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Various due-diligence processes and revisions of the currently existing Cyprus Investment Program (CIP) have led to major changes of the program, published in the Official Gazette of Cyprus at the end of August 2019.
The amendments affect the already defined donation criteria and amount. For any future applications, it is important that these changes are understood precisely as defined in the amendment of the Law. The update defines two major financial aspects as follows:

  1. Investors who apply for Naturalization under the Cyprus Investment Program from 15th May 2019 onwards must satisfy the financial criterion A.1. This criterion prescribes an additional donation of at least EUR 75,000 to the Research and Innovation Foundation and a donation of at least EUR 75,000 to the Cyprus Land Development Corporation.
  2. Under the combination of investments (criterion A.5) the applicant can purchase securities on the secondary market of the Cyprus Stock Exchange (CSE) up to EUR 200,000.
    Additionally, applicants with high-risk have been excluded from the program. There is now a clear definition of which individuals fall under that category and are thus not eligible. The Council defines as high-risk the following individuals:
  3. Politically exposed persons, including: persons who hold a political position; persons who have held a political position during the last five years;
  4. Persons who are subject to criminal investigation without being charged;
  5. Persons who are subject to criminal proceedings and are defendants in a criminal case which is pending;
  6. Persons sentenced to prison for serious offences and the set conviction does not appear on a criminal record;
  7. Persons affiliated with legal entities which have been restricted by the European Union (e.g. shareholders or senior executives of companies that are included in a list of sanctions);
  8. Persons who have been sanctioned by non-EU countries (e.g. USA, Ukraine, Russia);
  9. Persons associated with legal entities subject to sanctions by non-EU countries;
  10. Persons being investigated / charged for criminal offences and being sought across Europe by EUROPOL or internationally by INTERPOL;
  11. Persons who have been investigated / indicted for criminal offenses and have being sought across Europe by EUROPOL or internationally by INTERPOL but are no longer sought;
  12. Persons subject to sanctions by the United Nations Security Council.
    Understanding these major changes is of the highest importance for the applicant. As your trusted advisor, we want to secure that all imposed criteria have been meet prior to application submission.

Anna Philiotis

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