# 20. Final Assessment This chapter states conclusions only. Every assertion in it rests on material established earlier in the report and is cross-referenced to the chapter that carries the underlying analysis and sources. No figure appears here that has not already been derived and qualified in Part III. Where a comparison is computed here from figures established earlier, its inputs are cross-referenced and its arithmetic is shown. ## 20.1 Is this a replacement for EU citizenship? No. It is not a replacement, an equivalent or a repackaging of EU citizenship, and it must not be presented as one. The rights that ended for new applicants when the EU's investor-citizenship market closed were the rights attaching to the nationality of a member state, and through it to Union citizenship: free movement and residence throughout the Union; the right to work and to establish a business in any member state; municipal and European electoral rights; consular protection by any member state in third countries; transmission of that status to descendants under national nationality law; and a status that is permanent and not conditional on continuing to hold an asset. The Court of Justice of the European Union declared on 29 April 2025 that Malta had failed to fulfil its obligations under Article 20 TFEU and Article 4(3) TEU by establishing and operating such a scheme.[^20-1] Chapter 2 sets out how that position was reached; see §2.4 and §2.5. Of those rights, the reference structure recovers none. Discretionary naturalisation for exceptional merit or services may continue to exist in the national law of individual member states; where it does, it is decided case by case, is not purchasable and is never a priced product, and it is not what this structure addresses (§2.7). What it supplies instead are separate objects, each from its own instrument. An additional nationality and passport, with a distinct sovereign and consular relationship, may arise under São Tomé and Príncipe's Decreto-Lei n.º 07/2025, subject to due diligence and approval.[^20-4] Lawful residence in one member state, for five years and renewable while the qualifying conditions continue to be met, may arise under Article 100 of Greek Law 5038/2023 in the change-of-use category introduced by Article 64 of Law 5100/2024.[^20-6][^20-5] Short-stay movement in other Schengen states, up to 90 days in any 180-day period, may be exercised on the basis of that residence permit and a valid travel document, subject to the conditions of Article 21(1) of the Convention Implementing the Schengen Agreement and of Article 6(1)(a), (c) and (e) of the Schengen Borders Code — and not on the basis of the São Tomé passport, whose holders remain subject to the ordinary Schengen visa requirement under Annex I to Regulation (EU) 2018/1806.[^20-3][^20-2] Entry declaration obligations on arrival vary by member state. See §4.4 and §7.10. Two distinctions govern how those objects are to be read, and neither is a matter of emphasis. The first is a distinction of status. Union citizenship attaches to the nationality of a member state, which is why the commercialisation of the granting of that nationality engaged Article 20 TFEU at all, as the declaration recorded above shows.[^20-1] The Greek title is a national residence permit, issued by Greece under Greek law and conferring residence in Greece on the conditions of the permit; it is not a Union status, and it does not become one by being held alongside another nationality.[^20-6] The São Toméan passport creates no European immigration right of any kind — no right of entry, of stay or of residence in any member state — and its holders are visa-required for the Schengen Area.[^20-2] The second distinction is procedural. The two applications are made to two governments, under two unrelated instruments, and each is adjudicated separately against its own criteria; neither approval is evidence of the other, neither is a condition of the other, and the refusal of one leaves the other to be decided on its own merits (§6.7, §14.5, §14.6). Coordination of the work by any adviser goes to sequence and to the assembly of two files. It does not merge two statuses into one legal right, and nothing in this report should be read as suggesting that it can. The exclusions are equally definite: no EU citizenship, no EU passport, no employment rights, no residence outside Greece beyond the short-stay limits, no political rights, no automatic intergenerational European status, and no permanence independent of the qualifying property. Chapter 19 sets these out in full; see §19.8. ## 20.2 Is the structure commercially defensible? The question is answered by the character of the outlay, not by its size. Chapter 10 derives the cost model and Chapter 12 examines what happens to the capital afterwards. | Cost component | Illustrative amount | Character of the outlay | |---|---:|---| | São Tomé contribution (US$90,000) | €78,261 | Non-refundable | | São Tomé due-diligence and processing fee (US$5,000) | €4,348 | Non-refundable | | Greek main-applicant permit fee | €2,000 | Non-refundable | | Greek residence-card production charge | €16 | Non-refundable | | Qualifying Greek property | €250,000 | Retained in the client's ownership; value not preserved | | **Known base subtotal** | **€334,625** | | Illustrative single applicant at the report's planning assumption of €1 = US$1.15, which is neither a market rate nor a forecast (§10.2); government charges as published at 2 August 2026. The subtotal excludes property transaction taxes, professional fees and contingency. It also excludes the São Tomé post-grant document charges for the certificate of registration, passport and national identity card, published on the archived official programme site as an aggregate US$750 per applicant (approximately €652 at the same rate), absent from the gazetted fee annex and requiring confirmation at the date of application.