<!-- Appendix K — from "After the EU's Golden Passports", Kestrel Private, 6 August 2026. Canonical: https://kestrelprivate.com/research/after-the-golden-passports -->

# Appendix K — Risk Register

This appendix restates Chapter 14 in register form, for an engagement file. It introduces no risk that is not already established in the body of the report, and every row carries the section from which it derives, so that any entry can be read back to its analysis and, through it, to the instrument or dated source on which the analysis rests. It is used as a working document: each row is tested against the client's own facts at engagement, closed in writing where a mitigation is adopted, and re-tested against the schedules, statutes and administrative records in force at the date of application, because several rows below turn on positions that require confirmation at that date. The register is not ranked by probability. No probability can be evidenced for a legislative change, an administrative refusal or a bank's onboarding decision, and none is asserted here. Statements of current status are made as at 2 August 2026.

## K.1 How to read the register

**Who bears it.** In this structure the risk is borne by the client in every row. Where a risk falls on the family as a whole, or on the owner in the owner's capacity, the column says so; the client bears it in all cases, and no row transfers exposure to any adviser, operator or administration.

**Residual rating.** The rating expresses the exposure that remains after the available mitigation has been taken, not the likelihood of the event. Four values are used and no others:

- **Low** — the residual exposure is bounded, knowable in advance, and within the client's control or capable of being quoted, calendared or closed contractually.
- **Moderate** — mitigation reduces the exposure materially but part of it remains outside the client's control.
- **High** — mitigation does not reach the substance of the exposure, which may be material to the position.
- **Not quantifiable** — the report declines to characterise the residual exposure, because the governing practice, instrument or third-party judgement is unpublished, unsettled or unknowable at the date of this report. It is not a synonym for small.

**Qualified positions.** Where the body of the report carries a qualification — reported rather than primary-verified, or requiring confirmation at the date of application — the register carries the same qualification in the same words. No qualified statement is promoted here into a bare one.

## K.2 Programme and legislative risk

| Ref | Risk | Description | Borne by | Drivers and evidence | Mitigation available | Residual — what cannot be mitigated | Rating | § |
|---|---|---|---|---|---|---|---|---|
| K-01 | Greek programme change or category closure | The €250,000 change-of-use category may be narrowed, repriced or withdrawn by statute or by administrative specification | The client | Three threshold regimes in three years (Art. 91 L.5007/2022; Art. 64 L.5100/2024); the category's operative conditions sit partly in the administrative record, last updated 31 July 2026; Spain ended its programme on 3 April 2025 and Portugal removed real estate in 2023 (reported) | Complete and file before an announced change; rely on the grandfathering in Art. 64 §3 L.5100/2024 for a permit already granted | Legislative sovereignty. Grandfathering protects an existing permit, not the value of the property supporting it, and does nothing for an application not yet filed | High | §14.1, §7.14, §20.4 |
| K-02 | Greek threshold and fee increases | The programme continues on different terms: investment threshold, permit fee, family fees or card charge raised by statute | The client | Table 14.1 threshold history; transitional windows measured in months; €2,000 permit fee, €150/€450 family fees and €16 card charge set by L.5038/2023 Art. 171 | Recompute the cost model against the schedules in force at the date of application; minimise the interval between engagement and filing | No private arrangement fixes a sovereign fee schedule or threshold | High | §14.2, §10.1 |
| K-03 | Greek administrative reinterpretation | What qualifies is restated administratively after the client has bought and paid | The client | Circular 1/2026 (21 April 2026, reported) barred re-cycled residential use and paper-only conversions two years after the category opened; JMD 214926/2025 fixes the evidentiary date while the circular polices substance | Satisfy both the ministerial decision and the circular; treat a file that satisfies only the documentary test as exposed | Interpretation may change again after purchase, and the whole price is paid before the application | High | §14.3, §8.5 |
| K-04 | São Tomé programme discontinuation or revision | The citizenship framework may be amended or ended by the same means that created it | The client | Decree-Law 07/2025 entered into force on publication, 1 August 2025, and did not pass through Parliament, which the opposition criticised publicly (reported); parliamentary elections scheduled 27 September 2026, with the principal opposition party on record wanting the nationality law revised | Confirm programme status at the date of application; sequence so that the file is admitted rather than contemplated | A state that may create a programme by decree may amend or end it the same way | High | §14.1 |
| K-05 | Alteration of the contribution and fee schedule | The responsible ministers may alter the Anexo I minimum amounts and fees by joint order | The client | Decree-Law 07/2025, Art. 22(1)–(2): the power is qualified, operating "without prejudice to commitments assumed by the State in specific instruments", and an update does not affect processes already admitted | Treat published figures as current at their stated date only; shorten the interval to formal admission, which is the point at which figures crystallise for a file | The power itself is unconstrained as to future files | Moderate | §14.2 |
| K-06 | Deterioration in the citizenship component's institutional acceptance | Third-party institutions may treat the passport less favourably as the programme's record develops | The client | Vanuatu is the executed precedent for a state that lost a visa exemption on investor-citizenship grounds; the Commission's Eighth Report treats such schemes as a "potential ground" for suspension. São Tomé and Príncipe is already in Annex I of Regulation (EU) 2018/1806 and holds no exemption to suspend; no EU measure concerning the programme had been located as at 2 August 2026 (a dated statement of absence, not an assurance) | Full disclosure at every institution; expectations set to the passport's verified travel access rather than to any published count | Institutional acceptance is a judgement of third parties. Short-stay movement in the Schengen Area arises from the Greek residence permit throughout, so this row does not touch European mobility | Not quantifiable | §14.1, §12.12 |

