The 2020 CBI Index: Key findings – Caribbean still outranks rest of world

The CBI Index is intended as a practical tool, both for those who wish to compare citizenship by investment (CBI) programmes as a whole and for those who wish to compare specific aspects of each programme. These aspects are reflected by the CBI Index’s nine pillars: Freedom of Movement, Standard of Living, Minimum Investment Outlay, Mandatory Travel or Residence, Citizenship Timeline, Ease of Processing, Due Diligence, Family, and Certainty of Product.

Pillar 1: Freedom of Movement

European Union (EU) member states continue to offer the greatest number of countries and territories to which citizens can travel visa-free or with a visa-on-arrival, including free travel to the highest number of business centres. 

Schengen Area members Austria and Malta retained their scores of 10, with Cyprus also achieving 10 this year. Cyprus’ increase can be attributed to the fact that settlement rights are now considered under the Freedom of Movement Pillar. As members of the EU, Austria, Bulgaria, Cyprus, and Malta provide access to the greatest number of member states, the highest human development, and the greatest scope for movement of persons and workers. Bulgaria’s score of nine is a result of the lower number of jurisdictions made accessible on a visa-free and
visa-on-arrival basis.

The Caribbean island states of Antigua and Barbuda, Grenada, St Kitts and Nevis, and St Lucia closely follow the European nations with a score of seven. Of the 20 business hubs assessed in the 2020 CBI Index, citizens of St Kitts and Nevis and St Lucia have visa-free access to 15, and citizens of Antigua and Barbuda and Grenada have access to 14. Despite a slightly lower score of six, Dominica saw the greatest increase in visa-free and
 visa-on-arrival offerings since 2019 of all 14 CBI jurisdictions under evaluation.

Unlike Dominica, which forms part of the CARICOM Single Market and Economy along with its Caribbean counterparts, Vanuatu does not belong to a free-movement regime. In the 2020 CBI Index, Vanuatu fell below Dominica with a score of five.

New entrant Montenegro scored four points and was followed in descending order by Turkey and Cambodia, with Jordan once again attaining the lowest score. Being a member of ASEAN’s Economic Community did little to boost Cambodia’s score, as citizens of both Montenegro and Turkey can travel without a visa to more than twice as many destinations as citizens of Cambodia. 

Cambodia and Jordan each have visa-free access to only one business hub — in Cambodia’s case, Singapore, and in Jordan’s case, Hong Kong.

Pillar 2: Standard of Living

For the fourth consecutive year, Austria and Malta achieve the highest scores for standard of living with nine points. Their high life expectancy, safety levels, and ability to uphold basic freedoms propelled them to first place, as did their scores in education and gross national income. While Austria overshadows Malta with respect to education and gross national income, Malta performed better with respect to GDP growth and life expectancy. Cyprus achieves a score of eight and, once again, scored very highly in terms of citizens’ freedom and safety.

Achieving a score of seven points, the next rank comprises a diverse range of countries: Antigua and Barbuda, Bulgaria, Grenada, Montenegro, and Turkey. The two Caribbean nations in this group score better with respect to freedom. Antigua and Barbuda saw a marked increase in GDP growth since the 2019 CBI Index, and Grenada once again achieved the highest score of any country for education (with 16.6 years of schooling on average). Turkey improved its 2019 score by one point, largely as a result of its long-term educational reforms. Although coming in lowest of the European nations for education, gross national income, and citizens’ freedom, Montenegro’s competitive score for standard of living was achieved through its strong showing for safety and GDP growth.

St Kitts and Nevis and Dominica follow with a score of six points. Citizens of both enjoy the freedoms of their European counterparts, and St Kitts and Nevis also improved its gross national income, an indication of an improving economy. Advancing economic conditions were also reflected in Dominica’s improved score for GDP growth.

Cambodia is joined by Jordan, St Lucia, and Vanuatu in last place for the Standard of Living Pillar, with five points. St Lucia dropped one point from 2019, largely owing to a decline in relative safety — a common occurrence for countries with small populations where low incidences of crime can have a notable impact on statistics. Vanuatu’s single point loss over the previous period can be attributed to a small dip in life expectancy. 

