Latest / IMI Podcasts / #16: "It's a Jungle Out There": Nuri Katz on Mobility Standard

Transcript

#16: "It's a Jungle Out There": Nuri Katz on Mobility Standard · IMI Podcasts

• 0:02
  SPEAKER_03: Ladies and gentlemen, it's 7 p.m.
• 0:04
  SPEAKER_03: in Dubai, 3 p.m.
• 0:06
  SPEAKER_03: in Lisbon, 11 a.m.
• 0:07
  SPEAKER_03: in St.
• 0:07
  SPEAKER_03: Kitts.
• 0:08
  SPEAKER_03: Welcome to a new episode of the Mobility Standard, the podcast where we dissect current events, trends, and crucial questions related to investment migration.
• 0:19
  SPEAKER_03: I'm your host, Christian Nestaim, editor of Investment Migration Insider, and with me in today's episode I have my regular co-host, Ahmad Abbas, as well as our guest this week, Mr.
• 0:29
  SPEAKER_03: Nuri Katz, founder of Apex Capital Partners.
• 0:33
  SPEAKER_03: We spoke to Nuri about a range of current events, including Vanuatu's possible suspension from the EU visa waiver scheme and the possible implications that could have for the Caribbean 5.
• 0:45
  SPEAKER_03: We also talked about Montenegro's last-minute CBI extension and the industry's apparent failure to effectively lobby the European Commission.
• 0:55
  SPEAKER_03: All of that and a great deal more in today's episode of the Mobility Standard.
• 0:59
  SPEAKER_03: I'd like to remind you that you can follow all of IMI's stories on our website, imidaily.com, on our mobile phone apps, in our free newsletters, as well as on your favorite social media network.
• 1:10
  SPEAKER_03: You can also follow this podcast on Spotify, Apple Podcasts, and most other podcast platforms.
• 1:17
  SPEAKER_03: With the preambles out of the way, let's get this show on the road.
• 1:26
  SPEAKER_03: We got Nuri Katz here on the Mobility Standard for the first time.
• 1:30
  SPEAKER_03: And as is our custom here, we will start by asking our guest to introduce himself to those among our audience that don't already know him.
• 1:42
  SPEAKER_03: Nuri, um give the audience a quick rundown of who you are, where you're from, and how you came to run Apex Capital Partners.
• 1:52
  SPEAKER_02: Well, I'm Nuri Katz.
• 1:54
  SPEAKER_02: I'm sure most people don't know me, but uh I've been in the investor immigration business for just about 30 years now.
• 2:04
  SPEAKER_02: I started in uh way back in 1991 when nobody was nobody who's in the business now was in the business then.
• 2:13
  SPEAKER_02: Um I got into it purely by accident.
• 2:17
  SPEAKER_02: I I'm from Montreal, Canada, and Montreal is um actually where the whole investor immigration industry started.
• 2:28
  SPEAKER_02: Quebec was um the was the part of the Canadian investor immigration that was most popular started in the mid-80s.
• 2:42
  SPEAKER_03: Um we we talked about this uh when we had Sam Bayat on the podcast, how Montreal is really the cradle of this whole industry in many ways.
• 2:55
  SPEAKER_03: I mean, a lot of the big companies uh started out there, and then from there they kind of took over the world.
• 3:00
  SPEAKER_03: So you were part of that cohort then together with Armin Arten and Sambayat and Jean-Ponso Harvey and uh Marc Gaudé from uh from uh Yeah, we're all sort of the same age.
• 3:15
  SPEAKER_02: Eric uh Eric Major.
• 3:18
  SPEAKER_03: Eric Major, of course.
• 3:19
  SPEAKER_03: How could we forget?
• 3:20
  SPEAKER_02: Armand Arten came in a little bit later, he's a little bit younger than us.
• 3:24
  SPEAKER_02: Um there are a lot of other names that that you know that were around at that time.
• 3:28
  SPEAKER_02: But but this it also I I I actually was um although I'm I grew up in Montreal, I I um got into this while living in Moscow and Russia.
• 3:39
  SPEAKER_02: Um funnily enough, the the mayor of Montreal in 1991 came to visit Moscow.
• 3:46
  SPEAKER_02: I had moved there in 1990 to seek my fortune.
• 3:50
  SPEAKER_03: To be fair, a lot of big fortunes were made exactly in that moment in time during the you know, the the the glass nosed parastrike uh era, I guess.
• 3:59
  SPEAKER_03: You know, it was a risky business, of course.
• 4:01
  SPEAKER_03: It was uh it was uh kind of a wild west.
• 4:04
  SPEAKER_03: It was a real uh the wild a lot of ruffians.
• 4:08
  SPEAKER_03: The wild east.
• 4:10
  SPEAKER_02: Right, precisely.
• 4:11
  SPEAKER_02: Yeah, no, it was uh it was a very, very interesting time.
• 4:15
  SPEAKER_02: Um and uh and I enjoyed it very much, and I I was involved in uh in a number of different businesses, but I got into the Canadian investor immigration because uh business because um the mayor of Montreal at the time um came to visit the mayor of Moscow and and decided to visit with any Montrealers who were in Moscow, and I was the only one.
• 4:40
  SPEAKER_02: I was a young kid, and I was the only one, and we got to talking and he suggested that we do um that I get involved in the the uh investor immigration business.
• 4:50
  SPEAKER_02: Uh he introduced me to one to uh uh a banker at the uh national bank um of Canada, who was the National Bank at the time was one of the leading uh banks who was involved in this industry.
• 5:08
  SPEAKER_02: And uh one thing led to another.
• 5:10
  SPEAKER_02: Um uh and I started practicing um immigration law in Canada.
• 5:18
  SPEAKER_02: Um and uh you know it it was a very interesting time in the immigration business um in Canada, um altogether, not only in the investor immigration business, but in in the whole industry.
• 5:33
  SPEAKER_02: And the situation that exists today in the investor immigration industry is very reminiscent of that time.
• 5:42
  SPEAKER_02: Um it was sort of what do you mean by that?
• 5:45
  SPEAKER_03: What do you mean by that?
• 5:46
  SPEAKER_02: I'll explain.
• 5:48
  SPEAKER_02: Um at the time, pretty much anybody could just put up a shingle, a sign on their door, or even without a sign on their door, and get into the investor immigration business.
• 6:00
  SPEAKER_02: The Canadian in immigration law had a had a uh paragraph in it that said that pretty much anybody could become uh a representative of anybody else in immigration matters.
• 6:14
  SPEAKER_02: Um and so a huge amount of um of people both in Canada and outside of Canada suddenly became professional immigration consultants.
• 6:27
  SPEAKER_02: Um whether they they knew uh whether they had read the immigration law of Canada or any part of the immigration law or understood anything about it, they were certainly just willing to take a lot of money from a lot of people.
• 6:42
  SPEAKER_02: So my myself and a number of other colleagues, we spent years and years and years.
• 6:48
  SPEAKER_02: Um it must have been six, seven years that we spent lobbying the Canadian government to create standards and to create a licensing uh body that would um insist on continued education, um errors in omission insurance, all the kinds of things that that professionals of all sorts um have to have.