*Table K.1 — Programme and legislative risk, six rows. Derived from §14.1, §14.2, §7.14, §8.5, §10.1, §12.12 and §20.4. Assumptions: positions stated as at 2 August 2026; Circular 1/2026 content and the Spain/Portugal closures are reported tier, the circular's text not having been opened; the São Tomé concession arrangements referred to in the body are not public and are not relied on here. Instruments named inline govern; where the body qualifies a statement, the qualification is reproduced.*

## K.3 Application risk

| Ref | Risk | Description | Borne by | Drivers and evidence | Mitigation available | Residual — what cannot be mitigated | Rating | § |
|---|---|---|---|---|---|---|---|---|
| K-07 | Citizenship refusal | The naturalisation application is refused on statutory or discretionary grounds | The client | Lei 7/2022: refusal where the criminal record shows a conviction carrying more than one year's imprisonment; the general Art. 10(1) conditions continue to apply notwithstanding the waiver of residence and language requirements | Screen against the statutory grounds before engagement; complete documentary preparation; note that the contribution is payable only after approval | Approval is a government decision and cannot be guaranteed; refusal need not be reasoned in terms the applicant can address | Moderate — loss on refusal is bounded to the non-refundable US$5,000 fee and professional costs, the contribution being payable only after approval | §14.5, §18.9 |
| K-08 | Prosecutor's *visto* and the grant-instrument tension | The completed file requires a prior *visto*; if it is refused the process lapses. The Nationality Law and the decree describe the grant differently | The client | Decree-Law 07/2025, Arts. 11(3), 14(1)–(3); Lei 7/2022, Arts. 10(6) and 12. Neither text explains the articulation between grant by Government decree and approval by the unit director's *despacho* | Applicant-specific legal explanation obtained before filing; no reading of the articulation asserted | No published practice exists for a programme approximately one year old | Not quantifiable | §14.5 |
| K-09 | Nationality-count cap | Nationality may not be granted to a person already holding more than two foreign nationalities | The client, and each family member individually | Lei 7/2022, Art. 11(1)–(2); from 10 April 2026 the responsible unit is reported to have suspended acceptance of applications from holders of three or more foreign nationalities, invoking that cap | Count nationalities for every applicant at screening; confirm the reported hold at the date of application | A later fourth nationality causes immediate loss (see K-38) | Low — the statutory cap is knowable before any cost is incurred | §14.5, §14.15 |
| K-10 | Residence refusal on documentary deficiency | The residence application is documentary in character; a deficiency in any prescribed document is a refusal risk | The client | JMD 214926/2025 §2.6 prescribes the notarial certificate, registration or lawyer's attestation, ownership evidence, engineer's technical report, private insurance policy, €2,000 electronic fee and E9 copy; the fee is paid on filing | Complete documentary preparation before filing; administrative appeal within two months (€50, decided within 30 days) where the ground is documentary | The property must already have been bought and paid for in full before the application exists | Low — the requirements are prescribed and an appeal lies | §14.6, §8.16 |
| K-11 | Proxy filing and the compulsory visit | Filing by proxy before entry starts an exclusive 12-month period within which the applicant and each family member must enter Greece for biometrics and produce the outstanding insurance document | The client and the family | L.5038/2023, Arts. 10 §11, 8(ε) and 14 §7: two failures to appear at the summoned date cause rejection; biometrics are collected only in Greece | Schedule the visit realistically at the outset; treat the window as a fixed calendar obligation for every family member | The window does not pause for a citizenship application, a passport reissue or a change of personal circumstances | Moderate | §14.6, §14.17, §17.1 |
| K-12 | Processing duration | The file takes materially longer than any published standard | The client | The administrative record's stated completion deadline of 50 days is not an end-to-end time; on the proxy route the file completes only when biometrics are given. Ministry statistics for March 2026 record 10,032 pending investor applications, of which 3,399 were filed in 2024 | Plan on the official pendency data rather than on marketing timelines; sequence other commitments around an open-ended decision period | No service standard binds the outcome, and the property is committed throughout | High | §14.6 |
| K-13 | Age-out of a child on the residence side | A child reaching 21 ceases to hold a family permit and receives an independent three-year permit | The family | L.5038/2023, Art. 95 §2 and the type O.2 permit; family permits expire simultaneously with the sponsor's | Model each child's age at filing and at each renewal; budget the €450 fee for the independent permit | The age of a child at the date of a government decision is within nobody's control | Low — foreseeable, and a change of status with its own fee rather than a loss of status | §14.8, Ch. 16 |
| K-14 | Extended dependants on the citizenship side | Categories published by the programme are wider than the gazetted texts provide | The family | Negative finding against both gazetted texts: neither Decree-Law 07/2025 nor Lei 7/2022 provides for dependent children up to 30 or for parents or grandparents aged 55 and over. The only statutory hook is the ministers' power to approve the unit's internal procedures, and no such instrument has been located in the gazette. Passport issuance for adult dependent children aged 18 and over is reported placed on hold from 10 April 2026, with no evidence located that the hold has been lifted as at 2 August 2026 | Never price extended dependants as a statutory entitlement; obtain written confirmation of their treatment at the date of application | The divergence between published practice and published law is the administration's to resolve, not the applicant's | High | §14.8, Ch. 16 |
| K-15 | Source-of-funds failure | Source of wealth or of the specific funds cannot be evidenced to the standard applied | The client, and any professional who has committed resources in advance | The FATF and OECD recommend multi-layered due diligence in which each layer screens independently, and assessment of source of wealth as well as source of funds, extending to accompanying family members. Decree-Law 07/2025 requires a declaration of lawful origin with supporting bank documentation and a due-diligence report from a recognised entity; the Greek price must move through prescribed banking channels and be recorded in the deed | Assemble the file before engagement; route funds so that the same evidence serves both the application and the Greek acquisition-presumption position | History. Where wealth arose in a period or jurisdiction that produced no records, no preparation manufactures evidence; the correct response is deferral or decline, not a better narrative | Not quantifiable | §14.7, §15.14 |