Although Cambodia remains joint bottom for gross national income, it once again achieved the highest GDP growth with 7.5 per cent, narrowly outdoing Antigua and Barbuda. Cambodia, Jordan, and Vanuatu all rank highly for safety despite appearing in the bottom group for their overall pillar scores, while St Lucia mirrors the Caribbean countries of Dominica, Grenada, and St Kitts and Nevis with a maximum score for citizens’ freedom.

Pillar 3: Minimum Investment Outlay

With the exception of new entrant Montenegro, the scores under the Minimum Investment Outlay Pillar remain unchanged from the 2019 CBI Index. Fluctuations in currency exchange rates have had little impact and jurisdictions have not significantly altered the minimum threshold amounts for single applicants. Dominica and St Lucia once again attain a score of 10 by virtue of having the industry’s lowest threshold of US$100,000. While also offering citizenship to successful applicants for US$100,000, Antigua and Barbuda’s already sizeable Government Fee increased to US$30,000 on 1 April 2020, resulting in the country maintaining its score of nine.

The 2020 CBI Index once again assesses Vanuatu’s Development Support Programme (DSP) over the Vanuatu Contribution Programme (VCP). Having only been changed from an honorary citizenship programme in 2018, it is now a possibility that the DSP will become Vanuatu’s only CBI programme after a termination notice was issued to the sole authorised agent for the VCP in late May 2020. The minimum investment amount under the DSP stands at US$130,000, making it a more affordable option than Grenada and St Kitts and Nevis.

St Kitts and Nevis’ implementation of a limited-time offer for contributions to the government’s Sustainable Growth Fund only affects families, hence St Kitts and Nevis’ minimum investment amount remains on par with Grenada at US$150,000.

Cambodia and Turkey both scored eight, with Turkey’s minimum investment threshold undergoing no further reductions since it was slashed by 75 per cent in 2018.

Montenegro’s investment threshold scored six for its CBI Index debut. Its least expensive investment option is a €250,000 (US$294,000) investment in industry-specific, government-approved development projects in northern and central Montenegro, plus a €100,000 fee to be used to assist underdeveloped communities in the country. A total investment amount of €350,000 is therefore required, in addition to a significant €15,000 processing fee.

Bulgaria is followed by Malta, whose minimum investment amount remains unchanged in the 2020 CBI Index, but is set to increase significantly following the beginning of the Individual Investor Programme’s second iteration in September 2020. Jordan, Cyprus, and Austria also retained their investment requirements and were dealt the same scores.

Pillar 4: Mandatory Travel or Residence

There are five countries commanding this pillar: the Caribbean countries of Dominica, Grenada, St Kitts and Nevis, and St Lucia, as well as Jordan. These countries achieve perfect scores for imposing no travel or residence requirements on applicants, whether before, during, or after the grant of citizenship.

Newcomer Montenegro joined the second grouping of countries Austria, Cambodia, Turkey, and Vanuatu — all of which impose a one-time travel requirement on applicants — with a score of eight. Montenegro requires applicants to make a trip to collect their signed decision on the grant of citizenship from the Ministry of Internal Affairs. Turkey imposes a travel requirement for the purpose of supplying biometrics to obtain an ID card. However, some flexibility is afforded to applicants as biometrics can be taken at any Turkish consulate with the capacity to do so.

Antigua and Barbuda, Bulgaria, and Cyprus each scored six — a drop of one point due to methodological changes in the 2020 CBI Index, despite no change in programme requirements. People who obtain citizenship of Antigua and Barbuda must travel to the country to take the oath of allegiance and must be physically present for a minimum of five days within five years of obtaining citizenship. Children may fulfil these requirements after they turn 18. Both Bulgaria and Cyprus, while not enforcing physical residence requirements, require two trips to be made over the course of the application. Physical residence is distinguished from nominal residence. In Cyprus, for example, although there is a requirement to hold property in the country as a ‘permanent residence’ indefinitely, no physical presence is required.