• 7:13
  SPEAKER_02: You can't just put up your hand and say, hi, I'm a professional accountant, you have to have uh or an auditor, you have to have certain training.
• 7:20
  SPEAKER_02: And so we created training programs and and schools and universities, and but it took a long time to lobby the government to even pay attention to this stuff, and and the reason to pay attention to it was that a ton of people were were losing clients, were were trusting people who didn't have a clue of what they were doing, were just taking money.
• 7:44
  SPEAKER_02: And there were a lot of very, very sad stories of clients getting ripped off, of clients having their having lost not only money but time and and and and even there were consequences.
• 7:55
  SPEAKER_02: Clients who arrived in Canada, but because they had applied in the wrong way, or their representatives had applied in the wrong way, were deported from Canada and had their whole lives messed up.
• 8:05
  SPEAKER_02: And uh the stories I can go on forever about the stories.
• 8:10
  SPEAKER_02: Um and um and that has mostly ended in Canada.
• 8:16
  SPEAKER_02: Um can't it took Canada actually um well it's been about 15 years since the Canadian government changed the whole immigration law, not only to do with investor immigration, but but the whole law was changed that has to do with with uh um professional immigration, all sorts of different types of of immigration.
• 8:37
  SPEAKER_02: And within the new act of 2001, um they included a licensing body.
• 8:43
  SPEAKER_02: Um and they created this licensing body and they created it badly, actually.
• 8:48
  SPEAKER_02: And after a few years they had to close it down and create another licensing body.
• 8:54
  SPEAKER_02: And then they that lasted also another bunch of years, and just recently they shut down one licensing body and just created a new licensing body.
• 9:03
  SPEAKER_02: So it's been a whole struggle with just in one little Canada to create a uh a body that would control um professionals in immigration and make sure that they are held responsible to their clients.
• 9:22
  SPEAKER_03: Um It does say a lot about the momentous task facing the IMC, for example.
• 9:31
  SPEAKER_03: I mean, you talk about how difficult it was to do just in Canada and how you had to go through many iterations and you and you had you know you you had a government that could enforce these things, and even there it was very, very difficult.
• 9:45
  SPEAKER_03: Now imagine trying to do the same thing as one of the so that you had the IMC, that you have what is it, the GIIC.
• 9:53
  SPEAKER_03: Trying to enforce standards uh globally without even having the you know the force of government behind you.
• 10:01
  SPEAKER_03: It's an impossible task, no?
• 10:03
  SPEAKER_02: Well, it's it's um uh e yes, and I think that you know that that's part of I think the the the the industry has to actually get together in a more organized and a better way and and try to figure out um this monumentous task.
• 10:21
  SPEAKER_02: Because you know, it's it's very easy.
• 10:23
  SPEAKER_02: It's uh this was part of the experience that we had in Canada was that that um it's easy to regulate licensed um players.
• 10:34
  SPEAKER_02: What do you do about the ones who are not licensed?
• 10:36
  SPEAKER_02: You can't go, you know, you can't go after the ones who are not licensed for breaking the the rules and rec re regulations of the licensing board.
• 10:45
  SPEAKER_02: So, you know, if a lawyer is a member of a bar and he rips off his client, he can get kicked out of the bar.
• 10:52
  SPEAKER_02: But if he's not ever a member of the bar, what do you do with him?
• 10:55
  SPEAKER_02: You can't kick him out of the bar because he's not in the bar.
• 10:58
  SPEAKER_02: Um so um, and that was the that was part of the situation that that existed in Canada that took until just this past year, well, more than 15 years, for Canada to actually create a um to pass a law that made it criminal um uh to give uh advice on Canadian immigration to not by non-licensed um uh individuals.
• 11:29
  SPEAKER_02: And that and and now the licensing authority has the ability to invest to to do a criminal investigation with the police and the the secret services and all that kind of stuff.
• 11:44
  SPEAKER_02: It's given it some some teeth, but it took it took probably 20 years to create just that just in Canada.
• 11:51
  SPEAKER_02: Um and that's obviously you know the situation today in in the CBI business is that there are a number of uh licensed local agents who are who are regulated by the countries and the the those local agents um even are are they the the regulation there isn't so tough even on the local agents, but you know, for example in in St.
• 12:21
  SPEAKER_02: Kitts the the uh the local agents have to go through annual financial compliance, um annual f financial audits, uh compliance office uh audits, like due diligence audits.
• 12:38
  SPEAKER_02: The auditor has to come into the to our offices and um look at our files and make sure that we have done the correct due diligence on our clients and that the clients before we have submitted the the clients to the um uh to the government, um, that we have have um have been careful and that we were keeping our files a certain way and the correct way and all that.
• 13:06
  SPEAKER_02: Um and and but that's a very small minority of of the actors and the participants in this in this industry.
• 13:15
  SPEAKER_02: Most of the of the people, the companies in this industry have absolutely do not meet need to meet any standards of any government, including unfortunately, the marketing agents that the government um uh the governments put on their websites, they they're in order to become a marketing agent, you just have to pay a fee.
• 13:36
  SPEAKER_02: There's no standard um other than the principals aren't allowed to be in jail or something, they're not allowed to be criminals.
• 13:46
  SPEAKER_02: Um But uh there's no there's no uh standard that they have to live on.
• 13:51
  SPEAKER_02: For example, in in Antigua, um I as a local agent I have to carry um three million dollars worth of um errors and emissions insurance.
• 14:02
  SPEAKER_02: Uh wow, okay.
• 14:05
  SPEAKER_02: Um in it's actually even more than in in Canada, it's one million.
• 14:10
  SPEAKER_02: Here it's three million.
• 14:12
  SPEAKER_02: So if I'm if I mess up, I have an insurance company backing me up so that the to pay off the client if I kind of mess up my my files with him.
• 14:23
  SPEAKER_02: But that's only the local agents and only here.
• 14:28
  SPEAKER_02: I mean, we've seen so many situations where um you know you know the the most extreme situation was in Cyprus.
• 14:38
  SPEAKER_02: What happened in Cyprus where the politicians were offering uh to be uh to be immigration agents to criminals.
• 14:49
  SPEAKER_02: Um you know that that was just a very extreme situation.
• 14:52
  SPEAKER_02: And and what by that being allowed, because they didn't have a strong licensing um uh uh administration, um that closed the program down, and how many people have lost their livelihoods because of that, and what has happened to Cyprus because of that.
• 15:13
  SPEAKER_03: Um Well, what is it, 600 something agents uh overnight have nothing to do in Cyprus?
• 15:21
  SPEAKER_03: Um yeah.
• 15:22
  SPEAKER_01: And a ghost town of real estate developments just sitting there where nobody can afford, yeah.
• 15:28
  SPEAKER_02: All because it just wasn't regulated well.
• 15:32
  SPEAKER_02: And and we're seeing we're we're seeing the same thing.
• 15:35
  SPEAKER_02: I'm sorry, Christian.
• 15:36
  SPEAKER_02: Um we're we're you know, we we recently um heard the news about Vanuatu and what was happening there, and a lot of that is because there are no standards.
• 15:48
  SPEAKER_03: Um sorry, we'll get we'll get we'll get to Vanuatu in a second, but okay, you said uh that what happened in Cyprus happened because it wasn't well regulated enough partially.