*Table K.2 — Application risk, nine rows. Derived from §14.5–§14.8, §15.14, §17.1, §18.9, §8.16 and Chapter 16. Assumptions: the 10 April 2026 memorandum (nationality-count hold and adult-dependant passport hold) is reported tier, the memorandum not being public; the statutory three-nationality cap behind it is verified. The 50-day figure is quoted only to disclaim it as an end-to-end time.*

## K.4 Property and market risk

| Ref | Risk | Description | Borne by | Drivers and evidence | Mitigation available | Residual — what cannot be mitigated | Rating | § |
|---|---|---|---|---|---|---|---|---|
| K-16 | Property ineligibility | The property is a sound purchase and still fails to qualify | The buyer, who has already paid in full | One property, full ownership and possession, minimum acquisition value €250,000; change of use completed before the application, and — per the administrative record — after 5 April 2024; industrial buildings need five-year non-operation certification; the threshold is in practice once-only per property, the notary certifying prior investor-permit use | Engineer's technical report and notarial certificate obtained before commitment; the acquisition made conditional on them where the seller will accept it | The statute requires the whole price to be paid before the application, so eligibility is tested after the money has gone | High | §14.3, §8.5, §8.16 |
| K-17 | Conversion and planning defects | The property qualifies and is nevertheless defective | The buyer | Two engineer's documents do different work: the Art. 83 L.4495/2017 certificate of no unauthorised constructions or uses, and the JMD change-of-use technical report. The Electronic Building Identity is reported mandatory for transfers since 1 April 2022, the activating instrument not pinned — requires confirmation. Title work is complicated by the cadastre transition; central Athens conversion stock is drawn from a building population averaging over 40 years old | Legal and technical due diligence instructed by the buyer, not inherited from the seller; the buyer's engineer verifies the planning file independently | Latent defects no reasonable inspection discloses | Moderate | §14.4, §8.4, §8.5, §17.7 |
| K-18 | Developer and counterparty failure | Late delivery, works that do not match the planning acts, or failure of the party that carried out the conversion | The buyer | The full price and the completed conversion both precede the application, concentrating counterparty exposure on the buyer; the ministerial decision relies wholly on the notarial certificate as payment evidence | Prefer completed and certified stock; stage payment against issuance of the named planning acts; retain a final tranche until the reports can be issued; take Greek counsel on securing staged payments | The solvency of the converter. A warranty is worth what its giver is worth | Moderate | §8.13, §14.4 |
| K-19 | Eligibility premium in the purchase price | Price set by the statutory floor rather than by district comparables | The buyer | A unit at exactly €250,000 sized 60–100 m² implies €2,500–€4,167/m², at or above central-Athens average asking levels, in districts where conventional stock trades below that average (analysis on reported asking-price data). Portugal evidence records transaction prices exceeding fiscal values by approximately €38,000 at that programme's €500,000 threshold, with bunching; no Greece-specific study exists | The property-without-immigration test applied in writing before commitment; any premium quantified and carried into the capital arithmetic as a cost of the structure | The premium's size is not observable in any published Greek series, and it is not part of the retained asset | High | §8.3, §8.15, §12.3 |
| K-20 | Vacancy and letting underperformance | The property produces less than modelled, or nothing, while ownership costs continue | The owner | Long-term letting is permitted; short-term letting and sub-letting are prohibited for this category. Primary-residence leases are reported to run for a minimum of three years (requires confirmation at the date of application). Aggregator yields (4.38% national, 5.52% Athens) are built from asking prices and asking rents, and transacted yields are lower; the report's planning band for a floor-priced central conversion is 4.0–5.0% gross before costs, taxes and voids, stated as analysis. Earlier investor-permit owners are reported letting 10–15% below comparable market rents | Achievable rent evidenced by local comparables rather than vendor guarantees; a stated operating allowance of 15–25% of gross rent; conservative void assumptions, no verified eviction or arrears timelines being available | The letting restrictions are conditions of the permit, so the immigration condition constrains the investment | Moderate | §14.12, §8.9, §12.5, §12.6 |
| K-21 | Price decline | The asset falls in value over the holding period | The owner | National apartment prices fell 42.4% nominal from the Q3 2008 peak to the Q3 2017 trough, Athens 44.7%, across nine consecutive negative years; approximately 46% in real terms, and as of 2025 the index remained approximately 18% below its 2008 level in real terms. Housing rents fell 25.8% nominal from 2011 to 2018 and then held at the floor for three further years | Selection discipline and the zero-growth and downside cases treated with the same weight as the base case; the position sized so that the modelled range of outcomes is acceptable | Market risk. Capital preservation and appreciation cannot be assured, and a repeat of the verified cycle would apply to this asset | High | §14.14, §12.3, §12.9, §12.11 |
| K-22 | Resale illiquidity and buyer pool | The exit is slow, cheap or unavailable | The owner | No official time-on-market series exists; the 2008–2017 episode demonstrates conditions in which residential property became effectively illiquid for years. While the category remains open, the natural buyer is another applicant, and whether a resold conversion re-qualifies a new €250,000 application is an open administrative question requiring confirmation at the date of any resale. A reported pipeline of 1,000–2,000 conversion apartments from spring 2026 and 3,000–5,000 more by 2027 clusters in the same districts; net foreign inflows fell approximately 25.3% in 2025 | Exit planned at or after a five-year permit horizon; resale tested on the assumption that the successor buyer has no immigration motive; both sides' transaction costs applied | The exit is constrained twice, by the market and by the permit — selling during the permit's validity revokes it — and conventional property analysis does not capture the second constraint | High | §14.14, §8.14, §12.10 |

