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The Future Citizen Institute is the academic research arm of Kylin Prime Group, an investment migration consultancy. Their reaction to the report is the latest among a wide variety of responses from industry stakeholders.
See other responses to the EC report:
- IMC on EC Report: European Institutions Must Include IM Industry in Policy-Making Process
- “We Agree With Most of What’s in It,” Says MIIP-Boss Cardona About EC Report
- Eur. Commission Report on RCBI Ignores Socio-economic Benefits, Says H&P
- Kochenov: EU Report on Investor Citizenship and Residence – When the Commission Misleads
Future Citizen Institute’s response notes, among other points, that:
- The legitimacy of the “genuine link” doctrine in light of international law is highly questionable.
- The Commission’s invocation of the “sincere cooperation” principle is irrelevant in this matter.
- The Commission did not take the economic benefits of investment migration into consideration.
“The Commission relies heavily on the concept of the “genuine link”. […] this concept has been disputed ever since it was defined by the International Court of Justice in the Nottebohm case. The list of academic publications on the case is long and includes both early critiques by H. Golsong, Joseph Kunz and Mervyn Jones, among others, and more recent commentaries by Oliver Dörr, Albrecht Randelzhofer, Audrey Macklin, and Jacob Dolinger,” writes the FCI.
Read the full response here.