• 15:59
  SPEAKER_03: But partially because actually what happened in Cyprus is that the regulators, the the very politicians uh who administered the program were the ones doing the malfeasance.
• 16:12
  SPEAKER_03: So it's like no matter how great your regulations are, if the regulators are shady, right?
• 16:21
  SPEAKER_03: Then you can say the words.
• 16:27
  SPEAKER_03: The Latin phrase is quis custodiat ipsos custodus, who will guard the guards, right?
• 16:32
  SPEAKER_03: So yeah, uh, you can regulate it all you want, but if the regulators are uh the ones doing the malfeasance, then um you're out of luck.
• 16:41
  SPEAKER_03: So listen, I want to move on a little bit from away from the regulation question.
• 16:45
  SPEAKER_03: Yeah, uh, because it's been an uncharacteristically eventful couple of weeks in investment migration.
• 16:51
  SPEAKER_03: Uh the European Commission's Vanuatu statement and Vanuatu's response to that.
• 16:57
  SPEAKER_03: Uh Montenegro's last-minute extension.
• 17:00
  SPEAKER_03: Uh the Bulgarian government is saying it wants to do away with that country's RCBI program.
• 17:05
  SPEAKER_03: So, anyway, I want to spend uh much of this episode talking current events with you, Nuri.
• 17:12
  SPEAKER_03: But um I think before we move on to that, uh I want to understand what's foremost in your mind these days.
• 17:20
  SPEAKER_03: What are the priorities in Nuri's world right now?
• 17:23
  SPEAKER_03: What's keeping you up at night?
• 17:25
  SPEAKER_03: What are you focusing on?
• 17:26
  SPEAKER_02: Well, in all honesty, this has always been since in the last 25 years, the the the safeguarding of the industry has always been foremost on my mind.
• 17:40
  SPEAKER_02: Um I believe that this is a good industry um and that that helps a lot of people.
• 17:45
  SPEAKER_02: I think it's it's uh you know, I live in the Caribbean and I um I see how much good it has done um in in many of these countries in the Caribbean.
• 17:57
  SPEAKER_02: I mean, in in it's built roads in in uh St.
• 18:01
  SPEAKER_02: Kitts, it it helped uh lift Dominica back up from from the ashes of of a hurricane of Hurricane Maria.
• 18:11
  SPEAKER_02: Um in in uh Antigua, a lot of the pensions are being paid through CBI money.
• 18:18
  SPEAKER_02: This stuff is really this is the these this industry is really, really uh v important to a lot of countries.
• 18:26
  SPEAKER_02: And I also believe that it's a good industry that that at the core is um is protective of the countries that that have these programs.
• 18:37
  SPEAKER_02: I mean I I always say that the due diligence that is being done on candidates for um for citizenship in in CBI countries is the best due diligence known to man.
• 18:50
  SPEAKER_02: Um it's certainly much better due diligence than the US does on its EP5 uh clients and the Canadian government does on its on its uh investor immigration clients or the UK.
• 19:01
  SPEAKER_02: The UK doesn't do any due diligence.
• 19:04
  SPEAKER_02: These countries do incredible, incredible.
• 19:06
  SPEAKER_02: There's no category of immigrants that that have to go through the same kind of sturgeon due diligence as in this industry.
• 19:18
  SPEAKER_02: But I think the weak point is that it's a jungle out there.
• 19:23
  SPEAKER_02: Um I see in my in my little neck of the woods, I my main um my main uh source market is is Russia and and now the US.
• 19:36
  SPEAKER_02: Uh the US doesn't regulate CBI at all, obviously.
• 19:40
  SPEAKER_02: Anybody can put up a shingle and and and claim that they're that they are um uh professionals in in this in in this legal process.
• 19:51
  SPEAKER_02: Um and the same thing in Russia, and and I see I see the shingles going up and going down.
• 19:56
  SPEAKER_02: Over 30 years, I've seen so many companies that that because there was no regulation, they were able to open up for a few years, make a bunch of money, get in trouble, and then disappear.
• 20:10
  SPEAKER_02: Um I've seen that over and over and over.
• 20:12
  SPEAKER_02: And so that for me is the the weak link of this industry.
• 20:18
  SPEAKER_02: Um until we are well regulated and held up to certain standards.
• 20:24
  SPEAKER_02: Um the and and everyone is at fault that they're that we are not held up to these standards, including the governments of the of the countries that have these programs, um, including the companies themselves, including the owners of the companies, including everyone.
• 20:40
  SPEAKER_02: So that that's my biggest, I think that the that's the biggest, the the weakest link.
• 20:46
  SPEAKER_02: Um the the I think at the end of the day, the European Commission and the US, Canada, and the UK, when they really eventually look at these programs and they see the seriousness that the governments take when when they are reviewing candidates for citizenship, when they eventually get away from the you know, I I think the European Union and the people in the European Union and the European Commission who are looking at this industry are are taking a very superficial look at the industry.
• 21:26
  SPEAKER_02: They're looking, there's they're thinking, uh oh, money is being exchanged for citizenship.
• 21:31
  SPEAKER_02: Um that means that it's dangerous.
• 21:34
  SPEAKER_02: When in all honesty, yeah, money is being exchanged for citizenship, but it's also before it's before the exchange happens, the money goes through the most serious type of um uh of due diligence.
• 21:49
  SPEAKER_03: Yeah, listen, Nuri, I I I've argued this for a long time that it doesn't make sense to criticize citizenship by investment on the basis of national.
• 22:00
  SPEAKER_03: Security because it is the closely the most closely monitored avenue for immigration.
• 22:07
  SPEAKER_03: No other category of immigration is scrutinized to that extent.
• 22:12
  SPEAKER_03: So if CBI is a security threat, then by extension, all other types of immigration are a greater security threat.
• 22:25
  SPEAKER_03: There are three main criticisms that are levied against CBI, and I think only one of them has merit.
• 22:31
  SPEAKER_03: So the first one is the security threat argument.
• 22:35
  SPEAKER_03: The second is the moral argument, which is it's just, oh, it's just wrong.
• 22:40
  SPEAKER_03: Rich people shouldn't have privileges, uh, you shouldn't be able to sell citizenship.
• 22:44
  SPEAKER_03: Citizenship is something sacrosanct can't be commoditized, blah, blah, blah.
• 22:49
  SPEAKER_03: The third argument, which I think is the only one that really does hold water, is that there's too much opacity.
• 22:57
  SPEAKER_03: We're not transparent enough.
• 22:59
  SPEAKER_03: And the the interesting thing about that is that it's the only out of out of all the out of the three, out of the three main criticisms levied against CBI, that it's the only one that's within the CBI industry's control.
• 23:13
  SPEAKER_03: So the CBI industry can be more transparent, but a lot of the countries choose not to be transparent, sometimes because they they think it's a competitive advantage, not to share that information, right?
• 23:27
  SPEAKER_02: Well, I'll I'll tell you, I I agree with you, and um, you know, I I uh obviously the the European Commission and the other critics um who think that it's not right to sell citizenship for for money um are uh they don't understand or they don't care to understand or they're being very superficial as to you know everything is being sold for money, including cars and houses.