*Table K.3 — Property and market risk, seven rows. Derived from §14.3, §14.4, §14.12, §14.14, §8.3–§8.5, §8.9, §8.13–§8.16, §12.3, §12.5, §12.6, §12.9–§12.11 and §17.7. Assumptions: yield and pipeline figures are reported tier and asking-based where stated; the 4.0–5.0% band, the €500–€1,200/m² conversion-cost band and the premium-reversion overlay are analysis on verified premises, not published series; Greek tax and cost figures throughout are reported tier and subject to confirmation at the date of application.*

## K.5 Financial and currency risk

| Ref | Risk | Description | Borne by | Drivers and evidence | Mitigation available | Residual — what cannot be mitigated | Rating | § |
|---|---|---|---|---|---|---|---|---|
| K-23 | US dollar leg exposure | The contribution, the due-diligence and processing fee, the post-approval documents and the submitting agent’s retainer allowance are all denominated in US dollars — a dollar leg of US$100,750 — while the Greek side of the position is in euro. The sensitivity opposite prices the US$95,000 contribution-and-fee leg only | The client | Table 14.3: the US$95,000 dollar leg costs €86,363 at US$1.10 and €82,609 at the report's US$1.15 working assumption — €3,754 more at the adverse rate, roughly 9% of the reference case's ≈€40,375 implementation allowance, and roughly 21% of the approximately €18,027 of that allowance which remains once Kestrel Private's per-application professional engagement fees and the licensed submitting agent's retainer allowance are met (K-26, K-27) | State the assumed rate wherever a converted figure appears; convert and hold the required currency once timing is known; size the contingency for the movement rather than the point estimate | The contribution is payable only after approval and within 90 days of it, so the payment date is unknown when the position is taken and no ordinary hedge is available for an obligation contingent on a government decision | Moderate | §14.13, §10.2 |
| K-24 | Home-currency exposure on the euro leg | The property, Greek fees and all ongoing costs are euro-denominated; the client's income, liabilities and consumption usually are not | The client | The same exposure as K-23 in the opposite direction for a client whose home currency is weak against the euro, and applied to a much larger number | Convert on a planned basis rather than at the point of need; measure outcomes in the client's own currency as well as in euro | The client's home-currency outcome depends on a rate over an unknown horizon | Not quantifiable | §14.13, §12.3 |
| K-25 | Unrecoverable acquisition friction | Part of the capital deployed against the property never enters the asset | The client | Modelled acquisition friction of €14,855–€32,795 on a €250,000 purchase, 5.9–13.1% of the retained capital, against a commonly quoted 8–10% rule of thumb; the property must appreciate by that much merely to return the property-side outlay in nominal terms | Written quotations for every line before commitment; the with-agent and without-agent cases modelled separately; specialist rather than bank FX pricing considered | The friction is incurred with certainty while the offsetting appreciation is uncertain | Low — bounded, quotable in advance, and disclosed | §12.4, §8.6 |
| K-26 | Contingency exhaustion | The implementation allowance is insufficient on every costed configuration | The client | The reference case leaves approximately €40,375 for all costs beyond the identified base, and that residual does not move — it is the difference between a €375,000 planning figure and a €334,625 known base, neither of which moves. What it must absorb is larger than it appears. Two charges reach the allowance before any third-party implementation line does. Kestrel Private's professional engagement fee is charged per application, each application being separate work before a separate government, so a reference case instructing both programmes carries two fees — €18,000, or about 45% of the allowance. The licensed submitting agent's retainer allowance takes a further €4,348 (K-27). Approximately €18,027 is left for transfer tax, notarial and land-registry charges, legal and technical due diligence, translation and legalisation, insurance, banking, the São Tomé post-approval document charges and contingency — against acquisition friction alone modelled at €14,855–€32,795 (K-25), so that the low end of that single range consumes more than four-fifths of what remains before any other item is met, and the high end is nearly twice it. Priced line by line, the allowance's own list totals €40,600 at the lean end of every band, €62,463 in the heavy configuration and €76,263 at the top of every band: shortfalls of €225, €22,088 and €35,888, and all-in figures of €375,225, €397,088 and €410,888 against a €375,000 planning figure. A five-cent adverse currency move consumes a further €3,982 across the whole US$100,750 dollar leg — €3,754 of it on the contribution-and-fee leg priced at K-23, and about €227 more on the dollar lines that sit inside the allowance itself, the post-approval documents and the submitting agent’s retainer allowance. The optional company, banking and tax layer sits outside the €375,000 reference case; it carries no professional engagement fee, its cost being third-party throughout | Build the cost model bottom-up from written quotations for the specific case rather than from the planning figure; quote the engagement fee for each of the two applications instructed before work begins; obtain the submitting agent's retainer in writing before engagement; hold the contingency in the currency of the obligation; plan a single-applicant position at approximately €376,000 and never present €375,000 to a client as a budget | The allowance is exceeded on every costed configuration, including the leanest, so the planning figure is not a budget on any set of assumptions the report has priced; and costs quoted in a market with no published tariffs may move between engagement and completion | High | §12.1, §10.1, §10.2, §10.11, §10.14, §20.2 |
| K-27 | Unpublished licensed submitting agent's retainer | A São Tomé application is filed through the designated application channel, and the submitting agent's retainer is a client cost for which no published figure exists | The client | The programme's own channel publishes that applications are initiated through licensed marketing agents; the gazetted texts license and sanction agents but do not publish any client-facing retainer, and no source publishes one. The report carries €4,348 on every configuration: an allowance of US$5,000 at the report's planning assumption of €1 = US$1.15, separate from the government's due-diligence and processing fee of the same amount, and carried in Kestrel Private's own cost model. It is not published, not gazetted and not sourced to any instrument, and it is not a quoted retainer | Obtain the retainer in writing from the submitting agent before engagement, and price the citizenship side from that quotation rather than from the allowance; confirm at the date of application; treat the €4,348 as an allowance and not as a price | The allowance rests on no published figure, so the amount carried here may differ materially from the figure actually quoted, in either direction, and the difference falls wholly on the client | Not quantifiable | §12.1, §10.4, §10.11, §10.14, §20.2, §6.5, §18.3 |

