European investment migration is becoming increasingly compliance-led. If you are considering a Golden Visa, you should expect your identity, financial history, business interests and source of funds to be examined carefully.

There is no single EU-wide Golden Visa due diligence system that applies in exactly the same way across every member state. Each country continues to set its own residence-by-investment rules and application procedures.

However, EU institutions have maintained pressure on member states to address the security, money laundering, corruption and tax-evasion risks associated with investor migration schemes. National immigration authorities, banks, investment funds and property professionals are also applying their own checks.

A qualifying investment is therefore only one part of a successful application. You must also show that your wealth is legitimate, your financial records are consistent and the proposed investment complies with the relevant national rules.

Why European scrutiny has increased

The European Commission raised formal concerns about investor citizenship and residence schemes in a report published on 23 January 2019. It identified risks relating to security, money laundering, tax evasion and corruption, while calling for greater transparency and independent oversight.

On 28 March 2022, the Commission recommended that EU member states repeal investor citizenship schemes and carry out stronger checks on investor residence applicants. This included enhanced screening connected with sanctions following Russia’s invasion of Ukraine.

The distinction between citizenship and residence became even more important after the Court of Justice of the European Union ruled against Malta’s investor citizenship scheme on 29 April 2025.

The Court found that granting Maltese nationality in direct exchange for predetermined payments or investments amounted to the commercialisation of EU citizenship. The judgment related specifically to citizenship by investment. It did not abolish European residency by investment programmes.

You should therefore be cautious when Golden Visas and Golden Passports are discussed as though they are the same product. A residence permit does not automatically make you an EU citizen.

What due diligence can involve

Due diligence is not limited to obtaining a police clearance certificate. Authorities and regulated organisations may examine your personal, professional and financial background before approving an application or accepting an investment.

You may be asked to provide:

• Valid passports and identity documents
• Police certificates from relevant countries
• Tax returns and proof of tax residence
• Personal and company bank statements
• Audited or professionally prepared company accounts
• Shareholding and beneficial ownership records
• Employment contracts and dividend statements
• Property sale agreements and completion statements
• Probate records for inherited wealth
• Trust, foundation or holding company documents

The documents required will depend on the programme, your nationality, where you have lived and how you accumulated your wealth.

Your bank, fund manager or property lawyer may also request information that is not listed in the immigration authority’s standard document checklist. This is because each regulated party must meet its own legal and compliance responsibilities.

Source of wealth and source of funds

Source of wealth and source of funds are connected, but they are not the same.

Your source of wealth explains how you built your overall financial position. This could include income from employment, company profits, investments, property gains or an inheritance.

Your source of funds explains where the money used for the Golden Visa investment came from. It must usually be possible to follow the funds from their original source to the final investment account.

For example, you may have built your wealth by owning a UK business. Your supporting evidence could include Companies House records, company accounts, dividend vouchers, HMRC tax returns and bank statements showing the receipt of dividends.

Problems can arise when funds pass through several personal, corporate or offshore accounts without a clear explanation. Transfers from relatives, business partners or third-party companies may require additional evidence.

You should also calculate the investment and associated fees in both euros and GBP. Exchange-rate movements can change your final GBP cost before a transaction is completed.

Politically exposed persons and complex structures

Being identified as a politically exposed person does not automatically prevent you from securing residence. It does, however, normally result in enhanced checks.

Authorities and financial institutions may examine your public roles, close family relationships, business associates and links to state-owned organisations. They may also review sanctions lists and reliable sources of adverse information.

Complex corporate or trust structures are not necessarily improper. However, you must be able to explain why the structure exists, who controls it and how the money within it was generated.

Before choosing a programme, it can be helpful to review the differences between available routes through a structured residency and citizenship programme comparison.

How current European programmes approach compliance

Due diligence requirements vary between countries and investment routes.

The Greece Golden Visa remains primarily associated with qualifying property investment. Your checks may involve the immigration authority, a Greek bank, the seller, your legal representative and other professionals involved in the purchase.

Property thresholds and eligibility rules can vary according to the location and type of property. You should confirm that the proposed asset meets the current requirements before paying a deposit.

The Portugal Golden Visa no longer accepts ordinary property purchases as qualifying new investments. Current routes include qualifying non-property funds, scientific research, cultural support, job creation and certain company capital investments.

For example, Portugal’s qualifying fund route generally requires at least €500,000 in eligible non-real-estate collective investment organisations. Cultural investment can start at €250,000, subject to the legal conditions and any permitted reductions.

Under the Hungary Guest Investor programme, qualifying options include investing at least €250,000 in an eligible real estate fund registered by the Hungarian National Bank. A separate €1 million donation route is available for specified educational, research or artistic purposes.

The investment fund route must be supported by formal evidence from the qualifying fund manager or distributor. Immigration checks remain separate from the financial checks conducted by the fund and any participating bank.

The Italy Investor Visa currently offers several investment categories. These include €2 million in Italian government bonds, €500,000 in an Italian limited company, €250,000 in an eligible innovative start-up or €1 million for a qualifying philanthropic initiative.

Italian applicants must provide proof of financial resources, a criminal record document and other supporting information when requesting the initial certificate of no impediment.

Malta’s position requires particular care. Following the April 2025 EU court judgment, its previous standard investor citizenship model is no longer promoted as an ordinary citizenship-by-investment route.

The Malta Permanent Residence Programme remains a separate residence programme. Residency Malta states that applications undergo a multi-tier due diligence process covering applicants, dependants and, where relevant, donors, benefactors and business associates.

Property and investment checks remain essential

Where property is used, immigration eligibility does not replace normal legal due diligence. You should examine title, planning status, permitted use, valuation, developer history, taxes and any restrictions placed on the property.

Independent real estate services can help you assess whether the proposed property is legally suitable as well as commercially sensible.

Do not rely only on a sales agent’s statement that a development is “Golden Visa approved”. The current legal rules, the property documents and your individual application must all be reviewed.

How to prepare your application

Start organising your financial evidence before committing to an investment.

You should:

• Check names, addresses and dates across every document
• Explain unusually large or recent transactions
• Keep the transfer route as direct as reasonably possible
• Obtain certified translations where required
• Confirm document legalisation requirements
• Disclose the beneficial owners of relevant companies
• Prepare evidence for every included family member
• Retain records for future renewals and compliance reviews

Documents accepted by a UK bank may not automatically satisfy an overseas immigration authority. Requirements can also change while you are preparing an application.

Understanding how Coates Global operates can help you see why early eligibility assessment and coordinated document preparation are important.

Choose a defensible route

Stronger scrutiny should not discourage legitimate investors. Well-managed checks can support the long-term credibility of residence programmes and reduce the risk of abuse.

You should select a route based on your family plans, financial position, residence intentions and ability to maintain the investment. The lowest advertised threshold is not always the most suitable option.

It is also important to understand the difference between global residency and citizenship programmes and direct citizenship by investment programmes. The legal rights, residence requirements and citizenship prospects can be very different.

If you are considering a European Golden Visa, speak to Coates Global before transferring funds or signing an investment agreement. Contact the team for a confidential assessment of your circumstances, documentation and available investment migration routes.