[^20-12] It further excludes the retainer of the licensed submitting agent through which a São Tomé application is filed. That retainer is carried in Kestrel Private's own cost model as an allowance of US$5,000, approximately €4,348 at the same rate; being dollar-denominated, it moves with the programme's other dollar charges. It is not published, it is not gazetted, and it is not sourced to any instrument; a written quotation is required before engagement, and the line requires confirmation at the date of application. Both it and the document charges are carried among the costs the allowance must absorb rather than in the base (§10.4, §10.14, §12.1). Sources: §10.3, §10.4, §10.7; §1.5. Of the identifiable base, approximately €84,625 is spent and not recoverable, and €250,000 is retained as an asset the client owns. The illustrative single-applicant reference case of approximately €375,000 is a planning figure, not a computed total: it is posited, and what it leaves over is then derived. Set against the identifiable base, it leaves the approximately €40,375 the executive summary identifies for every other cost — property transfer tax or VAT as applicable, notarial expenses and land-registry or cadastral charges (§10.6); Greek legal and technical due diligence (§10.8); citizenship legal and professional work; translation, apostille and legalisation (§10.9); insurance and administrative costs (§10.10); residence filing and biometric expenses not already in the table above; banking and currency-conversion costs; property furnishing or completion costs; the São Tomé post-approval document charges (§10.4); the US$5,000 retainer allowance of the licensed submitting agent through which the citizenship application is filed (§10.14, §12.1); Kestrel Private's professional engagement, charged per application and therefore arising twice in a reference case that instructs both programmes (§10.11); contingency (§10.14); and unforeseen or case-specific expenditure. The costs of the optional layer sit outside the reference case altogether and are dealt with separately at §10.12; that layer carries no professional engagement fee, its cost being third-party throughout. The client receives, subject to eligibility, due diligence and government approval, the rights enumerated in §19.1 and nothing beyond them. Any defence of that arithmetic is qualified. Retained does not mean preserved, recoverable or liquid; §12.3 and §12.4 quantify the acquisition friction that is lost on day one, and §12.9 sets out the downside case. The reference figure, moreover, is an illustrative single-applicant planning model, not a package price; family composition alone displaces it, as Chapter 11 shows at §11.9. The decisive qualification, on the arithmetic itself, is that the allowance is smaller in substance than it appears, and two charges reach it before any third-party implementation line does. Kestrel Private's professional engagement fee is charged per application: each application is a separate body of work, with its own counterparties, its own schedule of disbursements and its own government reaching its own decision. The reference case instructs two programmes — the São Tomé and Príncipe citizenship application and the Greek investor residence application — and therefore carries two fees, €18,000 in all. A client who instructs only one programme pays one fee, and the optional layer carries no such fee at all, its cost being third-party throughout (§10.11, §10.12). The second charge is the retainer of the licensed submitting agent through which a São Tomé application is filed: the same unpublished, dollar-denominated allowance described above, carried at €4,348 on every configuration (§10.14, §12.1). The €40,375 allowance does not move: it is what the €375,000 planning figure leaves over the known base, and neither of those figures moves. What moves is what it must absorb. Approximately €18,027 of it remains for property transfer tax, notarial and land-registry charges, legal and technical due diligence, translation and legalisation, insurance, banking and currency conversion, and contingency — against acquisition friction alone modelled at €14,855–€32,795 (§12.4), so that at the low end of that single range the friction consumes more than four-fifths of what remains, and from any higher point in it the friction exceeds what is left outright. Priced line by line at §10.14, 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 against the allowance. The corresponding all-in figures are €375,225, €397,088 and €410,888 against a €375,000 planning figure. Within those qualifications, the structure is commercially defensible for the right client at the right property, and it is not defensible as a universal package. That is the executive summary's own formulation and this report does not soften it: the remaining allowance of approximately €40,375 is met