*Table K.4 — Financial and currency risk, five rows. Derived from §14.13, §12.1, §12.3, §12.4, §8.6, §10.1, §10.2, §10.4, §10.11, §10.14, §20.2, §6.5 and §18.3. Assumptions: single applicant; the report's working planning rate of €1 = US$1.15 (§10.2 governs) — a planning assumption set below the prevailing market rate, the European Central Bank's euro foreign exchange reference rate having stood at US$1.1535 on 3 August 2026 (ECB, euro foreign exchange reference rates, EUR/USD daily series, https://www.ecb.europa.eu/stats/policy_and_exchange_rates/euro_reference_exchange_rates/html/eurofxref-graph-usd.en.html, accessed 4 August 2026) — with US$1.10 and US$1.20 used as illustrative bracketing values and not as forecasts, US$1.10 being an adverse stress below the lowest daily reference rate of the preceding twelve months rather than an observed level; friction bands as modelled in §12.4 on a taxable value equal to the €250,000 price; Kestrel Private's professional engagement fee is charged for each of the two programme applications, so the reference case, which instructs both, carries two fees within the allowance and a client instructing one programme carries one, while the optional company, banking and tax layer carries no such fee at all, its cost being third-party throughout (§10.11, §10.12); the licensed submitting agent's retainer is carried as an allowance of US$5,000 — €4,348 at the report's planning rate — in Kestrel Private's own cost model, is published by no source and is not gazetted, and requires a written quotation before engagement and confirmation at the date of application. No operator, concession holder or firm is named anywhere in this table. Figures are as stated in the sections cited and are not recomputed here.*

## K.6 Tax risk

| Ref | Risk | Description | Borne by | Drivers and evidence | Mitigation available | Residual — what cannot be mitigated | Rating | § |
|---|---|---|---|---|---|---|---|---|
| K-28 | Failure to establish tax residence | The client who wants a tax outcome does not acquire the intended residence | The client, and any adviser who has assumed a tax result | Greek tax residence arises from presence exceeding 183 days cumulatively in any 12-month period, or from permanent or main residence, habitual abode or centre of vital interests, subject to treaty tie-breakers. The permit imposes no physical-presence condition: absences are statutorily no obstacle to renewal. São Tomé personal income tax is reported residence-based, with residence at more than 180 days per the only located secondary source — requires primary confirmation at the date of application | Take regulated tax advice in both the home and destination jurisdictions before any step is taken; treat relocation as a factual programme, not a documentary one | The home jurisdiction decides, on its own rules, whether the client has ceased to be resident. Departure is proved by facts, not documents | High | §14.10, §9.6, §9.7 |
| K-29 | Asset-acquisition presumption | The purchase triggers a deemed-income presumption in the year of acquisition once the property is let | The client | Objective living expenses never apply to a foreign tax resident, but the separate presumption on asset acquisition is disapplied only for a non-resident who acquires no income in Greece; it is covered by documented imported foreign funds from the client's own foreign accounts | Route the price through the client's own foreign accounts in the buyer's name and preserve the import evidence, created at the time of transfer | The exposure is evidential, so the evidence must exist and must not be reconstructed afterwards | Low | §14.11, §9.10 |
| K-30 | Place of effective management | A foreign holding company comes to be managed in fact from Greece and acquires Greek corporate tax residence | The client | Residence follows place of effective management at any time in the tax year, on facts and circumstances including day-to-day management, strategic decision-making, the annual general meeting, books, board meetings and directors' residence | Governance discipline documented from the outset where any entity is used; regulated advice before an entity is introduced | A tax authority may characterise facts differently, and later, than the client's adviser did | Moderate | §14.11, §9.11 |
| K-31 | Ordinary compliance failure | Filing obligations attaching to Greek ownership are missed | The client | The E9 property declaration is due by 31 January of the year following the deed and is the classic first compliance failure of foreign owners; a non-resident files once Greek-source income arises | Calendared obligations with a retained professional; outsourced compliance quoted in writing | Penalties follow the omission, not the intention | Low | §14.11, §8.11, §17.16 |
| K-32 | Lapse of the capital-gains suspension | The 15% tax on individuals' real-estate gains revives on the terms currently drafted | The client | Nothing is enacted beyond 31 December 2026; the provisions as they stand contain no rebasing, so the whole documented gain since acquisition would become taxable, with holding-period coefficients that rest on a single consolidated source and require confirmation. Chapter 12 models both continuation and lapse | Model both branches; time the exit with the position at the date confirmed | The legislature's decision after 31 December 2026 is unknown, and reported extension or abolition is under consideration only | Not quantifiable | §14.11, §12.10 |
| K-33 | Acquisition-tax classification | The transaction bears 24% VAT rather than transfer tax at 3.09% | The buyer | VAT applies to transfers of new buildings before first use by a VAT-liable constructor; the suspension regime runs to 31 December 2026 and, where it applies, transfer tax is paid instead. Which tax applies to a conversion sale is property-specific | Classification confirmed in writing by the purchaser's lawyer and notary before signing; the effect of a completion slipping past 31 December 2026 closed contractually | The suspension's fate beyond 31 December 2026 is not enacted | Moderate | §8.6, §12.4 |

*Table K.5 — Tax risk, six rows. Derived from §14.10, §14.11, §8.6, §8.11, §9.6, §9.7, §9.10, §9.11, §12.4, §12.10 and §17.16. Assumptions: all Greek tax figures in the report are reported tier, verified against convergent professional sources with the governing instrument identified, and remain subject to gazette confirmation at the date of application; the São Tomé 180-day threshold rests on a single secondary source and requires primary confirmation. Nothing in this table is tax advice to any person.*

