Speaker 0 00:00:00 On this episode of Cion 180, I'll be chatting with Bruno Leer, c e o of the Investment Migration Council, an inspirational, influential voice that has gone the distance in investment migration programs in the Caribbean. In an ever-changing world, be bold. Take risks, lead by example. Believe in your power. Say what you feel mean what you say. Hi, I'm Leslie Ann Cion, host of the new podcast series, cion 180. Join me at Cion 180 on this journey of discovery and advancement.
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Speaker 0 00:01:38 Hello again and welcome to Sea on 180. I am your host, Leslie Ann Cion. On this podcast series, we feature voices about the Caribbean from around the world who are making real differences in their areas of influence. I invite you to check out my
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Speaker 0 00:02:35 On today's episode, we are discussing investment migration programs, also known as citizenship by investment programs. These days, it's a hot topic, and so we are pleased to have as our guest, Bruno Lek, the first c e o of the Investment Migration Council. He leads the secretariat reporting to the governing board and is responsible for all investment migration council operations. He is a regular contributor to international publications and conferences in Europe, the Middle East, the Caribbean, Asia, and has held positions in London, Paris, and Hong Kong. He has extensive expertise and experience in the management and expansion of professional services associations and in investment migration programs, especially in the Caribbean. Bruno, thank you so much for joining us today.
Speaker 3 00:03:35 Thank you. It's nice to be with you.
Speaker 0 00:03:36 Thank you, Bruno. I know you're busy. Um, but I wanted to approach this topic first of all by dissecting what it's about. Um, as you know, in the Caribbean, it's developed a somewhat pejorative view, um, as a, a trade or, or sailor passports. Um, it's been described really as an investment migration program. Uh, can you give us a brief history about this and how it has become so popular globally?
Speaker 3 00:04:06 Yeah, of course. Uh, and again, thank you very much for inviting me to, uh, to your show. Investment migration is a form of legal migration, which is used by over 80 sovereign states globally. So this isn't something specific to the Caribbean programs comprise of either citizenship or residents by investments, which essentially allows individuals to gain either citizenship rights or residency rights in return for investments in their host countries. So these programs are often structured around, uh, entrepreneurship potential, which is, as we know already, a well-established practice in general immigration policy and used by many O E C D countries. So the development of a globalized economy in recent decades has led to the further expansion of investment migration, essentially, when it is managed effectively and well run, it creates benefits for the individual, of course, who's obtaining residency rights, citizenship rights. It creates benefits for the host country, which is attracting debt-free capital injections into its economy, and of course, wider society. Thus, it facilitates integration and we believe also, uh, contributes to peace, uh, in what is, uh, an increasingly connected and or interconnected world.
Speaker 0 00:05:52 Yes. So, Bruno, why, uh, c b I programs, uh, citizenship by investment investment migration programs are so popular in the Caribbean, and what are the benefits and drawbacks, um, as an income generator for these small island states?
Speaker 3 00:06:11 Hmm. Well, these are, are, are very good questions. Uh, let's break it down into who the main three groups of actors are. So the drivers, if you like. Um, first of all, you have the individuals. So these are investor migrants that come across, uh, from around the globe. They could be celebrities, they could be sports persons, they could be world-class doctors or business persons. We've seen, of course in Grenada, uh, that there are strong family links, uh, between Formula One driver Louis Hamilton. So a sport sports person. Um, others are generally looking to relocate and build a better life for themselves. Uh, and also their families. They're looking for security, better education, access, possibly they're looking for career opportunities, greater mobility. Uh, and these are the main reasons why individuals apply for citizenship or residents by investment programs. If you look at the Caribbean specifically, I think it's fair to say, uh, that many of the individuals applying to the Caribbean programs are certainly looking for, uh, greater mobility.