Malta’s considerably lower score of two is a result of its strict travel and residence requirements. Applicants must make two trips to Malta — the first to provide biometric data and the second to take the oath of allegiance — and must spend a minimum of 12 months in the country before the grant of citizenship.

Pillar 5: Citizenship Timeline

With an average processing speed of three months, St Kitts and Nevis clinches the top position owing to its Accelerated Application Process. This is the industry’s only guaranteed fast-track route to citizenship, with successful applicants completing the process within 60 days of the submission, albeit for an additional cost.

Also with an average turnaround time of three months, and with a score of nine, are Dominica, Grenada, Jordan, Montenegro, and St Lucia. Vanuatu’s processing time increased in 2020, resulting in it too receiving a score of nine.

Montenegro issued its first application approval in February, only 95 days after submission, but processing times will need to be monitored as the programme comes under pressure to process a higher number of applications going forward. An increased focus on efficient application processing over the past two years has seen Grenada’s processing times steadily decrease, helping the country climb up in the rankings. Its reduced processing time may be at least partly down to its adoption of a two-stage submission process in November 2019. 

Jordan and St Lucia both maintained last year’s score; a possible indication that Jordan’s programme has not experienced a significant increase in investor demand over the past year. Turkey rose by two points, joining Cambodia with a score of eight, despite its ever-growing application numbers. Antigua and Barbuda and Cyprus maintained a score of six. 

Malta, Austria, and Bulgaria remain the slowest CBI programmes, with respective processing times of 13 months, 24 months, and several years depending on the investment option taken.

Pillar 6: Ease of Processing

For the fourth consecutive year, the Caribbean programmes dominate this pillar for their straightforward, streamlined processing models. Previous distinctions between the top scorer, Dominica, and the remainder of its neighbouring jurisdictions are now being reflected, along with other things, in a standalone Certainty of Product Pillar. Paving the way for further future collaboration, the Caribbean programmes apply similar processing mechanisms to ensure that the CBI process is not overly cumbersome for applicants. They do not require applicants to undergo mandatory interviews, language tests, or culture or history tests, for example. The Caribbean programmes also allow applicants to forgo requirements to demonstrate minimum business experience or a proven track record of achievement, as is the case in Austria. Caribbean programmes are also famed for their responsive CBI units, and for official programme websites that are regularly updated. Vanuatu also joins the  Caribbean at the top of the table in this regard.

Of the European programmes, Malta ranks highest with a score of nine, followed by Cyprus with seven. Both require applicants to invest in tangible assets — real estate, in both cases. This process burdens applicants with extensive documentation. Unlike Malta, however, Cyprus does not have a dedicated CBI unit (or equivalent) to manage its applications, causing it to fall behind in this respect. 

Montenegro joins Jordan and Turkey with a score of six. While an official website for Montenegro’s CBI programme exists, the site has been inaccessible for months, making it difficult to award points to Montenegro on this basis. The ability to access an active, up-to-date website is an important resource for prospective applicants, who can view essential information, and access forms and updated lists of necessary documents. 

Montenegro, Jordan, and Turkey lack dedicated CBI units despite requiring applicants to demonstrate proof of complex investments, and this is reflected in their score. In Turkey, for example, applicants can choose between making a fixed capital investment, purchasing real estate, providing employment for at least 50 Turkish citizens, making a deposit in a Turkish bank, purchasing government bonds, or purchasing real estate  investment trust shares or venture capital investment trust shares.

Austria, Bulgaria, and Cambodia retain their last place positions for imposing more onerous requirements, such as a Khmer language and history and culture test in Cambodia, and an interview requirement in Austria and Bulgaria.

Pillar 7: Due Diligence

Scoring full marks for their stringent vetting procedures, Dominica, Grenada, Malta, and St Kitts and Nevis once again top the Due Diligence Pillar. Dominica, Malta, and St Kitts and Nevis have attained a perfect score for their commitment to robust due diligence every year since the inception of the CBI Index.

