EMPOWERING GLOBAL CITIZENSHIP®

MONTENEGRO
CITIZENSHIP BY INVESTMENT PROGRAM

CLIENT FACILITATOR AGREEMENT

MNE_CUS_CFA_2019-11-20

ARTON ADVISORS
TORONTO • MONTREAL • LONDON • PARIS • SOFIA • ISTANBUL TOWER 1, LEVEL 20, SUITE 2004, BURJ BOULEVARD PLAZA, DUBAI, UAE
LIMASSOL • CAPE TOWN • BEIRUT • SINGAPORE • DUBAI • BEIJING T +971 4 456 9220 F +9714 456 9229 WWW.ARTONCAPITAL.COM
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CITIZENSHIP BY INVESTMENT PROGRAM

CLIENT FACILITATOR AGREEMENT

THIS AGREEMENT

BETWEEN:
ARTON ADVISORS FZE, registered in Ajman Free Zone, license #7039, address the Boulevard Plaza, Tower 1, Suite
#2004, P.O. Box 31303, Dubai, United Arab Emirates, herein acting and represented by

, VP Business Development
..................................................................................................................................................................................................................................,
Name, position

...................................................................................................., ……….....................................................................................,
Email address Telephone

duly authorized as s/he declares,

hereinafter referred to as “ARTON” OF THE FIRST PART,

AND:

........................................................................................................................................................................................................,
Name

........................................................................................................................................................................................................,
Date and place of birth

........................................................................................................................................................................................................,
Current residential address

hereinafter referred to as “CLIENT” OF THE SECOND PART,

This Agreement includes and incorporates by reference the following Schedules:

• Schedule A: Scope of Work;
• Schedule B: Payment schedule;
• Schedule C: Grounds of refusal;
• Schedule D: Selected property.

WITNESSES THAT WHEREAS:

A. ARTON has experience facilitating investors and their families in emigrating to various jurisdictions;
B. ARTON uses its expertise and worldwide network to identify suitable individuals considering immigration to various
countries as Investors;
C. ARTON and CLIENT wish to enter into this Agreement to more particularly set forth the arrangement between the
parties in connection with the application process.
NOW THEREFORE in consideration of the premises, covenants, agreements and conditions herein contained and
other good and valuable consideration (the receipt and sufficiency of which is hereby acknowledged) the parties
hereto covenant and agree with each other as follows:

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1. ENGAGEMENT OF ARTON
1.1 ARTON, itself or through a certified partner/subcontractor, shall perform on behalf of CLIENT the services listed in
the Scope of Work schedule attached hereto as Schedule A.

