Pastizzi from Serkin, Red Bull from Havana: the 'genuine links' of the IIP

Receipts for Pastizzi from Rabat’s famous Crystal Palace Bar and for a Red Bull from a nightclub in Paceville were amongst the so-called “genuine links” presented by IIP candidates in order to prove the ties they had developed to Malta as they sought to get their hands on a passport. 

Applicants for the Individual Investor Programm – Malta’s €1.15 million cash-for-passports scheme for the global rich – allowed them to spend just an average of 16 days in Malta out of their supposed 12-month residency period. The system was put in place by Henley & Partners, the IIP’s ‘concessionaire’ and the government agency Identity Malta, which effectively reduced the residency process to a box-ticking and score-granting exercise, documents revealed in the Passport Papers show. 

A scoreboard was drawn up through which authorities could determine whether an applicant had established what they called “genuine links” to the island – with different things, such as the purchase or rent of property, the purchase or renting of a vehicle, a donation to a local charity, membership in a local club or organisation, the creation of a bank account, were given different point scores. 

An applicant then had to aim to overtake a certain threshold score. 

Henley & Partners would advise their clients as to how they could reach the score, especially if they have spent not nearly enough time in Malta (days spent in the country granted one points as well). 

Identity Malta however advised Henley not to simply stick to the minimum. “Please advise your clients to avoid going by the absolute bare minimum initiatives as this could give rise to difficulties if seen by the regulator,” an Identity Malta official told Henley & Partners in August 2015. 

A month later, another official advised “to stop looking at the barest minimum” when a Henley client representative asked for help on how many genuine links were needed to satisfy the regulator given that her client had not spent a lot of time in Malta. 

It is perhaps this desire by Identity Malta to see comprehensive evidence of these so-called links to Malta that led to some candidates providing anything and everything in an effort to prove their ties to Malta. 

The most common “genuine links” presented by applicants are without doubt flight tickets – be they airlines or by private jet – and hotel bookings. Most applicants stayed in high-end hotels such as the Westin Dragonara, the Intercontinental, and the Excelsior – rather than in the property that they were renting on the island during their residency period. 

The private jet receipt presented by Saudi princes Khaled Bin Fahad and his son Bandar

The Malta Independent and MaltaToday have already exposed how many applicants would rent a lacklustre property at the barest minimum of prices in order to satisfy the residency requirement, and then not spend a single day living in it. 

A number of applicants then donated between €5,000 and €10,000 to different local charities – with Puttinu Cares, Dar tal-Providenza, and the Malta Community Chest Fund proving to be the most popular – having been recommended to clients by Henley in the first place. 

Some also took out membership at gyms – normally the gym of the hotel that they would be staying it – while others became members of an organisation such as Marsa Sports Club or the Malta Society of Arts. 

This is where the links start to get tenuous at best: a number of clients took to scanning and sending every single receipt of their stay in Malta. 

Amongst documents seen by this newsroom in clients’ genuine links folders, one can find receipts from restaurants or cafes, from supermarkets, museum tickets, and receipts for taxis as well.   

Receipts for expensive purchases were also included. One applicant spent €6,000 at Sterling Jewellers, while another spent €4,000 at the same shop. Someone else spent €800 at the Loft interiors shop, while another applicant spent €1,761 at a restaurant in Pietà – €1,550 of which was on two bottles of wine. 

One particular applicant sent in a 37-page document of receipts for things ranging from purchases from the duty free at Rome’s Fiumicino airport, to museum tickets, to receipts for a toothpaste purchase and even a receipt for an ice-cream. 

Another applicant arranged a host of bus tickets onto a piece of paper and scanned them to include in her pack of evidence, while two more applicants included a traffic fine as evidence of their ties to the island as well (one fine was for parking on a single yellow line and the other was for parking too close to a corner). 

A police contravention for parking on a single yellow line was found in one applicant's 'links to Malta' folder

Cinema tickets were also included by some applicants as evidence of their links to the island.  One particular folder contained a receipt for a massage (with extra oil) as well. 

Several cinema tickets were used as proof of a genuine link to Malta

Another applicant included two receipts for pastries and drinks from Rabat’s Crystal Palace Bar (better known as is-Serkin) while another including a receipt for a €3.90 can of Red Bull from the Havana nightclub in Paceville. 

As Maltese as it gets: some applicants presented receipts from the Crystal Palace 'Serkin' bar to substantiate their IIP application

A grocery receipt – for a loaf of bread, a one-litre carton of milk, and two cans of baked beans – was also included in one of the folders, as was a slip of paper showing a failed withdrawal from a Bank of Valletta ATM in another client folder. 

In all of the above cases, the links presented were felt to be genuine enough for Identity Malta to accept. 

There were several more well-intentioned examples presented as links.  A number of applicants presented certificates of them and their children having completed English languages courses on the island, while one applicant even presented an Agenda bookshop receipt for the purchase of some Maltese grammar books. 

One applicant – Vadim Vasilyev, who was CEO of French football giants AS Monaco at the time – personally visited the Dar Sagra Familja in Zabbar and donated €15,000 to the home for the repair of the roof of its playroom besides also presenting some AS Monaco football kits – much to the delight of the nun who runs the house, who then wrote to Vasilyev to express her thanks.  

Likewise, Vasilyev met with an amateur football team and their squad, also presenting them with some AS Monaco memorabilia. 

Another applicant sponsored the Russian translation of Trevor Zahra’s ‘The Secret Life of Grandmother Genoveffa’, which actually became the first Maltese novel translated into Russian. 

Such exceptional examples however were few and far between. 

With the first round of the IIP concluded, the government is now planning a second round with slightly altered requirements, including what they described as an added emphasis on building links between applicants and the community. 

On his part, former Identity Malta CEO and current Komunità Malta CEO Jonathan Cardona – who was Henley’s main contact at the regulator for IIP-related matters – said that “physical presence, in contrast with legal residence, is not a precondition to acquire nationality in Malta nor in any other EU member state." 

Komunità Malta – which has replaced Identity Malta as the agency for the IIP, now simply dubbed citizenship by investment – on their part said that the genuine links scoring system was a management tool created by them and Henley “to ensure common standard practices in a fair and consistent way.” 

In a reply sent to a raft of questions from the collaboration, Henley said they are “fully aware of the potential inherent risks in handling client applications for residence and citizenship and have invested significant time and capital in recent years to create a governance structure that is committed to the highest of standards, with due diligence at its heart.” 

“However, ultimately it is the responsibility of the countries involved to investigate and vet applicants”, they said. 

Reporting by Nicole Meilak from MaltaToday & Albert Galea from the Malta Independent

This is a joint investigation by The Malta Independent, MaltaToday, and other partners, coordinated by the Daphne Caruana Galizia Foundation. The production of this investigation was supported by a grant from the Investigative Journalism for Europe (IJ4EU) fund.