# 5. The Reference Structure ## 5.1 Structure overview This chapter sets out the architecture of the reference structure: what each component is, why more than one jurisdiction is involved, how the components interact, what remains legally separate, and in what order it is implemented. The detailed legal, cost and risk assessment of each component follows in Chapters 6 to 9; this chapter is the map. The reference structure comprises two principal components in two jurisdictions, a third component that is an asset rather than a status, and an optional layer. | Component | Jurisdiction and instrument | Function in the structure | Assessed in | |---|---|---|---| | A — the citizenship component | São Tomé and Príncipe: Decree-Law No. 07/2025, under Law No. 7/2022 | Additional non-European nationality and passport | Chapter 6 | | B — the residence component | Greece: Article 100 of Law 5038/2023, as amended by Article 64 of Law 5100/2024 — the restricted €250,000 change-of-use category | Five-year renewable investor residence permit; short-stay Schengen mobility attaches to this permit | Chapter 7 | | C — the property component | Greece: the qualifying property itself | The residence permit's qualifying condition and a retained, at-risk European asset | Chapter 8 | | Optional layer | Company formation, banking applications and tax-residence assessment, engaged only where separately appropriate | Business, banking and potential tax position | Chapter 9 | *Components as defined in the executive summary (§1.4). The instruments are cited in full in §§5.3–5.4 and in Chapters 6 and 7. Component B is conditioned on Component C; Components A and B are legally independent of each other; the optional layer is separate from both immigration components.* The components are complementary parts of one coordinated position, not competing alternatives: each is assessed on its own legal terms, and their contributions and risks are weighed in Chapter 20. The combination is not new, and Kestrel Private does not claim to have invented it; the report's purpose is to establish what the structure provides, what it costs, which risks are assumed and for whom it may — or may not — be suitable. The report's cost anchor is an illustrative single-applicant reference case of approximately €375,000, computed at the report's planning assumption of €1 = US$1.15 (§10.2) and on charges published as at 2 August 2026, and subject to property-specific acquisition costs, professional fees, exchange rates, family composition and confirmation of all programme charges at the date of application (§1.5). Chapter 10 builds that figure bottom-up, Chapter 11 varies it by family composition, and Chapter 12 separates the capital that is spent from the capital that is retained at risk. ## 5.2 Why multiple jurisdictions are required, and why these Until recently, most of the objectives described in Chapter 3 could be pursued through a single instrument: an EU nationality acquired by investment. That market has ended. Cyprus closed its programme to new applications from 1 November 2020, Bulgaria abolished its scheme with effect from April 2022, and on 29 April 2025 the Court of Justice of the European Union declared that Malta — recorded by the European Commission in September 2022 as the only member state then operating such a scheme, and the last to close its route — had failed to fulfil its obligations under Article 20 TFEU and Article 4(3) TEU by operating it (§2.4).[^5-1][^5-2] Chapter 2 sets out that history; the consequence for structuring is what matters here. The objectives did not end with the programmes, and they do not all arise from the same legal source (Chapter 4): nationality from the nationality law of a state willing to grant it; European residence from an immigration permit; short-stay Schengen mobility, for a visa-required national, from a residence permit or a visa and never from the person; property rights from ownership; any tax outcome from tax law applied to the client's personal facts. No single modern programme provides every benefit (§3.9), and no single jurisdiction now delivers the set. The non-European states that grant citizenship by investment confer no European residence, and their passports are, in the cases relevant to this report, on the Schengen visa-required list — São Tomé and Príncipe appears in Annex I of Regulation (EU) 2018/1806.[^5-3] The European states that admit investors grant residence permits, not citizenship: in Greece, naturalisation follows the ordinary statutory tracks — the investor permit sits on the seven-year residence track, with examination, tax-filing and genuine-residence requirements that presuppose actual life in Greece (see §7.13).