Speaker 3 00:07:35 So they're looking for a citizenship, uh, where they perhaps can buy, uh, into real estate or investment funds, maybe spent a week or two holidaying on the island. So spending some much needed tourism dollars into the economy, but also use their, um, newly gained citizenship rights, uh, to have visa free access to countries where their birthright citizenship doesn't allow them, uh, similar access as a Caribbean passport. So the second, uh, area or group of actor are the sovereign states. So these range from the largest and mo most powerful. So you have the United States, which has, um, uh, an e B five program and other green cards programs. Uh, you have the United Kingdom, which has a variety of migration programs, uh, to the smaller, what we call peripheral economies that run investment migration programs to attract, uh, debt-free capital injection, but also talent experience, uh, and the investment that I, um, already mentioned.
Speaker 3 00:08:47 And then the third are the professional service providers like yourself. So these are, uh, you know, often the industry is serviced by law firms, whether they be, um, marketing agents abroad or they be local agents handling applications on behalf of third parties. Yes, we then have due diligence providers. So these are the companies, uh, that investigate applications and do a deep dive search into who this applicant is. So they look at, uh, that person's criminal records. They look at how that person has acquired the wealth to allow them, um, to, uh, buy a residency or abroad a second home, uh, or a citizenship. Um, and they will do a deep dive, uh, into that person and their immediate family. They will also look, is that person politically exposed? What do I mean by politically exposed? Well, I mean, is that person working in central government for a foreign state and is highly pos is in a high position, um, within that, uh, foreign state which could potentially open them up to corruption? Yes. So a lot of work is done by due diligence providers to ensure that only bonafide and fit candidates and should meet the risk profile and of a country offering either a residency or citizenship by investment programs.
Speaker 0 00:10:24 Yes. You raised some very interesting points there, Bruno, with that response, because I'll tell you why the profile that you are painting of a potential investor and applicant is somewhat removed from the initial perception as to who is the person, who are these folks that are interested in getting citizenship from, from another country, and why the Caribbean, and is it that the Caribbean is weaker in K Y C or due diligence or its transparency and governance structure that we are so popular? And I'd like you to debunk some of the myths about this, that somehow the Caribbean programs may be inferior in quality in terms of due diligence purposes as opposed to the other countries, the United States, the uk, um, Turkey Malter, et cetera, who also offer similar programs.
Speaker 3 00:11:21 Hmm. Well look on, it's, they're very good questions on paper. Uh, they're not, uh, any weaker at all. Uh, it very much depends on the risk appetites that a specific country has, uh, for attracting, uh, and approving a specific type of applicant. Now, if you look back, uh, maybe seven to 10 years ago, uh, when these programs became highly popular, so you had, of course, historically, investment migration has been used since the times of the Romans. If you contributed to the, uh, building of the Roman Empire in return, um, you would be given citizenship, uh, as a, as a Roman Yep. The United Kingdom, uh, in, in similar fashion, uh, re modernized it and did it when it built. Its, uh, its global, uh, empire of colonies. Uh, and we've seen it in more recent times with St. Kitts in the, uh, mid eighties. Uh, and then things went, you know, a little bit to sleep.
Speaker 3 00:12:24 Uh, the program was there wasn't, you know, incredibly popular. Um, and then came 2008 and the global financial crisis. And governments were, um, you know, absolutely, uh, you know, screaming out for, for funding. So they could either, you know, go and borrow money, which wasn't, you know, really there, um, or they could increase taxes, which is very unpopular. And so they had to find innovative ways of attracting debt-free investment and capital into their economies. Um, and one of those is to, uh, create residency by investment programs and citizenship by investment programs linked to real estate, all government bonds, um, or investment funds. Uh, and then we also saw the Caribbean, of course, uh, and to the free, so when we started, we just had sick kit, uh, then came along, others. Now you have Antigua, you have Dominica, uh, you have St. Lucia. Yes. Uh, and of course you have Grenada. Uh, and governments, you know, quickly realized that, um, to diversify our economies and replace lost investment from things like the sugar cane industry, uh, and tourism, which has been hit quite hard also, uh, citizenship and residency by investment completely legal form of migration is, uh, quite a straightforward way of attracting investment, uh, into the country. Uh, so you saw this proliferation, um, of these, uh, of these programs, uh, and then becoming, uh, increasingly popular.
