In the first days of November 2019, Cyprus was shaken up by a news story concerning the Cyprus Investment Programme.  Jho Low, a Malaysian businessman connected to the 1MDB scandal and sought by the authorities of Malaysia, Singapore and the USA, had managed to acquire a Cypriot citizenship by naturalisation.  

For the following few weeks, questions of how and why this was allowed to happen flooded the international press, inflicting, at least temporarily, a blow on the credibility of the Cyprus Investment Programme (CIP). At the same time, the Cyprus government in a fight against time initiated an intense investigation into the matter while also making sure to implement further transparency and robustness in regard to the CIP processes and guidelines.

It is now the end of November 2019. Nearly a month has passed and looking back, we realise that the storm is finally over. As it is now known, Jho Low was allowed the Cypriot citizenship in the year 2015, three years before becoming a red flag for Interpol and while fully compliant with the CIP regulations. Still, Mr Low’s citizenship was withdrawn, as were 25 more cases, incompliant with the CIP guidelines.  In total, less than 0.8% of issued passports were affected and by treating this crisis with openness and transparency, the Cyprus Investment Programme has reclaimed its credibility.  

Just as in Cyprus weather, the brief storm quickly gave way to the warm Cyprus sun. Cyprus is still one of the best relocation destinations in the world, with a thriving tourist industry, a rapidly growing real estate sector and perhaps the most attractive Investor Immigration programmes in the European Union.

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Under the regulation guiding the Cyprus Investment Programme (August 2019), eligibility criteria for the programme are as follows:

The applicant:

  1. has not previously been denied citizenship by any other EU country;
  2. possesses a Clean Criminal Record;
  3. can evidence his/ her source or wealth;
  4. can provide funds for his/ her investment, are acceptable by Cyprus banks;
  5. is not subject to criminal investigation, with or without being indicted;
  6. is not facing criminal prosecution as a defendant;
  7. is not convicted for serious crimes;
  8. is not and have not been associated with legal entities, facing restrictive measures from the European Union;
  9. is not subject to sanctions nor is associated with legal entities, sanctioned by third countries (e.g. United States, Russia and Ukraine) or the United Nations Security Council;
  10. is not nor was in the past under investigation and/or faces/ed charges for criminal offenses and is/was not placed in the European Wanted-List (EUROPOL) or International Wanted-List (INTERPOL);
  11. is not a “Politically Exposed Person” having held office in the past 5 years.

“Politically exposed person” generally means a person who is or who has been entrusted with prominent public functions in Cyprus or in another country, an immediate close relative of such person or a person known to be a close associate of such person

The definition, “prominent public function” is wide and includes among other (a) heads of State, heads of government, ministers and deputy or assistant ministers; (b) members of parliament or of similar legislative bodies; (c) members of the governing bodies of political parties; (d) members of courts or judicial bodies; (e) members of courts of auditors or of the boards of central banks; (f) ambassadors, chargés d' affaires and high-ranking officers in the armed forces; (g) members of the administrative, management or supervisory bodies of State-owned enterprises; (h) directors, deputy directors and members of the board or equivalent function of an international organisation; (i) mayor.

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