In the 2020 CBI Index, Montenegro joins Antigua and Barbuda with a score of nine by virtue of its biometric requirements, outsourced external due diligence, requirement for multiple police certificates, and exclusion of high-risk nationalities. Greater thoroughness in the authentication of an applicant’s source of funds would see Montenegro compete with the highest performing countries in future editions of the CBI Index.

Bulgaria, Cyprus, and St Lucia maintain their score of seven for due diligence. While all three require proof of a clean criminal record in at least the applicant’s country of birth and residence, Bulgaria and Cyprus make no provision for banned or restricted nationalities. Although St Lucia excludes applications from persons of Iranian origin, owing to potential risks posed to national security, unlike Bulgaria and Cyprus, it does not collect fingerprints or biometrics from applicants to its programme.

Next is Vanuatu, followed by Austria and Cambodia, which each attained a score of four. Austria fails to implement restrictions or extra due diligence checks on applicants from non-cooperative, sanctioned, conflict, or similar countries and, like Vanuatu, makes no provision for vetting by independent due diligence agencies. In Cambodia, points are also lost for a lack of emphasis on an applicant’s source of funds and the provision of police certificates from an applicant’s country of birth or residence.

In Turkey, while applicants are vetted by the Turkish National Intelligence Agency and Ministry of Internal Affairs, which work in cooperation with Interpol, applicants need not provide police certificates nor any documentary evidence of source of funds — something that can pose a serious risk to Turkey and partner countries. Turkey therefore scores three points, with Jordan one point behind for applying a lax system of due diligence with the fewest number of safeguards in place compared to all jurisdictions assessed.

Pillar 8: Family

Dominica and Grenada take the top spot in the new Family Pillar, achieving perfect scores across the board for their broad range of family-friendly provisions. Both countries allow the inclusion of children aged over 18 years, with few restrictions, as well as extended family including parents, grandparents, siblings, and the family of the main applicant’s spouse.

Malta, St Kitts and Nevis, and St Lucia each received a score of nine for their family inclusiveness. Both Malta and St Kitts and Nevis allow for the parents and grandparents of the main applicant or spouse to be included in an application. In Malta, parents and grandparents must be above the age of 55 years, living with and wholly maintained or supported by the main applicant. Similarly, in St Kitts and Nevis, parents above the age of 55 years and grandparents above the age of 65 are permitted as long as they are living with and supported by the main applicant. 

St Lucia, while not allowing grandparents to form part of an application, allows siblings of the main applicant to be included if they are under the age of 18 years, unmarried, and in receipt of consent from their parent or guardian to make an application. 

Antigua and Barbuda was awarded a score of eight, followed by Vanuatu with seven. In both countries, children over the age of 18 can be included in an application; however, a high degree of dependency must be demonstrated. In Antigua and Barbuda, for example, children aged 18 or over, but less than 28, may be included if they are enrolled as full-time students in a university or college educational programme that they are due to complete more than six months after submission of the application. While Antigua and Barbuda allows parents and grandparents to form part of an application, Vanuatu only makes provision for parents of the main applicant or spouse if over  the age of 50, residing with, and dependent upon the main applicant or spouse.

After recognising that Montenegrin law appeared to preclude dependants from obtaining citizenship under the CBI programme, Montenegro clarified that dependants were indeed eligible in a decision in December 2019. Montenegro scores six along with Cyprus, with Bulgaria and Turkey behind with five. While Bulgaria and Turkey both make provision for minor children of the spouse of the main applicant, neither allow extended family members to be included, and allow adult children only under the exceptional circumstance of when said children are rendered dependent as a result of a medical condition. 

Cyprus has provisions for children with severe mental or physical disabilities who are unable to work, and allows certain adult children to join an application. These adult children (of the investor only) must be aged up to 28 and be students attending an institution of higher education aiming to obtain a diploma or undergraduate Master’s degree. Children studying for a professional qualification are excluded. Montenegro is more lenient, allowing adult children of the main applicant of any age, as long as they are dependent on that main applicant.

