government-mandated pricing structure. Unlike in many other CIPs, the agent is not paid any commission from the government as a percentage of what their client invested. The beauty of this structure is that the agent’s margin is built into the prescribed retail fees, which makes everything clear.

Can we expect the introduction of further investment options, beyond business investment and fund contributions, such as real estate, for example?

Cyrus Arman: On the official website, we will begin listing available and eligible business investment options (at the EUR 400,000 level), to make it easier for applicants to pick suitable investments. The government is keen for these investments to take the form of legitimate, long-term, tax-paying, job-creating businesses.

The government has taken a very cautious approach in its design of the program. They are categorically opposed to introducing a real estate option, food-and-beverage-based businesses like restaurants and bars, as well as financial instruments susceptible to manipulation. The government wants to make sure the funds reach strategic economic sectors, and doesn’t consider the abovementioned sectors strategic. North Macedonia’s real estate market is not in need of CBI-funds, and the government also questions that sector’s ability to drive long-term employment growth.

When will the program open to applications and what does the process look like?

Cyrus Arman: The first batch of applications have already been submitted, so the program is already very much open. We like to think of this as a two-tiered program; First, there is a pre-approval stage in which the applicant needs to provide things like his/her CV so that the government can determine whether he/she fits the profile of the type of person they’d like to attract. This process takes between one and two months, at the end of which a pre-approval is issued. At this point, the client is invited to invest in the fund, following which additional due diligence period of 2-3 months takes place before a citizenship is granted.

Though applicants must visit North Macedonia at least once as part of the application process, there is no physical presence requirement for obtaining citizenship through this route. The government hopes, however, that the program will become popular among enterprising individuals looking for a business-friendly, low-tax jurisdiction to use as their European business base, which should also, in some cases, drive actual relocations to the country.

Sam Bayat, head of Bayat Legal Services, an appointed agent for the program in the MENA region, offers additional details on pricing and family structure.

What is the cost structure for investments and applications?

Sam Bayat: The contribution is EUR 200,000 but there is an additional application fee of EUR 20,000 for the main applicant, EUR 20,000 for the spouse, and EUR 10,000 for each eligible child, who may not be older than 18 years of age. Parents and unmarried siblings are not considered eligible dependents.

While the applicant and the minor dependents receive their citizenhips once processing is complete (within 2-5 month period), he explains, the spouse will only obtain it after more than a year has passed. Children born to the main applicant at a future date, however, would be eligible for citizenship right away, even if they are born outside of North Macedonia.

According to the legal memoranda prepared on the program seen by IMI, citizens naturalized through this program will have all the same rights as natural-born citizens, with the notable exception of the right to vote in the country’s elections. The same limitation applies to the future progeny of the main applicant, even when they are born in the country. The same memoranda reveal that North Macedonia will not accept applications from same-sex couples.

Which documents are required for application?

Documents required for filing applications include:

• A due diligence report by a reputable third-party international firm;
• An application form;
• Passports;
• Birth certificates;
• Marriage certificates;
• Police certificates;
• A sworn oath to be a loyal citizen of North Macedonia;
• A detailed CV for the main applicant;
• Passport photos;
• Powers of attorney;
• Bank statements or references to demonstrate a certain financial standing;
• Signed prospectus and share redemption documents with the government-approved fund;
• Transfer-receipt of the EUR 200,000 investment contribution;

What will the funds invest in?

The authorized funds will principally invest in:

• Startup companies
• Innovation and technology development
• Public Private Partnerships
• Environmental and recycling projects