Location, Timing, Execution: Our Method

Revision notes#

This article was corrected on 27 September 2026. A check of its figures and attributions against the cited sources found errors, which have been corrected in the text. The full list, with what the article said and what it says now, is in the corrections section at the end.

This article was corrected on 29 September 2026. An earlier version described Victaura's positions beyond its public project pages, with project labels, permit and construction dates those pages do not give, and design work in Ras Al Khaimah, where the position is off-plan capital. The text now follows those pages, and the disclosure of the positions sits at the end. Co-investment arrangements that are not set out on those pages were removed.

This article was corrected on 13 October 2026. The text, a table and the key takeaways gave construction and delivery years for two of Victaura's projects that their public project pages do not give. They have been removed, and the text follows those pages. The text and a table also tied the stage of one project to a permitting milestone that its project page does not give; that link has been removed.

This article was corrected on 13 October 2026. The corrections of 27 September presented two earlier counts of Article 24-bis taxpayers as errors. Both have published sources in different series, an Assonime study and the Department of Finance's income tax statistics, and the corrections section now says so. The figures in the text are unchanged.

This article was corrected on 13 October 2026. The location section and the key takeaways gave the ceiling on Zanzibar leases as enacted in 1992. They now give it as amended in 2010 and 2018, read in the acts published by Zanzibar's House of Representatives, and the corrections section says so.

The three principles#

Every Victaura investment rests on three principles, in this order: Location, Timing, Execution. Each answers a different question. Location answers what the asset is. Timing answers when to commit capital. Execution answers how the scarce site is converted into a finished, scarce product that an institutional buyer will underwrite.

The order is not stylistic. A finished building cannot fix the wrong site, because the constraint that protects value is geographic or statutory, and that constraint cannot be relocated. A correctly timed entry into the wrong jurisdiction is a cycle bet, not a value-add thesis. A scarce site without execution is a permission to admire the land. Each principle is necessary. None is sufficient on its own.

This article is the operating manual of the model. It restates each principle with the regulatory texts, cycle base rates and underwriting inputs that sit behind it, and maps four of the markets where we hold positions (Lake Como, Zanzibar and Gili Air, where we develop projects, and Ras Al Khaimah, where we hold an off-plan capital position) against the three. The companion reading is our public Approach page, /en/our-approach/.

Location: structural scarcity, not narrative scarcity#

Scarcity is the first protection of value at the top of the market, and not all scarcity is equivalent. The relevant distinction is between scarcity that is statutory, constitutional or geographic, and scarcity that is narrative. The first survives a transparent world. The second does not.

Lake Como is permit-constrained by statute. Under Italy's Code of Cultural Heritage and Landscape (Legislative Decree 42/2004, Article 142, paragraph 1, letter b), a 300-metre band from the shoreline of every lake is of landscape interest by law. On Como this covers the shoreline except areas that on 6 September 1985 were already zoned A or B in town plans (Article 142, paragraph 2). Any intervention requires prior autorizzazione paesaggistica, issued by the Region or a delegated body after the opinion of the territorially competent Soprintendenza (Article 146). The statute does not prohibit new building; it subjects every lakefront intervention to a landscape assessment. Our working assumption (Victaura Research assumption) is that this assessment favours the restoration of existing buildings over new volume. The protected band itself cannot be moved.

Indonesia is constitutionally constrained. Article 33(3) of the 1945 Constitution, together with the Basic Agrarian Law of 1960 (UUPA) Articles 9, 21 and 26(2), reserves Hak Milik (full freehold) for Indonesian citizens. International investors participate through long-term Hak Sewa (lease), Hak Pakai (Right to Use) for up to 80 years under Government Regulation 18/2021 (30 + 20 + 30), or a foreign-owned company (PT PMA) holding Hak Guna Bangunan on land it does not own outright. On a small island like Gili Air the perimeter is also finite by arithmetic. The constraints stack: the freehold tier is structurally unavailable to foreign capital and the developable plot count is bounded by physical geography.