• 23:53
  SPEAKER_02: And my home that I live in was sold for money to me.
• 23:57
  SPEAKER_02: So um and yes, rich people have have um fortunately or unfortunately, they have access to better hotels and and better cars and a lot of things.
• 24:10
  SPEAKER_02: Um but um I I I I think you're right.
• 24:24
  SPEAKER_03: Why would we give the industry's detractors ammo?
• 24:29
  SPEAKER_03: Right?
• 24:30
  SPEAKER_03: Why not just be super duper clean so that there's nothing for them to put their finger on?
• 24:36
  SPEAKER_02: I I agree.
• 24:37
  SPEAKER_02: I I think a bit of it is a political issue within the individual countries.
• 24:42
  SPEAKER_02: Um I think um it's uh in all honesty, uh you know, Canada is a great example of of uh uh of a lack of transparency.
• 24:54
  SPEAKER_02: Um the Quebec program, you basically kind of know where some of the money is going, but you don't really know.
• 25:02
  SPEAKER_02: Um in a lot of the other uh countries, the other provinces you don't really know where it's not being really well reported.
• 25:09
  SPEAKER_02: Um but um but yeah, look, transparency of where and how the money is being used would give ammunition to the countries to say, listen, I'm using this money to build roads, to build to support schools, to support you know, whatever infrastructure projects.
• 25:28
  SPEAKER_03: Dominica's building an airport, right?
• 25:30
  SPEAKER_03: International airport.
• 25:31
  SPEAKER_02: Dominica's building an airport and and other infrastructure.
• 25:35
  SPEAKER_02: Right.
• 25:35
  SPEAKER_03: So um uh I mean Dominica is an amazing example of how um how CBI has basically saved thousands of people from So I want to stop you there with that, because um you you you we've gone over this, yes, of course, uh tremendous economic contribution, uh life-saving sometimes, especially in uh uh in the face of natural disasters, as has been the case in the Caribbean on a number of occasions.
• 26:07
  SPEAKER_03: Uh we heard now uh last week that uh the European Commission that it was proposing to the European Council that Vanuatu's visa waiver with the Schengen area be revoked, at least for those who naturalized after 2015, I think it was.
• 26:25
  SPEAKER_03: Um now, of course, if that does come to pass eventually, and it's not a foregone conclusion, like not just because the commission proposes it doesn't mean the council will adopt it.
• 26:37
  SPEAKER_03: Um but let's say it does, it would absolutely decimate interest or demand for citizenship in Vanuatu.
• 26:45
  SPEAKER_03: And by extension, you would be removing effectively 50% of government revenue.
• 26:52
  SPEAKER_03: Uh I mean, it was at least during the height of the pandemic in 2020?
• 26:56
  SPEAKER_03: Close to 50% of all government revenue in Vanuatu came from citizenship by investment.
• 27:02
  SPEAKER_03: And that would fall away, obviously, if they lost visa-free access to Schengen.
• 27:08
  SPEAKER_03: So to what extent is to what extent would the European Commission then be responsible for uh a severe economic downturn in Vanuatu?
• 27:20
  SPEAKER_03: I mean, I understand that it's of course Europe's prerogative to unilaterally decide whom they will still Yeah, they can do that, right?
• 27:32
  SPEAKER_03: Uh they they they could argue, look, we're not responsible for Vanuatu's having structure their economy in such a way that us taking away visa waiver agreements will um send them into a depression.
• 27:47
  SPEAKER_03: Uh on the other hand, that same, you know, the same Europe does does uh try to provide aid packages, etc., to Vanuatu.
• 27:56
  SPEAKER_03: So to what degree do you think they're responsible?
• 27:59
  SPEAKER_03: To what degree can they be blamed for for making such a move if it does come to pass?
• 28:04
  SPEAKER_02: Well, I think that that uh Vanuatu was an extreme example of a lack of of responsibility.
• 28:14
  SPEAKER_02: Um the Vanuatu was doing zero due diligence on on um its candidates for for citizenship.
• 28:24
  SPEAKER_03: And sorry, I I I have to arrest you on that.
• 28:27
  SPEAKER_03: I don't I don't think uh I think a lot of people a lot of listeners would take issue with that.
• 28:33
  SPEAKER_03: A lot of listeners, I think, would take issue with that statement that Vanuatu does no due diligence.
• 28:38
  SPEAKER_03: Okay, so I don't think that's true.
• 28:39
  SPEAKER_02: Let's say that the due diligence standards of Vanuatu um, let's say that that's so that because I I I wasn't there.
• 28:48
  SPEAKER_02: Um rumor has it that the Vanuatu standards, and clearly from the statement that that was made by um the European Commission, um, the standards of due diligence left a little bit to be wanted.
• 29:03
  SPEAKER_02: Let's just say let's just put it that way.
• 29:06
  SPEAKER_02: Um the fact that only one candidate for citizenship was refused um when the market itself, when everybody was saying, oh, Vanuatu accepts everybody.
• 29:16
  SPEAKER_02: You can be a criminal, it doesn't matter.
• 29:17
  SPEAKER_02: They accept everybody.
• 29:18
  SPEAKER_02: That that was how it was spoken about in the industry.
• 29:22
  SPEAKER_02: I don't know what the exact truth is, but reading reading what the um what the European Commission says, it it looks kind of scary.
• 29:31
  SPEAKER_02: Um I I think that that um you know Vanuatu has a as as part of the you know ever every country, every member of the United Nations, um, and every you know every independent country that's a member of the United Nations has a responsibility as part of the international security apparatus um to secure the world, to be part of the security apparatus of the of the world.
• 30:05
  SPEAKER_02: And whether if if it's just tiny little, I say Vanuatu is tiny compared to St.
• 30:10
  SPEAKER_02: Kitts, it's five times the population.
• 30:12
  SPEAKER_02: But um, whether it's Vanuatu or St.
• 30:15
  SPEAKER_02: Kitts, you know, they're they're part of Interpol, they're part of um of various other uh organizations that that are important to the security of the world.
• 30:27
  SPEAKER_02: And they have to take that responsibility seriously, um even if they're a small country, even if they need the money.
• 30:36
  SPEAKER_02: And um and from the report, and again, I'm basing just my words on the report because I I I've never been to Vanuatu, I've never worked in Vanuatu, I've never had any clients in Vanuatu.
• 30:48
  SPEAKER_02: Um uh but from the report um it looked like like Vanuatu was not taking their role as seriously as they they their role in the in as in the uh international security apparatus um as seriously as they should.
• 31:06
  SPEAKER_02: And and there are consequences to it.
• 31:09
  SPEAKER_02: Um and if the consequences are that that all all that the world can do in order to pressure Vanuatu to take it to take their role seriously, um if that's if taking away visa-free to Europe is is what they can do to make Vanuatu behave more responsibly, again, I'm just basing myself on the on this report, um, is um if if that's what it takes, then that's what it takes.
• 31:47
  SPEAKER_03: But do you think that the European Commission can ever be satisfied uh about citizenship by investment programs?
• 31:56
  SPEAKER_03: I mean, yes, okay, maybe they had um some uh apprehensions about the Vanuatu due diligence, and we don't have to get into, I mean, neither you nor I know exactly uh what type of due diligence they do.
