It's important to understand what the ownership of a Maltese passport represents to foreign nationals, especially to those from outside the EU, and what would lead an individual to invest (quite heavily) in one. Maltese citizenship by default grants EU citizenship. This includes rights to freedom of movement within the EU's Schengen area, as well as free access to the EU's economic market.

Where do applicants come from?

It's clear from the available data that there are a handful of distinct countries from which the majority of applicants originated. The most prominent country of origin is Russia, which comprises approximately 37% of all applicants for Maltese citizenship, irrespective of their success in doing so. Second is China with approximately 12% of all applicants, followed by Saudi Arabia at roughly 10% of all applicants.

A considerable number of applicants for Maltese citizenship already held multiple passports at the time of applying. Of those with dual (or more) citizenship, many held citizenship of St Kitts and Nevis, another stronghold location where Henley & Partners operates.

Obtaining dual citizenship with Malta is illegal for citizens of some countries. This is certainly the case with Saudi Arabia, for instance. Saudi citizens must seek discretionary royal permission to obtain an additional passport elsewhere. Despite legal restrictions on holding dual citizenship in some jurisdictions, Individual Investor Programme (“IIP”) Malta still accepted many applicants from those countries.

Applicants in context

The period of Malta's citizenship programme – from the establishment of its policy in 2014 and onward – aligns with a few key events that provide a backdrop to certain trends in applicant demographics. The dominance of Russian applicants across this period comes after the EU imposed sanctions on the state in 2014 with regard to the Crimean Referendum and Russia's military intervention in Ukraine.

These sanctions were important contributants (alongside a significant fall in oil prices) to the collapse of the ruble and to the Russian financial crisis during 2014-15; there were evidently financial incentives that Maltese citizenship presented to prospective Russian nationals. Although they remain a very small minority of applicants for Maltese passports overall, an increase in the number of UK applicants is evident in 2017. This follows the Brexit referendum in June 2016, when the UK voted to leave the EU.

The influence of US populism

2017 also marked a conscious shift in the demographics of Malta's citizenship programme, which came about as a result of decisions internal to Malta as opposed to changes in external influxes of prospective applicants. The Maltese government implemented what was essentially a Trump-style ‘Muslim ban’ on potential IIP applicants. A notice, dated 30 January 2017 and written by Jonathan Cardona, had been circulated among employees at Henley & Partners detailing the decision of Identity Malta to bar “individuals who hold citizenship from...Iraq, Syria, Yemen, Libya, Sudan, [and] Somalia” from being accepted to IIP Malta. Following this notice, in a Henley & Partners' email chain (dated 27th February 2017) discussing a Syrian applicant, it was written that “[Identity Malta] are awaiting guidance from the PM's office. Apparently their decision depends on what the US do”.

The issuance of Cardona's notice on 30 January came three days after former US President Donald Trump signed Executive Order (“EO”) 13769 banning entry to the US (for 90 day visits) for nationals of Iran, Iraq, Libya, Somalia, Sudan, Syria, and Yemen. Save for Iran, these are the exact countries which were included in Cardona's list. The email reference to the Maltese Prime Minister's decision being dependent on “what the US do” could very well be referring to the legal retaliation against Trump's Executive Order.

Following the Trump administration's tenure, President Joe Biden has since repealed the ‘Muslim ban’. In Malta, however, bans on applicants from some of the aforementioned countries for citizenship under Maltese Exceptional Investor Naturalisation (MEIN) programme, still appear to persist. While Libya is no longer a banned nationality, applicants from Syria, Sudan, Yemen and Somalia are still prohibited. It also appears that Iraq has been removed from the list since Cardona's initial notice in January 2017 (perhaps in alignment with Trump's removal of Iraq from EO 13780, which followed the dismantling of the initial EO 13769). In addition, Iran has been added to the list of prohibited countries, as has South Sudan.