only in a tightly controlled single-applicant case, and is not a sufficiently robust basis for a universal advertised package (§1.5). The figures above are that sentence's basis. Once the submitting agent's retainer is counted, the tightly controlled case — every band at its lean end at the same time — meets the allowance, and the €375,000 planning figure with it, by €225. There is no costed configuration in which the allowance is sufficient, so the qualifier "tightly controlled" no longer rescues it. The honest statement is therefore not that €375,000 holds in a lean case, but that €375,000 is a planning reference which the leanest case meets once every real cost is counted, and that a defensible single-applicant planning figure is closer to €376,000. Kestrel Private's assessment must price each position from written quotations rather than from either figure, and must say so to the client before the position is taken. ## 20.3 Which element creates the greatest value? Two elements carry most of it, one legal and one structural. The ordering describes their contribution to the structure as a whole; it is not a ranking of the components against one another, which remain complementary parts of one coordinated position, each assessed on its own legal terms (§5.7). The first is the European residence position itself. A five-year permit, renewable while the qualifying conditions continue to be met, in a member state of the European Union, is the only component of the structure that produces a lawful and continuing presence inside the Union.[^20-6] Short-stay movement in the other Schengen states may be exercised on the basis of that permit and a valid travel document, subject to the conditions of Article 21(1) of the Convention Implementing the Schengen Agreement and of Article 6(1)(a), (c) and (e) of the Schengen Borders Code (§4.4, §7.10).[^20-3] It may include qualifying family members under the applicable rules (§7.9), and it can be held in reserve without minimum stay while remaining capable of use if circumstances change (§3.4). It confers no employment right and no citizenship expectation (§7.11, §7.13), and it depends on continued ownership of the qualifying property (§7.12). Those limits are precisely why it is defensible: it is a residence right, described as a residence right. The second is the separation of rights on which the structure is built. The former model concentrated nationality, mobility, establishment and succession in a single European status, which meant that one legislative or judicial event could remove all of them at once — as it did. Here each objective is sourced from a different instrument in a different jurisdiction, so that the failure of one component does not of itself extinguish the others: the loss of the Greek permit would not of itself affect the São Tomé nationality, and the closure of the São Tomé programme to new applicants would not affect a permit already issued. That is separation of legal source, not immunity from loss. Each right remains subject to the revocation and opposition provisions of its own instrument. The Greek permit is revocable on disposal of the qualifying property and on breach of the short-term-letting prohibition (§7.12, §14.15). On the São Tomé side, the Public Prosecutor may institute judicial opposition before the administrative court within six months counted from the declaration of acquisition of nationality, an opposition that has no suspensive effect; the decree's administrative sanctions extend to revocation of nationality; and the decree contains no express refund provision for either outcome (§6.8).[^20-4][^20-11] Chapter 5 develops the design at §5.7 and §5.8. The design also imposes a discipline that the report treats as part of the value: every right must be attributed to the instrument that actually creates it, which makes the structure auditable in a way a single packaged status was not (§4.9, §19.1). The citizenship component's value is of a different kind and is not subordinate to either of those two. It may supply an additional nationality with its own sovereign and consular relationship, a second travel document held independently of the client's existing one, and a family contingency capable of transmission under São Tomé's nationality law by declaration and registration rather than automatically (§3.5, §6.10). That value is real where the client's existing nationality is the practical constraint, and slight where it is not (§6.1, §6.13, §6.14). Value is also asked comparatively, against what the closed schemes cost, and the question has a usable answer only if the comparison is stated with its limits. Those schemes and their instruments are set out at §2.1 and are not restated here. One limitation governs everything below it. Malta and Cyprus conferred the nationality of a member state and, with it, Union citizenship; the reference structure confers neither and recovers none of the rights attaching to them (§19.8, §20.1). A difference in price between the two is not a difference in price for the same object, and nothing in the table below should be read as suggesting that it is. | Scheme and configuration | Total | Spent, not recoverable | Taking the form of an asset owned | |---|---:|---:|---:| | Malta MEIN, 36-month tier, leased property | €690,000 | €690,000 | — | | Malta MEIN, 36-month tier, purchased property | €1,310,000 | €610,000 | €700,000 | | Malta MEIN, 12-month tier, leased property | €840,000 | €840,000 | — | | Malta MEIN, 12-month tier, purchased property | €1,460,000 | €760,000 | €700,000 | | Malta IIP, 2013–2020 | €1,150,000 | €650,000 | €500,000 | | Cyprus at closure, Κ.