Citizenship for sale

New breed of 'economic citizens' hold multiple passports to manage wealth and maximise travel freedom, helped by a growing army of advisers.

Having multiple passports and citizenship that bears no relation to where you were born is something most people associates with James Bond or Jason Bourne. But these days it is no longer simply the stuff of spy stories.

Numerous countries have jumped on the bandwagon to offer "economic citizenship" programmes, opening doors for financially independent individuals to obtain second, third or more passports and acquire more nationalities -- as long as they can afford to pay.

"Citizenship by investment" programmes (CIP) have given rise to a new type of immigrant. Forget the image of destitute migrants fleeing war, poverty or human rights violations. Economic citizens have more than enough wealth.

In the past, secondary citizenship might have been perceived as a shady activity engaged in by unscrupulous oligarchs to evade law and tax. The new breed of economic citizen uses the opportunity afforded by a second or third domicile to move, manage and enlarge wealth in ways that might not be possible in one's original home country. Frequent travellers also appreciate the ease of visa-free access to dozens more countries that comes with citizenship in some countries.

The idea of citizenship or residency for sale is not new. Indeed, many countries offer residency to investors willing to commit a certain minimum amount of funds. Advanced economies such as the United States, the United Kingdom and Canada have had "immigrant investor programmes" dating back to the mid-1980s to mid-1990s, according to a study by the International Monetary Fund (IMF) in 2015. Australia, the US, the UK, Singapore and countries in the EU still offer residency -- a first step to apply for citizenship -- to foreign investors.

Smaller countries sensing an opportunity to earn relatively easy money offer a more direct route to obtaining citizenship and passports. These include Cyprus, Dominica, St Kitts and Nevis, and in the past Ireland and several Pacific island states, according to an IMF study.

CIP has become a big business. In 2014 alone, US$2 billion was spent to acquire citizenships and passports, according to Vikram Mansharamani, a lecturer at Yale University in the Programme on Ethics, Politics and Economics. Caribbean countries are becoming the global capital of the citizenship by investment industry, Mr Mansharamani wrote in an article published on the Fortune magazine website in April last year.

One of the notable success stories is St Kitts and Nevis, which uses money from selling passports to service debts. Revenue from CIP is reportedly 25% of the gross domestic product of the small Caribbean state. Other Caribbean nations such as Grenada and Antigua and Barbuda -- already known as a luxurious hideaway for billionaires and global jet-setters including Eric Clapton and Robert De Niro -- launched CIPs in 2013.

Asia Pacific has become an emerging market for the CIP business. Business analysis from Henley & Partners, a consulting firm specialising in CIP and residency for investment, reported that Chinese and Russian billionaires are major clients. Eighty percent of B-5 visas issued by the United States are held by Chinese nationals, while wealthy Russians and Chinese represent 50% of the passports sold in St Kitts and Nevis.

Now, Henley & Partners and ot

hers are looking at Southeast Asian countries including Thailand, Vietnam and the Philippines as new markets.

"We have come to Asia and Bangkok because of the growing wealth in the last 15 years. This region has become a major area in terms of wealth and commerce. We are looking for investors to put investment into a Caribbean country, which in terms of the citizenship by investment industry is a good place to put your money, and citizenship is just a bonus," said Rufus Gobat, director of business development of Citizens International, an Antigua-based specialist firm offering private client services necessary for citizenship investment in the Caribbean.

Mr Gobat and Brian Dobbin, the company's managing director, came to Bangkok early last month to meet prospective local clients, wealthy Thais whom they declined to name. "Discretion is paramount in this industry," said Mr Dobbin.

An individual investor is required to put US$400,000 into real estate or make a $200,000 donation to obtain a passport and citizenship from Antigua and Barbuda. It is rated a particularly strong passport offering visa-free entry to more than 130 countries, including Canada, Great Britain and countries with Schengen visas in Europe.

By comparison, holders of Thai passports can enter only 71 countries without obtaining a visa, the Philippines 61, Indonesia 58 and Bangladesh 39. Holders of the "strongest" passports -- from the US, many EU members, the UK and Canada -- have greater mobility and can enter over 170 countries.

As a member of the British Commonwealth, Antigua offers its citizens access to British educational and medical services. Antigua last year abolished personal income tax and also has no capital-gains or inheritance taxes. At the same time, there are opportunities to invest in the booming real estate and tourism sectors, renewable energy and food.

"My personal idea is that you can never have too many passports in terms of security. No one is really safe, no matter where you are on earth," said Mr Dobbin, who himself holds citizenship in Ireland, Canada and Antigua and Barbuda.

"There is sensitivity in terms of having other citizenship and it is not something that anyone can have, but it is something that you should do if you can. When you need an umbrella on a rainy day and you don't have one, it sounds foolish," said Mr Dobbin, who also is planning to visit Vietnam and Singapore to meet potential clients.

Antigua and Barbuda is not yet on the radar of experts in Thailand who deal with the wealthy and influential. When Asia Focus contacted investment bankers and a top local law firm to ask about the citizenship-by-investment business, they had little information or declined to comment.

Yet, it is an open secret that the mega-rich in Thailand have second or third or even more passports that would make Jason Bourne envious. A case in point is former prime minister Thaksin Shinawatra, who reportedly holds many passports to enable his jet-setting fugitive life -- citizenship of Montenegro and residency in Dubai among them.