Austria and Jordan score four, with Austria allowing disabled children aged over 18, subject to conditions, and Jordan allowing parents of the main applicant provided they are solely supported by that main applicant. Cambodia scores just two, reflecting the fact that only a spouse or minor child of the main applicant may be included in an application.

Pillar 9: Certainty of Product

Dominica and St Kitts and Nevis both achieve perfect scores under the new Certainty of Product Pillar. Having debuted in 1984 and 1993 respectively, their programmes have stood the test of time. Dominica has suffered no serious CBI-related scandal in its 17 years of operation, and, as a result, is a highly reputable destination for second citizenship. St Kitts and Nevis has garnered a reputation as the ‘platinum standard’ of the CBI industry and benefits from global renown. Subject to neither application caps nor calls for abolition, the stability of both the Dominica and St Kitts and Nevis programmes is high. 

Elsewhere in the Caribbean, Antigua and Barbuda and Grenada form the second grouping with eight points, gaining points for their relative stability and ability to adapt to meet the needs of investors. Antigua and Barbuda, for example, announced that it would be exploring the feasibility of accepting applications from stateless applicants in March 2020. It then issued updated application forms in May 2020. Such small but significant tweaks demonstrate an intention to finetune and improve the application experience.

St Lucia scores six along with Cyprus and Turkey. Continually plagued with threats by the opposition to repeal all amendments to the CBI programme since the St Lucia Labour Party left power — the latest ones made as late as the June 2020 election campaign — St Lucia loses points for stability as questions remain as to what could happen to the programme should there be a change of government. Similarly, Cyprus loses points for stability because it faces continued probing from the European Commission. In April, for example, a letter was sent by the European Commission to EU member states Bulgaria, Cyprus, and Malta, calling for an end to the programmes and asking for a discontinuation plan to be submitted to the Commission. Although Cyprus has a long-established programme (albeit subject to sweeping changes over time), its yearly cap of 700 approved applications is also a source of concern to applicants, particularly as the cap nears its end.  

Despite only becoming operational in 2017, the surge in popularity of Turkey’s programme cannot be overlooked nor understated. According to official Ministry of Interior data from March 2020, 3,882 main applicants had received approvals in the preceding five months, seemingly making Turkey the most popular CBI programme in the industry. Turkey also benefits from having no cap and no significant calls to end the programme. 

With scores of five points are Malta and Vanuatu, closely followed by Austria and Bulgaria, which received scores of four points. Despite Malta’s industry renown, its programme lacks stability, again due to the mounting pressure from the European Commission and the announcement of a new iteration of the Individual Investor Programme that will be rolled out at the beginning of September 2020. The programme will reportedly undergo a significant overhaul, including a greater emphasis on applicants demonstrating a connection to Malta. 

Vanuatu loses points for its youth and poor reputation in the industry, stemming from the country’s dual programme structure and ongoing questions over whether the DSP does indeed confer full citizenship on successful applicants. While Austria and Bulgaria feature longstanding programmes, established in 1985 and 2009 respectively, both lose points for their lack of global renown and initiative in keeping pace with the rest of the industry.

Montenegro, having had very little time to establish itself in the industry and having reportedly received a mere 28 applications as of June 2020, joins Cambodia with a score of three points. Jordan takes last place in the Certainty of Product Pillar, picking up only two points for its relatively unknown programme.

Final Scores: The Highest-Ranking Programmes

Retaining their position at the top, the Caribbean nations outperform their counterparts, due in large part to their affordability and speedy, simple processing mechanisms. 

Emerging for the fourth consecutive year as the world’s best CBI programme, Dominica balances an excellent reputation for meeting the needs of investors with strong due diligence, a low minimum investment outlay, efficient processing, and a renewed focus on family reunification.

St Kitts and Nevis maintained its percentage score of 89, preserving a commitment to stringent due diligence and demonstrating once again that it is the jurisdiction with the fastest citizenship timeline. The country also increased the number of visa-free and visa-on-arrival destinations for its citizens, though its freedom of movement score decreased slightly owing to a change in the methodology of this pillar, which now takes into account settlement rights. The country also fared well with the addition of the Certainty of Product Pillar, thanks to its reputation as the platinum standard of the industry.