Zanzibar is statutorily constrained. Under the Land Tenure Act 1992, rights of occupancy are reserved to Zanzibaris and non-Zanzibaris access public land by lease, for a maximum of 99 years granted in terms of up to 33 years (Sections 24, 46 and 47, as amended in 2010 and 2018). There is no freehold option for non-citizens. The Zanzibar Investment Act 2023, which repealed the ZIPA Act 2018, has the Authority grant land leases to investors in Special Economic Zones and facilitate leases outside them through the Minister responsible for lands (Section 27) and grants Strategic Investment Status from USD 50 million on Unguja and USD 5 million on Pemba, with at least 30 per cent of capital as equity (Second Schedule). This is closer in legal grammar to the Indonesian framework than to the freehold designated zones of the United Arab Emirates.

Ras Al Khaimah is contractually scarce inside a defined freehold corridor. RAK Decision No. 20 of 2005 and Decision No. 12 of 2007 allow non-nationals to own freehold in projects of designated developers; the areas marketed as freehold include Al Marjan Island, Mina Al Arab and Al Hamra Village. The supply on Al Marjan is controlled by the master developer and shaped by Wynn Resorts' integrated resort, which holds the first commercial gaming facility licence issued in the United Arab Emirates (GCGRA, 4 October 2024) and whose estimated construction cost Wynn raised in August 2026 by USD 600 million to around USD 5.7 billion (Gulf News, 5 August 2026). Unlike Como, there is no statutory cap on aggregate supply. The scarcity is corridor scarcity, not statutory scarcity. The distinction is consequential for underwriting.

Narrative scarcity is what remains when statute, constitution and geography are stripped out. A market with around 10,000 branded units among the more than 34,000 residential units planned in Ras Al Khaimah for 2026 to 2030 (CBRE, reported September 2026) is a market with momentum, not structural scarcity. Knight Frank's PIRI 100 for 2025 reads Tokyo +58.5%, Dubai +25.1%, Lake Como +6.5%, Milan +0.4%, London -4.7%. In November 2025, before the Iran war, Knight Frank expected prime Dubai prices to rise around 3% in 2026 and noted that citywide price growth may have already peaked. In March 2026, after the war began, the value of Dubai residential sales fell nearly 20% on February, to USD 10.1 billion (REIDIN data).

Timing: reading the inflection points#

Timing is the discipline of reading structural drivers, not the noise of the cycle. We define an inflection point as the moment a binding constraint changes state. A permit grant. A statutory regime open or close. A milestone in an integrated-resort cycle. Timing is not a forecast; it is a posture against an observable event.

Lake Como, the fiscal and supply inflection of 2024 to 2026. Italy's Article 24-bis substitute tax was introduced in 2017 at €100,000, doubled to €200,000 for residence transferred after 10 August 2024 (DL 113/2024) and rose to €300,000 from 1 January 2026 (Law 199/2025, the Budget Law 2026). The MEF counted just under 100 users for tax year 2017; for 2024 the Corte dei Conti counts 1,923 beneficiaries, 1,374 main taxpayers and 549 family members (as reported by Il Fatto Quotidiano, June 2026). On prices, Knight Frank's PIRI 100 places Lake Como at +6.5% in 2025, and Engel & Völkers describes foreign demand on the lake as predominant, led by buyers from the United States, Germany and the Gulf. The inflection is the gap between a growing foreign demand base and a supply constrained by statute.

Ras Al Khaimah, the integrated-resort cycle and the 2026 conflict layer. Wynn Al Marjan was targeted for a 2027 opening. On the Q1 2026 earnings call of 7 May 2026, chief executive Craig Billings said Wynn expected 'a modest delay' in the opening timeline, citing logistical and shipping challenges in the region and referring to the regional conflict. On 4 August 2026 Wynn set the opening for September 2027 and raised the estimated construction cost by USD 600 million to around USD 5.7 billion (Gulf News, 5 August 2026). The Macau analogue is the base rate we use. As a Victaura Research assumption, not a sourced statistic, we underwrite an integrated-resort property cycle that peaks some years after opening and can correct by 30 to 50 per cent in a policy shock, the pattern we read in Macau around the 2014 to 2016 anti-corruption campaign. We treat Singapore's Marina Bay Sands as the more stable case. Timing in RAK is not the catch of the peak but the underwriting of a known mean-reversion pattern.

Zanzibar, the ZIPA permit and the arrivals inflection. OCGS Zanzibar recorded 736,755 international arrivals in 2024, up 15.4%, with Europe at approximately 72% of visitors and Italy the single largest source market at 11.8%; by the end of October 2025 arrivals had already reached 743,605 (The Citizen). The timing inflection is the ZIPA permit grant itself, the moment the construction window opens against a regulatory clock and a measurable demand curve. For a developer, the inflection is the permit, not the launch.