• 32:09
  SPEAKER_03: Vanuatu says that they do take it seriously, the European European Commission says something else.
• 32:15
  SPEAKER_03: Um but look at a country like Malta, for example, which I think nobody can argue that I mean Malta probably has um it's certainly as good as the Caribbean, certainly as thorough as the Caribbean when it comes to uh vetting, maybe even better.
• 32:34
  SPEAKER_03: Um and and they they've they've gone to great lengths to sort of mollify the concerns of the European Commission.
• 32:43
  SPEAKER_03: They've added a residency period to provide more uh so-called genuine links between the applicant and the and the country of Malta.
• 32:54
  SPEAKER_03: And even with all of that, the European Commission still insists that Malta uh discontinue or phase out over time its citizenship by investment uh operations.
• 33:08
  SPEAKER_03: So it looks to me as though it doesn't, I mean, the the degree to which you have robust due diligence from the perspective of the European Commission is immaterial.
• 33:20
  SPEAKER_03: It's it's another thing to complain about for the European Commission if if there's not good enough due diligence.
• 33:27
  SPEAKER_03: But even if you have good due diligence, it's still not enough for them to give you uh the green light.
• 33:35
  SPEAKER_02: Well, I think um there's another issue.
• 33:39
  SPEAKER_02: Um and and and it and to me it comes back to um transparency, um, which is a big issue in which was a very, very big issue in in Malta.
• 33:52
  SPEAKER_02: You know, the the usage of the funds, the where payments were going, were the funds going all to Malta, or were they going elsewhere?
• 34:01
  SPEAKER_02: And there's a very big question as to where the funds were being held.
• 34:05
  SPEAKER_02: There are many, many different issues in the within the Maltese program that were very, very opaque.
• 34:11
  SPEAKER_02: But um, but aside from that, um and and and then other issues that were that of of corruption in in in uh in Malta.
• 34:22
  SPEAKER_02: And I think that the European Commission was looking at at Malta, I I guess maybe it's not even really fair of them to be doing it, but as a part of Europe that has to be checked a little bit more than than Norway, or well Norway isn't part of the EU, but um, but of you know, I don't know, uh France or something like that.
• 34:42
  SPEAKER_02: I don't think I think that there's this big brother, little brother aspect of of in international relations that had that had an effect on on how the European Commission is judging Malta.
• 34:55
  SPEAKER_02: Um but I also think that part of the problem is that we ourselves are doing a very bad job at um at promoting what we are doing.
• 35:09
  SPEAKER_02: The countries and the the players in this, the stakeholders in this industry have done a very bad job in um unfortunately we we have to take the European Commission seriously.
• 35:25
  SPEAKER_02: That's part of this industry.
• 35:27
  SPEAKER_02: Um and we have a we have done a very bad job in organizing ourselves um and lobbying the European Commission, explaining, teaching, showing, promoting, marketing to the European uh over overlords um that uh uh uh showing how this these programs actually work and arguing the fact that no, these programs are not um uh are not a security risk, like you know, they don't lead to money laundering, they don't lead to tax evasion, they have nothing to do with tax evasion.
• 36:11
  SPEAKER_02: It's just been a very um we've done a bad job of it.
• 36:17
  SPEAKER_02: Both the countries themselves who are involved in this industry, as well as I would say us, you know, the sort of the major stakeholders in this industry have been I take the blame myself.
• 36:31
  SPEAKER_02: I I haven't really participated in going to Brussels and lobbying Brussels, but we should have um some kind of more effective lobbying group, which we there's there are all a bunch of groups that have been for, but they're not effective, clearly.
• 36:49
  SPEAKER_03: Part of the reason why those lobbying efforts uh have not been effective, I think, is because there's uh a great deal of fragmentation among the the large companies in this business.
• 37:02
  SPEAKER_03: You know, they there are separate initiatives aimed at lobbying.
• 37:06
  SPEAKER_03: There's no I don't think there's uh too much of a pooling of lobby resources between the big players, right?
• 37:15
  SPEAKER_02: Uh well, yes, and I I as I said I take the blame.
• 37:19
  SPEAKER_02: Um I think I take responsibility for the fact that unfortunately there isn't an effective um forum that has been able to both to unite um the important stakeholders in this industry, not just the companies that are trying to make money off of this industry, but the countries as well, in order to present the value of this industry to the countries that are participating in it.
• 37:53
  SPEAKER_03: Back to Vanuatu for a moment, uh, because uh my impression of most people's reaction to that news was ah, this was totally expected.
• 38:04
  SPEAKER_03: Uh was uh it was a question of time, uh, they have themselves to blame.
• 38:09
  SPEAKER_03: Shouldn't we be speaking up in defense against the European Commission?
• 38:14
  SPEAKER_03: Because this could have implications for the Caribbean Five, right?
• 38:17
  SPEAKER_03: I mean, if we don't it it it's it it's one of those situations where you know they they came for Vanuatu and I said nothing.
• 38:25
  SPEAKER_03: Right?
• 38:26
  SPEAKER_02: Yeah, yeah, no, I get it.
• 38:29
  SPEAKER_02: The Maltese program, unfortunately, they had an opportunity when they started to really work very closely with the European Union um and teach the European Union what it was all about, but instead they kind of ignored the European Union and tried to um how should I say um uh uh sort of both kind of meet the standards while not meeting the standards of the European Union or But didn't they get didn't they get the nod of approval from the European Commission?
• 39:11
  SPEAKER_03: There was something that was signed, some sort of MOU or something?
• 39:14
  SPEAKER_02: No, they didn't.
• 39:15
  SPEAKER_02: What they they said that they did, but they didn't.
• 39:18
  SPEAKER_02: Um what what really happened?
• 39:21
  SPEAKER_02: Well, they they the the European Union asked for this genuine connection to to uh um to Malta.
• 39:30
  SPEAKER_02: Um and the Maltese put in a year-long residency requirement and uh and and allowed for people not to be resident.
• 39:40
  SPEAKER_02: They said, well, do what you asked, but then they didn't do what they asked.
• 39:43
  SPEAKER_02: And they they accepted as residency membership in a yacht club.
• 39:48
  SPEAKER_02: Well, that's not residency, and and membership in a gym is not residency, and membership and you know give donating money to a museum is not residency.
• 39:59
  SPEAKER_02: Residency is residency.
• 40:01
  SPEAKER_03: Um the government Well what they were what they were trying to what they were trying to get was what what's called genuine links, right?
• 40:09
  SPEAKER_02: And they were saying, well, what genuine links the genuine links was not the issue.
• 40:13
  SPEAKER_02: Residency was the issue.
• 40:15
  SPEAKER_02: They just started talking about genuine genuine links.
• 40:18
  SPEAKER_02: What they agreed to with the what the European Commission asked for and they said that they would do is they was residence, not genuine links.
• 40:32
  SPEAKER_02: Genuine links are not genuine if it's donating money to a yacht club.
• 40:38
  SPEAKER_02: Um and so the European Union was and this was an open secret.
