# Appendix I — Suitability and Decline Matrix This appendix is the working form of the suitability assessment set out in Chapter 13, with the decline grounds of §13.14 and the confirmations of §20.6 set out as a checklist. It introduces no criterion that does not appear in the body of the report, and each line carries the section from which it derives. It is used in the order set out below: Part 1 profiles the client against each characteristic and records which of the four verdicts the characteristic supports; Part 2 applies the nationality gate, which is decisive and is taken first in practice (§13.2); Part 3 is read last and is dispositive — a single entry in Part 3 displaces any number of favourable entries in Parts 1 and 2. Where a verdict differs between rows, the assessment does not average them: the narrower verdict governs, and the reason is recorded. Every entry states the position as at 2 August 2026 and requires confirmation at the date of application. Kestrel Private coordinates; regulated professionals in each jurisdiction advise; the decision to admit any applicant rests with the governments of São Tomé and Príncipe and of Greece (§18.9). --- ## Part 1 — Client-profile matrix | Client characteristic | Full structure may be suitable | Residence component only | Citizenship component only | Not suitable | |---|---|---|---|---| | **Existing nationality and its position on dual citizenship** (§13.2, §13.11) | Home law permits acquisition of a second citizenship without loss, and the São Toméan cap is not engaged: nationality may not be granted to a person already holding more than two foreign nationalities (Lei n.º 7/2022, Art. 11) | Home law extinguishes the existing citizenship on voluntary acquisition of another, so the citizenship component is treated as unavailable (§13.2, §13.12) | Home law permits a second citizenship and the client has no European requirement now or foreseeably (§13.13) | Acquisition would extinguish a citizenship the client intends to keep and no residence-only objective exists; or the client already holds two foreign nationalities in addition to the original (§13.14) | | **Schengen position of the existing passport** (§13.2, §13.4) | Annex I passport (Regulation (EU) 2018/1806): short-stay mobility arises from the Greek permit under Art. 21 of the Convention Implementing the Schengen Agreement, never from the São Tomé passport, which is itself Annex I | Annex I passport where the citizenship component is unavailable; the mobility objective is served by the permit alone | Annex II passport (United Kingdom, United States, Israel, UAE nationals): neither component adds mobility, and the case must rest on contingency and succession objectives or fail (§13.13) | The mobility required is EU-wide residence or employment, or more than 90 days in any 180 outside Greece — rights no component confers (§13.4, §19.8) | | **Objective** (§13.1, §13.11, §20.5) | An additional non-European nationality held for contingency and diversification, a renewable European residence position, short-stay Schengen mobility through it, a European property asset, and family inclusion within the applicable definitions | European foothold, short-stay mobility and a European asset, with the second nationality unavailable or without articulated purpose | Contingency, consular diversification and family planning, with no European base wanted and no €250,000 property commitment prudent (§6.13) | EU citizenship, European employment, EU-wide establishment, or a guaranteed financial, banking or tax outcome (§13.14, §20.1) | | **Family composition and succession objectives** (§13.3, §11.9, §16.7) | Each member maps to both definitions: Greek Art. 95 §2 (spouse or cohabitation-agreement partner, unmarried children under 21, direct ascendants of the spouses or partners, adult children lacking legal capacity) and the São Toméan decree (spouse and children, the spouse qualifying only on a marriage of more than five years under the regime of community of acquired property (*comunhão de bens adquiridos*), cumulatively, or a court-recognised de facto union of more than three years) | Family members qualify under Art. 95 §2 but not under the decree — recently married spouses and dependent parents are the recurring mismatches (§13.3) | The family objective is a non-European fallback for the spouse and children within the decree's definitions, with no European base | The plan depends on the administering unit's published extended categories (children up to 30, parents and grandparents aged 55 and over), for which no statutory basis is visible in either gazetted text, or on adult dependent children affected by the passport-issuance hold reported from April 2026 — both requiring confirmation at the date of application (§13.3, §20.6) | | **Time horizon** (§13.5) | The family can hold the qualifying property for at least the first five-year permit term and for as long as the European position is wanted; the permit is renewable for equal periods only while the property remains in the holder's ownership and possession | As for the full structure: the property-holding horizon is the European-access horizon | No property horizon arises; the contribution is payable