On the 22 August 2019 the Ministry of Interior announced a new round of changes to the CIP (Cyprus Investment Programme).  This article summarises these important changes, which we wish to highlight to all potential clients considering filing a citizenship application in Cyprus.

The following were the three main changes:

  1. Donation of EUR 75k to the Cyprus Land Development Corporation and donation of 75k to the Research and Innovation Foundation will only be required after the relevant application approval.

This was an important clarification which provides certainty to the investor that only upon approval of his/her citizenship application will they be required to make the necessary donation to the Cyprus Land Development Corporation.

  1. It is possible to invest up to EUR 200k in the secondary market of Cyprus Stock Exchange.
  1. Certain categories of applicants will not be approved for citizenship. The categories include the following:
  1. Politically Exposed Persons (PEPs) who hold an office or those who have held an office in the previous 5 years.
  2. Persons who are under criminal investigation but are not yet convicted.
  3. Persons who have been convicted for a criminal case (it should be noted this requirement was stated within the CIP law from 2013).
  4. Persons who have been convicted of serious crimes (e.g. bribery, tax evasion) and whose conviction has been subsequently removed/overturned.
  5. Persons who are connected with legal entities to which sanctions have been imposed by the EU (e.g. shareholders or high-ranking officials of such entities).
  6. Persons who are no longer connected with entities stated in (e) above, but were connected when the relevant sanction was imposed. Persons who resigned before sanctions were imposed are exempted.
  7. Persons to which sanctions are imposed by other jurisdictions.
  8. Persons who are connected with legal entities to which sanctions have been imposed by other jurisdictions.
  9. Persons who are being prosecuted for criminal offences and are wanted by Europol or Interpol.
  10. Persons who have been prosecuted for criminal offences by Europol or Interpol in the past, irrespective of the outcome of such prosecution.
  11. Persons who are sanctioned by the UN.

It is clear that the primary aim of the Cyprus government with this latest round of changes to the CIP is to clarify to all prospective applicants, and service providers alike, the strict requirements in place for investors to proceed with a CIP application.

These changes furthermore enhance the image of the CIP by showing transparency in what the relevant requirements/exclusions are and should help minimise the instances of ineligible investors filing a CIP application.

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