On May 13, 2022, the Regulation Amending the Regulation on the Implementation of the Law on Turkish Citizenship was published in Turkey’s Official Gazette. The new regulation amended some provisions in the 2010 Regulation on the Implementation of the Law on Turkish Citizenship that govern the country’s citizenship-by-investment program. This program makes a foreigner who invests in Turkish assets or investment funds eligible to obtain Turkish citizenship without needing to fulfill the lawful residency requirement that is part of the ordinary eligibility criteria.
Under the new rules, persons become eligible for citizenship without the residency requirement by (1) purchasing real estate in Turkey with a value of at least US$500,000, or the equivalent in a foreign currency, under an agreement not to sell for three years, or (2) concluding a contract promising the sale of a condominium or a condominium easement (for an apartment that is not yet built or is in the process of being built) for a minimum of US$500,000, paid in cash, with a commitment not to transfer or cancel the easement for a period of three years. (Regulation art. 20(2)(b).) The amendments increased the value limits for both options, which were previously US$250,000.
The amendments also expanded eligibility for Turkish citizenship under the regulation to those who invest US$500,000 in a retirement fund designated by the Turkish Insurance and Private Retirement Regulation and Supervision Authority, with a commitment not to withdraw money for three years. (New art. 20(2)(f).)
The amendments supplement the existing citizenship-by-investment program by providing for the following additional bases for eligibility: making a fixed capital investment of at least US$500,000; creating 50 jobs in Turkey; depositing US$500,000 or the equivalent in foreign currency in a bank operating in Turkey, with a commitment not to withdraw for three years; investing at least US$500,000 in Turkish sovereign debt securities, with a commitment to hold for three years; or investing US$500,000 in a real estate investment fund or venture capital investment fund, with a commitment not to withdraw for three years. (Regulation art. 20(2)(a), (c), (d), (e).) Satisfying citizenship-by-investment criteria does not guarantee citizenship — the executive has wide discretion to deny a citizenship application on grounds of national security and public order. (Law on Turkish Citizenship art. 12.)The amendments to the citizenship-by-investment rules were made in the context of the recently accelerating depreciation of the Turkish lira, which some observers have characterized as a currency crisis.