Δ.Π. 379/2020, residential-investment route | €2,200,000 plus VAT | €200,000 | €2,000,000 | | Cyprus at closure, Κ.Δ.Π. 379/2020, other qualifying routes | €2,700,000 plus VAT | €200,000 | €2,500,000 | | The reference case, stages one and two | €375,000 | €125,000 | €250,000 | MEIN is Malta's naturalisation for exceptional services by direct investment; IIP is the Individual Investor Programme that preceded it. The Maltese and Cypriot figures are the gazetted minimums for a single main applicant as set out at §2.1, and exclude agent, professional and dependant fees, which were charged in addition. The two Cypriot lines are the two routes the regulation provides. Regulation 7(1) of Κ.Δ.Π. 379/2020 requires a privately-owned permanent residence of at least €500,000 plus VAT in addition to the €2,000,000 qualifying investment, giving €2,700,000; Regulation 7(4) dispenses with that separate residence where the qualifying investment is itself made in residential units under Regulation 6(2), provided one such unit is worth at least €500,000 plus VAT and is held for life, giving €2,200,000. The residential route is therefore the floor, and the scheme's minimum is stated here as that floor. VAT is not quantified in either line. Regulation 7(5) adds a third case, not tabled here, where units already used for another applicant's naturalisation require €2,500,000 of investment. Cypriot conditions were revised repeatedly across the programme's life (§2.1). Malta's leased configurations left nothing owned at the end of the five-year lease term. The Maltese IIP's retained column comprises the €350,000 property and the €150,000 of approved securities held for the statutory period. The reference case is the illustrative single-applicant planning figure of §20.2, at the report's planning assumption of €1 = US$1.15, and comprises stages one and two only: Malta and Cyprus had no company layer, so the optional layer is excluded to keep the comparison like for like (§10.12). Unlike the historical figures it includes Kestrel Private's professional engagement fees and every third-party cost the allowance must absorb (§10.11, §10.14), so each gap stated below is understated rather than flattered. Its €125,000 is the planning figure less the retained property, and §20.2 records that the planning figure is itself exceeded in heavier configurations priced. Comparisons computed for this section from the figures at §2.1 and §20.2. Against Malta the comparison goes to the proportion of the outlay that is spent and does not return. In each of MEIN's four gazetted configurations, and in the IIP, the greater part of the money was a contribution and a donation the applicant did not see again — €610,000 to €840,000, against €125,000 here, which is lower by between 80% and 85% across MEIN's four configurations and by 81% against the IIP. The cheapest Maltese configuration that ever existed, the 36-month tier on a lease, consumed €690,000 in full and left the applicant owning nothing when the lease term ended. That is the whole of the Malta comparison, and it is narrower than it appears. Retained is not preserved, recoverable or liquid: §12.3 and §12.4 quantify the acquisition friction lost on day one and §12.9 sets out the downside case, and a property that falls in value moves into the spent column what the table places in the retained one. Against Cyprus that comparison fails, and the failure is stated here rather than left to be found. Almost the whole of the Cypriot €2,200,000 was the applicant's own investment and residence: €2,000,000 took the form of assets the applicant owned, against €200,000 in mandatory donations. Per euro spent and not recoverable, the Cypriot scheme therefore left €10.00 of owned asset, where the reference case leaves €2.00. Both denominators have to be named, because they are not alike: the Cypriot €200,000 is the gazetted donations alone, excluding VAT and all professional and agent fees, while the €125,000 here is every euro of the planning figure that is not the property. Counting the excluded items would move both ratios in the same direction, and €10.00 would remain the larger. On the measure that answers Malta, Cyprus answers back, and the Maltese purchased configurations themselves retained only €1.15 of asset for each euro spent. What the Cyprus comparison supports is a different and narrower proposition, and it concerns the amount of capital required to participate at all. At its lowest, on the residential-investment route of Regulation 7(4), that scheme was open only to an applicant able to commit €2,200,000 plus VAT, and to no one else; on its other routes, €2,700,000 plus VAT. The reference case is stated at €375,000, approximately one-sixth of the lower figure. That is a statement about the size of the sum, not about the quality of what the sum obtains, and what it obtains is materially less, because it is not Union citizenship (§20.1). No recommendation follows from either comparison. This report examines one structure; it does not hold that structure out as preferable to the schemes that closed, and those schemes are in any event no longer available to be chosen (§2.2, §2.4, §2.8). ## 20.4 Which element creates the greatest risk? The structural risks, as distinct from the case-specific ones, are not symmetrical with the value. The case-specific failure points are set out at §14.5 to §14.9 and §14.15 and are returned to at the end of this section. The first is legislative and policy change on either side. The Greek investor-residence thresholds have been revised repeatedly, and the €250,000 change-of-use category is a restricted route defined by Article 64 of Law 5100/2024 whose operative conditions are carried in the administrative record rather than only in statute — a record whose entry for this category was last updated on 31 July 2026.