February 27, 2022

Dear Sirs/Madams,

IAS has been monitoring, on behalf of its investors, the recent news regarding any potential impact, of the current situation in Europe, on the concession residence permit for investment program.

In that context, we would like to report that yesterday the Portuguese Minister for Foreign Affairs stated that SEF would suspend preemptively the analysis of the applications of Russian citizens under the aforementioned program.

The grounds presented by the Minister for such decision are that this is a measure aimed as safeguard the sanctions that will be adopted against Russia and Russian citizens, by the European Union.

There has been no further context, details or information regarding this decision, issued by the Portuguese Government or by SEF.

The situation is volatile and the information we have access to, today, is quite limited. We, however, believe the following preliminary conclusions can be drawn, regarding the announced measure:

  1. i) As per the Minister’s statement, we are dealing with a suspension on the analysis of the applications of Russian citizens to the program and not a ban;
  2. ii) The suspension will not affect investors that have a valid residence authorization;
  3. iii) The suspension is directly linked to the sanctions that will be divulged by the European Union and that target specific individuals, therefore both the nature of the suspension and the context identified to justify it, denote it is a temporary measure;
  4. iv) The announcement issued by the Ministry represents a restriction on current Portuguese legislation, a restriction that, in order to be valid, needs to be adequately stated and justified. Therefore, additional information and context is expected to be received in the coming days.

We will continue to monitor this situation as well as any further updates on any related matters. Furthermore, we will keep the current announcement dully updated.

Finally, we would like to extend our solidarity and support to all individuals affected by the extraordinary circumstances we are all living.

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