Speaker 3 00:14:00 It was a little bit looser back then. Uh, I don't think there was much of a structure, uh, around citizenship and residency by investment. But if you fast forward to today, the organization that, uh, I co-founded nearly a decade ago now. Uh, one of the first things we did was create a code of ethics and professional conduct, put some housekeeping in order for governments, uh, attorneys dealing with migration files, uh, and third party promoters to start following, um, harmonized standards. So, you know, back to your point, these programs are, you know, you know, often, um, misrepresented, mistreated in, uh, particularly in the media. Uh, and they're often politicized at the end of the day. They are, um, if well structured, they are legal means, uh, of migrating migration is, um, is a fax. There are over 300 million migrants, uh, roaming around the world, uh, looking for, uh, a new place, uh, to live.
Speaker 3 00:15:05 So essentially then what we had, um, is the banks getting more involved, uh, and undertaking, you know, more, uh, uh, deeper due diligence, uh, and being a little bit more selective as to who could come in and who could not. Uh, and I think that's a very good thing. Um, so the perception that often people will have, and that I shared before, um, researching this, um, this industry, uh, was that it's really for, um, wealthy Russians, wealthy Chinese, um, that have dubious, uh, amounts of wealth, which is unexplained, and they're moving around the world wealth that, you know, the simple fact is that today, investment migration is far more democratized, uh, than it was 10 years ago. Uh, often the marketing leads people to believe that, you know, it's people with private jets and, you know, huge yachts. Uh, but actually it's not eight times out of 10, it really isn't that.
Speaker 3 00:16:10 Um, we see increasing numbers of, uh, sports people, celebrities, uh, but also surgeons, doctors. Um, I, you know, recently heard of a case of, um, an Indian doctor who's a neurosurgeon, and she needed to move, you know, quickly around the world. Um, and her passport didn't allow her visa free access to as many countries, um, as an acquired passport through the Caribbean, which we give you access to, let's say 130, 150 countries, uh, around the world. Uh, so that was a, you know, big eye opener, uh, for, for this surgeon that needed to travel quickly,
Speaker 0 00:16:54 Professional middle class. It, it's, it's interesting that you raised that point about global accessibility because this is one of the key, uh, attractive components to the programs. And I'm wondering, for instance, in recent times, as we've discussed Bruno, um, how concerned should Caribbean governments be, uh, with regard to recent announcements from the United States, uh, with its amendment to the E T U S visa, uh, the eu and the UK's intention, uh, to clamp down on C B I passport holders access, of course, on the pretext of protecting, um, their, their national borders. Um, what, what do you say to this?
Speaker 3 00:17:41 Well, look, investment migration programs, legal pathways, they will, will come and they will go. Um, we've seen that in Ireland 10 days ago. Uh, we've seen that in, in other countries, uh, particularly in the Caribbean. We've seen Canada resin its visa free access to ST kits, uh, a number of years ago. Uh, and then Antigua followed. Um, and that was for, you know, a whole bunch of different reasons. Uh, and then recently the US government, uh, has made the announcements that E two treaties, um, with, uh, countries like Grenada that has an E two treat due in the United States, you, um, citizens will need to have had, uh, to have three years continuous residency in, um, their home country before applying, uh, for the E two, uh, treaty. So my, you know, these things, policy will always change dependent on who is in governments. What I can tell you is that yes, you're absolutely right.
Speaker 3 00:18:46 Investment migration is attracting, uh, the increasing attention of policymakers, particularly in the European Union, but the primary focus on the EU member states operating such pathways. Having said that, non-EU countries with visa free access to the European GaN area have also been under microscope. So as recently as March this year, the European Parliament adopted a report calling on the EU executive body, the European Commission, which is the, essentially the civil service of the European Union to regulate investment migration in the eu. So this is summarizing all current, applicable e rules and procedures, the corresponding regulatory gaps in the EU objectives for investments, migration. Um, and this particular report addresses six non EU countries, those being Antigua, Dominica, Grenada, St. Kitts, St. Lucia, uh, and Vanuatu with visa free access to the eu. So in summary, there is greater scrutiny on the EU level, and there is an implication for Caribbean states.
