The MOF (Ministry of Finance) has started checks on the qualifying investments undertaken between 1st of May 2013 and 31st of December 2018 as part of the Cyprus Investment Programme.
The MOF requested the members of the Register of Service Providers of the Cyprus Investment Programme to provide supporting documents for their clients qualifying investments to check that they still hold those qualifying investments which entitled them to be naturalized under the Cyprus Investment Programme
The announcement requests supporting documentation of the status or completion of the investments maid by the Cyprus Investment Programme applicants during the 1st of May 2013 and 31st of December 2018.
The MOF announced on the 20th of December 2019 (available only in Greek) is a result of the cabinet of ministers decision of the 23rd of October 2019 and 6th of November 2019. During that time the cabinet of ministers was called to address two scandals which brought about several negative publicity for the Cyprus Investment Programme and Cyprus as a nation.
A Reuters special report outlined how Cambodia’s long-ruling prime minister, Hun Sen, and family members obtained the European citizenship via the Cyprus Investment Programme. Continue Reading …
And soon after that in November another report broke out by a local news papper regarding the Jho Low being naturalized by investment. Low being connected to the 1MDB scandal in Malaysia and alleged to have embezzled hundreds of millions from the state owned fund. Continue Reading …
What is a Qualifying investment?
The Cyprus Investment Programme requires, among other things, that a qualifying investment is made in order to be eligible for naturalization. At the moment the qualifying investment stands at:
- At least €2,0 million for the purchase or construction of buildings or for the construction of other land development projects (residential or commercial developments, developments in the tourism sector) or other infrastructure projects.
- At least €2,0 million for the purchase or participation in companies or organizations established and operating in the Republic of Cyprus.
- At least €2,0 million from alternative investment funds (AIF) or Registered Alternative Investment Funds (RAIF) established in the Republic of Cyprus, licensed/registered and supervised by the Cyprus Securities and Exchange Commission (CySec) and whose investments are made exclusively in the Republic of Cyprus.
- The applicant may proceed with a combination of the above investments, provided that the total investment will amount up to at least €2,0 million.
What supporting documents are required for qualifying investments in Cyprus real estate?
The list below has been taken from the official letter addressed to the members of the Register of Service Providers of the Cyprus Investment Programme. It seems that the aim of MOF Checks on the Cyprus Investment Programme is to confirm the ownership of the qualifying investment by the client/investor irrespective of the stage that the project is in. For projects in development they require an architect’s confirmation since the qualifying investment ownership would not be directly evident. Whereas for completed projects they would still require an architect to confirm the delivery of the project but also a land and survey search slip showing the owner of the property.
- Confirmation, signed by the project architect regarding the progress of development of the project which consist of the qualifying investment or/and each clients permanent residence.
- Confirmation, signed by the project architect, that the real estate delivered comprise of the qualifying investment or/and the permanent residence of each client.
- Confirmation from the Cyprus registrar of companies that the investors or clients maintain the same percentage of participation in the company used to perform the qualifying investment.
- A recent land and surveys proof of search for each property comprising of the qualifying investment.
What supporting documents are required for qualifying investments in Cyprus Business?
In contrast to the above for qualifying investments in Cyprus business it seems that the process is simply supported by the confirmation of the auditor and supporting documents from the registrar of companies.
- Accounting firms confirmation that the qualifying investment included in the application has been performed.
- Confirmation from the Cyprus registrar of companies that the investors or clients maintain the same percentage of participation in the company used to perform the qualifying investment.
A possible complicated issue with providing supporting documents of the completion of the investment is the fact that certain Cyprus funds established to invest in particular asset classes might not have launched the investment strategy yet and as such would create complications towards providing supporting documents.
What is the Register of Service Providers of the Cyprus Investment Programme
The Cyprus Ministry of Finance in an aim to increase the credibility of the Cyprus Investment Programme put together a special Committee of Supervision and Control for the Cyprus Investment Programme. The Committee of Supervision and Control for the Cyprus Investment Programme, consists of representatives from the Ministry of Finance, the Ministry of Interior and Invest Cyprus and was established on the basis of a Council of Ministers Decision, aiming at further improving the Cyprus Investment Programme.
The Committee of Supervision and Control for the Cyprus Investment Programme supervises persons registered as providers of Cyprus Investment Programme and even has introduced a Code of Conduct.
The Register keeps record of those persons that are registered and requires that they adhere to the Code of Conduct.
Harris Sharpe
Author – Photographer
For many years he has worked and devoted his skills and efforts towards building a successful career as a leading executive. From humble beginnings, his aim has always been to yield results; with a keen focus to attention to detail and client satisfaction. His experience has always been varied and not specific, at times he preferred it. With that in mind, he has dealt with CySEC on licensing and ongoing regulation, international private equity and credit fund managers, NASDAQ and NYSE listed companies occasional millionaires as well as self-made millionaires. His passion though is difficult transaction work organizing and deploying people for a common goal. Harris enjoys reading and studying the Cyprus law and sharing that information on this website.