2. CLIENT CONSENT AND RESPONSIBILITIES

2.1 CLIENT shall provide ARTON with any requested information or documents in order to perform its duties as well
as to adhere to ARTON’s instructions given in the application process.
2.2 CLIENT hereby consents to ARTON or its agents, partners and subcontractors, collecting, using and disclosing
the personal information of CLIENT, obtained pursuant to the Enquiries and Searches, for the purpose of considering
and determining the eligibility of CLIENT as an applicant under the Program. ARTON will share such personal
information received from Third Parties with CLIENT.
2.3 CLIENT acknowledges and understands that while ARTON will use reasonable skill and care and carry out its
services hereunder in a timely and professional manner, ARTON makes no guarantee or assurance to CLIENT that
the CLIENT will be accepted as an applicant under the Program or accepted as a resident/citizen by the relevant state
authorities and shall only be responsible to provide the services listed in this Agreement. For avoidance of doubt,
grant, refusal or revocation of CLIENT’s status under the Program is made under the sole discretion of the relevant
state authorities and ARTON is neither involved in the process nor is ARTON liable or responsible in any manner
whatsoever for any delay in processing, granting, rejection or revocation of CLIENT’s application under the Program.
2.4 CLIENT shall respect all legal requirements regarding the application process, including but not limited to
maintenance of CLIENT investment under the applicable rules, and acknowledges that any breach of CLIENT
legal obligations may lead to revocation of his/her status to which ARTON shall not bear responsibility.
2.5 By signing this agreement, CLIENT hereby give their consent to ARTON to transfer CLIENT’s personal data –
including without limitation identity of CLIENT, CLIENT’s personal and professional background, documents and
statements pertinent to the accumulation of CLIENT’s personal net-worth, the duties entrusted to ARTON, the
investment, the origin of funds, and the investment process to a Third Country or an international organization in line
with Article 49(1)(a) of the General Data Protection Regulation (GDPR). This consent shall not be deemed to act as a
limitation or waiver of any obligation that ARTON may have vis-a-vis any applicable law. In line with Article 7(3) of the
GDPR, this consent may be withdrawn at any time in the future by sending an email to info@artoncapital.com or by
other methods of communication listed in ARTON’s General Privacy Notice, which is available upon request. The
withdrawal of consent shall not affect the lawfulness of processing based on consent before withdrawal.
2.6 ARTON implements appropriate technical and organizational security measures to (1) protect CLIENT’s personal
information in its custody and (2) prevent unauthorized and unlawful processing of, or accidental loss, destruction or
damage of CLIENT’s personal data, taking into account the guidelines promulgated in Article 32 of the GDPR, and
takes every reasonable precaution while handling CLIENT’s personal data and shall not be liable in any manner
whatsoever to CLIENT for any documents which are lost in transit by accident, theft, natural calamities (act of God) or
any other reason outside the control of, or not arising out of a willful default of ARTON.
2.7 All information disclosed to CLIENT regarding the mechanics or substance of the Program shall be treated as
confidential (“Confidential Information”) and shall not be divulged by CLIENT to any person without the prior written
consent of ARTON, which consent shall not be unreasonably withheld.

3. APPLICATION OF FEES
3.1 CLIENT shall make the necessary transfer to cover the investment amount and the applicable government and
program fees in accordance with the Payment schedule introduced in Schedule B and Schedule D.
3.2 CLIENT must cover all bank fees and charges so that the net amount received from CLIENT is the same as the one
indicated in Schedule B and Schedule D.

4. COMMENCEMENT AND DURATION

4.1 This Agreement shall become valid on the date it is signed. If there is a difference between the signature dates, the
later date shall be considered as the Commencement date.
4.2 Subject to being terminated before the parties have fulfilled their obligations set here above, this Agreement shall
continue in force from the Commencement date until the earlier of events as outlined in Clause 5.

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5. TERMINATION PROVISIONS
5.1 Notwithstanding anything to the contrary set forth herein, ARTON may terminate this Agreement forthwith by
sending a written notice to CLIENT, and the Fee shall be deemed non-refundable, if:
a. CLIENT withdraws the immigration application after signing this Agreement;
b. CLIENT refuses to attend any interview when convened by ARTON with the relevant state authorities;
c. after 2 (two) months has passed from the Commencement Date, CLIENT fails to provide ARTON with any
requested information or documents to perform its duties;
d. after 30 (thirty) as of signing Schedule D, CLIENT fails to provide ARTON with any requested information or
documents to perform its duties;
e. CLIENT has not made the required payments in the amount and the prescribed terms in Schedule B and/or
Schedule D of this Agreement, unless otherwise agreed in writing in the correspondence regarding the
personal investment under the Program;
f. any information that CLIENT has provided in respect of the immigration application has turned out to be untrue,
inaccurate or incomplete;
g. CLIENT commits a material breach of its obligations under this Agreement and in the case of a breach capable
of remedy, such breach is not remedied within 14 (fourteen) days of CLIENT being notified of such breach.
5.2 In the event of any termination of this Agreement, ARTON shall return any and all original documents, which
CLIENT has provided, and ARTON and its agents shall destroy any documents or information in their possession that
represents non-public personal or financial information regarding CLIENT, unless ARTON and its agents are legally
required to maintain such information.

6. NOTICE
6.1 Any notice, demand or other communication required or permitted to be given to any party hereunder shall be
given in writing and addressed as follows (or to such other address as the addressee party may from time to time
provide in a notice given under this Section 6):
a. In the case of ARTON:
...................................................................................................................................................................
...................................................................................................................................................................

b. In the case of the CLIENT:

...................................................................................................................................................................
...................................................................................................................................................................