The UK non-dom abolition, the corridor effect. On 6 April 2025 the remittance basis for non-domiciled residents, whose roots go back to Pitt's income tax of 1799, was abolished and replaced by the four-year Foreign Income and Gains regime. No official count of departures since the reform exists yet: HMRC figures released in July 2026, as reported, show about 9,000 non-domiciled individuals leaving in the tax year to 5 April 2025, down from 11,200 the year before, and accurate post-reform estimates are not expected before next year. Henley & Partners had forecast a net loss of 16,500 UK millionaires in 2025; we do not use that figure, because Tax Policy Associates (Neidle, July 2025) questioned whether the data were fabricated and Henley's 2026 report contains no migration figures. Whatever the size of the corridor, the binding constraint at the receiving end is finished lakefront product, not residence quota.

Execution: the operator advantage#

In a market short of finished product, execution is the differentiator. Scarcity creates the entry barrier; execution converts entry into a deliverable asset. The four stages that determine outcome are permitting navigation, design discipline, construction execution and milestone capital deployment. Each is a defined process, not a marketing line.

Permitting navigation. On Lake Como the operative permits are the autorizzazione paesaggistica under D.Lgs 42/2004 (Region or delegated body, after the Soprintendenza's opinion), the permesso di costruire (Comune), and the technical authorisations that follow. The Modern Villa on Lake Como is permit-advanced; the Two Villas on Lake Como are in permit phase, with construction expected to follow in 2026. In Zanzibar the operative permit is the ZIPA permit. In Indonesia the operative structures are Hak Pakai or PT PMA Hak Guna Bangunan, with the permit cycle in parallel. The discipline is uniform: we begin construction only once the full authorisation process is complete. The cost of premature mobilisation is higher than the cost of waiting.

Design discipline. The setting is the asset. On a 300-metre protected band, design that fights the landscape does not pass landscape authorisation. On a coral coast the operative discipline is setback against sea level rise (a Western Indian Ocean trend of 3.88 mm per year against a global average of 3.45 mm per year, per Communications Earth & Environment, January 2026), light footprint, and marine-grade materials. Bernstein, Gustafson and Lewis (Journal of Financial Economics, 2019) found that US coastal homes exposed to sea level rise sell for approximately 7 per cent less than comparable unexposed homes, a discount driven by sophisticated buyers and communities worried about global warming. Setback is no longer an externality; it is an underwriting input.

Construction execution and milestone capital deployment. The standards we work to are institutional: document control, structural sign-off, milestone inspections, contractor selection, supplier traceability. We work with local craftsmen, suppliers and trades wherever possible, because the alternative is both more expensive and structurally weaker over a multi-year window. Capital is deployed against milestones (permit grant, foundations, structural envelope, finish-out, handover), which is how an institutional partner underwrites a project and how we structure inflow. The corollary is operator exposure to its own execution: no abstract capital wall protects a delivery that has slipped.

Ring-fencing by structure. Every project is held through a dedicated, ring-fenced SPV under Greystone B.V. (Netherlands), with governance at the project level. This is the structural answer to a question every institutional allocator asks: whether the capital in one project can be reached by the liabilities of another.

What happens when one is missing#

Location without execution is a permission to admire the land. A scarce site without an operator capable of navigating permits, commissioning compliant design and delivering institutional-grade construction is a holding cost. In a market short of finished product (Como is the canonical example), the constraint that protects value also blocks delivery for the unprepared operator. The site retains its scarcity; the investor retains the holding cost.

Timing without location is a cycle bet. Entering Dubai at +25.1 per cent PIRI in 2025 against a corridor with no statutory supply cap has no defence when the cycle moderates. Knight Frank's November 2025 forecast for Dubai prime, issued before the Iran war, was +3 per cent; CBRE counts around 10,000 branded units among the residential units planned in Ras Al Khaimah for 2026 to 2030; and the UAE intercepted missiles and drones on 4 and 5 May 2026, when a drone started a fire at an oil facility in Fujairah (Al Jazeera, 5 May 2026; Iran's Revolutionary Guards denied carrying out the attacks). As of 26 September 2026 no formal ceasefire is in force (GlobalSecurity, Iran war update). None of this disqualifies the corridor. It does mean the operator who entered on the cycle, without an exit defended by structural scarcity, is exposed to the 30 to 50 per cent draw-down that our Macau-based assumption places in the base rate.