[^5-4] Discretionary naturalisation for exceptional merit survives in some national laws, but it is case-by-case, creates no right to approval and cannot be purchased (§2.7). The full objective set can therefore be pursued only across jurisdictions, and what results remains a set of separate positions, each standing or falling on its own law. Coordination of the work is the lawful response to that fragmentation, and it has a price: each added instrument brings its own authority, conditions and failure modes; Chapter 14 therefore treats the structure's risks component by component. Where a client's objectives are narrower, fewer components may serve them (§§13.12–13.13). Where the full set is in view, the components operate together, and no component is a substitute for another. That explains why more than one jurisdiction is needed. It does not explain why these two, and an adviser is entitled to ask: there is no shortage of citizenship programmes, and no shortage of residence programmes. The reference structure follows from three tests, applied in order. **First, short-stay Schengen movement must come from a member state's residence permit.** For a visa-required national it cannot come from a passport (§4.4), and a visa-free third-country passport is not equivalent: that exemption is a policy position which can be withdrawn, and Regulation (EU) 2025/2441 now names investor-citizenship schemes as a ground on which it may be suspended (§12.12). A structure whose European mobility rests on a visa exemption holds something the issuing side can remove. This test excludes every citizenship-only route, however strong the passport. **Second, if capital must be spent rather than retained, spend as little as achieves the objective.** No citizenship-by-investment route returns the qualifying sum: São Tomé and Príncipe's contribution to the National Transformation Fund is non-refundable, exactly as the Caribbean donations are. That is a constraint of citizenship programmes, not a choice between them. What differs is the ratio. The Caribbean donation route places the entire qualifying sum beyond recovery by design (§12.12); the structure examined here confines the spent element to the citizenship contribution and puts €250,000 — the larger part by some distance — into a property the client continues to own. Ownership is not preservation, and acquisition friction of roughly 5.9%–13.1% is unrecoverable from the first day (§12.4). But a retained asset and a spent contribution are different things, and this structure is built so that the larger number is the retained one. **Third, subject to the first two, the lowest identified cost — and the trade-off that buys.** On the residence side, the Greek €250,000 change-of-use category is the lowest property threshold this report located in the European Union that yields an investor residence permit; Spain is reported to have ended its programme with effect from 3 April 2025, a report not confirmed against the national instrument for this report and requiring confirmation at the date of assessment (§2.6, §7.14), and the surviving alternatives sit materially higher. On the citizenship side, São Tomé and Príncipe's published contribution is the lowest located. What that price buys is a programme approximately one year old, with no long public operating record, and this report treats that as a material risk rather than a footnote (§6.12, §14.2). A client who wants an established operating history should expect to pay for it. Those three tests, in that order, produce the structure examined here. They are not the only defensible tests. A client who does not need Schengen movement, who would rather spend a smaller sum than commit a larger one to an illiquid asset, or whose objective is a stronger travel document rather than a European base, is served by a different structure — and the assessment discipline in Chapter 13 exists to reach that conclusion rather than this one. Where mobility requirements are specific rather than general — a particular set of destinations, a business travel pattern, a family split across jurisdictions — the first test above is not answered by a passport ranking at all. It is answered by comparing the client's existing nationality, destination by destination, against what each candidate document and permit would actually add (§6.9). That is an applicant-specific analysis, and it should be run before a programme is chosen rather than after. What follows examines one structure. It does not recommend it over the field. ## 5.3 Component A: non-European second citizenship The citizenship component is naturalisation by investment in São Tomé and Príncipe under Decree-Law No. 07/2025, gazetted and in force on 1 August 2025, which implements the investment and donation naturalisation ground in Article 10(2) of the country's Nationality Law, Law No. 7/2022.[^5-5][^5-6] The programme rests on a non-refundable contribution to the National Transformation Fund: US$90,000 for a single applicant, US$95,000 for a family application of two to four people, and US$5,000 for each additional qualifying dependant, together with a US$5,000 due-diligence and processing fee per application.[^5-5] The responsible ministers may alter these amounts by joint order; an update does not affect applications already admitted.[^5-5] Those are the gazetted minima as at 2 August 2026, and the gazetted texts are not the whole operating picture. On reported information, the administering unit has since April 2026 placed on hold both the acceptance of new applications from persons holding three or more foreign nationalities and the issuance of passports to adult dependent children, pending a revised dependency framework; the same unit publishes dependant categories — children up to 30, and parents and grandparents aged 55 or over — that have no visible basis in either gazetted text (§§6.3, 11.5–11.7, 16.4–16.5).