only after approval and is non-refundable (Decree-Law 07/2025, Art. 14) | The horizon is shorter than the first permit term, or the client expects to realise the property within it — disposal during the permit's validity revokes the permit (§7.12) | | **Liquidity** (§13.5, §12.10) | Liquidity needs do not depend on the property: there is no early exit that preserves the permit, a long let carries a mandatory minimum three-year term, and no official time-on-market statistics are published | As for the full structure | The contribution is spent capital and no liquidity expectation attaches to it | The client requires access to the €250,000, or income certainty from it, within the permit term (§13.14, §20.6) | | **Risk tolerance** (§13.6, §12.9) | The client has read the §12.9 downside — including the step in which selling to cut losses also ends the residence position — and can absorb it without the family's finances or plans becoming distressed | The same test, confined to the Greek-side programme, decision, post-approval, market, currency and liquidity risks | Programme-maturity, decision and post-approval risk only: independent due diligence, the Public Prosecutor's prior visto, the six-month judicial-opposition window and revocation as a defined sanction (§6.12) | The client cannot tolerate programme, property or liquidity risk as concretely described in §13.6 and Chapter 12 | | **Tax-residence intention** (§13.8, §9.6–§9.8) | No relocation intended: the permit does not create tax residence, and a holder below the reported thresholds who keeps the centre of vital interests abroad is normally taxable in Greece on Greek-source income only — subject to confirmation at the date of application | As for the full structure; where relocation is contemplated, regulated Greek and home-country advice is required before acquisition, and the Art. 5A regime is elective, conditional and requires a qualifying investment of at least €500,000 | The passport confers no tax status; reporting under the Common Reporting Standard is keyed to tax residence, not citizenship | The client believes the structure itself delivers a tax status, or requires a guaranteed tax outcome (§13.14) | | **Banking need** (§13.9, §9.4–§9.5) | The client understands that an application is not an approval, that enhanced due diligence is prescribed as a minimum for investor-residence applicants from 10 July 2027, and that the right to a basic payment account extends to consumers legally resident in the Union subject to the directive's conditions | As for the full structure | No Greek account arises from the citizenship component; institutions establish all nationalities and passports held at onboarding, and the passport conceals nothing | The client's interest in the structure is a changed banking identity — this describes misuse and the engagement ends there (§13.9) | | **Property-investment expectations** (§13.7, §8.15) | The property is assessed twice and passes the property-without-immigration test; the client accepts floor pricing, the exclusion of short-term letting for this category, an indicative long-let planning band of the order of 4–5% gross before costs, taxes and voids, and the zero-growth case | As for the full structure | No property component is instructed | The client requires guaranteed rental income, guaranteed appreciation or an assured recovery of the €250,000 (§13.7, §13.14) | | **Source-of-funds readiness** (§13.10, §15.14) | Source of wealth can be explained and evidenced, the specific funds traced through documented channels, the narrative consistent with tax filings, and screening outcomes clean or conclusively resolvable | The same standard, undiminished | The same standard: the decree requires a declaration of lawful origin of funds with supporting bank documentation and an independent due-diligence report (Anexo III) | The file cannot be brought to that standard; where the defect is curable with time and documentation the correct outcome is deferral, not decline (§15.14) | *Table I.1 — Client-profile matrix. Rows are the client characteristics assessed in Chapter 13; columns are the four verdicts available under §13.11, §13.12, §13.13 and §13.14. Assumptions: a private individual or family, national of a non-EU state, on the illustrative single-applicant reference case of approximately €375,000 (§10.14, §20.2), with all positions stated as at 2 August 2026 and each requiring confirmation at the date of application. The residence-only and citizenship-only columns are assessment outcomes on the client's own legal position and objectives, not competing routes; where both components are available they are complementary parts of one coordinated position (§5.7, §13.11). Row count: 11. Derived from §13.1–§13.14, §20.5 and §20.6.* --- ## Part 2 — Nationality gate Two São Tomé-side rules apply to every row before the table is read. Under Article 11 of Lei n.