The Golden Visa due diligence checklist nobody publishes

Most Golden Visa marketing material focuses on benefits. This page focuses on what can go wrong — and the specific things to verify before signing anything.

On the program itself

• Read the actual law, not the brochure. Most programs are governed by 1–2 specific statutes (Portugal: Lei 23/2007 + Lei 56/2023; Greece: Law 4251/2014 amendments). Either read it or hire a local lawyer who has.
• Check the regulator's published statistics. AIMA (Portugal), Greek Ministry of Migration, USCIS (EB-5) all publish approval rates and processing times. Compare against what your consultant is promising.
• Look for pending reforms. Spain's closure was telegraphed for 18 months. Portugal's real estate exit was telegraphed for a year. Read local political news, not just immigration websites.

On the investment vehicle

• Who is the regulator? Portuguese funds must be CMVM-registered. Greek developers must hold a builder's license and clean title. EB-5 Regional Centers are USCIS-designated.
• What's the track record? Has this fund manager ever exited a fund? At what return? How many EB-5 projects has this Regional Center successfully processed I-829s for?
• Where does my money sit between subscription and deployment? Escrow account? Whose escrow? Is it segregated?
• What are the senior debts ahead of my equity?
• What's the clawback if the program rejects my visa?

On the consultant or agent

• Who pays them? If a consultant offers 'free' services, the fund or developer pays them a 5–8% commission. That's not free, that's a hidden fee on you.
• Are they licensed? Lawyers in Portugal must be Ordem dos Advogados members. Real estate agents in Greece must be registered. Immigration consultants are often unregulated.
• Will they put your fee structure in writing — including all kickbacks from third parties?
• Get a second opinion from a lawyer with no economic interest in your investment choice.

On the fund / project itself

• Audited financial statements for the last 3 years
• List of LPs / co-investors and concentration
• Independent valuation of underlying assets
• Specific deployment plan with milestones
• Exit mechanics and historical liquidity events

On your own situation

• Source of funds documentation, ready before you start
• Background check / police clearances from every country you've lived in for 6+ months over the past 10 years
• Apostilled birth, marriage and education certificates for all dependents
• Tax residency certificates from your current country
• Pre-immigration tax opinion from your home country advisor

If the answer to 'when can I see audited financials?' is 'after you sign the NDA and pay the reservation fee', walk away.

Red flags worth walking away over

• Guaranteed buyback at par after 5 years (illegal in most jurisdictions for risk-bearing investments)
• Pressure to wire to a personal account, not an escrow
• Consultant who insists on a single fund / project
• Promises about citizenship timelines that are faster than the published statute allows
• Refusal to introduce you to existing investors who completed the program

FAQs