[^5-7] Neither position could be confirmed against an official announcement, and both require confirmation at the date of application. The purpose of the component is additional nationality. Subject to eligibility, due diligence and approval, it may provide a second citizenship and passport, reduced dependence on one country of nationality, an alternative sovereign and consular relationship, family contingency, and potential intergenerational status subject to nationality law (§6.10). It does not provide EU citizenship, European residence, European employment rights or visa-free access to the Schengen Area: nationals of São Tomé and Príncipe require a Schengen visa when travelling solely on that passport.[^5-3] The citizenship component is therefore never the source of European mobility in this structure; that role belongs to the residence component (§5.4). The first caution framing the component is its age: the programme has existed in law for approximately one year as at 2 August 2026 and lacks a long public operating history (§6.12). Second, state control neither begins nor ends with the decision: the completed file requires a prior clearance (visto) from the Public Prosecutor before any decision is taken, and after acquisition there is a six-month window for judicial opposition, together with defined sanctions extending to revocation of nationality (§§6.7–6.8).[^5-5] Third, São Toméan law refuses the grant to a person already holding more than two foreign nationalities and withdraws it from a naturalised citizen who acquires a fourth (§6.3; §13.2).[^5-6] The component's value also varies with the client's existing passport; for some nationalities it adds little (§§6.13–6.14). ## 5.4 Component B: European residence through qualifying property The residence component is the Greek investor residence permit under Article 100 of Law 5038/2023 (the Immigration Code), permit type B.5, as amended by Article 64 of Law 5100/2024.[^5-8][^5-9] The reference case relies on the restricted €250,000 change-of-use category: full ownership and possession of one property with a minimum acquisition value of €250,000 whose principal spaces have changed from commercial or another qualifying use to residential.[^5-8] The statute requires the change of use to be completed before the application is submitted; per the official administrative record for the category (last updated 31 July 2026), the conversion must also have been completed after 5 April 2024, when Article 64 entered into force.[^5-8][^5-10] The same exception covers listed buildings under restoration; the reference case uses the change-of-use limb (§7.4). The category must not be confused with the general €400,000 and €800,000 thresholds, and qualifying stock is not universally available. The permit is granted for five years and is renewable for equal periods while the property remains in the holder's ownership and possession. Absence from Greece is no obstacle to renewal — there is no physical-presence condition. The permit does not establish a right of access to any form of employment, and sale of the qualifying property while the permit is valid revokes the seller's permit.[^5-8] Qualifying family members — the spouse or cohabitation-agreement partner, unmarried children under 21, the direct ascendants of the spouses or partners, and adult children lacking legal capacity regardless of age — may be included under the family-reunification rules (§7.9; Chapter 16).[^5-8] Short-stay Schengen mobility arises from this permit: under Article 21 of the Convention Implementing the Schengen Agreement, the holder of a valid residence permit issued by a member state, travelling with a valid travel document, may move within the territories of the other member states for up to 90 days in any 180-day period, subject to the entry conditions.[^5-11] In this structure, that mobility belongs to the Greek permit and only to the Greek permit. The permit is not citizenship and does not mature into it automatically; it carries no European passport, no unrestricted EU-wide residence or employment, and no automatic tax residence (§7.13; Chapter 19 consolidates the rights position). ## 5.5 Component C: the retained European asset The €250,000 in the residence component is not a fee. It is the acquisition price of a property the client owns outright — which is why Chapter 12 distinguishes contribution capital, which is spent, from retained capital, which remains invested and at risk (§12.1). The property's dual function — immigration condition and investment asset — is the source of the structure's central commercial risk: a property can satisfy the residence category and still be a poor investment (§8.3). Kestrel Private's property assessment must therefore answer two separate questions. Does the property qualify for the residence permit? And would it remain commercially defensible if the immigration benefit were ignored? A positive answer to the first does not establish a positive answer to the second. Chapter 8 applies that discipline in full, culminating in the property-without-immigration test (§8.15). While the permit is in use, the asset operates under statutory constraints: selling it revokes the permit; short-term letting is prohibited for this category, with revocation and fines attaching to breach; long-term letting is expressly permitted.