7. MISCELLANEOUS PROVISIONS
7.1 No subsequent alteration, amendment, change or addition to this Agreement will be binding upon the parties
hereto unless duly acknowledged and signed by both parties.
7.2 The validity of this Agreement, its interpretation, implementation, enforcement, the respective rights and
obligations of the Parties and all other matters arising in any way out of it, or its expiration or earlier termination for
any reason shall be governed by and construed in accordance with the laws of Dubai, UAE.
7.3 CLIENT fully releases, acquits, waives and forever discharges ARTON and its controlled entities, affiliates,
subsidiaries, sister companies, successors, assigns, and all of its respective agents, shareholders, directors, officers,
representatives, employees, partners, service providers, other representatives from any and all claims, charges,
complaints, actions, causes of action, disputes, demands, agreements, covenants, promises, losses, liabilities,
judgments, obligations, debts, direct and indirect damages, lost profits, reputational damages, attorneys’ fees, costs
and/or any other liabilities of any kind, nature, or character whatsoever, that might arise out from the delay, rejection
or revocation of the CLIENT’s application under the Program and from any other agreement signed with ARTON in
relation to CLIENT’s application under the Program, including this Client Facilitator Agreement.

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7.4 In the event of any dispute between the Parties arising under or about this Agreement, the Parties shall attempt
to settle the matter by negotiations between them in good faith. If one Party serves formal written notice on the other
Party that a dispute arising under or about this Agreement has arisen and the Parties are unable to resolve the dispute
within a period of thirty (30) days from the service of such notice, the courts of Dubai, UAE will have the sole
jurisdiction.
7.5 The Schedules attached to this Agreement are an integral part hereof and are incorporated into this Agreement
by reference and are deemed to be part hereof.
IN WITNESS WHEREOF the parties thereto have executed this Agreement as of the date referred to above in two
identical copies.

Signed on ................................................................................................. by ARTON ADVISORS FZE:

Name ................................................................................................. Signature ....................................................

Signed on ................................................................................................. by CLIENT:

Name ................................................................................................. Signature ....................................................

In the presence of:

Name ................................................................................................. Signature ....................................................
Address .......................................................................................................................................................................................
Occupation .......................................................................................................................................................................................

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SCHEDULE A
SCOPE OF WORK

A1.1 By signing this Agreement, the CLIENT hereby appoints ARTON to act on CLIENT’s behalf and represent CLIENT
in relation to and upon carrying out all procedures pursuant to the Montenegrin legislation for or in connection with
CLIENT’s participation in the Citizenship by Investment Program of Montenegro. This includes acting on CLIENT’s
behalf and representing CLIENT in the procedures under the Decision on The Criteria, Method and Procedure for
Selection of Persons Who May Acquire Montenegrin Citizenship by Admission for the Purpose of Implementation of
Special Investment Programs of Special Importance for the Business and Economic Interests of Montenegro adopted
on November 22, 2018 by the Government of Montenegro pursuant to Article 3a paragraph 2 of the Decision on the
Criteria for Determining Scientific, Business, Economic, Cultural and Sports Interest of Montenegro for the Acquisition
of Montenegrin Citizenship by Admission (Official Gazette of Montenegro 34/10, 40/16 and 62/18).
A1.2 ARTON, itself or through a certified partner/subcontractor, shall perform the following services on behalf of the
CLIENT:
a. act as facilitator and coordinator on behalf of the CLIENT in respect of all matters pertaining to the immigration
application, including, without limitation, liaising between the CLIENT, the Montenegrin Authorities, the real
estate developer, and a Lawyer as defined below;
b. engage various institutions to make enquiries, verifications and/or due diligence searches of the CLIENT,
verification of the source of the funds, and a background verification report which is part of the CLIENT’s
immigration application;
c. engage a lawyer, to act on behalf of CLIENT and on behalf of all qualifying family members in all matters
pertaining to the citizenship application, including, without limitation, liaising between CLIENT, the
Montenegrin Authorities, and the real estate developers (‘Lawyer’).