[^20-5][^20-7] A category created by statute and specified administratively can be altered by the same means; §7.14 and §14.1 examine the exposure and §14.2 the fee and threshold history. On the citizenship side, the São Tomé framework is approximately one year old at the date of this report, and the responsible members of government may alter the fees and minimum contribution by joint order, with changes not affecting applications already formally admitted.[^20-4] Programme continuity cannot be assumed on either side. The wider direction of travel is also visible, and it must be stated precisely. The European Commission's Eighth Report under the visa-suspension mechanism recommends that the concerned Eastern Caribbean countries take all measures necessary for adequate security vetting of applicants pending the discontinuation of their schemes, and records that the operation of a scheme granting citizenship in exchange for pre-determined payments or investments, without the person concerned having any genuine link, constitutes a potential ground for the suspension of visa-free travel under the revised mechanism; it also states that compliance with EU law requires candidate countries to abolish existing investor citizenship schemes.[^20-10] That mechanism cannot operate against São Tomé and Príncipe, whose nationals are already visa-required under Annex I and in respect of whom there is accordingly no visa-free status to suspend;[^20-2] the passage is cited here as EU policy direction only. For this structure the material continuity risk attaches to the Greek permit, because that is where the European mobility originates (§7.14, §14.1). The second is the investment quality of the property. 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 can cost: national apartment prices fell 42.4% and Athens prices 44.7% peak to trough across nine consecutive negative years, and on 2025 data — seventeen years after the peak — the national index had recovered in nominal terms only, remaining approximately 18% below its 2008 level in real terms (§12.3, §14.12).[^20-8][^20-9][^20-14] Chapter 8 applies the property-without-immigration test at §8.15; Chapter 12 models the zero-growth, downside and exit cases at §12.8 to §12.10. 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. Those two do not exhaust the risk. Compliance and refusal risk is the third family, and it is case-specific rather than structural: citizenship refusal (§14.5), residence refusal (§14.6), source-of-funds failure (§14.7), banking rejection (§14.9), post-approval revocation (§14.15) and adviser or intermediary failure (§14.16). Investment migration has drawn sustained criticism from intergovernmental bodies on money-laundering, corruption, identity-concealment and tax-transparency grounds, and that criticism is set out with its sources at §2.5, in the opening of Chapter 3 and in Chapter 15; its practical consequence for the client is that screening is adversarial by design and that a file which cannot be evidenced does not proceed (§15.1, §15.10 to §15.14). That criticism is not a characterisation of applicants. Those bodies proceed, as this report does, on the footing that many clients have legitimate wealth and legitimate objectives, and that the distinction between them and the rest is drawn by evidence rather than by assumption. A fourth family of considerations lies outside the client's own file, and this report neither disposes of it nor argues it. Each scheme carries a purpose, recorded here with its actual provenance and not as a finding: São Tomé and Príncipe's is stated in its statute, while Greece's is inferred from the structure of the provision itself, no explanatory statement having been read (§7.4). São Tomé and Príncipe's stated ground is Article 10(2) of Lei n.º 7/2022 — investment unequivocally increasing employment and contributing significantly to development, distinction in sport, science or culture, or direct support to the country — with the contribution directed by statute to the National Transformation Fund, which the decree subjects to an annual independent audit, to oversight by the Court of Auditors and the Central Bank, and to quarterly reporting to the justice minister, the Public Prosecutor and the National Assembly.[^20-4][^20-11] Greece's €250,000 figure is an exception to thresholds of €400,000 and €800,000, available only where the main spaces of a property change use to residential or a listed or preserved building is restored or reconstructed — on the face of the instrument, a concession tied to converting non-residential space into housing and to restoring protected buildings.