[^5-8][^5-9] Those constraints shape income and liquidity (§8.10, §8.14); the resale, exit and downside scenarios are modelled in Chapter 12. Ownership is not preservation: the property remains exposed to transaction costs, defects, planning and conversion risk, market and currency movement, and resale illiquidity — **"retained" must never be read as "guaranteed"** (§12.3). ## 5.6 Optional component: company, banking and tax residence A suitable client may add a European company with registered office and accounting arrangements, personal and corporate bank-account applications, and an assessment of tax residence — including the Greek non-dom regimes (§9.8) — where genuine relocation and qualification are contemplated. This layer is optional and separate from both immigration components; Chapter 9 examines it, including when it is unnecessary (§9.16). Its boundaries are the point. A company does not create personal tax residence. A residence permit does not automatically create tax residence. Property ownership does not create non-dom status. A bank-account application is not a bank-account approval (§9.5, §9.6). Any tax result depends on the client satisfying the domestic residence, domicile, physical-presence, reporting and continuing compliance requirements of the relevant jurisdiction — and on the client's position in every other relevant tax jurisdiction, including the home country (§9.12). The optional layer is therefore professional establishment and application coordination. It is not, and is never sold as, the purchase of banking access or tax status. ## 5.7 How the components interact The components are legally separate but operationally interlocking. The first interaction that matters at the level of structure design concerns travel documents, which pair with the permit. At a Schengen border the mobility right rests on the residence permit, but Article 21 requires the permit to be accompanied by a valid travel document.[^5-11] The permit is a uniform-format card on which nationality is a mandatory printed entry — in practice, the nationality of the passport against which the application was made.[^5-12] No Schengen-wide rule prescribes how the two documents are matched at the border; the only published national standard located is Belgium's, which requires both documents to be carried and all five identity parameters, including nationality, to match completely.[^5-13] The client should therefore expect to travel on the passport against which the Greek permit was issued, and should not assume that the São Toméan passport can be paired with a permit issued against the original nationality. Whether Greece re-issues a permit after the holder acquires a further nationality is not published in the instruments reviewed and requires confirmation with Greek counsel at the date of application; Greek law does oblige the holder to declare a change of nationality, and of passport details, through the immigration portal within two months.[^5-14] In every configuration, the mobility remains the permit's, never the passport's. Second, succession law is a genuine interaction. Regulation (EU) 650/2012 governs the succession of a third-country national with Greek property: the default applicable law is that of the deceased's habitual residence at death, but Article 22 permits a person to choose the law of a state whose nationality he possesses, and a person with multiple nationalities may choose the law of any of them.[^5-15] Acquiring São Toméan nationality may therefore widen the choice-of-law menu for the succession as a whole, including the Greek property. The election is heavily caveated. The content of São Toméan succession law requires confirmation at the date of application and was not verified for this report. Whether a Greek court would in fact apply the chosen law to Greek-situs property is untested: Article 35 permits a court to refuse to apply a provision of the law specified by the Regulation where that application is manifestly incompatible with the public policy of the forum.[^5-15] The choice governs civil succession only — Greek inheritance tax applies to Greek-situs property regardless of the law chosen.[^5-16] The choice must be made in a valid disposition of property upon death, with succession counsel in each relevant jurisdiction, and it must never be treated as a device against forced heirship. See §6.10 and §13.3. Third, one source-of-funds file may serve more than one reviewer. The São Toméan decree requires the contribution to be deposited into the Fund's bank account and the application file to include a declaration of the lawful origin of funds with supporting banking documentation.