Speaker 3 00:20:05 What you have is the European Commission, uh, we believe, um, should consider whether a non-EU country is offering golden visas, uh, as a factor when deciding on exemptions from visa requirements and then updating the EU visa code on cooperation with third countries, um, that want to phase out their golden passport schemes. That is something that the, uh, EU is working on. I know that the EU has written, uh, the European Commission has written to the, um, five countries in the Caribbean with citizenship by investment programs, asking for in-depth information on how these programs are run. So you are quite right. There is increasing, uh, scrutiny, uh, but now it's in your government's hands, uh, to take timely action to protect, uh, your national investment, uh, migration pathways. And one of those ways to do that is to perform a policy evaluation of the national rules and procedures, ensuring that there are high, uh, security standards, uh, cross-checking of applicants, uh, in-person interviews, uh, intermediaries, uh, are also looking, uh, into, uh, while looking into what intermediaries, um, are doing and that there is, uh, in, in ensuring efficient, uh, prevention of money laundering and financing, uh, of terrorism.
Speaker 3 00:21:39 So ensuring that your, um, your national legislation is up to date with, um, the recent proposals from, uh, the European Union. And then of course, one of the things, of course, uh, to be communicative. So you need to be having proactive dialogue with EU institutions, but also with United States.
Speaker 0 00:22:02 Yes. So, so Bruno, that, that brings me to another question, um, in light of, of what you are saying. Should uh, Caribbean governments promote their citizenship by investment programs differently in light of the intense scrutiny, um, that is ongoing in recent times? And or what should we be looking at for adjustments, uh, to, to sort of satisfy the risk appetite of the international community?
Speaker 3 00:22:36 Hmm. Well, you know, first of all, um, I think that countries in the Caribbean, um, are internationally recognized sovereign states. Uh, and if they're acting within international law, they should protect their sovereign rights to decide their way forward and not be bullied by, um, you know, what you could call as, you know, old colonialists, uh, in the EU and in the United States. Yes. Um, so that's the first thing is defend your sovereign rights, uh, to operate internationally and legally, um, as is enshrined in your constitutions and the many bilateral agreements that you have, uh, with, you know, international organizations, times have moved on. There is, I understand, um, a lot of competition, but there are also a lot of these, um, there, well, there are a lot of programs, but there are a lot of migrants. Um, and as long as that continues to increase, there is no reason why countries like Grenada shouldn't benefit from it.
Speaker 3 00:23:47 What I will say is that the approach to promoting, um, citizenship by investment programs, um, needs to change internationally. Um, there are a number of, uh, actions, promotional actions taken in outside of, uh, let's say Grenada in, uh, third countries quite far away from, from Grenada, uh, which are, you know, questionable in how they position, uh, the Caribbean. So promoting price, discounts, fast processing, uh, these are all things which are not conductive to a very good citizenship by investment program as of today. Yes. So I think countries in the Caribbean very seriously need to have a thing of how their countries are perceived abroad, not only by, uh, their marketing agents promoting the product, uh, but those standards are then picked up by policy makers in the meetings I've had and said, look, this is how they're promoting, um, the Caribbean passports with big posters in magazines, free ACC, visa free access to the, you know, to European Union processing in three months.
Speaker 3 00:25:14 Uh, and the EU that send, you know, that triggers a lot of red flags for them. Understandably so, yes, EU policymakers will say, well, how do you possibly undertake deep dive due diligence in three months on, on an applicant and their family? Um, it's almost impossible, uh, to do that because it requires highly specialized, uh, due diligence, uh, companies to be able to turn around such reports. Uh, and then international police checks need to be carried out. So your marketing agents abroad should stop promoting, um, a 90 day turnaround on an application. These are quality programs that potentially bring in huge amounts of revenue that is much needed revenue that can be invested in schools, in hospitals, in higher education, in sending children, uh, to further their education abroad in specialized universities for medical training, um, to help build, um, old, um, pension homes to invest in infrastructure to protect life, uh, under the sea. Yes. To create programs against climate change. Yes. So these programs are value very, very valuable, uh, and you need to protect their sustainability and longevity.
