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Amendments to Citizenship Scheme

Cyprus Amendments to Citizenship Scheme

The Council of Ministers, during its assembly on the 31.7.2020 has made changes to the current Cyprus Investment Programme, affecting applicants as per the 17-18.8.2020.  In general, the main new terms are as follows:

  • All applicants must, during the 5 years, for which they are obligated to keep their investment and residence, provide the Ministry of Finance and Ministry of Interior of proof that such investment and residence is still under their name;
  • Donations:
    • The investor should donate at least EUR 100,000 to the Research and Innovation Foundation. This donation was previously set at EUR 75,000. Such donation will need to take place after the approval for citizenship but before the issuance of the certificate of naturalization. The alternative to this donation has also changed. It is no longer possible to invest in a certified innovative enterprise, which has acquired the relevant certificate by the Ministry of Finance, or a certified social enterprise. It should be noted that the above obligation is deemed to be fulfilled if the investor has made an investment under bullet point 2 of requirement 3 below of an amount of at least EUR 400,000 in a company whose operations fall within the primary sector of the economy, or the secondary sector of the economy (construction companies are excluded), or in the sectors of research and development, education, health and renewable energy sources, or
    • The investor should donate at least EUR 100,000 to the Service of Industry and Technology for the implementation of targeted sponsorship project for micro and small enterprises. Such donation will need to take place after the approval for citizenship but before the issuance of the certificate of naturalization; or
    • The investor should donate at least EUR 100,000 to the Renewable Energy and Energy Saving Fund. Such donation will need to take place after the approval for citizenship but before the issuance of the certificate of naturalization; or
    • The investor should donate at least EUR 100,000 to the National Solidarity Fund established under the provisions of the Law on the Establishment of a National Law Solidarity Fund. Such donation will need to take place after the approval for citizenship but before the issuance of the certificate of naturalization; and
    • The investor should donate at least EUR 100,000 to the Cyprus Land Development Corporation. This donation was previously set at EUR 75,000. The funds are used for the financing of housing schemes for affordable housing and for the materialization of other housing schemes/measures. Such donation will need to take place after the approval for citizenship but before the issuance of the certificate of naturalization.
  • The investment amount of EUR 2,000,000 can be investment as follows:
  • Investment in the primary sector of the economy or in the fields of research and technology, education, health or renewable energy sources, or the creation of developments, such as residential or commercial developments, developments in tourism sector or other infrastructure projects, or for the purchase or construction of real estate, including investment in a building land, provided that the application includes an investment plan for development of such. It is however now explicitly prohibited to set up a land development company with the aim of channeling the investment. All other criteria under this option remain the same;
  • Under the previous investment option of Purchase/establishment/participation in Cypriot companies or businesses, the number of Cypriot or EU citizens which must be employed by such company was five (5). This has been increased to nine (9). All other criteria under this option remain the same;
  • The investment in Investment in Alternative Investment Funds/Registered Alternative Investment Funds/financial assets of Cypriot companies or Cypriot organizations that are licensed by Cyprus Securities and Exchange Commission, remains the same.
  • Under the Combination of the aforementioned investments, it is no longer indicated that an investment of up to EUR 200,000 may also be made in securities of the secondary market of the Cyprus Stock Exchange.
  • The funds for the investment and for the purchase of the permanent residence should be transferred from the personal account of the investor or from his company’s/ies’ accounts based abroad and are sent to Cypriot credit institutions or payment institutions, which are licensed and supervised by the Central Bank of Cyprus.
  • The expiration date of the clean criminal record has been increased from 3 months to 6 months.
  • Politically Exposed Persons who have held government office can now apply after 12 months have passed after they no longer held such office. The term was previously five years.
  • Family members of the main applicant do no longer need to wait for filling of their application until the main applicant has received citizenship. They may now file the applications simultaneously.
  • It is no longer allowed for married children to apply under the application of their parent.
  • The parents of both the main applicant and the spouse can now apply. Previously only the parents of the main applicant could apply under the same application. It is further specified that the main applicant and the main applicants’ parents can purchase 1 residence of EUR 1,000,000.
  • The investor and his/her family members are not included in any of the following categories of persons:
    • persons whose name is not included in the list of persons whose property is ordered to be frozen by the European Union;
    • politically exposed persons, within the meaning given to it by Article 2 of the Law on the Prevention and Suppression of Money Laundering and who hold a state office at the date of application or have held a state office 12 months before the date of submission of the application;
    • persons who have been convicted of a serious criminal offense punishable by imprisonment of 5 years or more or of another serious offense or of a dishonorable offense or involving moral indecency, where such offense also constitutes an offence in the Republic of Cyprus and which carries a prison sentence as per above;
    • persons who are subject to criminal investigation either in the Republic or in another country in connection with a serious criminal offense, which carry a prison sentence of 5 years or more, or for other serious offense or for a dishonorable offense or involving moral indecency;
    • persons associated with any natural or legal person, entity, body or carrier to which restrictive measures have been imposed by the European Union which are still in force, such as shareholders or senior management of companies on sanctions lists;
    • persons who were, but are no longer associated with, any natural or legal person, entity, organization or body subject to restrictive measures imposed by the European Union which are still in force, such as shareholders or senior executives affiliated with companies on sanctions list, who had such affiliation when the sanctions regime was imposed;
    • persons who have been sanctioned by the European Union or the United Nations which are or were in force for a period of up to 12 months prior to the submission of the application;
    • persons, who are affiliated with any natural or legal person, entity, organization or body that has been sanctioned by the European Union or the United Nations or which has been in force for a period of up 12 months prior to submission of the application;
    • persons who were, but are no longer, associated with any natural or legal person, entity, organization or body to whom restrictive measures have been imposed by the European Union or the United Nations which are or have been in force for a period of up to 12 months prior to filing the application, such as shareholders or senior management of companies on the sanctions list, which were affiliated with the companies concerned when the sanctions regime was imposed;
    • persons wanted across Europe by EUROPOL or internationally by INTERPOL.

All other criteria remain the same.

It should further be noted that the Council of Ministers has the discretionary power to reject an application even if all necessary documentation has been submitted and the Ministries of Finance and Interior may request any additional documentation and information at any stage.

For any further guidance regarding this procedure or if you require an initial consultation, please do not hesitate to contact our Law Firm at [email protected], , +357 22 251 777 or +357 25 261 777 or please visit our office in Nicosia or Limassol.

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