[^5-5] The Greek permit file is built differently: Article 100 prescribes the permitted payment methods for the qualifying property, and the documentation rules rely on the notarial certificate — covering the parties, the property, the price, the payment method and full payment — rather than on any separate source-of-funds file.[^5-8][^5-17] In Greece, scrutiny of the origin of funds arises instead through the credit institution, the notary, and the duty placed on one-stop services by Circular 1/2026 to refer suspicious flows to the tax and anti-money-laundering authorities.[^5-18] A source-of-wealth and source-of-funds file prepared once, to the standard of the most demanding reviewer, may therefore serve the citizenship application, the Greek banking relationship and the notarial file — which is why preparation precedes everything else (Chapter 15). Fourth, the family perimeters differ. The two programmes define eligible family members differently: in São Toméan law, the spouse — where the marriage has subsisted for more than five years under the regime of community of acquired property (*comunhão de bens adquiridos*), both conditions cumulative on the face of Article 6(1), or where a court-recognised de facto union has subsisted for more than three — and the children of the principal applicant, on the Nationality Law's conditions; in Greek law, the spouse or cohabitation-agreement partner, unmarried children under 21, the direct ascendants of the spouses or partners, and adult children lacking legal capacity regardless of age.[^5-5][^5-6][^5-8] Inclusion in one component does not imply inclusion in the other, and family costs scale differently in each. Chapters 11 and 16 work through the combinations, including the divergence between the gazetted dependant definition and the administering unit's published categories (§5.3). These interactions are planning matters. None of them fuses the components legally — the next section states what stays separate. ## 5.8 What remains legally separate The structure contains exactly one legal coupling: the residence permit is conditioned on the qualifying property. The permit is granted and renewed only while the property remains in the holder's ownership and possession, and sale during the permit's validity revokes it.[^5-8] Every other pairing of components is legally independent: the grants are made by different sovereign authorities, under different instruments, on separate applications, and approval of one confers no right, priority or presumption in the other. No component upgrades another. The São Toméan passport does not alter the Greek permit's conditions, duration or renewal terms, and it holds no Schengen position of its own — its holders are visa-required nationals under Annex I of Regulation (EU) 2018/1806.[^5-3] The Greek permit does not improve the passport's visa position anywhere, and it leads towards Greek citizenship only through the ordinary naturalisation track, whose seven-year residence, examination and tax-filing requirements presuppose genuine relocation (§7.13).[^5-4] Property ownership without the permit confers no residence status (§4.5). And no element of the structure — permit, passport, property or company — creates tax residence (§4.6, §9.6). Failure of one component does not legally unwind another. A refusal, lapse or revocation on one side does not, as a matter of law, terminate the other: the conditions of the Greek permit are fixed by Article 100 and do not refer to any further nationality the holder acquires or loses (subject to the declaration duty and the open re-issuance question at §5.7),[^5-8] and the loss grounds in São Toméan nationality law do not refer to the holder's foreign residence status.[^5-6] Two qualifications keep that statement honest: grounds that go to the person rather than to a component — source-of-funds failure, criminal or sanctions findings — can surface in each process independently, because both apply their own due diligence (Chapter 15; §§14.5–14.7); and institutions apply their own judgement to investment-acquired documents, a treatment examined at §6.11. Legal independence is not financial independence in time. Capital committed to one component is not released by another component's failure: a client who has bought the property and is then refused the permit owns a Greek flat without a residence status, and a client whose citizenship application fails has still paid the due-diligence fee. That is the sequencing risk analysed at §14.17, and it is why this report insists that each component justify itself on its own terms — the property under the property-without-immigration test (§8.15), the passport against the client's existing nationality (§§6.13–6.14). The separation, finally, is the compliance boundary. Precisely because the components remain distinct legal statuses, they must never be presented — by Kestrel Private or by anyone else — as merging into a European status. The structure is not a substitute for EU citizenship, and Chapter 20 opens with that question for a reason (§20.1). ### Why the reference structure does not recreate Union citizenship The structure does not reconstruct Union citizenship. The proposition is stated here in terms, rather than left to be inferred from the separations set out above. São Tomé and Príncipe independently decides whether to grant its own non-EU nationality, under its own Nationality Law and implementing decree, on its own due diligence, and with its own grounds of refusal, opposition and revocation.