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SCHEDULE B
PAYMENT SCHEDULE

B1. DONATION
B1.1 CLIENT hereby acknowledges and agrees that CLIENT must deposit to a designated escrow account under the
Citizenship by Investment Program of Montenegro the amount of €100,000 intended for the development of less
developed local self-government units for the purpose referred to in Article 18 of the Law on Regional Development.
This amount is considered non-refundable contribution under the Citizenship by Investment Program of Montenegro.
B1.2 CLENT hereby acknowledges and agrees that in the event the application is refused by the relevant state
authorities the amount referred to in Section B1.1 shall be refunded in full by the Montenegrin Government, according
to Article 15 of the Decision on the Criteria, Method and Procedure for Selection of Persons Who May Acquire
Montenegrin Citizenship by Admission for the Purpose of Implementation of Special Investment Programs of Special
Importance for the Business and Economic Interests of Montenegro adopted by the Government of Montenegro on
November 22, 2018.
B1.3 CLIENT hereby acknowledges and agrees that the amount specified in Section B1.1 is a requirement under the
Citizenship by Investment Program of Montenegro and failure to make this contribution in the specified terms to the
designated escrow account may result in CLIENT’s disqualification from the application procedure.

B2. INVESTMENT OPTION

B2.1 CLIENT hereby acknowledges and agrees that together with the donation under Section B1.1, CLIENT must make
investment in real estate development project determined by the Government of Montenegro upon proposal of the
public administration body in charge of sustainable development and tourism.
B2.2 CLIENT hereby acknowledges and confirms that they select the following investment option, based on current
project availability:

A. Acquisition of property for a total value
equal to or above €450,000 for the purpose
of investing in some of the development
projects in the Capital of Podgorica or the
coastal region of Montenegro.
■ B. Acquisition of property for a total value equal
to or above €250,000 for the purpose of
investing in some of the development projects
in the northern or central region of Montenegro,
save for the Capital of Podgorica.

TOTAL A: see Schedule D TOTAL B: see Schedule D

B2.3 CLIENT acknowledges and agrees that unless otherwise advised by ARTON, the payment under Section B2.2
shall have to be made within the terms set out in Schedule D to this Agreement.
B2.4 CLIENT acknowledges and agrees that the Government of Montenegro may set a minimum mandatory holding
term of the investment under Section B2.2.
B2.5 CLIENT hereby acknowledges and agrees that the investment specified in Section B2.2 is a requirement under
the Citizenship by Investment Program of Montenegro and failure to make this investment in the specified terms to
the designated escrow account may result in CLIENT’s disqualification from the application procedure.
B2.6 CLENT hereby acknowledges and agrees that in the event the application is refused by the relevant state
authorities, the investment amount specified in Section B2.2 and in Schedule D shall be refunded in full by the
Montenegrin Government, according to Article 15 of the Decision on the Criteria, Method and Procedure for Selection
of Persons Who May Acquire Montenegrin Citizenship by Admission for the Purpose of Implementation of Special
Investment Programs of Special Importance for the Business and Economic Interests of Montenegro adopted by the
Government of Montenegro on November 22, 2018.

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B3. DEPENDENTS
B3.1 By signing this Agreement, CLIENT confirms that CLIENT wishes to include the following family members
under CLIENT’s application:
A. No family members B. Family members (relation to CLIENT, name, and age):
……………………………………………………………………………………....……………………….
……………………………………………………………………………………....……………………….
……………………………………………………………………………………....……………………….
……………………………………………………………………………………....……………………….
……………………………………………………………………………………....……………………….
……………………………………………………………………………………....……………………….
……………………………………………………………………………………....……………………….
……………………………………………………………………………………....……………………….
B4. BREAKDOWN OF FEES
B4.1 The table below shows the breakdown of the cost pertinent to CLIENT’s application for the Program:

Item Amount (EUR)

Government fees €10,000

Due diligence fees €10,000

Total (EUR): €10,000

B4.2 CLIENT acknowledges and agrees that 5% VAT applies to AC advisory fees in case CLIENT is UAE resident.
B4.3 CLIENT acknowledges and agrees that unless otherwise specifically agreed by the Parties in writing, all and any
costs and expenses pertinent to international travels and sojourn for the CLIENT and any accompanying family
members in relation to the application process under the Program shall be at the expense of CLIENT.