Speaker 0 00:26:43 Yes. Very important points, because that of course, touches on the United Nations sustainable development goals, et cetera, and the enormous macroeconomic benefits that, uh, can be enjoyed by these countries. But I wanna take you up on two points, um, that I think are worth, uh, distilling a bit more. One is that a lot of the Caribbean governments, uh, contract the marketing and promotion of their programs to, uh, international representatives, marketing agents, and sometimes in this predatory industry, uh, lot of damage can be done in the type of marketing, um, which is almost out of control, um, at times because it contains a lot of misrepresentations. And I don't find that our Caribbean governments are monitoring or surveilling or supervising, uh, these international marketing agents sufficiently because they are in effect, sometimes doing some damage, um, to the sustainability and viability of these programs. And as much as we say that we are staunch defenders of our sovereignty, uh, the reality is Bruno, that as small islands, uh, underdeveloped developing states, if the international community says it doesn't want an offshore, uh, jurisdiction existing, it'll pass the legislation that has us almost obsolete, that we are forced to repeal the legislation that allows offshore finance, uh, to take place.
Speaker 0 00:28:15 So in some circles, it may be felt that recent announcements are heading in the direction of wanting to shut down these programs, and that is why I am delighted to hear you speak, uh, to the overall economic and social benefits that they can bring, uh, to the country. But do you think that governments have more of a role to play, um, in, in monitoring what is put out there by the marketing agents in the international community?
Speaker 3 00:28:44 I think it's not an industry, which is by all means perfect, but neither is banking, is cryptocurrency, <inaudible>, you know, you know, neither is industry, whether it's agriculture or, you know, turning metals into, uh, homeware products. Uh, what we do know is that there are benefits to host countries and wider society, uh, from meaningful financial contributions to that society and to that culture. Um, and it's critical in funding key government activities such as disaster relief and social programs. We also know that there are many benefits to individuals that use investment migration to start new businesses in their chosen jurisdiction to benefit from greater mobility or simply to live, uh, in a country. So there is a lot of positive impact that is investment and development, finance and driving local economies. And this is me saying this, this is research that's been uptake, uh, undertaken by, uh, the International Monetary Fund, uh, uh, the European Parliamentary Research Service, uh, and of course the very good investment migration research papers.
Speaker 3 00:29:54 What I do think, though, is coming back to your, to your first, uh, comment in, in that governments or some governments are outsourcing the totality of promotion of, uh, programs, uh, all over the world and putting all their eggs in one basket. Yes. Um, I think that was probably suitable as the programs were being launched, and it was the right fit for Caribbean countries that were new to this industry. So you would, uh, like any industry, you import the talents if you don't know how to do it yourself. Yes. But I think at this point, with many of the programs, you know, have been, you know, going on for 7, 8, 9, 10 years, um, I think back now, um, local grenadians, um, are very well equipped, have the intellectual capacity, have the education, the training, and the experience to run the programs 100% themselves, including proper oversight on third parties, which essentially are acting as ambassadors to the country and to put marketing and sales standards.
Speaker 3 00:31:15 We've done some work on this. We've publicly made available a report, uh, uh, and a code of marketing and sales promotion standards for governments and for third country, uh, uh, agents to abide by. Um, so all our members are abiding by these different codes. Um, and that is one of those, so it's not a perfect industry. Uh, I've said it before. Yes. The importance of improving standards, uh, is that it should definitely be on the top of the list for these programs to be, uh, sustainable. Uh, but by implementing improved standards and regulation of the sector, we can ensure that the benefits of investment migration are retained whilst minimizing the risks of abuse. Now, there's always abuse, no matter, you know, sort of what area of business you are. I don't think investment migration has more abuse than banking, uh, for example, uh, it's just that because it is migration, it's very interesting for the media because they love migration stories Yes.