• 40:42
  SPEAKER_02: It was an open secret that they had to have a residence so they could rent a residence, and 30 people would rent one bedroom apartment in order to show to the government that that uh uh they had a residence.
• 40:57
  SPEAKER_02: And there were all sorts of games being played, and now it's a lot of it has been cleaned up.
• 41:01
  SPEAKER_02: There's no question.
• 41:02
  SPEAKER_02: It's a very different program today than it was when it first started.
• 41:06
  SPEAKER_02: Um totally different program.
• 41:09
  SPEAKER_02: And I I think unfortunately the um uh the European Commission doesn't really understand the changes that have been made in in Malta and how much it's it's been improved.
• 41:19
  SPEAKER_02: It's it's it's really day and night today than when it was when it started.
• 41:23
  SPEAKER_02: But no, they never got the approval.
• 41:25
  SPEAKER_02: They got a we'll wait and see and watch what you guys are doing from the European Commission.
• 41:33
  SPEAKER_03: So, but the the question of genuine links, I think, is uh is a difficult one.
• 41:37
  SPEAKER_03: First of all, I mean there are good arguments for genuine links being what's called ultra virus, so it's outside of the law.
• 41:46
  SPEAKER_03: There is there is no this is uh Professor Kochnob's argument that there is no Professor Koch who is on who works for one of the citizenship companies, right?
• 41:58
  SPEAKER_03: Who is yeah, he's on uh on good terms with Henley and partners, with the IMT, he has some kind of role there, I think.
• 42:07
  SPEAKER_02: So he's he's not he's not totally I don't I don't know him personally, but um I from what I understand he he's you know I I don't think the European Union sees him as being a an objective player because he's he's on um and that's per that's perfectly on Yeah, it's perfectly understandable.
• 42:27
  SPEAKER_03: He's he's affiliated with the industry, nonetheless, the law is the law, right?
• 42:32
  SPEAKER_03: It's not it's not his interpretation of it necessarily.
• 42:36
  SPEAKER_02: It's the law is the spirit of the law and then there's the letter of the law.
• 42:41
  SPEAKER_03: Right, of course, of course.
• 42:42
  SPEAKER_03: But the the other thing is genuine links, you know, what the commission wants is exactly what Malta can't give it.
• 42:50
  SPEAKER_03: Because if you ask for actual genuine links, that would imply a multi-year residency period.
• 42:58
  SPEAKER_03: It would imply you know you living there, having actual connection.
• 43:06
  SPEAKER_03: Right.
• 43:06
  SPEAKER_03: But but the point is that the whole reason why it's called citizenship by investment is it's not citizenship by living there first, right?
• 43:16
  SPEAKER_03: It's citizenship by investment.
• 43:18
  SPEAKER_03: That's the idea.
• 43:20
  SPEAKER_02: Then you can call it like it's called in Canada, investor immigration.
• 43:25
  SPEAKER_02: Um and and different countries have different standards.
• 43:30
  SPEAKER_02: I mean, the the um, you know, I I think what the European Commission wanted to see in Malta was not genuine links, but residents.
• 43:40
  SPEAKER_02: And I think even more if I was and it hasn't been reported anywhere, this is just my feeling.
• 43:46
  SPEAKER_02: I think they wanted to see tax residency as the genuine link.
• 43:51
  SPEAKER_02: And obviously, no one wanted to become a tax resident, and that's why somebody came up with the idea of joining a yacht club as a job as Becoming a genuine link.
• 44:01
  SPEAKER_02: I think that the European Commission wanted these people to become tax residents of the country so that they would report to the country their earnings.
• 44:12
  SPEAKER_02: And that that would be a safeguard, a financial safeguard for Europe.
• 44:17
  SPEAKER_03: But by that standard, Europe can't have citizenship by investment programs.
• 44:23
  SPEAKER_03: Because a citizenship by investment program means you invest or you donate and you get the citizenship, but you don't need to spend much time in the country.
• 44:33
  SPEAKER_03: Why?
• 44:33
  SPEAKER_03: Right?
• 44:35
  SPEAKER_03: That's what the Caribbean has.
• 44:36
  SPEAKER_02: That's what the Caribbean has, but why does Europe have to have that?
• 44:40
  SPEAKER_03: No, I'm not saying they have to have it.
• 44:41
  SPEAKER_03: I'm saying that's the same thing.
• 44:43
  SPEAKER_02: Why can't you call it citizenship by investment?
• 44:50
  SPEAKER_02: Normally to become a citizen of countries, there's a there's a residence period.
• 44:55
  SPEAKER_02: I don't know what it is in in uh in Malta, but normally if you're uh you become a permanent residence through a certain process and then you have to live there for six, seven years.
• 45:05
  SPEAKER_02: I think it's probably in Europe it's generally six years.
• 45:08
  SPEAKER_03: Typically, typically five to seven years, typically.
• 45:10
  SPEAKER_02: Five to seven, right.
• 45:11
  SPEAKER_02: Um so why can't you um uh call it citizenship by investment?
• 45:17
  SPEAKER_02: You have a one-year residence requirement.
• 45:20
  SPEAKER_02: Okay, but that's that's what I call exchange for the money.
• 45:24
  SPEAKER_03: I call that semi-direct citizenship by investment.
• 45:27
  SPEAKER_03: That's what you have to do.
• 45:29
  SPEAKER_00: That's what you have.
• 45:30
  SPEAKER_03: No, no, but what I'm saying, I'm I'm just okay, this is a question of terminology, right?
• 45:34
  SPEAKER_03: So I'm trying to differentiate when I say citizenship by investment program, I mean on the model, the original St.
• 45:40
  SPEAKER_03: Kitts model, where you invest, you don't have to be here, and you'll become a citizen, right?
• 45:46
  SPEAKER_03: I'm saying that that, if we're gonna follow, if we're gonna satisfy the European Commission, it means we can't have that in the EU, right?
• 45:55
  SPEAKER_03: Uh what you're talking about is semi-direct citizenship, which is what they have, semi-direct citizenship by investment, which is what they're doing.
• 46:03
  SPEAKER_03: Yeah, an expedited naturalization uh because you've contributed economically.
• 46:08
  SPEAKER_03: But it's not instant, like in the Caribbean, instantly upon approval, right?
• 46:12
  SPEAKER_03: Well, not in Bulgaria, in Bulgaria, they have what you refer to here, they have a semi-direct uh citizenship by investment program.
• 46:21
  SPEAKER_03: So you have to be resident first for a number of years, and then you can become a citizen.
• 46:27
  SPEAKER_03: But the European Commission also is not happy with that model.
• 46:32
  SPEAKER_02: Well, look, I I I again I I I think I mean uh the UK has that also, and Canada has that, and the US has that.
• 46:40
  SPEAKER_02: Um has a the investor immigration model, which is you get citizenship after six years if you invest today a certain amount of money.
• 46:48
  SPEAKER_02: It's one route to citizenship or to in or to immigration.
• 46:54
  SPEAKER_02: Um look, I I think that um the um the European I'm I'm confused in all honesty.
• 47:06
  SPEAKER_02: It's hard for me to understand how these commissioners at the European Commission don't really seem to understand the difference between residence and citizenship, between um, you know, because they don't really understand the difference between the RCBIs and the CBIs and the all that.
