EUR 200k North Macedonian Citizenship by Investment Program Nears Launch

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While there’s been talk of opening a CIP in North Macedonia for several years, developments this week indicate such an event is now close at hand.

As discussed on countless occasions in IMI, a large number of countries worldwide have clauses in their nationality acts that give the state’s executive and/or legislative branches discretionary power to naturalize individuals they deem of special merit. In Europe alone, dozens of countries have such provisions in their laws but that doesn’t mean they have citizenship by investment programs (CIPs). A CIP is born when governments

1. formally articulate detailed requirements and procedures for obtaining citizenship through economic contributions (providing a framework that’s predictable for prospective applicants);
2. establish the necessary legal and bureaucratic infrastructure and authority to effectively process applications (setting up a processing unit, designing application forms, arranging for escrow agreements, etc.); and
3. publicly sanction the promotion of a standardized naturalization scheme for investors (announcing that a formal program exists and is officially supported by the government).

A year and three months ago, the government of North Macedonia effectively took the first of those steps by issuing a decision “defining the criteria for special scientific, economic, cultural, sports, or other national interest to acquire citizenship” in the country.

It laid out the tangible financial requirements the government would consider “special economic interest”:

A special economic interest, in the sense of this decree, exists if a foreigner who submitted the application for acquiring citizenship of the Republic of Northern Macedonia invested capital in the amount of at least 400,000 euros per person as a direct investment in new facilities, excluding catering establishments and trade facilities, with at least ten full-time employees for a period of at least one year.

Special economic interest, in terms of this decree, exists even if a foreigner who submitted an application for acquiring citizenship of the Republic of Northern Macedonia, invested capital in the amount of at least 200,000 euros per person, for a period of at least two years, in a private investment fund, which meets the following conditions:

• • the investment fund has a minimum of 5,000,000 euros of initial capital before submission of the investment program to the Fund for Innovation and Technological Development;
  • the investment fund invests in supporting the economy, innovation or innovative activities, but does not invest in real estate of any kind except in business premises for the needs of the private investment fund or the Innovation Fund and technological development and in infrastructure development projects;
  • the investment fund should not have more than 500 foreigners as investors who have submitted applications for the acquisition of citizenship of the Republic of Northern Macedonia on the grounds of this ordinance.

(See the full Decision, in Macedonian, for further details on which requirements the government sets out for qualifying funds.)

The planning for the subsequent steps in launching a North Macedonian CIP, IMI understands, had progressed rapidly in the following months but were delayed by the advent of the pandemic.

Agents appointed

Today, however, a fresh development appears to indicate the program has moved a great deal closer to a formal launch:

In a press release published in the Bangkok Post, Harvey Law Group discloses that it has been appointed “Master Compliance for the Asian Continent for the North Macedonian Economic Citizenship Program.”

The firm’s founder and principal, Jean-François Harvey, said “HLG is truly honored to be entrusted with a major role in promoting this unique citizenship program throughout Asia. Our integrity and proven reliability in providing a seamless access to global mobility solutions have earned the trusts of prestigious parties such as the Government of North Macedonia, our clients, and our partners. We hope to successfully offer meaningful citizenship solutions and its benefits with the North Macedonia Economic Citizenship Program across our global network of offices.”

Additionally, an ostensibly official program website (we note the absence of a .gov domain name, but also that such is absent from the government’s own main website as well) has published a list of authorized agents:

The global Master Agent is a Skopje-based company named Global Business Solutions. HLG is listed as the “Agent and Master Compliance Agent” for Asia, while Asara Group DMCC holds the title of “Master Agent” for the MENA and CIS regions.

A number of other firms, furthermore, are listed as “other agents” for the MENA and CIS regions:

• RIF Trust (Part of Latitude Group)
• Huriya Private
• iLand Group Corp.
• Bayat Legal Services
• Biz Co

The website further indicates that a North Macedonian firm named DDK is the “appointed law firm” while the local chapter of BDO, the accounting giant, is the “appointed auditor for the funds”.

Speaking to IMI via telephone, HLG’s Jean-François Harvey says the program will initially have a cap of 1,000 main applicants and that the government has so far approved two separate funds, each of which is authorized to take investments from up to 500 CIP applicants. “We refer to it as an investment,” he says, “but it is more accurately considered a donation to a sovereign fund because the government will be under no obligation to return the capital.”

“The government,” says Harvey, “are focused on attracting clients of a particular profile. They want highly successful people who can contribute to the local economy.”

IMI understands that the various concessionaires, together with the government, are currently finalizing a number of forms and agreements needed to definitely begin receiving applications.

HLG has also provided an unofficial English-translation of application forms as outlined in a January 2020 gazette.

Though there appears not to have been a public (or at least not publicized) tender for concessionaires along the model pursued by the CIPs of Malta and Montenegro, sources close to the process indicate that the government had privately approached most of the industry’s major government advisory firms before making appointments.

Would give Montenegro a run for its money

With a minimum contribution of just EUR 200,000, a North Macedonian CIP would pose a formidable competitive challenge to that of neighboring Montenegro, where investments start at EUR 350,000. The two countries offer similar advantages; both countries’ passports boast visa-free access to 124 destinations worldwide, including the Schengen Area. Both countries are in relatively advanced stages of EU-accession negotiations.

After two years of disappointing setbacks for the investment migration market, which included the sudden and permanent closures of the Cypriot and Moldovan CIPs, a new entrant from the Balkan peninsula would be warmly welcomed.

IMI will be back with further details, a Q&A with key stakeholders, and more analysis in the coming days.