[^20-5][^20-6] Those are stated purposes, not established results, and the report applies to them the scepticism it applies to everything else. No verified evidence of a delivered outcome under either scheme has been located. The São Tomé framework is approximately one year old; no audited Fund account or Article 21 quarterly return has been located as at 2 August 2026; and Article 13(1) reverts net proceeds to the Fund "in the defined percentages", a split defined outside the decree whose terms are not public.[^20-4] Greece publishes no breakdown of investor permits by investment category, so the uptake of the change-of-use route is not officially known (§8.7). The countervailing concerns remain live and are recorded in this report rather than resolved by it: the money-laundering, corruption, identity-concealment and tax-transparency criticism of investment migration generally, and the security-vetting and policy direction set out earlier in this section (§2.5); São Tomé and Príncipe's absence from any commitment to the automatic exchange of financial account information, a transparency gap never offered here as a benefit (§6.11, §9.14); the governance question an undisclosed revenue split raises; and the housing-market effect of investor demand in the eligible segment, evidenced in the closest comparable market and presented as that market's evidence rather than as a Greek finding (§8.3). A stated purpose is the reason a legislature gave. It is not a finding that the purpose has been served, it is not a defence of either programme, and it reduces no risk stated in this chapter. ## 20.5 For whom does the structure make sense? Chapter 13 sets out the suitability framework. What follows states general conclusions drawn from it. It is general information and not legal, tax, immigration or investment advice to any person, and no decision should be taken on it without the regulated professional advice described in the Foreword and in Appendix O. Sharpened to its essentials, the structure may be appropriate where all of the following hold at once. - The client's source of wealth and specific investment funds can be explained and evidenced to the standard set out in Chapter 15, before any application is contemplated (§15.1). - The objective is nationality diversification, lawful residence in Greece under the Greek permit and the short-stay movement that permit carries, family contingency and international asset diversification — the objectives the structure actually addresses (§13.1, §1.9). - The existing nationality is one against which a second, non-European nationality provides a measurable practical benefit, assessed for that client rather than from a generic ranking (§6.13, §13.2). - The €250,000 can be committed to a single illiquid asset for at least the life of the permit, with no expectation of interim access, since disposal in this category causes the permit to be revoked (§7.12, §13.5). - The property would be defensible as an investment if the immigration benefit were ignored (§8.15). - The client accepts that legislative change, refusal and property underperformance are live possibilities and can absorb them without the position becoming untenable (§13.6, Chapter 14). Where those conditions hold, the two components are complementary parts of one coordinated position, and the assessment proceeds one component at a time. ## 20.6 For whom does it not? The report is more useful where it dissuades. The structure should not be pursued, and Kestrel Private would expect to decline or defer the engagement, in the following cases. - The client requires EU citizenship, an EU passport, unrestricted EU-wide residence or the right to work in the Union. None of these arises from any component, and no sequence of components produces them (§19.8, §20.1). - The client's objective is a stronger travel document alone. Nationals of São Tomé and Príncipe are visa-required for the Schengen Area,[^20-2] and for many holders of an existing passport the addition may deliver little or no mobility advantage (§6.9, §6.14). - The client already holds three or more nationalities other than that of São Tomé and Príncipe, or is otherwise affected by the three-nationality limit in Article 11 of Lei n.º 7/2022 — nationality may not be granted to a person already holding more than two foreign nationalities, and a naturalised citizen who later acquires a fourth nationality loses São Toméan nationality by operation of law. The programme has been reported to enforce the cap from April 2026, a matter requiring confirmation at the date of application (§6.3).[^20-11] - The application depends on dependants outside the statutory categories. Neither São Tomé gazetted text contains any provision for dependent children up to 30, or for parents or grandparents aged 55 or over; the published extended categories rest on administrative practice rather than on published law, and both positions are set out at §6.3 and §16.5.[^20-4][^20-11] - The application depends on adult dependants affected by the passport-issuance freeze reported in April 2026 and unresolved as at 2 August 2026 — a reported matter requiring confirmation at the date of application (§6.3, §16.4).