º 7/2022, nationality may not be granted to a person who already holds more than two foreign nationalities, and a naturalised citizen who later acquires a fourth nationality loses São Toméan nationality by operation of law. The administering unit is reported to have placed acceptance of applications from individuals holding three or more foreign nationalities on hold from 10 April 2026, invoking that cap; the position requires confirmation at the date of application (§13.2, §20.6). | Nationality | Citizenship component legally available | Schengen position of the existing passport | Principal funding or exchange-control constraint | Resulting recommendation | |---|---|---|---|---| | South Africa | Yes. Section 6(1)(a) of the Citizenship Act 88 of 1995 was declared invalid from its promulgation by the Constitutional Court on 6 May 2025; no prior permission is required | Annex I — visa required | R2 million single discretionary allowance (Exchange Control Circular No. 6/2026, from 8 April 2026) plus R10 million foreign capital allowance per individual per calendar year, the latter against a SARS Tax Compliance Status verification | Both components may be instructed; the primary-market case. The Greek permit, not the passport, carries the mobility; the citizenship component's value is contingency and diversification (§13.2) | | United Kingdom | Yes; no application or permission required | Annex II — visa-exempt, up to 90 days in any 180-day period | No exchange-control constraint; standard source-of-funds evidence | Both components may be instructed, but the citizenship component's value is contingency only and must be tested against §13.14(9). Not to be presented as a tax solution (§13.8) | | United States | Yes; intent to retain US citizenship is presumed | Annex II — visa-exempt | No exchange-control constraint; US taxation of worldwide income and US reporting continue unchanged | Both components may be instructed; the structure adds US reporting surface and US tax advice is required at engagement (§13.2) | | India | **No.** Under section 9(1) of the Citizenship Act 1955 citizenship ceases automatically on voluntary acquisition of another citizenship; the passport must then be surrendered, and Overseas Citizen of India registration is a lifelong visa and residence status, not citizenship | Annex I — visa required | Outward-remittance ceilings under the Liberalised Remittance Scheme require confirmation at the date of application | Residence component only (§13.2, §13.12) | | China (PRC) | **No.** Dual nationality is not recognised, and a national settled abroad who voluntarily acquires a foreign nationality automatically loses Chinese nationality | Annex I — visa required | US$50,000 individual annual foreign-exchange quota; reported further restrictions on the use of the quota require confirmation | Generally unsuitable absent specific facts — lawfully established offshore capital, another nationality or another residence, evidenced rather than assumed. The assessment should say so at the first conversation (§13.2) | | Nigeria | Yes for citizens by birth; citizens otherwise than by birth forfeit on acquiring a foreign nationality (Constitution 1999, s. 28(1)) | Annex I — visa required | Reported exchange-control scarcity at official windows; funding typically from existing offshore assets | Both components for citizens by birth, with the whole weight of the assessment on source-of-funds evidence for the offshore assets (§13.2, §13.10) | | Türkiye | Yes. Law No. 5901 contains no automatic-loss rule; multiple citizenship is annotated in the family registry | Annex I — visa required | Standard source-of-funds evidence; no Türkiye-specific verified constraint | Both components. One mobility particular must be disclosed: the Greek permit does not open Cyprus, the Decision No 565/2014/EU concession excluding citizens of Türkiye (§13.2) | | Israel | Yes; acquiring a foreign nationality does not of itself cause loss | Annex II — visa-exempt | No verified constraint recorded | Both components available, but the citizenship component's value is contingency only and must be tested against §13.14(9) (§13.2) | | Pakistan | Generally no. A citizen simultaneously a citizen of another country ceases to be Pakistani unless the other status is renounced, and São Tomé and Príncipe is not among the 22 gazette-notified countries; the cessation rule is disapplied for persons under 21 and for a married female citizen of Pakistan | Annex I — visa required | No verified constraint recorded; standard source-of-funds evidence | Residence component only, save in the two statutory exceptions, where the position requires confirmation under Pakistani legal advice (§13.2) | | Bangladesh | **No.** Foreign naturalisation loses Bangladeshi citizenship, and the Dual Nationality Certificate route is confined to citizens of European, North American and specified Asian states, which São Tomé and Príncipe is not; a reported later expansion of the eligible list requires confirmation | Annex I — visa required | No verified constraint recorded; standard source-of-funds evidence | Residence component only (§13.2) | | Lebanon | Yes. Under Article 8 of Decree No. 15 of 19 January 1925 loss occurs only where the foreign nationality is acquired pursuant to an authorisation granted by the Head of State; acquisition without authorisation does not of itself cause loss | Annex I — visa required | No verified constraint recorded; standard source-of-funds evidence | Both components, subject to