[^5-5][^5-6] That nationality creates no right to enter or reside in Greece, no residence right anywhere in the Union, no right of employment in any member state, no Union citizenship and no EU passport. Its holders are visa-required nationals under Annex I of Regulation (EU) 2018/1806.[^5-3] Greece independently decides whether to grant a conditional national residence permit to a fully disclosed third-country national. Disclosure is a legal duty rather than a courtesy: the permit records the nationality of the passport against which the application was made (§5.7), and the holder must declare any change of nationality, and of passport details, through the immigration portal within two months.[^5-14] The Greek permit, rather than the São Toméan passport, is the source of any limited Schengen short-stay mobility, which arises under Article 21 of the Convention Implementing the Schengen Agreement and is confined to 90 days in any 180-day period on that article's conditions.[^5-11] The two statuses do not merge, convert or legally enhance one another. Neither is a shortcut to Greek or Union citizenship: Greek naturalisation is reached only through the ordinary statutory tracks, with their residence, examination, tax-filing and genuine-residence requirements (§7.13), and the São Toméan nationality neither shortens that track nor substitutes for any part of it.[^5-4] Because the statuses are separate, the loss, refusal or revocation of one does not change the legal nature of the other: an applicant refused in São Tomé holds, or does not hold, a Greek permit on the Greek permit's own terms, and a holder whose Greek permit lapses is a São Toméan national with a São Toméan national's travel position and nothing more. ### Concerns that remain relevant The legal distinction disposes of a claim, not of a risk. That the components are separate statuses, each lawfully acquired, says nothing about whether a particular applicant, a particular file or a particular programme is sound. The concerns that the EU institutions and the international standard-setters have raised about citizenship and residence by investment continue to apply to this structure in full:[^5-19][^5-20] - security and sanctions exposure; - money laundering and terrorist financing; - corruption, and the role of professional enablers; - source of wealth and source of funds; - concealed identity or concealed nationality; - prior immigration or banking refusals; - tax evasion and false claims of tax residence; - the integrity of Common Reporting Standard exchange and of beneficial-ownership transparency; - effects on housing and on the local property market; - conflicts of interest in the intermediary market; - limited physical presence in the state granting the status; - future policy change in any jurisdiction involved. These are assessed at their proper length in Chapter 14, component by component; in Chapter 15, which owns source of wealth, source of funds and due diligence; and, for the effects on housing and on the local property market, in Chapter 8 (§8.3, §8.7, §8.15) and Chapter 12; they are not restated here. What belongs here is the boundary of the argument this section makes. Full disclosure, traceable funds, independent government screening, lawful acquisition, continuing qualification, regulated advice in each jurisdiction and effective oversight mitigate these concerns. They do not resolve them. Legality alone resolves none of them: a structure may be entirely lawful and still be unsuitable for the client, inadequately documented, badly timed, or exposed to a policy change no adviser controls. ## 5.9 Implementation sequencing Parts of the sequence are fixed by law. On the Greek side, the qualifying conversion must be completed before the residence application is submitted — per the administrative record, after 5 April 2024 — and the full purchase price must have been paid, through the prescribed banking channels, before the application.[^5-10][^5-8] Property selection, due diligence, acquisition and payment therefore necessarily precede the residence filing. The application itself may be filed by proxy before the applicant first travels to Greece; the applicant and each family member must then enter Greece and submit biometrics, together with the outstanding health-insurance document, within an exclusive 12-month period from filing, and two failures to appear at the summoned date cause the application to be rejected.[^5-14] On the São Toméan side, the US$5,000 due-diligence and processing fee is payable at application, while the contribution becomes payable only after approval, within a 90-day window, failing which the process lapses — the decree provides for no refund in that event. The contribution is followed by the oath, which may be sworn before a São Toméan diplomatic or consular agent abroad; the decree imposes no travel, visit or residence requirement.