In response to recent events, the United States, European Union and United Kingdom, among others, have imposed a broad range of sanctions targeted at Russian entities. Separately, the United States and the European Union have expressed the intent to curtail  their own “golden passport” schemes.

In a joint statement the European Commission and the White House said, “we commit to taking measures to limit the sale of citizenship—so called golden passports—that let wealthy Russians connected to the Russian government become citizens of our countries and gain access to our financial systems.

As of 4 pm on 17 February 2022, the United Kingdom has stopped accepting new applications under its own CBI programme.  

While those appear to only be limited to oligarchs and “Russians connected to the Russian government”, EU Member States such as Portugal and Greece may be going beyond this range of persons.

According to media publications in Portugal, the country’s Foreign Affairs Minister, Mr Silva has stated that Portugal’s Borders and Immigration Service (SEF) has suspended the assessment of golden visa applications for Russian citizens. This would appear to limit future applicants, but it is unclear if this would affect those who already hold such visas.

The Greek Ministry of Migration and Asylum stated they would temporarily suspend the issuance and renewal of residence permits for investors who are citizens of the Russian Federation regardless of whether they are on the sanctions’ list or not.

In addition, Reuters reported that while the Maltese Prime Minister Robert Abela initially resisted calls to limit applications from Russia and its ally Belarus following the invasion of Ukraine, the Agency responsible for processing requests said the scheme was suspended for Russians and Belarusians because “recent developments” meant the necessary due diligence could not be performed satisfactorily.

Unresolved questions abound: will these steps affect persons of Russian origin who are not Russian citizens; persons who have dual citizenship of Russia and other countries (including eg, Ukraine), and whether the policy change would affect other nationals as part of a broader turning of political and public opinion.  wh

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