Upon the passing of the first 120 days, in which the applicant’s proposal for obtaining citizenship by investment is being evaluated in depth, the Minister will issue an “ In Principle Approval “of the application. This is a strong statement by the Malta authorities that, based on the facts and documents presented, including a declaration or executive summary as to how the applicant intends to fulfill the “genuine link” requirement, the applicant has very strong credentials for acceptance within the Programme.
It is therefore at this point that the applicant would need to pay the balance of EUR 640,000 and pass on to fulfill and execute his mandatory requirements as well as continue to gather proof of establishment of his genuine links to Malta.
The onus is therefore now on the applicant as to whether to continue to actively pursue the Programme having been given the green light by Malta.
Clearly, if for some extraordinary reasons, the applicant fails to perform his obligations and abandons the Programme entirely, then the payment may be lost. However, at such an advanced stage in the process, one would presume that the applicant would be expected to carry this through to the end.
It is worth mentioning also that the law covering the Malta IIP refers to a period of 6 months to 2 years within which to execute the Programme, and if for some reason or other, the applicant delays to fulfill the 12 month genuine link proposal in his earlier application statement, the Programme continues to remain operational until such time as this requirement is fulfilled within such 2 year period – the only implication here would be that the final outcome of the Programme would be slightly delayed.
The only other reason that could possibly result in the loss of the amounts paid – following the issue of the ‘In Principle Approval’ – would be if matters of say a criminal nature come to light in respect of the applicant that would automatically debar him from continuing to execute the Programme.