[^5-5] Those rules produce an asymmetry worth noting. The residence component commits the structure's largest sum earliest: the €250,000 is spent before the permit application can even be filed. The citizenship component defers its principal payment until after approval. Early risk therefore concentrates in the property decision, so the property due-diligence discipline of Chapter 8, and the sequencing-risk analysis of §14.17, attach mainly to Components B and C. The citizenship and residence applications are legally independent of each other and may be prepared in parallel or instructed separately. The summary sequence below maps the stages to Chapter 17, which owns the detail; elapsed-time expectations and the renewal calendar are addressed there, and no processing time is guaranteed by any authority — all timing statements in this report are indicative. | Stage | Principal actions | Component | Detail | |---|---|---|---| | 1 | Strategy, objectives mapping and suitability decision | Whole structure | §§17.1–17.3; Chapter 13 | | 2 | Source-of-funds pre-clearance | Whole structure | §17.4; Chapter 15 | | 3 | Family eligibility confirmation under each programme's rules | A and B | §17.5; Chapter 16 | | 4 | Property selection; legal and technical due diligence; engagement of local regulated professionals | B and C | §§17.6–17.7, 17.9; Chapter 8 | | 5 | Tax and structural assessment, where the optional layer is contemplated | Optional layer | §17.8; Chapter 9 | | 6 | Property acquisition and payment through the prescribed banking channels | B and C | §17.10 | | 7 | Residence application, biometrics and issuance | B | §§17.11, 17.15 | | 8 | Citizenship application, approval, contribution and oath | A | §§17.12, 17.15 | | 9 | Banking application and, where separately justified, tax-residence implementation | Optional layer | §§17.13–17.14 | | 10 | Post-approval compliance; renewal and monitoring calendar | Whole structure | §§17.16–17.17 | *Indicative sequence for a single coordinated engagement. Stages may be instructed separately, and stages 7 and 8 may run in parallel; the order within Components B and C (acquisition and payment before application) is fixed by law as cited in the text of this section — payment is a statutory precondition of the Component B filing; stage 6 is therefore attributed to both components. No stage's outcome — approval, timing or cost — is guaranteed. Source: Chapter 17; statutory sequencing points per §5.9.* Chapter 17 sets out the full implementation process step by step; Chapter 18 allocates the roles — including what Kestrel Private does not do, and the decision-making authority that rests with governments alone. ### Notes [^5-1]: European Commission, press release IP/22/5422 (referral of Malta to the Court of Justice of the European Union over its investor citizenship scheme; chronology of the Cyprus and Bulgaria terminations), 29 September 2022, official print version, https://ec.europa.eu/commission/presscorner/api/files/document/print/en/ip_22_5422/IP_22_5422_EN.pdf (accessed 2 August 2026). [^5-2]: Court of Justice of the European Union (Grand Chamber), judgment of 29 April 2025, *Commission v Malta*, C-181/23, EU:C:2025:283, operative part, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62023CJ0181 (accessed 2 August 2026). [^5-3]: Regulation (EU) 2018/1806, Annex I (São Tomé and Príncipe listed; visa required under Article 3(1)), consolidated version of 30 December 2025, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230 (accessed 2 August 2026). [^5-4]: Hellenic Republic, National Registry of Administrative Public Services (mitos.gov.gr), «Πολιτογράφηση Αλλογενών Αλλοδαπών» (naturalisation of foreign nationals; 3/7/12-year residence structure, the investor permit on the seven-year list; record last updated 30 July 2026; in Greek), https://mitos.gov.gr/index.php/ΔΔ:Πολιτογράφηση_Αλλογενών_Αλλοδαπών (accessed 2 August 2026). [^5-5]: São Tomé and Príncipe, Decreto-Lei n.º 07/2025 («Regulamentação da Nacionalidade por Investimento ou Doação»), Diário da República, I Série, N.º 33, 1 August 2025, pp. 429–440 — Articles 3(h), 8, 10, 11, 14, 18 and 22 and Anexos I and III (in Portuguese; gazette facsimile), https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf (accessed 2 August 2026). [^5-6]: São Tomé and Príncipe, Lei n.º 7/2022 (Lei da Nacionalidade), Diário da República, I Série, N.º 25, 10 March 2022 — Articles 6, 10(2), 10(4)–(5), 11 and 16 (in Portuguese; gazette facsimile), https://citizenshiprightsafrica.org/wp-content/uploads/STP-Lei.07.2022.pdf (accessed 2 August 2026). [^5-7]: Reported, not official: IMI Daily, "São Tomé Introduces Remote Passport Issuance, Clarifies Three-Nationality Rule" (Citizenship by Investment Unit director's memorandum of 10 April 2026; hold on new applications from persons holding three or more foreign nationalities; hold on passport issuance to adult dependent children aged 18 and over), 11 April 2026, https://www.imidaily.com/africa/sao-tome-introduces-remote-passport-issuance-clarifies-three-nationality-rule/; corroborated by NTL International, "São Tomé and Príncipe CBI 2026 legislative updates", 14 April 2026, https://ntlinternational.com/press/sao-tome-and-principe-cbi-2026-legislative-updates. The published dependant categories (children up to 30; parents and grandparents