Grenada saw its citizenship timeline improve for the second year in a row. It also benefitted greatly from the addition of the Family Pillar, owing to its extensive provisions for dependants. 

St Lucia retained its position above Antigua and Barbuda, thanks in large part to its faster citizenship timeline, lack of travel or residence requirements, and renewed emphasis on family. Greater stability, as well as diligence in authenticating an applicant’s source of funds, are potential areas of improvement for St Lucia. For example, St Lucian forms could do more to ascertain an applicant’s historical employment, and 12-month bank statements should be mandated for all main applicants. 

Finishing in fifth place, despite a slight improvement in citizenship timeline, Antigua and Barbuda still lags behind its Caribbean counterparts.

Vanuatu remains the best CBI programme outside of the Caribbean, maintaining a low minimum investment outlay and commitment to ease of processing. This year however saw Vanuatu’s processing times increase, likely owing to an upsurge in applicants under the rejuvenated DSP. Issues remain with respect to due diligence processes in the country, in particular around a lack of sophisticated applicant checks and extensive source of wealth declarations. In the coming year, it will be interesting to see whether Vanuatu’s performance in the Certainty of Product Pillar improves if efforts are indeed made to scrap the VCP and clearly define the DSP. 

In Europe, Malta overtook Cyprus in terms of both overall scores and percentage scores. Malta’s upward trajectory is likely a reflection of it being a more family-friendly jurisdiction than Cyprus, hence the addition of the Family Pillar tips the balance in favour of Malta. In addition, Malta retained perfect scores under the Freedom of Movement and Due Diligence Pillars, while continuing to score highly for its excellent standard of living. However, Malta imposes burdensome travel and residence requirements, resulting in a much slower citizenship timeline than the vast majority of the other programmes assessed this year. Whether the new iteration of Malta’s Individual Investor Programme will see it drop in the rankings or continue to climb remains to be seen.

Despite falling in the rankings, Cyprus performs respectably in many pillars, and the inclusion of settlement rights in the assessment of the Freedom of Movement Pillar saw it improve in this regard thanks to its membership of the EU.

Debuting above Turkey is this year’s new entrant, Montenegro. Placing joint eighth with Cyprus in both overall and percentage scores, Montenegro emerged with robust due diligence, low travel and residence requirements, and a short citizenship timeline. Montenegro’s CBI programme will be monitored in the coming year as we observe how processing times are affected as the programme garners greater renown.

Turkey takes tenth place overall in the 2020 CBI Index. By virtue of its more affordable, faster, and significantly more popular CBI programme, Turkey held its spot above Bulgaria. Undeniably attractive to applicants — a majority of whom derive from the Middle East — Turkey could improve its score next year by placing emphasis on strict applicant vetting and simplifying the process for applicants by establishing a dedicated CBI unit and website. On the flip side is Bulgaria, which, despite offering citizens extensive visa-free and visa-on-arrival access and a good standard of living, has failed to secure investor interest. Lengthy processing times and taxing requirements, such as a mandatory interview, are likely causes of the programme’s lack of favour with potential investors.

The three worst-performing programmes in the 2020 CBI Index were those of Austria, Cambodia, and Jordan, placing twelfth, thirteenth, and fourteenth respectively.

Despite standing out for its freedom of movement and high standard of living, Austria offers a long citizenship timeline and provides little clarity when it comes to processing. A common feature of the bottom three programmes is their failure to provide certainty to applicants, with Austria, Cambodia, and Jordan each lacking popularity and renown, reputation, and willingness to adapt — features that are required to succeed in the industry. Facing the additional challenges of limited visa-free and visa-on-arrival offerings and a lower standard of living for citizens however, Cambodia and Jordan fall below Austria.

Taking last place yet again, Jordan still has large strides to make with respect to tightening its seemingly non-existent due diligence and raising its profile in the market.