Execution without location is irrelevant. This is the least common failure, because operators do not typically execute well into a non-scarce site. When it occurs, the finished product competes against an open supply curve, on price, not on constraint. The institutional bar is therefore the simultaneous presence of all three principles: a supply constraint at the site, an identified inflection at entry, and an operator who can deliver, with capital deployed against milestones.

The institutional bar#

Eighteen months of statute have closed the privacy-via-opacity model. On 1 January 2026 the EU's DAC8 directive entered into force and 46 jurisdictions began collecting data under the OECD Crypto-Asset Reporting Framework (CARF) for first exchanges in 2027, with 31 more committed to exchanges by 2028 or 2029 (OECD, 14 September 2026). Spain abolished its Golden Visa by Ley Orgánica 1/2025 in April 2025. The Court of Justice of the European Union ruled Malta's citizenship-by-investment scheme contrary to EU law in case C-181/23 on 29 April 2025. Portugal's 2024 State Budget (Law 82/2023) closed the original NHR regime to new entrants and replaced it with the narrower IFICI. The UK abolished the remittance basis for non-domiciled residents, rooted in Pitt's 1799 income tax, on 6 April 2025. The structural closure of opacity is dated: CARF exchanges are scheduled to cover all 77 committed jurisdictions by 2029.

What this means for the institutional bar is simple. Alignment, governance, disclosure and conflict are no longer private matters. The institutional buyer the segment now selects is the operator that publishes its assumptions, names its conflicts and triangulates its numbers. Our own conflicts are named in the disclosure at the end of this document, which sets out the positions held through Greystone B.V. and how the document is classified under MiFID II. We do not rely on the Henley wealth migration dataset: Tax Policy Associates (Neidle, July 2025) questioned whether its figures were fabricated, Henley said in August 2025 that it had initiated an independent audit and review of New World Wealth's methodology and data, and its 2026 report contains no migration figures.

Family office allocation to real estate is consistently misquoted. UBS GFO 2025 puts the average real estate allocation of family office portfolios at 11 per cent in 2024 (18 per cent in the United States, 11 per cent in Europe); Goldman Sachs Family Office Investment Insights 2025 reports 11 per cent for private real estate and infrastructure combined; the Campden and RBC North America Family Office Report 2024 reports an average of 17 per cent. These are allocations of the family office investment portfolio; our reading (Victaura Research assumption) is that they do not capture residences or real estate held by the family business. On a total wealth basis the only figure we found is older: Savills and Wealth-X estimated in 2014 that European UHNWIs held 31 per cent of their wealth in real estate. The figures are not in conflict; they measure different perimeters.

The 2026 application#

The framework is not a manifesto; it is what the live work looks like in the current year. Four of the markets where Victaura holds positions sit at four different stages of the Location-Timing-Execution sequence.

Lake Como, Pognana Lario and Carate Urio. Two of our projects on a lake whose shoreline band is protected by statute. The Modern Villa on Lake Como in Pognana Lario, a lakefront villa with a private dock held under regional concession, is permit-advanced. The Two Villas on Lake Como in Carate Urio are in permit phase, with construction expected to follow in 2026. PIRI places Lake Como at +6.5% in 2025; Engel & Völkers describes foreign demand as predominant, led by buyers from the United States, Germany and the Gulf. The timing inflection is the fiscal regime moving to €300,000 in 2026; the supply curve does not move.

Zanzibar, Nungwi. Two projects on the northern tip of Unguja. Arrivals reached 736,755 in 2024 (+15.4%), Italy the single largest source market. Secret Zanzibar Hotel & Villas is in active development. The execution work is climate-resilient design against a Western Indian Ocean sea level trend of 3.88 mm per year, setback discipline, and a light operational footprint.

Gili Air. Boutique scheme on a finite island in the Indonesian archipelago. Foreign tenure is Hak Pakai 80y or PT PMA Hak Guna Bangunan, no Hak Milik. Bali recorded approximately 6.3 million international arrivals in 2024 (Bali Provincial Tourism Office); Indonesia 13.9 million overall (BPS). The constraint stack is constitutional (UUPA 1960, Constitution Art. 33(3)) and physical. The execution work is parcel-level selection, a building envelope sized for bleach-event ecology, and a Hak Pakai tenure structure with an 80-year horizon.