[^20-13] - The client cannot tolerate illiquidity. There is no redemption date, no secondary market and no assurance of resale at any particular price or within any particular period (§8.14, §12.10, §14.14). - The client expects an assured outcome as to approval, banking, rental income, capital preservation or a tax result. None of those can be guaranteed, and no component of the structure provides for one (§18.10, §19.8). - Source of funds cannot be traced, tax filings conflict materially with the stated wealth history, or sanctions or criminal concerns cannot be resolved (§15.11, §15.13, §15.14, §1.8). - The total cost outweighs the practical value of what is obtained. Where a client's objectives are met by a single component, the coordinated structure is not the correct instrument for them, and Chapter 13 addresses those cases directly at §13.12 and §13.13. ## 20.7 Kestrel Private's final position Kestrel Private's position is conditional, and it is stated component by component. On the citizenship component: it may provide an additional nationality and passport, a distinct consular relationship and family contingency, subject to eligibility, due diligence, prior consideration by the Public Prosecutor and government approval (§6.5, §6.7). The acquisition remains open to judicial opposition for six months after the declaration of acquisition, and the decree's sanctions extend to revocation (§6.8). Its programme is young, its operating history short, and its value depends entirely on the client's existing nationality. It provides no European right of any kind (§6.1, §6.9, §6.12). On the residence component: it may provide lawful residence in Greece under the conditions of the permit, renewable while those conditions continue to be met, together with short-stay movement in other Schengen states on the terms and subject to the conditions set out at §4.4 and §7.10. It is the source of the structure's European position and of its principal continuity risk, and it confers neither employment rights nor any assured route to naturalisation (§7.1, §7.13, §7.14). On the property component: it is simultaneously an immigration condition and an at-risk investment, and it must be assessed twice — once for eligibility and once as an asset that would have to justify itself with the immigration benefit removed. A positive answer to the first question does not establish a positive answer to the second (§8.15). On the optional layer: it is professional establishment and application coordination, not the purchase of banking access or tax status. A company does not create personal tax residence, a residence permit does not create tax residence, and an application is not an approval (§9.1, §9.5, §9.6). Its cost is third-party throughout — corporate registrar and formation charges, corporate-service provision, and the corporate team that performs the work — and it carries no professional engagement fee of the firm's (§10.12). On Kestrel Private's own role: the firm coordinates and does not advise in a regulated capacity; regulated professionals in each jurisdiction advise, and decisions rest with governments. The firm's professional engagement is charged as a fixed fee agreed in writing before work begins, and that fee is charged for each of the two programme applications, because each application is a separate body of work before a separate government. A client instructing one programme pays one fee; the reference case, which instructs both, carries two; there is never a third (§10.11, §18.1, §18.9). This report is general information and is not legal, tax, immigration or investment advice to any person; the Foreword and Appendix O state that boundary in full. On the cost of the position: the €375,000 reference figure is a planning reference and not a price, and on this report's own line-by-line costing it holds only for the leanest configuration priced, including the leanest, once the licensed submitting agent's retainer is counted (§10.14, §12.1, §20.2). Kestrel Private's position is that a single-applicant position should be planned at closer to €376,000, that every line should be quoted in writing for the specific case before the position is taken, and that the reference figure should not be given to any client as a budget. One further matter belongs in a final position, because its absence is sometimes implied. No institution of the European Union, and no government of any state named in this report — including the Hellenic Republic and the Democratic Republic of São Tomé and Príncipe — has reviewed, approved or endorsed this report, its analysis, its conclusions or the reference structure it examines. The report is Kestrel Private's own work. The programmes it describes are sovereign programmes of the governments concerned, and nothing here should be read as their view of them. Appendix O states the same disclosure in terms. This report was written to be quoted against the industry it describes and, where the facts require it, against Kestrel Private. Its conclusion is not that the structure is good or bad, but that it can only be judged in parts. One structure has been examined here, on the three tests set out at §5.2; it is not put forward as the right answer for every objective, and a client whose objectives differ is served by a different structure. The former model concentrated multiple rights in one European nationality. The present structure separates those objectives — and must be judged component by component. ### Notes [^20-1]: Court of Justice of the European Union (Grand Chamber), judgment of 29 April 2025 in Case C-181/23, *Commission v Malta*, EU:C:2025:283, operative part and paras 96–102, 106; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62023CJ0181 (accessed 2 August 2026). [^20-2]: European Parliament and Council, *Regulation (EU) 2018/1806 listing the third countries whose nationals must be in possession of visas when crossing the external borders and those whose nationals are exempt from that requirement*, Annex I; consolidated version of 30 December 2025; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02018R1806-20251230 (accessed 2 August 2026). [^20-3]: *Convention Implementing the Schengen Agreement*, Article 21, as replaced by Article 1(2) of Regulation (EU) No 265/2010 of 25 March 2010; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32010R0265 (accessed 2 August 2026). The Article 21(1) conditions comprise a valid travel document, the entry conditions of Article 6(1)(a), (c) and (e) of the Schengen Borders Code, and the absence of a national alert in the member state concerned. [^20-4]: 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, pp. 429–440, 1 August 2025 (Portuguese); gazette facsimile; facsimile mirror at https://ntltrust.com/wp-content/uploads/2025/09/STP-CBI-Act-01082025-1-1.pdf (accessed 2 August 2026). The gazette reference governs; the mirror is an industry-hosted copy and is cited for accessibility only. [^20-5]: Greece, Law 5100/2024, Article 64 (Government Gazette A′ 49/05.04.2024), as codified with Law 5167/2024 (A′ 207/20.12.2024) (Greek); official consolidated text at 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). [^20-6]: Greece, Law 5038/2023, *Immigration Code* (Government Gazette A′ 81/01.04.2023), Article 100, consolidated text (Greek); https://www.taxheaven.gr/law/5038/2023 (accessed 2 August 2026). [^20-7]: Greece, National Registry of Administrative Public Services (mitos.gov.gr), *Permanent golden visa (change of use) – Initial issuance*, 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). [^20-8]: Bank of Greece, *Apartment price index (national)*, series QGRN628BIS as republished by the Bank for International Settlements, series to Q1 2026; https://fred.stlouisfed.org/graph/fredgraph.csv?id=QGRN628BIS (accessed 2 August 2026). [^20-9]: Bank of Greece, *New Index of Apartment Prices by Geographical Area* (Athens series), file version 25 November 2025; http://web.archive.org/web/20260718123712/https://www.bankofgreece.gr/OpenDataSetFilesALL/DOAM/New_Index_of_Apartment_Prices_by_Geographical_Area_en_2025-11-25.xls (accessed 2 August 2026). [^20-10]: European Commission, COM(2025) 792 final, *Eighth Report under the Visa Suspension Mechanism* (Article 8(4) of Regulation (EU) 2018/1806), 19 December 2025, Annex I recommendation and footnote 9; https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0792 (accessed 2 August 2026). The Annex I recommendation is addressed to the concerned Eastern Caribbean countries; the report is a monitoring document with no legal force of its own. [^20-11]: São Tomé and Príncipe, Lei n.º 7/2022, *Lei da Nacionalidade*, Diário da República I Série N.º 25, 10 March 2022, Articles 10.º(2), 11.º and 19.º–20.º (Portuguese) — Article 10.º(2) being the naturalisation ground the decree implements (investment unequivocally increasing employment and contributing significantly to development; distinction in sport, science or culture; or donation of direct financial or other support to the country); gazette facsimile; facsimile mirror at https://citizenshiprightsafrica.org/wp-content/uploads/STP-Lei.07.2022.pdf (accessed 2 August 2026). [^20-12]: São Tomé and Príncipe Citizenship by Investment Unit, *Financial Layout*, official programme site on the government domain cip.gov.st, publishing an aggregate charge of US$750 per applicant for citizenship documents (certificate of registration, passport and national identity card); https://cip.gov.st/donation-to-the-national-transformation-fund (accessed 4 August 2026). Official-site content, not gazetted: Anexo I to Decreto-Lei n.º 07/2025 contains no passport, identity-card or certificate fee, and the industry-reported split of that aggregate has no basis in the gazetted text. The amount requires confirmation at the date of application. [^20-13]: Reported: IMI Daily, *São Tomé Introduces Remote Passport Issuance, Clarifies Three-Nationality Rule*, 11 April 2026, reporting a Citizenship by Investment Unit Director's memorandum of 10 April 2026; https://www.imidaily.com/africa/sao-tome-introduces-remote-passport-issuance-clarifies-three-nationality-rule/ (accessed 2 August 2026); corroborated by NTL International (industry press page), *São Tomé and Príncipe CBI 2026 legislative updates*, 14 April 2026; https://ntlinternational.com/press/sao-tome-and-principe-cbi-2026-legislative-updates (accessed 2 August 2026). The memorandum is not public, no official announcement has been located, and no evidence has been found that the hold has been lifted as at 2 August 2026. Secondary sources only — the position requires confirmation at the date of application. [^20-14]: Real-terms deflation of the note 8 series computed for this report from Eurostat, harmonised index of consumer prices for Greece (ELSTAT-compiled), annual average index CP00 "all items"; https://ec.europa.eu/eurostat/api/dissemination/statistics/1.0/data/prc_hicp_aind?format=JSON&lang=EN&geo=EL&coicop=CP00&unit=INX_A_AVG (accessed 2 August 2026). On the 2025 annual averages the national index stands approximately 18% below its 2008 level in real terms notwithstanding nominal recovery (§12.3).