Lebanese legal confirmation of the client's own position (§13.2) | | Egypt | Qualified. Prior permission is required; without it the person continues to be regarded as Egyptian, and with it Egyptian nationality is forfeited unless the permission includes retention for the person, spouse and minor children, declared within one year | Annex I — visa required | No verified constraint recorded; standard source-of-funds evidence | Both components only where the permission-and-retention step is completed under Egyptian legal advice before the citizenship component is instructed; otherwise residence component only (§13.2, §13.14) | | United Arab Emirates (nationals) | Requires confirmation at the date of application; the outbound rule for an Emirati acquiring a foreign citizenship is not verified in this report | Annex II — visa-exempt | No verified constraint recorded | Neither component adds mobility. The citizenship component should not be instructed until the outbound rule is confirmed, and must then be tested against §13.14(9) (§13.2) | | Gulf-resident expatriates (any nationality) | Determined by the nationality held, not by the emirate of residence — a UAE residence visa confers no Schengen rights | Follows the nationality held | Typically funded from banked expatriate capital; standard evidence | The row of the client's own nationality applies. Indian, most Pakistani and Bangladeshi nationals take the residence-only outcome; Lebanese, Turkish, Nigerian-by-birth and Egyptian-with-permission nationals may take both (§13.2) | | Russia and Belarus | Not the operative constraint | Annex I — visa required | Article 5b of Regulation (EU) 833/2014 prohibits EU credit institutions from accepting deposits above €100,000 from Russian nationals or Russia residents absent EU nationality or an EU residence permit, so the €250,000 purchase cannot lawfully be routed in the ordinary way | Effectively excluded as at 2 August 2026: Greek issuance and renewal for Russian citizens was announced as suspended on 28 February 2022 and remains suspended in practice, the current status requiring confirmation. The assessment should state the exclusion at the outset (§13.2, §13.14) | *Table I.2 — Nationality gate. Nationality-law entries per the primary instruments named inline and cited in Chapter 13; Schengen entries per Regulation (EU) 2018/1806 (consolidated version of 30 December 2025), Annexes I and II. The funding column states the principal verified constraint only and is not exhaustive; the absence of a recorded constraint is not a finding that none exists. Row count: 15 (13 named nationalities, one residence-based class, one two-state exclusion). Every entry is stated as at 2 August 2026 and requires confirmation at the date of application. Derived from §13.2, §13.12 and §20.6.* --- ## Part 3 — Decline and deferral register The register reproduces §13.14 and the confirmations of §20.6, with the deferral standard of §15.14. Decline is recorded where the defect is structural; deferral where it is curable with time and documentation. A single entry displaces any number of favourable entries in Parts 1 and 2. A decline is not a failure of the engagement; it is the engagement working (§13.14). | No. | Circumstance | Outcome | Reason | Section | |---|---|---|---|---| | 1 | Source of wealth cannot be explained and evidenced | Defer where curable; decline where not | Source-of-funds readiness is the gate through which every other suitability finding passes | §13.14(1), §13.10, §15.2, §15.12, §15.14 | | 2 | The specific investment funds cannot be traced to their origin through documented channels | Defer where curable; decline where not | Both programmes are built on banking rails; wealth of any origin must arrive as documented fiat through regulated institutions | §13.14(2), §13.10, §15.2, §15.9 | | 3 | Tax filings conflict materially with the stated wealth history | Defer where reconcilable; decline where not | The narrative must be consistent with the client's filings before any application | §13.14(3), §15.13 | | 4 | Funds have passed through unexplained third parties | Defer where the chain can be documented; decline where not | Unexplained intermediation cannot be presented to independent due diligence or to a credit institution | §13.14(4), §15.8 | | 5 | Sanctions, criminal or material regulatory concerns cannot be resolved | Decline | An institution that cannot complete customer due diligence must refuse the relationship, and the same obligation applies under the EU Anti-Money-Laundering Regulation from 10 July 2027 | §13.14(5), §13.9, §15.11 | | 6 | The client is a Russian or Belarusian national | Decline | Greek issuance and renewal remain suspended in practice and the funding path is blocked by Art. 5b of Regulation (EU) 833/2014 absent EU nationality or residence; current status requires confirmation | §13.2, §13.14(5) | | 7 | The client expects guaranteed banking, immigration or tax outcomes | Decline | No such guarantee exists anywhere in the structure; a client who requires one has been sold a product that does not exist | §13.14(6), §18.10, §19.8, §20.6 | | 8 | The client requires immediate EU citizenship | Decline | Transactional investor citizenship in