Citizenship by Investment Program in Montenegro will be full in place by 2020

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Dejan Medojević, Head of Montenegro’s Secretariat for Development Projects, has said that applications for the country’s Citizenship by Investment Program (CIP) expect to be received by the end of 2019 and that the full program will be in place by next year.

The roadmap was revealed during an interview with Dnevne Novine Daily where Medojević commented that the program was not to do with the usual sale of passports “but rather an important development project for Montenegro.”

Medojević explained the multi-tier approach to vetting applications where they would all undergo checks with the intermediary agents, international due diligence firms, auditors and the Ministry of Internal Affairs in that order.

Medojević states that “the final controls are to be taken by the Ministry of Internal Affairs and the National Security Agency.”

The much-awaited Montenegro CIP has been subject to several delays since 2017 when the government prohibited bids from two different consortia to design and implement the program after finally opting to develop the program without relying on a concessionaire.

The same Secretariat announced in September 2018 that the program would have “all the tools and mechanisms necessary for effective activity” by the beginning of November that year, an outlook that has now changed considerably.  

A further setback occurred when the committee charged with selecting due diligence providers discarded all 13 applications for the contract, allegedly because all failed to comply with the requirements. The Secretariat has re-issued a call for due diligence partners, and a new application deadline is set for 1st April. 

From 26th February, the Secretariat has also requested applications from real estate developers looking to have their projects approved as a qualifying option for the CIP.

The government announced on 13th March that it had selected only Henley & Partners, Arton Capital, and Apex Capital from a pool of around 12 companies which had applied to become accredited intermediaries for the CIP.

Before the launch, the government must still select providers of international due diligence, which is likely to happen in late April or May. The decision must further approve CBI-qualifying property developments as, according to the program requirements, real estate is the only sanctioned asset class.

Industry observers have also noted the potential barriers presented by the wording in the Citizenship Act, which seems to provide no legal basis for the naturalisaton of the dependents of the CIP-investors. This is a challenge that will need to be addressed before agents can confidently submit their applications.

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