Ras Al Khaimah, Al Marjan. Freehold for non-nationals under RAK Decisions 20/2005 and 12/2007. Wynn Al Marjan, estimated construction cost raised in August 2026 to around USD 5.7 billion from USD 5.1 billion (Gulf News), opening moved to September 2027 (Wynn Q2 2026 results, 4 August 2026) after a 'modest delay' flagged on the 7 May 2026 earnings call. The value of Dubai residential sales fell nearly 20% month on month in March 2026 (REIDIN). The US and Israeli war on Iran began on 28 February 2026 (Operation Epic Fury), the Strait of Hormuz was largely closed, and the UAE intercepted missiles and drones on 4 and 5 May 2026, when a drone started a fire at an oil facility in Fujairah (Al Jazeera; Iran's Revolutionary Guards denied carrying out the attacks); as of 26 September 2026 no formal ceasefire is in force and Hormuz oil traffic is reported at about 60 to 70 per cent of pre-war levels, a figure GlobalSecurity describes as unverified and attributes to officials speaking to The National on 23 September. The timing case is no longer the cycle catch but entry against a master-developer-controlled corridor, with the Macau correction window in the base rate. The execution work is of a different kind, because this is an off-plan capital position, not a development: an established local developer builds, and Victaura's work is unit selection, the timing of entry and the management of resale.

Each market sits at a different stage of the same framework. Como is the location-and-execution case at fiscal inflection. Zanzibar is the timing-and-execution case. Gili Air is the location-and-tenure case under constitutional constraint. RAK is the timing case under cycle and conflict risk. None is a single principle; all are the same three principles, weighted differently.

What this means for an investor#

For a family office or principal advisor, the implications are practical. First, our working assumption (Victaura Research assumption) is that locations with structural scarcity are less exposed to short-term cycles than the broader market. Second, the binding constraint at delivery is execution: in a constrained market, a site becomes an asset only once the finished product is delivered. Third, scarcity is verifiable: 300 metres is 300 metres, an island has the perimeter it has, a constitution either allows freehold to foreigners or it does not. Facts to underwrite, not narratives to take on trust.

The portfolio implication is diversification across jurisdictions, not concentration in one. Lake Como is permit-constrained and culturally consolidated. Zanzibar and Gili Air carry tenure ceilings that limit exit liquidity; Zanzibar arrivals grew 15.4% in 2024. RAK carries freehold liquidity but no statutory supply cap and a visible event-driven cycle. Exposure to each market has to be sized to its own friction profile.

The order matters because the principles are not interchangeable. Location first, because the constraint that protects value cannot be relocated. Timing second, because capital is committed against an observable event, not a forecast. Execution third, because it converts a scarce site into a finished, scarce asset an institutional partner will underwrite. Simple to state, demanding to execute. That is the entire point.

Skin in the game disclosure. Victaura, through its parent Greystone B.V. (Netherlands), develops projects on Lake Como (Italy), in Nungwi, Zanzibar (Tanzania), on Gili Air and in Uluwatu, Bali (Indonesia), and holds an off-plan capital position on Al Marjan Island, Ras Al Khaimah (UAE). Readers should assume commentary may be influenced by, or benefit, these positions. This document is classified as marketing material under MiFID II Article 24(3). It is not investment advice.

