Henley & Partners

In 2006, the firm restructured St. Kitts and Nevis's citizenship-by-investment program, and obtained exclusive rights to market St. Kitts & Nevis worldwide.[1] The company gave the country's government a $20,000 fee for every successful applicant for its passport program.[1] Applicants for passports could either invest in real state on the islands or donate to the Sugar Industry Diversification Foundation (SIDF), which was intended to invest on behalf of the St. Kitts and Nevis population.[1] The contract between Henley and Partners and St. Kitts and Nevis ended in 2013.[1]

In 2014, the US and Canada flagged that St. Kitts and Nevis was allowing financial criminals and individuals evading sanctions to obtain passports through the Henley and Partners scheme.[1] Canada ended its visa-free agreement with St. Kitts and Nevis.[1]

Observers have had persistent concerns about the lack of transparency about SIDF, which was set up by Henley and Partners. The IMF said in 2014 that the SIDF needs to make "substantial improvement in its reporting to enhance the transparency of its operations."[1] The U.S. State Department said in 2017 that there was a "lack of financial oversight" of the SIDF.[1] Transparency International said it was unclear whether the SIDF used its money to benefit the St. Kitts and Nevis population.[1]

It was later revealed that the SIDF's investments had failed. SIDF invested its money into a failed resort business and a company owned by a Henley associate with ties to chairman Christian Kälin.[1] In 2017, the St Kitts and Nevis government stopped allowing passport applicants to pay into the SIDF.[1]

According to 2022 reporting by the OCCRP, there is evidence that Henley CEO Christian Kälin helped to finance the successful 2010 re-election campaign of Denzil Douglas, the St. Kitts and Nevis prime minster.[15] At the same time, Henley entered into at least three agreements with the SCL Group or its affiliated companies to help each other in the Caribbean region.[15] Henley has denied financing the Douglas campaign. However, Douglas stated in an unpublished 2018 interview that Henley did fund his campaign and that the SCL Group was hired to manage the campaign. Henley responded by calling Douglas a liar.[15]

In 2013, Henley & Partners participated in a public tender and won the right to design and globally promote Malta's citizenship-by-investment program, the Malta Individual Investor Programme, which raised over $1 billion within 18 months of its launch.[16] Arton Capital, a competing firm, filed a judicial protest, appealing the decision to award the contract to its competitor, claiming that Henley & Partners provided consultation to the government on a similar program before.[17] Arton Capital settled out of court in 2015.[18]

The program provides citizenship to foreign individuals and their families who are believed to contribute to the country's economic development. The country later introduced more stringent conditions for acquiring citizenship, such as proof of residence in Malta for at least 12 months.[19]

The launch of the Malta Individual Investor Programme in 2014 drew criticism from opposition officials, who claimed the program could open a back door into Europe for criminals.[20] It was reported at the time that officials believed the screening process would be compromised because Malta had outsourced the vetting of citizenship applicants to a single company.[20]

Jho Low, a businessman involved in the 1Malaysia Development Berhad scandal and international fugitive, was believed to be a client of Henley & Partners. Media reported that Low obtained a Cypriot passport by investing €5 million in a transaction facilitated by the firm.[21][22][23] Henley & Partners denied these allegations, asserting that Low was never a client and was specifically rejected as such in 2015.[24] Leaked documents in 2021 revealed that Henley worked for Low through a Cypriot intermediary. Henley pocketed 710,000 euros for its services to Low.[25][26]

In 2021, thousands of the firm's emails and documents were leaked.[2] It revealed how some applicants to the Maltese scheme claimed to be resident of the country by renting apartments but leaving them unoccupied.[2] In an undercover video shot as part of the coverage following the leaks, an employee of the firm advised prospective applicants to only "do the bare minimum" in satisfying the scheme's criteria.[27] The documents also showed that Henley & Partners knew of government's plans to launch a citizenship-by-investment programme two months before the public tender for a company to operate it was annonuced.[28] As the European Union had clashed with the Maltese government over the programme before,[29][30] the leaks were seen as strengthening the EU's case against it.[30][31]

An OCCRP investigation, relying on leaked Henley documents, found the following clients in Henley's internal documents:[32]

• Seyed Ali Sadr Hashemi Nejad – an Iranian banker involved in large-scale sanctions evasion
• Ruben Vardanyan – a Russian banker involved in money laundering scandals
• Ali Othman Badri Sindi – an Iraqi Kurdish politician who was the Kurdistan region's minister of planning
• Hussain Ali Habib Sajwani – an Emirati property magnate sanctioned by Canada for his involvement in corruption
• Ricardo Benjamin Salinas Pliego – a Mexican businessperson with a history of controversies and fraud allegations
• Pedro Padilla Longoria – a Mexican businessperson charged by the U.S. Securities and Exchange Commission for fraud
• Sudheer Sriram – an Indian businessperson who has been flagged by Interpol in relation to fraud and been arrested by the Indian government
• Sergei Yuschenko – a Russian businessperson who was targeted in Russia for fraud
• Firuza Kerimova – the wife of Russian oligarch Suleyman Kerimov who was under sanctions by the United States and detained for tax evasion in France
• OlawaSeun Ogunbambo – a Nigerian oil magnate who was wanted in Nigeria for fraud
• Armen Sarkissian –  the President of Armenia