Why we send one in ten families away — before they pay us anything

Since we launched, roughly one family in ten who has approached us has been told, politely, that we cannot take their case.

No fee has been paid. No application has been filed. In most instances, nothing is wrong with the family at all — the documentation behind their capital simply will not withstand the scrutiny that Latvia's authorities apply to every residence application. Sending them away costs us money. It is also the reason we can offer what we offer.

The screen we run before you pay us anything

When a family reaches us and asks about the Latvian investor residence programme, the first substantive conversation is not about our fees, our timelines, or our office in Riga. It is about the source of the €50,000 they are proposing to invest.

Our sworn advocate Mārtiņš Grīnbergs, admitted to the Latvian Bar in 2008, works with our partner law firm to review the family's bank statements and the documentation that supports the origin of that capital. This is done before the engagement letter is signed and before any money moves. If the documentation would not survive the multi-agency review that the Office of Citizenship and Migration Affairs (OCMA), the Latvian State Security Service, and the Latvian Financial Intelligence Unit conduct on every application, we say so at that stage.

The family walks away without having paid us anything.

Why we bear this cost

The Latvian programme has a feature that is unusual in European residency by investment: the €50,000 share-capital component is contractually protected. It is wired into our operating company as a share subscription, and the investor is registered as a shareholder in the Latvian Company Register within forty-eight hours. Our shareholder agreement contains a buyback clause: if the residence permit is refused, our company repurchases the shares at the full €50,000 subscription price. The capital returns to the family.

That clause is not marketing language. It is a legal obligation on us, enforceable in Latvian courts.

The consequence, if you think about it for a moment, is that we — not the family — carry the downside of a refused file. A firm that eats its own refusals cannot afford to submit weak ones. Every application we file that fails is €50,000 of our capital tied up in a buyback obligation. There is only one honest way for a firm in that position to operate: turn away the files that would fail, at the beginning, before anyone has paid or committed.

The one-in-ten rate is not generosity. It is what the structure forces us to do.

What we look for, and what turns a file away

The great majority of families who approach us have entirely legitimate wealth. The question is not whether the money is honestly earned. The question is whether the paper trail can prove that to a Latvian regulator who has never met the family.

We look for continuity: how the wealth was accumulated, over how many years, in which jurisdictions, through what transactions, and whether the documentation from banks, tax authorities, and corporate registries lines up. What most often causes us to send a file away is not wrongdoing. It is missing paperwork — bank records that are no longer available, transactions structured through intermediary entities whose accounts cannot be produced, or wealth transferred within a family generations ago without documentation that would satisfy a European authority today.

Where the gaps can be closed with additional evidence, we will tell the family exactly what to produce, and we will wait until they have it. Where they cannot be closed, we say so.

The alternative — and why we don't offer it

A different kind of firm could file the application anyway, take the fee, and let OCMA decide. If the application is refused, that firm keeps what it has been paid and the family loses the capital along with the refusal. The commercial logic is straightforward — for the firm, every application generates revenue whether it is approved or not.

That model exists across the European residence-by-investment market. We understand why it exists. We have chosen not to operate it because we do not believe it is possible to combine a genuine capital-protection guarantee with a policy of taking every case that walks through the door. One of the two has to give, and the version most commonly encountered in the market is that the "guarantee" turns out to be conditional on approval — which is another way of saying it is not a guarantee at all.

Our version is the other way round. The buyback obligation is unconditional if OCMA refuses the file. The corollary is that we will not accept a file we believe will not survive OCMA's review.

What this means if you are considering us

If you are a family investigating the Latvian programme and considering us as your counsel of record, the practical implication is straightforward. Our first conversation with you will be careful, and it will spend more time on the origin of the capital than on the destination. If, after that conversation, we say that the file is one we would like to take on, then the terms of the shareholder agreement and the buyback clause apply exactly as described. If we say that the file is not one we can take on, we will explain why, in writing, and we will suggest what would need to change for the answer to be different.

Either outcome is an honest answer. In our experience, most families prefer that to a warm reception followed by a filed application and a refused decision six months later.