## K.7 Banking risk

| Ref | Risk | Description | Borne by | Drivers and evidence | Mitigation available | Residual — what cannot be mitigated | Rating | § |
|---|---|---|---|---|---|---|---|---|
| K-34 | Onboarding refusal | An account application is refused, delayed or later exited | The client | A bank-account application is not a bank-account approval, and no part of this structure changes that. The standard-setters record that reputational risks associated with these programmes can affect correspondent banking relationships, citing an IMF Article IV assessment of Vanuatu; no São Tomé-specific banking consequence is evidenced | Full disclosure of all nationalities from the outset; a documented source-of-wealth file the bank can test; where the client holds the Greek permit, the right of access to a basic payment account for consumers legally resident in the Union may be engaged, subject to its conditions | Onboarding is a commercial decision of the bank alone | High | §14.9, §9.5 |
| K-35 | Expectation that the second passport conceals origin | The additional passport is presented as though it displaced the original identity | The client | Financial institutions are advised to establish that all nationalities and passports are disclosed at onboarding, to ask for the original birth certificate and the passports held in the original identity, to verify place of birth and all current citizenship holdings, and to mark such passports as investment-acquired | Disclose every nationality and passport at every institution, without exception | For a legitimate client the practical result is disclosure and possibly enhanced questions, not exclusion; concealment is not available and must never be represented as available | Low | §14.9 |
| K-36 | Expectation of a reporting advantage | The citizenship component is assumed to change financial-account reporting | The client | São Tomé and Príncipe has made no commitment to the automatic exchange of financial account information, but reporting obligations are keyed to tax residence rather than citizenship; a Greek account opened by the client will be reported to the client's residence jurisdictions | Set the expectation correctly before the position is taken; take regulated advice on reporting in the client's residence jurisdictions | The passport confers no reporting advantage, and none should be inferred from the jurisdiction's list status | Low | §14.9 |

*Table K.6 — Banking risk, three rows. Derived from §14.9 and §9.5. Assumptions: the standard-setting guidance is the FATF/OECD November 2023 report as cited in the body; list-status statements are statements of status as at 2 August 2026, not endorsements, and coexist with the jurisdiction's non-participation in automatic exchange. The report records, as those bodies do, that many clients of these programmes have gained their assets legitimately.*

## K.8 Post-approval and revocation risk

| Ref | Risk | Description | Borne by | Drivers and evidence | Mitigation available | Residual — what cannot be mitigated | Rating | § |
|---|---|---|---|---|---|---|---|---|
| K-37 | Judicial opposition to the acquisition | The Public Prosecutor may institute opposition before the administrative court within six months of the declaration of acquisition | The client | Decree-Law 07/2025, Art. 14(7)–(8): the opposition is brought before the administrative court and has no suspensive effect on the acquisition. The decree's Art. 14(7) exercises the right "nos termos do artigo 20.º da Lei da Nacionalidade", and Art. 20(2) of Lei 7/2022 designates the Tribunal da Primeira Instância; the two texts diverge on the competent forum and the point requires São Toméan counsel's advice (§18.2). The decree contains no express refund clause for this or any other scenario | Nothing available to the applicant beyond the accuracy and completeness of the original file | The window runs whatever the applicant does, and the standing of a young programme is affected by files other than the client's | Not quantifiable | §14.15, §14.5 |
| K-38 | Loss of nationality after grant | Defined statutory loss grounds and the nationality-count rule | The client | Lei 7/2022, Art. 16: acts against state security, repeated acts against public health, or acquisition by fraud, decreed after a final court conviction, with no possibility of reacquisition. A naturalised citizen who later acquires a fourth nationality loses São Toméan nationality immediately. Decree-Law 07/2025 also lists revocation of nationality among administrative sanctions, with a prior hearing always guaranteed | Accuracy in the application; the nationality count monitored for the life of the position before any further citizenship is acquired | Reacquisition is not available on the statutory loss grounds | Low — the grounds are conduct-based and knowable | §14.15, §14.5 |
| K-39 | Permit revocation on sale | Resale of the qualifying property during the permit's validity revokes the seller's permit | The client and, through the sponsor, the family | L.5038/2023, Art. 100 §8: the qualifying third-country-national buyer acquires a permit right while the seller's permit is revoked simultaneously; a selling third-country national must obtain certification whether the property was used for a permit | Exit sequenced deliberately, with the residence consequence accepted and priced in advance | The consequence is a condition of the permit and cannot be waived | Low — entirely within the holder's control once understood | §14.15, §12.2, §12.10 |
| K-40 | Letting-prohibition breach | Short-term letting or sub-letting of a post-April-2024 qualifying property | The owner | L.5038/2023, Art. 100 §7A: revocation of the permit and a standalone €50,000 administrative fine on the owners or possessors; long-term letting is expressly permitted under §7 | Long-term letting only, acknowledged in writing by the client; no short-stay income assumed in any model or sales material | The prohibition is absolute for this category regardless of district | Low — conduct-based and avoidable | §14.15, §8.10, §12.5 |
| K-41 | Company-seat use | A change-of-use property is used as the seat or branch of a business | The owner | L.5038/2023, Art. 100: the prohibition is express; the exact mapping of the €150,000 fines within §7A to this breach requires confirmation against the gazette text | The prohibition acknowledged in writing and monitored; no entity registered at the address | The sanction mapping is unconfirmed as at 2 August 2026 | Low — conduct-based and avoidable | §14.15, §8.10 |
| K-42 | Renewal failure | The permit is not renewed because the property position is no longer provable | The client and the family | Renewal re-proves the property documentarily: continued ownership and possession, a fresh private insurance policy, the €2,000 fee, the E9 copy, the definitive registration certificate where deferred at initial grant, and solemn declarations that the main spaces remain residential and the property is not a company seat or branch | A renewal calendar maintained from the date of grant; registration completed rather than left on the initial-issuance attestation; insurance renewed annually | The property must remain owned, residential and compliant for as long as the residence position is wanted | Moderate | §14.15, §8.1, §17.17 |
| K-43 | Family permits expire with the sponsor's | Family permits are family-reunification titles that expire simultaneously with the sponsor's permit | The family | L.5038/2023, Art. 95 §2 and the type O.1 permit | Family renewals sequenced with the sponsor's; the age-out of a child at 21 anticipated (K-13) | The dependency of the family titles on the sponsor's title is structural | Low | §14.15, §14.8, Ch. 16 |