Such practices have given the citizenship-by-investment business a bad name in the eyes of the general public, with many people believing it is yet another way for the influential and connected to hide wealth and dodge responsibility.

Mr Gobat appeared taken aback when asked by Asia Focus about transparency and tax evasion. Antigua and Barbuda, he said, had legal requirements asking residents to clearly prove the source of their funds.

"We are not somewhere like Dubai where you can move money off radar. But in terms of financial advantages, we have big tax advantages, zero taxation on income for residents and citizens. Our currency is pegged to the US dollar, strong for banking and investment," he said.

Antigua and Barbuda has become increasingly famous among billionaires in China since it started CIP. In 2014, President Xi Jinping met Antiguan Prime Minister Gaston Browne and stressed bilateral cooperation. China opened a fully fledged embassy in St John's, the capital with around 20,000 residents in a country with a total population of 100,000. Chinese billionaire Sun Yinhuan, the founder of the leading investment firm Yida Group, has invested in huge property development in Antigua Barbuda -- $1 billion to build Singulari, a complex with a marina, hotel and the largest casino in the Caribbean region.

The Chinese-Canadian billionaire Xiao Jianhua also received an Antiguan passport in 2014, along with an ambassador-at-large title. However, he has not been enjoying his citizenship nor the sun, sand and sea of Antigua. Having apparently run afoul of Chinese authorities, he disappeared in late January from his luxurious apartment at the Four Seasons Hotel in Hong Kong and is reported to have been taken to Beijing.


One thing is clear, however: citizenship by investment is becoming a phenomenon associated with the lifestyle of the ultra-rich and a new avenue for wealth management.

"It is something that people in the wealthy community in Russia talk about. My friends have it," said a St Petersburg native who gave her name as Natalia, during an interview by Skype with Asia Focus. Her husband works in the telecommunication business and spends half the year travelling on business. He decided to buy an Antiguan passport to make travel easier and to invest in a new holiday home in a tropical climate.

"Please understand that we don't plan to leave St Petersburg or leave Russia," said Natalia. "I love my city, I'm proud to be a St Petersburg denizen and never plan to leave my motherland. We just acquired citizenship because we want a holiday home to stay during the winter. St Petersburg's winter is brutally cold and I want my young daughter to enjoy nice weather and sea, sand and sun."

As well, she said, the Caribbean island was full of business opportunity for investment in terms of tourism.

Major financial institutions have also started to take notice of this new industry, with some bewilderment and concern. The International Monetary Fund in 2015 issued a study titled "Too Much of a Good Thing? Prudent Management of Inflows under Economic Citizenship Programmes". It concluded that the popularity of citizenship for sale reflected "the combination of growing wealth in emerging markets and increase in global uncertainties and security issues such as Arab Spring, terrorism attacks or political and economic uncertainties".

Another factor driving wealthy billionaires from rich countries to obtain second citizenship is lower tax rates. Yet, the IMF study offered a caution about potential effects on recipient countries such as potential inflation. The other concern is transparency.

In 2014, Washington singled out the CIP in St Kitts and Nevis for enabling Iranians to skirt sanctions and enter the US. To protect the CIP industry, the country reportedly closed it programmes to Iranians in 2011.

In 2014, the Daily Telegraph of London uncovered a CIP in Bulgaria that was making it very easy for foreigners to live and work in the EU and UK by simply paying £150,000 without having to live or work in Bulgaria. The same year, Viviane Reding, a vice-president of the European Commission, criticised CIP in a speech stressing that citizenship must not be up for sale.


It's inevitable that there will always be a few bad apples in the passport-selling market, but most practitioners are working to keep all activities above-board and the industry continues to grow stronger. The Investment Migration Council (IMC), launched in October 2014 in Geneva, has developed a code of ethics for members in the investor immigration and citizenship advisory field to follow.

In June 2016, Henley & Partners released the first global quality of nationality index or QNI, drawing extensive media coverage including from the BBC and The Economist.

The index was created to show which nationalities fared better in terms of legal status that might contribute to business opportunities. QNI is seen as a valid comparative ranking assessment for financially independent individuals to make decisions on acquiring dual citizenship.

The index ranks German citizenship the highest in the world over the last five years with a score of 83.1%. The Democratic Republic of Congo sits at the bottom at 14.3%. Europe and North America perform quite well in the index while new members of the EU such as Bulgaria, Romania and Croatia have benefited from integration with EU.

The Asia-Pacific Region is ranked quite far below the global mean, reflecting wide economic disparities. A few countries such as Japan, New Zealand and Singapore are listed in the higher tier while the likes of Myanmar, Pakistan and Afghanistan predictably do not fare well.

"Everyone has a nationality of one or more states. States differ to a great degree. Russia is huge, Swaziland is small; Luxembourg is rich -- Mongolia is less so. Just as with the states, nationalities themselves differ too," said Professor Dr Dimitry Kochenov, a law professor at the University of Groningen in the Netherlands who was one of the creators of the QNI.

The assessment used various criteria such as GDP, air transport data, economic and political policy, rate of social unrest, military policy and arms involvement, economic performance and political factors.

"Importantly, there is no direct correlation between the power of the state and the quality of its nationality," said Dr Kochenov. "Nationality plays a significant part in determining our opportunities and aspirations, and the index allows us for the first time to analyse this objectively."


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