the EU has ended, and the structure is not, and must never be presented as, a substitute | §13.14(7), Chapter 2, §20.1 | | 9 | The client requires unrestricted EU-wide residence or employment | Decline | The permit establishes no right of access to employment and no residence outside Greece beyond the short-stay limits | §13.14(8), §13.4, §19.8 | | 10 | The second nationality would not provide a meaningful benefit | Decline the citizenship component | The contribution would be US$90,000 of spent capital serving no articulated purpose; where the European objectives are real, the residence-only variant may still be assessed on its own merits | §13.14(9), §13.12, §13.13, §6.13 | | 11 | The client's objective is a stronger travel document alone | Decline the citizenship component | Nationals of São Tomé and Príncipe are visa-required for the Schengen Area, and for holders of a strong existing passport the addition may deliver little or no mobility advantage | §20.6, §6.9, §6.14, §13.13 | | 12 | The client cannot tolerate programme, property or liquidity risk as concretely described | Decline | The operative test is the §12.9 downside read in full, including the step in which selling to cut losses also ends the residence position | §13.14(10), §13.6, Chapter 12 | | 13 | The client cannot tolerate illiquidity | Decline | There is no redemption date, no secondary market and no assurance of resale at any particular price or within any particular period | §20.6, §8.14, §12.10, §14.14 | | 14 | The total costs outweigh the practical value of the structure on this client's facts | Decline | Includes the case where family composition takes the true cost far beyond the single-applicant reference figure; where the objectives are met by a single component, the coordinated structure is not the correct instrument | §13.14(11), Chapters 10–11, §11.9, §20.6 | | 15 | Home nationality law would extinguish a citizenship the client intends to keep | Decline the citizenship component | India, China, most Pakistani and Bangladeshi cases, and Egypt without completed permission; the residence-only variant remains open on the ordinary conditions | §13.2, §13.12, §13.14 | | 16 | The client cannot lawfully fund the position from where the capital sits | Defer pending evidence of lawfully established offshore capital; decline where none exists | Mainland PRC nationals absent specific facts; unresolved exchange-control positions elsewhere | §13.2, §13.14 | | 17 | The client already holds two foreign nationalities in addition to the original, or intends to accumulate a further one | Decline the citizenship component | Nationality may not be granted above the Art. 11 cap, and a fourth nationality acquired later extinguishes São Toméan nationality by operation of law; the reported April 2026 application hold requires confirmation | §13.2, §13.12, §20.6, §6.3 | | 18 | The plan depends on dependants outside the statutory categories, or on adult dependent children affected by the reported passport-issuance hold | Defer pending confirmation | The administering unit's extended categories rest on administrative practice, not published law, and no family plan should be priced on them as if they were statutory; the position requires confirmation at the date of application | §13.3, §20.6, §11.5 | | 19 | A South African client's SARS affairs cannot support the Approval for International Transfers process | Defer | The binding constraint on the South African funding path is tax-compliance status, not quantum; the engagement should pause there | §13.2, §13.10, §15.14 | | 20 | The client's interest in the structure is a changed banking identity | Decline | A São Toméan passport conceals nothing from a financial institution, which is directed to establish all nationalities and passports held; this describes misuse and the engagement ends | §13.9 | | 21 | The client is unwilling to be documented to the prescribed enhanced due-diligence standard | Decline | Enhanced due diligence for investor-residence applicants becomes an EU-law minimum from 10 July 2027; a client unwilling to be documented to that standard is unsuitable now and will be more so later | §13.10, §13.9 | | 22 | The client is unwilling to be advised within professional boundaries | Decline | Kestrel Private coordinates, regulated professionals in each jurisdiction advise, and governments alone decide | §13.1, §18.9, §20.7 | *Table I.3 — Decline and deferral register. Items 1 to 5, 7 to 10, 12, 14, 15 and 16 reproduce §13.14 and its two closing grounds; items 6, 11, 13, 17 and 18 reproduce the confirmations of §20.6; items 19 to 22 reproduce the readiness and boundary conditions of §13.1, §13.2, §13.9 and §13.10. The decline/defer split follows §15.14: deferral where the defect is curable with time and documentation, decline where it is structural. Item count: 22, comprising 15 recorded as decline (items 5 to 15, 17, 20, 21, 22), two as defer (items 18, 19) and five as conditional — defer where the defect is curable, decline where it is not (items 1, 2, 3, 4, 16); 15 + 2 + 5 = 22. All entries state the position as at 2 August 2026 and require confirmation at the date of application. Derived from §13.1–§13.14, §15.14 and §20.6.*