aged 55 and over) are those of the programme's official site, "Become a Citizen" page, archived capture of 17 July 2026, https://web.archive.org/web/20260717032201/https://cip.gov.st/become-a-citizen. The memorandum itself is not public and no official announcement was located; all three propositions require confirmation at the date of application (all accessed 2 August 2026). [^5-8]: Greece, Law 5038/2023 (Immigration Code, Government Gazette A′ 81/01.04.2023), Article 100 (permit type «Β.5») and Article 95(2); consolidated text, codification through Law 5307/2026 (in Greek), https://www.taxheaven.gr/law/5038/2023 (accessed 2 August 2026). [^5-9]: Greece, Law 5100/2024 (Government Gazette A′ 49/05.04.2024), Article 64, as codified with Law 5167/2024; official consolidated text hosted by the Ministry of Migration and Asylum (in Greek), https://migration.gov.gr/wp-content/uploads/2025/03/Νόμος-5100_2024-κωδικοποιημένος-με-τον-5167_2024-ΦΕΚ-Α-49_5.4.2024.pdf (accessed 2 August 2026). [^5-10]: Hellenic Republic, National Registry of Administrative Public Services (mitos.gov.gr), "Permanent golden visa (change of use) – Initial issuance" (completion of the change of use after 5 April 2024 and before the application; record last updated 31 July 2026), https://en.mitos.gov.gr/index.php/ΔΔ:Permanent_golden_visa_(change_of_use)_–_Initial_issuance (accessed 2 August 2026). [^5-11]: Convention Implementing the Schengen Agreement, Article 21, as replaced by Regulation (EU) No 265/2010, Article 1(2) (and as amended by Regulation (EU) No 610/2013: "90 days in any 180-day period"), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0265 (accessed 2 August 2026). [^5-12]: Regulation (EC) No 1030/2002 (uniform format for residence permits), consolidated version of 21 November 2017, with Regulation (EU) 2017/1954, Annex (entry "8. Nationality." mandatory on the card), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02002R1030-20171121 and https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32017R1954 (accessed 2 August 2026). [^5-13]: Belgian Immigration Office (IBZ), "Visa-free travel with residence permits — general principles" (both documents carried; 100% match of five identity parameters, including nationality), https://dofi.ibz.be/en/themes/entry/border-control/visa-free-residence-permits/general-principles (accessed 2 August 2026). [^5-14]: Greece, Law 5038/2023, Government Gazette A′ 81/01.04.2023 — Articles 8(ε) (sickness insurance), 10(11) (proxy filing; entry, biometrics and the outstanding insurance document within an exclusive 12-month period), 14(7) (two failures to appear at the summoned date: application rejected), 19 (declaration of changes of nationality and passport details within two months) and 20 (fines for non-declaration); gazette facsimile (in Greek), https://www.elinyae.gr/sites/default/files/2024-09/81α_2023.pdf (accessed 2 August 2026). [^5-15]: Regulation (EU) No 650/2012 (Succession Regulation), Articles 20–23 (universal application; habitual-residence default; choice of the law of a nationality possessed, including by a person with multiple nationalities), Article 34(2) and Article 35 (public policy of the forum), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012R0650 (accessed 2 August 2026). [^5-16]: Greece, Law 2961/2001 (Inheritance and Gift Tax Code), Article 3 (Greek-situs property taxed regardless of the nationality or residence of deceased and heir); consolidated text (in Greek), https://www.taxheaven.gr/law/2961/2001/article/3/view (accessed 2 August 2026). [^5-17]: Greece, Joint Ministerial Decision 214926/2025 (Government Gazette B′ 6014/11.11.2025), Article 2 §2.6 (documents specific to the change-of-use category; the notarial certificate as the evidence of parties, property, price, payment method and full payment — no separate bank-statement file is prescribed), FEK text (in Greek), https://www.pomida.gr/assets/File/1236_20250206014.pdf (accessed 2 August 2026). [^5-18]: Greece, Circular 1/2026 of the Secretary General for Migration Policy, 21 April 2026 (referral by one-stop services of misleading advertising and suspicious flows to the tax authority and the anti-money-laundering authority) — content reported via Sioufas & Associates, https://www.sioufaslaw.gr/golden-visa-διευκρινίσεις-εφαρμογής-του-άρθρ-100/, and IMI Daily, https://www.imidaily.com/europe/greece-cracks-down-on-golden-visa-fraud-in-sprawling-new-circular/; the circular text itself was not opened and the content is reported, not primary (both accessed 2 August 2026). [^5-19]: European Commission, *Investor Citizenship and Residence Schemes in the European Union*, COM(2019) 12 final, 23 January 2019 (security, money-laundering, tax-evasion and transparency risks identified for both scheme types); via EUR-Lex, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52019DC0012 (accessed 2 August 2026). [^5-20]: FATF/OECD, *Misuse of Citizenship and Residency by Investment Programmes*, FATF, Paris, November 2023 (approved by the FATF Plenary, 25–27 October 2023), https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Misuse-CBI-RBI-Programmes.pdf (accessed 2 August 2026). Chapter 15 carries the pinpoint references.