*Table K.7 — Post-approval and revocation risk, seven rows. Derived from §14.5, §14.8, §14.15, §8.1, §8.10, §12.2, §12.5, §12.10, §17.17 and Chapter 16. Assumptions: on the residence side every revocation ground listed is conduct-based and within the holder's control, provided the conditions are understood and monitored; on the citizenship side they are not. The Art. 100 §7A fine mapping and the renewal late-filing rule require confirmation against the current consolidated gazette text.*

## K.9 Execution and sequencing risk

| Ref | Risk | Description | Borne by | Drivers and evidence | Mitigation available | Residual — what cannot be mitigated | Rating | § |
|---|---|---|---|---|---|---|---|---|
| K-44 | Capital committed before any decision exists | The two components fail in opposite ways | The client | On the residence side the property must be acquired, paid in full and converted before the application is filed, so more than €250,000 is irrevocably committed before any residence decision exists. On the citizenship side the order is reversed: the processing fee is non-refundable after submission, but the contribution is payable only after approval, within 90 days | The sequence fixed in writing before either file is opened; the client's tolerance for the committed period tested at suitability screening | A client who assumes a common pattern will misjudge both; the Greek commitment cannot be made conditional on the outcome | High | §14.17, §14.6, §13.5 |
| K-45 | Mismatched crystallisation points | Published figures fix at different legal moments in the two components | The client | Citizenship figures fix on formal admission; Greek thresholds fix on enactment of an amending statute subject to its transitional window; Greek permit fees fix on payment of the electronic fee at filing; an existing permit renews on the conditions in force at the time of grant | A single sequencing plan that shortens the interval during which one file sits between two crystallisation points | Two sovereign administrations run two independent timetables; neither is obliged to accommodate the other | Moderate | §14.17, §14.2, §17.1 |
| K-46 | Passport and permit identity matching | A permit issued against the original passport is presented with a newly issued second passport | The client | The Convention Implementing the Schengen Agreement requires the residence permit plus a valid travel document, and no EU provision requires that document to be the passport against which the permit was issued. The uniform residence-permit card prescribes nationality as a mandatory entry and no passport-number field. Official Belgian guidance requires both documents and a 100% match of five identity parameters including nationality — the only published national standard located, and the strictest documented benchmark rather than the Schengen norm | Travel on the matching original passport pending Greek counsel's advice; the declaration and reissue position settled before the second passport is used at a border | Whether Greece re-keys the permit to a newly acquired second nationality while the original subsists is not published in the statute, the ministerial decision or the administrative record, and requires confirmation from Greek counsel at the date of application | Not quantifiable | §14.17, §5.9 |
| K-47 | Declaration obligations on change of status | Changes of nationality and of passport details must be declared | The client | L.5038/2023, Arts. 19 §§1(β),(γ), 19 §4 and 20 §1: declaration through the migration information system within two months, a €100 fine and €200 on repetition; card details may be changed only on the strength of the foreign authority's own documents; reissue carries a €100 fee. Where the original nationality is lost on acquiring São Toméan citizenship, the declaration route becomes obligatory | A calendared obligation triggered by any grant, loss, renewal or reissue of a passport | The card can follow only what the foreign authority's own documents establish | Low | §14.17, §17.17 |

*Table K.8 — Execution and sequencing risk, four rows. Derived from §14.2, §14.6, §14.17, §5.9, §13.5, §17.1 and §17.17. Assumptions: the Belgian standard is carried as the strictest documented national benchmark, no Schengen-wide matching rule having been located in the Borders Code, the Convention or the Commission's practical handbook; Greek re-keying practice is unpublished. Short-stay movement in other Schengen states arises from the Greek residence permit throughout, and the second passport remains subject to the ordinary Schengen visa requirement.*

## K.10 Adviser and intermediary risk

This section is stated from the published risk literature and applies to the market as a whole, not to any named participant. The same bodies that identify the vulnerabilities below record, in the same report, that these programmes attract an array of clients, many of whom have gained their assets legitimately and have benign intentions. Both statements belong in the file.

