How to become authorized agent for Moldova CBI scheme?

The Moldova Government has published conditions for becoming authorized agent for citizenship by investment program of Moldova (MCBI). Agents with successful applications will receive EUR 10,000 as commissions

In accordance with the Government Decision No. 786 of October 4, 2017 on obtaining citizenship by investment, in order to qualify to receive a fee on the submission of successful applications, such applications must be submitted by and registered to an accredited agent (“Agent”).

In order to apply to become an Agent, applicants are required to provide information regarding:

• (a) the legal entity or the local jurisdictional equivalent (e.g. lawyer) conducting entrepreneurial or professional activity in the Republic of Moldova (“Company”); and
• (b)  the directors and ultimate beneficial owners (“UBO”) of the Company;

And if applicable;

• c) the international holding company of the Company; and
• d) the directors and UBO’s of the international holding company.

For the purpose of this application, persons described as (b) and (d) above shall be considered “Principals”.

Applications may also be submitted by companies, which have not yet established as a Company in the Republic of Moldova. However, once approved, supporting documentation is required within thirty (30) days to demonstrate the establishment of a local entity. Applications must be accompanied by no less than the information regarding (c) and (d) for applicants that have not yet incorporated a local company.

Eligibility Criteria

In order to qualify to become an Agent, the company and its principal(s) must demonstrate that they:

1. Are:
   1. a)  a member in good standing of an investment migration industry association, namely:
      1. Investment Migration Council;
      2. Registered Immigration Advisor OISC (Office of the Immigration ServicesCommissioner, UK);
      3. Immigration Consultants of Canada Regulatory Council;
      4. any other recognized and approved organization by the Commission forexamining the file for obtaining citizenship by participating in the investment

         program in the Republic of Moldova; or

   2. b)  practicing the profession of lawyer with a high reputation.
2. Have established, or will establish within thirty (30) days of the date of approval, a Company in the Republic of Moldova (including local bank accounts for the purpose of remitting and receiving funds);
3. Have a suitable website;
4. Have an internal compliance capacity capable of conducting suitable due diligence checks on prospective applicants;
5. Have professional indemnity insurance coverage in the minimum sum of EUR 500,000;
6. Have provided proof of payment of the application fees (see Section 4.1.); and
7. Have successfully passed the personal and company due diligence checks (must be withoutcriminal or civil convictions, be of good character, and not under investigation).

An applicant shall not be qualified to be an Agent if a Principal of the company:

1. Is a Politically Exposed Person (“PEP”) or a spouse, partner, or child of a PEP;
2. Is a member of the Secretariat or the Commission or a spouse, partner, or child of a member ofthe Secretariat or the Commission;
3. Has been convicted or is under investigation for any criminal offences of any civil or criminaloffence;

4. Is bankrupt, has a company in receivership, or has made arrangements with creditors; or
5. Has previously had an Agent’s accreditation revoked.

Agent can be revoked

An Agent’s accreditation shall be revoked if:

1. The ability, resources, experience or integrity of the Agent has fallen below the standard that might reasonably be expected;
2. The annual fee remains unpaid for fourteen (14) days after it has become due; or
3. The Agent no longer maintains and operates a Company in the Republic of Moldova.

Agents will have their accreditation reviewed on an annual basis.

An Agent who no longer meets the accreditation requirements will have their accreditation revoked. Supporting documentation for a renewal application will be published in due course.

Application and Renewal Fees

The application fee is EUR 15,000 per calendar year (starting in January). The fee for months prior to January will be calculated pro-rata.

As illustration of the above, applications submitted in November 2018 will require an application fee of EUR 2,500 + EUR 15,000 = EUR 17,500, and will become renewable in January 2020

Application fees and renewal fees are payable to the Secretariat of the Commission on a non- refundable basis. The fees are required to support the due diligence examination, and processing of the Agent application.

Once the decree of citizenship has been signed, and the funds have been released from the Escrow account, the Secretariat will request the Agent to submit an invoice for the outstanding Agent Fees.

Agents will receive EUR 10,000 per successful application.