• 47:22
  SPEAKER_02: Um and they don't understand that that just becoming by becoming a citizen of a country, you don't necessarily become a tax resident of the country, and it doesn't allow you to hide your your bank accounts from it.
• 47:37
  SPEAKER_02: They seem to not have really delved deep into the the issues, and they're just seeing sort of this idea of money floating around that that uh and people buying passports for money, and it bothers them.
• 47:52
  SPEAKER_02: Right.
• 47:52
  SPEAKER_02: But um sorry.
• 47:54
  SPEAKER_02: And that's our and that's again I'm saying I'll say the same thing that I said before.
• 47:58
  SPEAKER_02: That's our failure.
• 47:59
  SPEAKER_02: We fail in to teach them the what is important and what the issues are, and that they are wrong when they say that that when they think that that that becoming a citizen gives you some tax preferences, which is just factually wrong.
• 48:19
  SPEAKER_02: And it's and it's our problem.
• 48:22
  SPEAKER_02: We have allowed that to happen.
• 48:24
  SPEAKER_02: We as the the stakeholders in this industry um have uh allowed that to happen and we haven't changed it.
• 48:32
  SPEAKER_02: We have not been effective in changing it.
• 48:33
  SPEAKER_02: It's a fact.
• 48:35
  SPEAKER_03: If you could go back ten years to change that approach, what would you do differently?
• 48:41
  SPEAKER_02: Um I would have organized us in a in a very different um in a very different way.
• 48:50
  SPEAKER_02: Um I would have um you know, like in like in every group of people, there's there's politics and there's personal interests and and all that.
• 49:03
  SPEAKER_02: Um and unfortunately, those politics and personal interests have have gotten in the way of both the professional stakeholders in this industry and the countries that are involved in the industry of coming together as an organized body and and um putting um uh and and putting our best face forward or putting our best foot forward.
• 49:33
  SPEAKER_02: Um it's uh I mean a lot of it, I I again, as I said, I I I blame myself.
• 49:40
  SPEAKER_02: I would have gotten all the countries to to organize publicly with but then this again gets to to the the issue also of um of licensing.
• 49:52
  SPEAKER_02: Um the governments have to be careful about who they deal with and how they deal with, and has to they when they organize together, they have to organize with those who they've already they know who they're dealing with.
• 50:03
  SPEAKER_02: And there should be an organization of all the countries and the licensed stakeholders in this um who are have put together a uh a um I guess a pot of money who should and and hired professional lobbyists in in um uh in Brussels, not not just you know a bunch of us talking to people around and to politicians.
• 50:35
  SPEAKER_02: And it should be a coordinated effort with a real budget and a real system and a and with with real, we're not the lobbyists.
• 50:42
  SPEAKER_02: We should be hiring lobbyists.
• 50:44
  SPEAKER_02: Um and uh I think that I think what there's a lot of room for us to improve the way that we uh safeguard our industry.
• 50:54
  SPEAKER_03: Let me let me talk to you about Montenegro for a second.
• 50:59
  SPEAKER_03: Please do.
• 51:00
  SPEAKER_03: Um yeah, uh I don't know much about it.
• 51:04
  SPEAKER_03: All right.
• 51:04
  SPEAKER_03: Well, there you know, you know more than most, I think.
• 51:07
  SPEAKER_03: So the their citizenship program was saved by the bell, of course, in the nick of time, uh on New Year's Eve, I believe, or the day before.
• 51:16
  SPEAKER_03: The day before.
• 51:17
  SPEAKER_03: And um, of course, Apex uh is one of the licensed, one of three licensed agents together with Henley and Partners and Art and Capital.
• 51:25
  SPEAKER_03: Uh, you've been involved in that program from the very beginning.
• 51:29
  SPEAKER_03: Can you give us the play-by-play of what took place in the final weeks before the extension, to the extent that you're privy to such deliberations, of course?
• 51:40
  SPEAKER_02: I'll tell you the truth.
• 51:41
  SPEAKER_02: The truth is I wasn't privy.
• 51:44
  SPEAKER_02: Um this was uh um I I heard a lot of rumors, a lot of people were talking, um, both within the country and outside of the country.
• 51:55
  SPEAKER_02: Um, but there were no official um contacts with with uh, as far as I know, with any of the uh uh approved agents, um, the three of us.
• 52:08
  SPEAKER_02: Um uh obviously um within the government.
• 52:14
  SPEAKER_03: It would have been nice, it would have been nice to know in advance, wouldn't it?
• 52:17
  SPEAKER_02: Well, you know, um I'll tell you it it it for for all of us just as a business thing, uh it it uh it was actually it all worked out well for us because the the you know we we know through our experience in Quebec and in the federal program and the Quebec program and in Sink Kitts in 2015 and in lots of different countries where the threat of a program ending leads to everybody sitting on the sidelines just coming making decisions faster.
• 52:54
  SPEAKER_02: So that was very good for our firm and and I'm assuming for the other firms as well, the the two the two other licensed agents.
• 53:02
  SPEAKER_02: A lot of clients who were thinking of doing um uh Montenegro um you know uh retained us and and uh at uh in the last months leading up to uh um to uh the uh uh the end of the year.
• 53:19
  SPEAKER_02: And if they if if we had known that they were going to extend, we would have had a responsibility to tell them that and tell them, don't worry, you can join, you can start later.
• 53:28
  SPEAKER_02: Uh within the government, from what I understand from you know publicly available sources, there was a very big argument as to whether or not to extend the program.
• 53:39
  SPEAKER_02: Um and it was it came down to the wire.
• 53:42
  SPEAKER_02: Um I think they did the right thing.
• 53:44
  SPEAKER_02: I think they made the right decision that will be good for Montenegro.
• 53:47
  SPEAKER_02: Um I also think that the the um the European Commission, when it wrote that they'd like to see um these programs phased out by 2025 in Europe, um, allowed Montenegro at least a little bit of wiggle room to uh to continue the program a little bit longer.
• 54:10
  SPEAKER_03: Um but implicit green light.
• 54:13
  SPEAKER_02: Well, I think that they that's the interesting thing is I think that the European Union gave an implicit green light to you know both to Malta and to and to others.
• 54:23
  SPEAKER_03: Um sorry, you said two to others, you say are you saying uh effectively they're they're they're signaling to other prospective CBI countries in Europe who who are who might also be you know in uh in line for EU accession.
• 54:40
  SPEAKER_03: That's like, okay, you can you can open a CIP, but just make sure it's closed by 2025.
• 54:45
  SPEAKER_03: Maybe that's what they meant.
• 54:48
  unknown: Yeah.
• 54:48
  SPEAKER_02: Okay.
• 54:49
  SPEAKER_02: I don't know.
• 54:49
  SPEAKER_02: I don't know what they could have said close it down.
• 54:53
  SPEAKER_02: I mean, they they could have said close it down this week or next week, or but instead they gave four years um to to uh to close down.
• 55:03
  SPEAKER_02: But I I I think that there was a genuine debate within the Montenegrin government as to what to do, and I think that they they the debate went on to the last day of the year, and at the last day of the year they had to come up with a decision, and this was the decision that they made, and I think it was the correct decision.