B5. PAYMENT SCHEDULE

B5.1 The investment and the applicable fees are due as follows:
a. Investment / Contribution: 100 (one hundred) percent due once approval in principle is issued by the Program.
CLIENT acknowledges that the real estate developer may require the advance transfer of reservation deposit.
The amount and the schedule of payment of such reservation deposit are subject of separate agreement,
between the CLIENT and the respective real estate developer. Some developers may insist on all purchase
funds in escrow at the time of the application submission.
b. Program processing fees: 100 (one hundred) percent upon signing this Agreement unless otherwise advised
by ARTON. Refund policies may apply subject to the provisions of the applicable legislation.

B6. WIRE TRANSFER INSTRUCTIONS

B6.1 All payments under this Schedule B shall be transferred as per Wire Transfer Instructions sent to CLIENT by
ARTON.
B6.2 The wired funds must cover all bank fees and charges so that the net amount received from CLIENT is the same
as the one indicated in the Wire Transfer Instructions.
B6.3 Upon receipt of funds, confirmation of the funds received will be issued to CLIENT.

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SCHEDULE C
GROUNDS FOR REVOCATION

C1.1 CLIENT is required to review the following section and sign it. Please contact ARTON if for any reason CLIENT is
not clear about the text, and/or is not clear about CLIENT’s situation regarding any point listed herein.
C1.2 CLIENT acknowledges and understands that a person who was acquired Montenegrin citizenship on the grounds
of an investment can be deprived of it if it is established that:

• CLIENT has had given false information or deliberately concealed facts or circumstances in connection with
the application criteria on their application form or if the international due diligence agent has given inaccurate
data in their report. In either case, the funds transferred by CLIENT under the program shall not be refunded;
• the decree on naturalization has been made on the basis of false statement; deliberate concealment of facts
or circumstances important for making of decree, except if the person who acquired the Montenegrin
citizenship should become stateless person;
• the person is irrevocably sentenced for criminal offence against humanity and other interests protected by the
International Law;
• the person is irrevocably sentenced for planning, organizing, financing or any other manner of assisting to or
committing of terrorist acts or providing of shelter to organizers, perpetrators or participants in terrorist
activities;
• the person is a member of organization with activities aiming against the security and defense of Montenegro.

CLIENT:
Name ................................................................................................... Signature ............................................................

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SCHEDULE D
SELECTED PROJECT

D1.1 By signing this Schedule D, CLIENT hereby acknowledges that the following property/properties represent
CLIENT’s selection for the Program:
…………………………………………………………………………………………………………………………………………………………………..………………………………………
…………………………………………………………………………………………………………………………………………………………………..………………………………………
…………………………………………………………………………………………………………………………………………………………………..………………………………………
…………………………………………………………………………………………………………………………………………………………………..………………………………………
TOTAL AMOUNT OF INVESTMENT: ……………………………………………………………………………………………………………….………….
…………………………………………………………………………………………………………………………………………………………………………….......….
D1.2 By signing this Schedule D, CLIENT hereby acknowledges that CLIENT must transfer the total amount of the
investment in accordance with wire transfer instructions sent to CLIENT after which CLIENT’s investment will be subject
to project availability.
D1.3 CLIENT acknowledges and understands that failure to cover the investment and applicable fees may result in the
rejection of CLIENT’s application under the Program.

Signed at ...................................................................................... on this ............... day of ......................................... 20.....

CLIENT:
Name ........................................................................................... Signature ...............................................................
in the presence of:
Name .................................................................................................................. Signature ..............................................................................
Address .................................................................................................................. Occupation ..............................................................................

Signed at ....................................................................................... on this ............... day of ......................................... 20.....

ARTON ADVISORS FZE:
Name ........................................................................................... Signature ...............................................................

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