The Ministry of Finance is checking that naturalized investors going back to 2013 fulfilled investment requirements and has given service providers until February 15th to provide the paperwork.
In a circular headlined “Check on the retention of investments and/or the permanent residence of persons naturalized under the Cyprus Investment Program”, dated December 5th, 2019, the Cypriot Ministry of Finance requests “as soon as possible and no later than December 31st”, the following documents, as applicable:
- Certificate signed by the project architect on the progress of construction of the property (s) constituting the investment and/or the permanent home of each investor/investor;
- Certification by the project architect that the property (s) constituting the investment and/or the permanent home of each investor/investor and / have been erected and delivered to the investor/investor and/or his / her company investor/investor;
- Certification by the Registrar that the investor/investor retains the same percentage of participation in the company through which the investments or part of the investments were made, for the three years following his / her naturalization date;
- If the investment involved a purchase or incorporation or participation in Cypriot companies and companies, a certificate from an approved accounting firm confirms that the investment plan included in the naturalization application has been implemented;
- A recent copy of the Certificate of Real Estate Research by the Department of Land and Surveys for each of the properties comprising the investment and / or the permanent residence of the naturalized / non-investor / investor.
On December 12th, the Ministry followed up with an extension of the deadline, citing delays and holidays:
“Due to the delay in receiving the letter from some, and in view of Christmas and New Year holidays the Ministry of Finance announces extension of submission of relevant documents until 15 February 2020.”
Following the appointment late last year of three official due diligence partners, Cyprus has been engaged in extensive retroactive due diligence on investors naturalized under the country’s CIP between 2013 and 2018, a period during which – the Ministry has conceded – vetting standards were not up to par. The retroactive due diligence process aims to mitigate erstwhile shortcomings in background checks.
In 2017 and 2018, following pressure from European political bodies, the Cyprus CIP underwent a series of reforms designed to reinforce the program’s integrity and mollify EU concerns. Significant changes included the introduction of an annual cap on applications (which, by October 2019, had created a historical first application backlog for the program), a formal registry of and licensing requirement for service providers, as well as a fortified vetting process.
While reforms were already well underway at the time, October 2019 revelations showing immediate family members of Cambodia’s prime minister and global billionaire fugitive Jho Low held Cypriot passports further galvanized efforts to rectify past negligences.