| Ref | Risk | Description | Borne by | Drivers and evidence | Mitigation available | Residual — what cannot be mitigated | Rating | § |
|---|---|---|---|---|---|---|---|---|
| K-48 | Reliance on a single screening layer | The client relies on screening whose adequacy cannot be audited | The client | The FATF and OECD identify weak intermediary oversight as a core vulnerability, recording that many marketing agents work with little oversight or accountability, and recommend that each vetting layer screen independently rather than rely on screening already undertaken by another | Independent regulated professionals retained by the client in each jurisdiction; refusal to rely on any single participant's assurance that a matter has been checked | A client cannot audit the internal screening of a foreign administrative channel | High | §14.16, Ch. 18 |
| K-49 | Unverified promotional claims | Processing times, travel-access counts and rankings are relied on as fact | The client | Programme-site statements on decision times, agent numbers and application volumes are statements of the site, not independently audited; no official list of the passport's total travel access is published, and rankings are not sources | Every claim tested against the primary instrument or an official source before reliance; verified travel-access examples used in place of counts | Marketing material will continue to circulate regardless of what the file records | Low | §14.16 |
| K-50 | Diffused responsibility across the chain | A chain of participants in which responsibility for the whole is allocated to nobody | The client | The programme operates a licensing regime — applications are initiated through licensed marketing agents, an annual agent licence fee of US$5,000 applies, and unlicensed promotion is punishable by a fine of up to US$500,000 — but the scope and territorial reach of that provision are not defined in the text | Written engagements with responsibilities allocated expressly; a documentary trail sufficient for a third party to reconstruct every step | No adviser can substitute for a government's decision; decision-making authority rests with governments | Moderate | §14.16, Ch. 18, §18.9 |
| K-51 | Unsettled regulatory perimeter | Whether an adviser without an EU establishment falls within the EU anti-money-laundering perimeter | The client | The anti-money-laundering regulation lists investment migration operators among obliged entities, but its architecture is establishment-based and it contains no extraterritorial-application clause; FATF Recommendation 22 applies customer due diligence to designated non-financial businesses and professions, including real-estate agents, lawyers, notaries and accountants | Engagement of professionals who are regulated in their own jurisdiction on terms recorded in writing | Whether the listing reaches an adviser without an EU establishment is not settled; the report describes the perimeter and stops there | Not quantifiable | §14.16 |

*Table K.9 — Adviser and intermediary risk, four rows. Derived from §14.16, §18.9 and Chapter 18. Assumptions: stated from the published risk literature at the level of the market; no participant is named, and no row asserts misconduct by any person. The FATF/OECD findings and the legitimate-client finding are carried together, as the source carries them.*

## K.11 Register summary

| Category | Rows | High | Moderate | Low | Not quantifiable |
|---|---:|---:|---:|---:|---:|
| Programme and legislative risk (K.2) | 6 | 4 | 1 | 0 | 1 |
| Application risk (K.3) | 9 | 2 | 2 | 3 | 2 |
| Property and market risk (K.4) | 7 | 4 | 3 | 0 | 0 |
| Financial and currency risk (K.5) | 5 | 1 | 1 | 1 | 2 |
| Tax risk (K.6) | 6 | 1 | 2 | 2 | 1 |
| Banking risk (K.7) | 3 | 1 | 0 | 2 | 0 |
| Post-approval and revocation risk (K.8) | 7 | 0 | 1 | 5 | 1 |
| Execution and sequencing risk (K.9) | 4 | 1 | 1 | 1 | 1 |
| Adviser and intermediary risk (K.10) | 4 | 1 | 1 | 1 | 1 |
| **Total** | **51** | **15** | **12** | **15** | **9** |

*Table K.10 — Distribution of residual ratings across the register. Counts are of the rows printed in Tables K.1 to K.9; each category row sums across the four rating columns, and each column sums to the total shown. The ratings express residual exposure after available mitigation, not likelihood, and no probability is assigned anywhere in this appendix. Assumptions and sources: as stated in the caption to each preceding table.*

## K.12 The three most material and least mitigable risks

The register is not weighted, and the count in Table K.10 is not a ranking: fifteen low-rated rows do not offset one high-rated row. Three exposures nonetheless stand out, consistent with §20.4, because in each the available mitigation does not reach the substance of the risk.

**First, legislative and policy change on either side, and on the Greek side in particular (K-01, K-02, K-04; §14.1, §14.2, §7.14, §20.4).** The Greek investor-residence thresholds have been revised repeatedly, and the €250,000 change-of-use category is a restricted route whose operative conditions are carried partly in an administrative record rather than only in statute — a record whose entry for this category was last updated on 31 July 2026. A category created by statute and specified administratively may be altered by the same means. On the citizenship side the framework is approximately one year old, and the responsible members of government may alter the fees and minimum contribution by joint order, changes not affecting applications already formally admitted. Programme continuity cannot be assumed on either side. The material continuity risk attaches to the Greek permit, because that is where the European mobility originates. The mitigation is timing, and timing is not control.

**Second, the investment quality of the property (K-19, K-21, K-22; §8.15, §12.9, §12.10, §20.4).** The property is an immigration condition and an investment asset, and it can satisfy the first function while failing the second. The Greek market's own record establishes the magnitude of what a poor selection may cost: national apartment prices fell 42.4% and Athens prices 44.7% peak to trough across nine consecutive negative years, and, seventeen years after the peak, recovery in nominal terms only, the index remaining approximately 18% below its 2008 level in real terms. A property that qualifies for the permit but would not be bought on its own merits converts the largest single item in the cost model into the largest single source of loss. Diligence improves selection; it does not create a market, and the exit is constrained twice over, by the market and by the permit.

**Third, the pre-commitment of capital to decisions that remain the governments' to make (K-07, K-12, K-16, K-44; §14.5, §14.6, §14.17, §18.9).** The whole price of the property must be paid, and the conversion completed, before the residence application exists; the citizenship decision is a government decision that cannot be guaranteed and need not be reasoned in terms the applicant can address; and no service standard binds either administration to a timetable, official Greek pendency data showing 3,399 applications filed in 2024 still pending in March 2026. Preparation shortens the exposed interval and improves the file. It does not shift the decision, and decision-making authority rests with governments throughout.

Two features of the position work in the client's favour and are recorded here for completeness rather than for comfort. The São Tomé contribution is payable only after approval, so a refused applicant loses the non-refundable fee and the professional costs rather than the contribution. And on the residence side every revocation ground in Table K.7 is conduct-based and within the holder's control, provided the conditions are understood and monitored. Neither feature bears on the three exposures above.

This appendix is general information forming part of the report and is not legal, tax, immigration or investment advice to any person. It is used alongside regulated professional advice in each jurisdiction, and every position in it is confirmed against the instruments and schedules in force at the date of application.