• 55:23
  SPEAKER_02: Um I think that it will serve Montenegro well.
• 55:26
  SPEAKER_03: Um I think it'll serve certainly the developers um who were um at various stages of of fundraising um will have um you know will have more of a chance to complete their projects, which is which is very important to uh now, of course, those who want to obtain citizenship by investment in Montenegro will have to come up with an additional hundred thousand euros uh as a donation.
• 55:58
  SPEAKER_03: To what extent do you think that is going to impact demand, uh especially viewed in light of Montenegro's position vis-a-vis the Caribbean programs?
• 56:09
  SPEAKER_03: I know they're not exactly substitutes, but um they are sort of in the same uh range in the market.
• 56:17
  SPEAKER_03: How do you how do you think it'll impact?
• 56:19
  SPEAKER_02: I don't think that I mean the the the uh the outlay of capital at at um for the Montenegro program was always more than double than the the outlay of capital in in uh in the Caribbean.
• 56:34
  SPEAKER_02: Um I I think that it it will potentially keep some people on the sidelines.
• 56:43
  SPEAKER_02: I I don't think the effect will be that great, um but um I think that uh um uh uh uh you know we we assume that um clients won't spend people who are interested in second citizenship won't spend more than 10 percent of their net worth on on citizenship um on the on a second citizenship.
• 57:09
  SPEAKER_02: So if you assume that with all the fees and all the everything, the the the due diligence fees, the application fees, the fees paid to us, and that the the an application per family was about 400,000 dollars, 400,000 euros for 450,000 euros, then we're talking about people whose net worth is at least north of 4.5 million euros, four and a half, five.
• 57:40
  SPEAKER_02: I I think those kinds of people, if they really want the second citizenship, the extra hundred thousand, while it might be important, it's five percent, it's it's what is it, a quarter, one percent of their net worth or less, what is it, a quarter of a percent of their net worth.
• 57:58
  SPEAKER_02: Um 2.5%, I'm sorry, of their net worth.
• 58:02
  SPEAKER_02: I I don't think um and and knowing the net worth of our clients, our um are of our our you know, our clients are what most clients are not at that minimum of 4.5, but they're higher up, it's a small, it's a small um it's a small change for them.
• 58:25
  SPEAKER_02: It'll it'll have an effect.
• 58:27
  SPEAKER_02: 100,000 euros is 100,000 euros to to whoever it is.
• 58:31
  SPEAKER_02: Um but I in the Caribbean, um, as I said, in the Caribbean where you can um where where a person can become a citizen at 100,000 euros, uh dollars, um that kind of a person who is looking at those programs, most of those people are are a lot more price sensitive than the ones that are looking at at Montenegro.
• 58:58
  SPEAKER_03: So Okay, in the in the Caribbean, yeah, as you say, 100,000 US dollars, and now the new minimum in Montenegro is effectively 450,000 euros, and we can call that 500,000.
• 59:12
  SPEAKER_03: Yeah, why is Montenegro?
• 59:14
  SPEAKER_02: It was 400,000, it was 400,000 two weeks ago.
• 59:19
  SPEAKER_03: Right.
• 59:20
  SPEAKER_03: But is a Montenegrin citizenship five times as valuable as uh St.
• 59:25
  SPEAKER_03: Lucian citizenship or a Dominican citizenship?
• 59:28
  SPEAKER_02: I I would argue that it's a totally different thing.
• 59:30
  SPEAKER_02: It's like a a uh a you know a house and uh apartment building, or uh it's just a totally different thing.
• 59:38
  SPEAKER_02: It's not it's not the same thing.
• 59:39
  SPEAKER_02: Uh you can't you can't compare apples and oranges, right?
• 59:43
  SPEAKER_02: Um the the it's not a question of what it's worth.
• 59:50
  SPEAKER_02: Um it's it's it's worth whatever um the potential buyers are willing to pay for it.
• 59:56
  SPEAKER_02: Um so look, the the a lot of a lot of people were buying, were investing uh applied for citizenship in Montenegro, but to be clear, the in the number of applications that went in for to the Montenegro program was clearly maybe 10% of what goes to the Caribbean, 15%, maybe?
• 1:00:23
  SPEAKER_03: Yeah, yeah.
• 1:00:24
  SPEAKER_03: What what are we talking like uh six, seven, eight hundred applications in the last year for Montenegro and in the Caribbean, maybe five thousand?
• 1:00:33
  SPEAKER_02: Yeah.
• 1:00:33
  SPEAKER_03: So something like that.
• 1:00:34
  SPEAKER_03: Yeah.
• 1:00:35
  SPEAKER_02: So I mean, and and it'll still that that I don't see a reason for that um that to change.
• 1:00:42
  SPEAKER_02: I don't think that more than 10% or 15% of citizenship applications will continue to go to uh uh Montenegro.
• 1:00:51
  SPEAKER_01: Even with Montenegro, what's the chance that they'll lose uh you know access to the Singen area?
• 1:00:56
  SPEAKER_01: It's a it's an entirely different uh you know asset.
• 1:01:00
  SPEAKER_01: I I I I don't see any reason why they would.
• 1:01:03
  SPEAKER_01: Exactly.
• 1:01:04
  SPEAKER_01: But you know, if can you tell uh client that Antiguan Barbuda would never lose it as a certainty?
• 1:01:11
  SPEAKER_01: You can.
• 1:01:11
  SPEAKER_02: That's you know it's I can't guarantee I I have a weakness in life.
• 1:01:16
  SPEAKER_02: I have a very big weakness in life.
• 1:01:18
  SPEAKER_02: I can't tell the future.
• 1:01:20
  SPEAKER_02: I just don't know what's gonna happen in the future.
• 1:01:24
  SPEAKER_02: Um and maybe I'm unique in that way that I can't do that.
• 1:01:27
  SPEAKER_03: Yeah, I then you're in the wrong line of business.
• 1:01:29
  SPEAKER_02: I'm in the wrong line.
• 1:01:30
  SPEAKER_02: So I I can't guarantee um I can't guarantee these these kinds of things.
• 1:01:36
  SPEAKER_02: Um I mean uh uh when when uh uh St.
• 1:01:40
  SPEAKER_02: Kitts lost its Canada uh visa-free, a number of petitions um decided to do the CIP in Antigua because Antigua had the the citizenship, the the visa-free to Canada.
• 1:01:54
  SPEAKER_02: And then and then Antigua lost their visa-free to Canada.
• 1:01:58
  SPEAKER_02: Who would have known?
• 1:01:59
  SPEAKER_03: Um that's it for today, folks.
• 1:02:04
  SPEAKER_03: But we'll be back soon with another episode of the Mobility Standard.
• 1:02:08
  SPEAKER_03: In the meantime, I encourage you, the listener, to send us the questions you have about investment migration.
• 1:02:14
  SPEAKER_03: If we're able to answer them, we'll do so during our next episode.
• 1:02:18
  SPEAKER_03: I want to remind you to follow our work on imidaily.com, the world's number one publication for investment migration, home to the internet's greatest collection of investment migration data, real estate expert opinion, and the intelligence you need to be a successful investment migration professional.
• 1:02:36
  SPEAKER_03: Thank you for listening.