Doomed to repeat it: why the UK shouldn't reopen the golden visa door

Those who cannot remember the past are condemned to repeat it. The British Government would do well to consider this as it weighs up whether to reintroduce an investor visa route to the UK. There is now a wealth of evidence that scheme like tend to be a disaster, presenting national security risks with negligible benefit to our economy. So it is worth reminding ourselves of what has gone wrong before and what, if anything, could be different this time? 

Risky business 

Proposals to resurrect an investor visa scheme come as a surprise to those that have followed the UK’s experience with previous “Tier 1 (Investor)” route, which was closed in February 2022 following Russia’s large-scale invasion of Ukraine. A Government review of that scheme found it represented both a money laundering and national security risk, with the then immigration minister admitting that there was “little evidence that this type of passive investment programme offers an effective model for delivering material value to the UK economy”. 

With this in mind, how can the UK ensure a new investor visa pathway does not roll out the red-carpet for criminals and state threats, or is it too much risk for questionable benefit?  

Know your applicant 

The most pressing need of any new system would be to ensure applicants do not represent a significant danger to the UK. In 2015, our analysis highlighted the UK’s Tier 1 Investor visa was being targeted by those from high corruption risk jurisdictions and hostile states. These concerns proved well-founded, as over the years a steady flow of cases emerged showing Tier 1 visas given to those subsequently investigated or sanctioned by UK authorities, including:  

• members of the Prince Group, now designated by the UK Government as a transnational criminal organisation 
• the Hajiyev family from Azerbaijan, whose assets were targeted by the NCA using the UK’s first unexplained wealth orders 
• Roman Abramovich and nine other Russian oligarchs now sanctioned due to their links to Vladimir Putin 

These visa recipients were able to access the UK due to major deficiencies in the systems for checking applicants. This included a ‘blind faith’ period between 2008 and 2015 when there was no set responsibility for carrying out checks on applicants – the Home Office assumed the private sector were doing due diligence, while the private sector thought it was the Home Office’s responsibility. Consequently, the UK Government issued thousands of visas to applicants who they knew little about.  

Of more concern to the current UK Government should be the period after this. Checks were outsourced to the private regulated sector, yet a major investigation by the Times and Channel 4 found this offered little protection, as ‘professionals’ welcomed high-risk applicants with open arms. 

Any new system would likely still be largely reliant on the private sector to carry out anti-money laundering checks on applicants. How would the Government ensure these checks were carried out more effectively than during the previous system? 

Inviting trouble 

While some might think an “invitation only” system would be the main mitigation for risk, this approach brings with it a new set of difficulties. 

If the onus falls solely on officials to assess investors and make invitations, this discretion opens up the risk of undue influence and inducements from those seeking to secure invitations. One only has to remember the Hinduja scandal that toppled Peter Mandelson (the second time) to see how easily allegations might arise over quid pro quos, even if they are later reported to be unfounded. 

Safeguards would need to be put in place to mitigate corruption risk if this approach was pursued. 

A further complication to this approach is that risk does not remain static. In an increasingly volatile world, an investor who may have been deemed a safe bet one day can soon become an illicit finance or security risk when new facts emerge around them, or their circumstances change. 

If the Government were to lean on wealth managers and law firms to source possible visa recipients, this again exposes the regime to the weaknesses of private sector anti-money laundering regulation, especially when there could be strong financial incentives for those businesses involved in head-hunting applicants. Again, there are lessons to be learned from past experience. Dolfin Financial – one of the biggest operators in the Tier 1 visa sector – was forced to close following the UK’s financial watchdog identifying major concerns over its measures to tackle economic crime. What measures, if any, could the Government put in place to ensure another Dolfin did not open the door to more dubious applicants? 

Questionable rationale 

The invite only investor visa route appears to be a response to reports of a millionaire ‘exodus’ from the UK, authored by a firm who advises clients about cash for residency and citizenship schemes. It received widespread pickup, with analysis by the Tax Justice Network, Tax Justice UK, and Patriotic Millionaires UK found almost 11,000 articles parroting these claims. Yet their research also found the claims of an exodus were unfounded. Indeed the original authors of the report have now rowed back on the claims in its initial report. So is this a solution looking for a problem? If the Government are keen on attracting talent and investment, other routes are available which focus on skills and success, rather than access to £5 million.  

Sending the wrong message 

The UK is in a crucial phase in its battle against illicit finance, and its efforts will soon be under global scrutiny. The UK now holds the Presidency of the global anti-money laundering standards body, the Financial Action Task Force, meaning it will be responsible for delivering key priorities in tackling illicit finance globally during this time. The UK itself will be subject to a FATF review over the next 18 months seeing its own anti-money laundering measures assessed and graded. In 2023 FATF published a report warning of the risks posed by citizenship and residency by investment schemes. Any move by the UK to reintroduce such a scheme threatens to undermine the UK’s FATF Presidency as well as its own assessment. 

On top of this the UK is hosting a global summit in December aimed at tackling illicit finance. At a time when other countries are closing their citizenship by investment schemes, the UK introducing a new investor visa route may lead to questions around Britain’s credibility in the global fight against money laundering. 

The risks around investor visa schemes are now well understood, threatening the UK’s national security and financial system, as well as its credibility as a leader in the fight against dirty money. In 2025, Transparency International co-signed a letter to the Chancellor urging a rethink of the proposals to introduce a new one. With this in mind, it may be best for the next Prime Minister to find new ways to attract investment to the UK.