Speaker 3 00:32:30 Salacious stories, and it's very <laugh>. Absolutely. They, you know, they make good reading for 24 hours. Yep. Um, when banking stories are really not interesting that much, because there's really essentially no human element to most of the banking stories you hear about when migration stories have a human element, uh, to them. So there is, there is, I think, you know, some abuse since I've been, you know, in this business I've seen less and less of it, which is great. Um, the sector, it does face concerns around issues of due diligence, transparency, uh, and illegal activities, uh, which can occur when it is abused. Um, and, but these abuses based stem from a lack of common standards and regulation, uh, and they can be changed. Uh, the IMC stands ready to assist governments, uh, that want to make, uh, those improvements. Uh, and I truly believe, uh, that investment migration, uh, can be here to stay if there is this common approach, uh, to due diligence, uh, standard, better risk management and oversight, uh, and transparency and information sharing mechanisms.
Speaker 0 00:33:52 Yes. That, that's a great segue into the final question. Um, and that is, will these Caribbean citizenship by investment programs survive, uh, the new challenges based on, on recent trends that we've discussed? Can it survive?
Speaker 3 00:34:10 It's a very difficult question to answer, really. I, uh, I'm not, uh, I'm not a politician, so you need to have that will, uh, of the politics, uh, of it. Uh, we've seen programs close overnight because there's been a general election. Uh, we've seen programs open because, again, because there's a, an election, an incoming government is supportive and outgoing, wasn't supportive, and vice versa, uh, we've seen a lot more work being done, uh, in the policy circle. So regulation, um, which we support, uh, is in the pipeline for, for residency programs and countries in the Caribbean will need to be geared up and ready and invest in public affairs work, which it hasn't had to do in the past to ensure the sustainability of the programs. So there are areas where, uh, O E C S countries can and should work together whilst at the same time competing on the stage for the same clients.
Speaker 3 00:35:15 Yes. Uh, and I think that is when you start separating the adults from the children, uh, in the room. So whether or not the programs can continue to operate, I think, you know, we will see change. Definitely. Programs will come, programs will go. The fact is though, with 300 million migrants roaming around the world, uh, it's impossible to stop. Um, globalization, uh, where we are today, we've come out of a pandemic, uh, of two and a half years. And frankly, people just want to start traveling, uh, again, for the most part. Uh, and they want to move country. I speak regularly to people say, Hey, you know, I'm interested, um, to spend a year or two in Libon in Portugal, um, or I've spent six months in Antigua. I want to go down to Panama and spend six months there. Yes. They also have a whole new generation, uh, of younger, uh, people, uh, that now see themselves as more highly mobile than their parents' generation. Uh, and you know, these people are in their twenties to late, well, let's say in their twenties, early, early to late twenties. So you're seeing that shift. So the, the demand will continue to be there. It's now for governments to adapt their citizenship and residency products to meet that demand and also, uh, to ensure that they, um, they structure them in a manner which is acceptable to, uh, supernational bodies, uh, whose interest is security, money laundering and financing of terrorism and so forth. Yes. So I'm quite upbeat for the Caribbean.
Speaker 0 00:36:55 Good. I'm glad that we can end on an optimistic note. Bruno, thank you so much. Thank you for the work that the Investment Migration Council does. Um, and thank you for the attention that you pay to the Caribbean. I am sure that we'll be the better for it. Thanks again for your time today.
Speaker 3 00:37:14 Thank you so much.
Speaker 0 00:37:19 Thank you again so much, Bruno. I think this was such a timely discussion, taking into consideration how quickly developments are taking place in the investment migration space and the many discussions that are being held as we speak at the levels of governments in the region. It's been great hearing from you, giving your broad base perspective on the topic and your council's leading role. I hope everyone involved in the C B I space gets an opportunity to hear your views and outlook on this issue. Thank you. I believe this was so necessary. Thank you for being with us on the C on 180 podcast. This is season four, and we continue to learn from our community of professionals who graced our platform. Don't forget to hit us up on social media platforms. We do love hearing from you all. Tune in again next Sunday for another episode, or check us out anytime on YouTube and on c on one eighty.com for all current and past episodes. This is C on 180. Be safe, everybody.
