I was asked by IMI Daily to provide commentary on an Al Jazeera investigation examining Cyprus’s Citizenship Investment Program (CIP) and allegations concerning corruption and the granting of citizenship to certain individuals.

The concerns raised by the investigation should not simply be dismissed. The Cyprus programme had weaknesses in its earlier years, particularly in relation to due diligence and the oversight of applicants. However, it is important to distinguish those historical shortcomings from the programme as it had evolved by August 2020.

The Cypriot government had acknowledged deficiencies in the earlier system and had introduced a series of measures intended to strengthen due diligence, transparency and continuing oversight. The programme had also recently undergone another substantial regulatory revision, with new regulations taking effect on August 18, 2020. These included stronger supervision of service providers, additional eligibility restrictions and other measures intended to reinforce the integrity of the programme.

For that reason, I regarded the Al Jazeera investigation as “neither fair nor helpful” when it presented historical shortcomings without sufficient recognition of the changes that had subsequently taken place.

This does not mean that the past should be ignored. Where previous applicants are subsequently found to have obtained citizenship improperly, the appropriate response must be lawful and properly investigated. Cyprus is an EU member state with established legal protections, and any action concerning citizenship must be undertaken in accordance with the rule of law.

At the same time, it is important to recognize what the programme had become. In my view, the Cyprus CIP was, by this stage, one of the more rigorous investment-migration programmes internationally. Significant resources had been devoted to due diligence and to improving the programme’s governance and credibility.

This matters because the CIP was not simply an immigration product. It had become an important source of foreign investment for Cyprus and provided an opportunity for international investors and their families to establish a connection with the country.

Our firm’s involvement in the programme provides an opportunity to participate in that process and, more importantly, to provide investors with a legitimate and structured route into Cyprus. For us, the programme represents opportunity and hope for families seeking greater security, mobility and a future in Europe.

The broader lesson is that investment-migration programmes should be judged not only by their past mistakes, but also by the effectiveness of the reforms introduced to correct them. The appropriate response to deficiencies is stronger regulation, better due diligence and effective oversight - not the assumption that an entire programme remains defined by its earlier weaknesses.

Cyprus had recognized the problems and was taking steps to address them. The challenge was to ensure that those reforms were implemented consistently and that the programme’s future credibility was protected.