Corrections, 27 September 2026#

What the article said and what it says now. The published version said the 300-metre landscape band covers lakes classified of public interest, that the Soprintendenza issues the authorisation and that the statute rules out new lakefront building; D.Lgs 42/2004 Articles 142 and 146 apply the band to every lake, exclude areas zoned A or B in 1985, have the Region or a delegated body issue the authorisation after the Soprintendenza's opinion, and require authorisation rather than prohibiting construction. It cited Zanzibar leases of up to 99 years under Section 27 of the ZIPA Act 2018 and Strategic Investment Status under the Tanzania Investment Act 2022; the ZIPA Act 2018 was repealed by the Zanzibar Investment Act 2023, which sets the USD 50 million Unguja and USD 5 million Pemba thresholds, and leases rest on the Land Tenure Act 1992. That correction gave the Act's ceiling as 49 years, its 1992 wording; amendments of 2010 and 2018 set it at 99 years, granted in terms of up to 33. It based Ras Al Khaimah freehold on UAE Federal Law 11/2021, which concerns industrial property; the basis is RAK Decisions 20/2005 and 12/2007. It gave London prime at -2.2% in the PIRI 100; The Wealth Report 2026 gives -4.7%. It gave Lake Como +54% over five years and foreign demand of about 60% from Engel & Völkers and Nomisma; neither figure is in those sources, and both have been removed. It said Dubai prime transactions fell 20% year on year in March 2026; REIDIN data show the value of all residential sales fell nearly 20% on February. It gave 9,000 branded units in the Ras Al Khaimah pipeline; CBRE reports around 10,000. It dated Wynn's Q1 2026 call to 8 May 2026 and had Craig Billings attribute the delay to the Iran conflict; the call was on 7 May, Billings cited logistical and shipping challenges, and Wynn has since set the opening for September 2027. It quoted ECFR's Cinzia Bianco calling the UAE a front-line state and dated the Fujairah strikes to 3 and 4 May 2026; the quotation could not be found and has been removed, the strikes were on 4 and 5 May, and the conflict is now dated as of 26 September 2026. It gave 94 users of Italy's 24-bis regime in 2017 and about 1,631 in 2024, a 17-fold increase; the text now gives the MEF's count of just under 100 for 2017 and the Corte dei Conti's 1,923 beneficiaries for 2024, 1,374 of them main taxpayers. The two earlier figures have published sources in different series, 94 in an Assonime study on Agenzia delle Entrate payment data (Towards Italy, No. 7/2026) and 1,631 in the Department of Finance's income tax statistics for tax year 2024, so the 17-fold multiple compared two series. It gave a UK high-net-worth outflow of 1,800 to 3,800 with 400 to 600 moving to Italy, and a non-dom regime in continuous operation since 1799; these were unsourced model estimates and have been replaced by HMRC data, and the regime dates back to 1799 but was not continuous. It placed 76 jurisdictions under CARF from 1 January 2026; the OECD lists 46 collecting data from 2026 and 77 committed in total. It gave Western Indian Ocean sea level rise of about 3.5 mm per year, 4% above the global mean; the Communications Earth & Environment paper gives 3.88 mm per year for that basin. It described the Bernstein, Gustafson and Lewis discount as applying to Florida properties; the study covers US coastal homes. It gave a median family office real estate allocation of 11% from three converging surveys, and 25 to 40% of total wealth; UBS reports an average of 11%, Goldman Sachs 11% for real estate and infrastructure combined, Campden and RBC 17%, and the only total-wealth figure found is 31% from Savills and Wealth-X in 2014. The Macau correction of 30 to 50% is now labelled as a Victaura Research assumption, and the unsourced Singapore growth rate has been removed.

A further review on the same day refined some of the corrections above and fixed further points. The article described Wynn Al Marjan as a USD 5.1 billion resort; in August 2026 Wynn raised the estimated construction cost by USD 600 million to around USD 5.7 billion (Gulf News, 5 August 2026). It said the resort was targeted for an early 2027 opening and that press coverage linked the May 2026 delay to the Iran war; on the Q1 2026 call Wynn referred to opening in 2027, and Craig Billings cited logistical and shipping challenges and the regional conflict. It said Iran struck Fujairah on 4 and 5 May 2026; according to Al Jazeera, the UAE intercepted missiles and drones on both days, a drone started a fire at an oil facility in Fujairah on 4 May, and Iran's Revolutionary Guards denied carrying out the attacks. It gave Hormuz flows at 60 to 70 per cent of pre-war levels without qualification; GlobalSecurity describes that figure as unverified and attributes it to officials speaking to The National on 23 September. It said Section 27 of the Zanzibar Investment Act 2023 has the Authority grant land leases to investors; the section provides for leases in Special Economic Zones, with leases outside them facilitated through the Minister responsible for lands. In the execution section it named the Soprintendenza as the body issuing the Lake Como landscape authorisation; under Article 146 of D.Lgs 42/2004 the Region or a delegated body issues it after the Soprintendenza's opinion. It attributed Bali's 6.3 million international arrivals in 2024 to BPS; that figure comes from the Bali Provincial Tourism Office, while the 13.9 million for Indonesia is from BPS. It said Henley had not published the results of its August 2025 audit; the text now states only that Henley said it had initiated an independent audit and review of New World Wealth's methodology and data (Spear's, 19 August 2025).