The 2021 CBI Index: Programme profiles

The Antigua and Barbuda Citizenship by Investment Programme

The Antigua and Barbuda Citizenship by Investment (CBI) Programme was established by the Antigua and Barbuda Citizenship by Investment Act, 2013. Antigua and Barbuda offers four investment options for successful applicants.

The first allows single applicants or families of up to four persons to make a minimum contribution of US$100,000 to the National Development Fund, a not-for-profit organisation created to run both public and private projects, as well as charitable initiatives, such as improving access to healthcare and education. This contribution threshold was proposed under a limited-time offer that was indefinitely extended in October 2019.

The second option, the minimum threshold for which was introduced in March 2020, requires the applicant to make an investment of at least US$200,000 into a government-approved real estate project for a period of five years. Additionally, an applicant with no more than three additional family members may make a joint investment with a ‘related party,’ with both the applicant and the related party making a minimum investment of US$200,000 each. A related party is one with the same Licenced Agent as the applicant.

The third option entails an investment of US$1.5m into an eligible government-approved business project. Applicants can apply as joint investors so long as each applicant makes a minimum investment of US$400,000 into a project worth at least US$5m.

The final option — introduced in October 2018, but modified significantly in May 2020 — applies to families of at least six persons who invest US$150,000 into the University of the West Indies Fund (UWIF). In addition to receiving citizenship, one member of the family will also be entitled to a one-year, tuition-only scholarship.

Government fees apply for three of the four options and due diligence fees apply to all. Government fees of US$30,000 apply for any family of up to four persons, and increase by US$15,000 with each additional person included in an application. The only exception to this rule is the UWIF option, where no government fee is due for families of six persons. In all cases, 10 per cent of the government fees are due upon submission of the application and are deemed non-refundable.

In 2021, application processing by the CBI Unit, the government body responsible for reviewing all applications under the Programme, remains relatively slow. Due diligence procedures in Antigua and Barbuda are generally strict, and all economic citizens hold e-passports. Several nationalities are excluded outright from the application process.

There is no mandated interview or knowledge-based test, but Antigua and Barbuda requires applicants to travel to the nation, or to an embassy or consulate, to sign an oath of allegiance. Furthermore, once awarded, citizenship is conditional on the applicant spending five days on Antiguan or Barbudan soil within five years of obtaining citizenship. This requirement is waived for children until after they reach the age of majority at 18. Due to Covid-19 travel restrictions, Antigua and Barbuda’s residence requirement was suspended until summer 2021. The CBI Unit has, in the interim, been allowing economic citizens to take the oath of allegiance virtually, if satisfied that travel restrictions prevent travel to the nation or to one of its embassies or consulates.

Changes to the Programme in late 2020 made Antigua and Barbuda one of the most family friendly jurisdictions in the Caribbean, allowing many family members, including unmarried siblings of any age, to join the main applicant’s journey to second citizenship.

Antigua and Barbuda accepts dual nationality.

Citizenship by Investment in Austria

The particulars of Austria’s CBI procedures are not clearly codified in the nation’s laws. Rather, the scheme draws broad legitimacy from Article 10(6) of the 1985 Nationality Act, which gives leave to the federal government to grant citizenship where a person displays actual or expected outstanding achievements. The federal government may, by an order, lay down specific stipulations regarding the grant of nationality under Article 10(6). Its failure to fully do so has made the Austrian scheme one of the least transparent processes in the economic citizenship arena.

The outstanding achievement underlined in Austria’s laws can be economic and can cover those whose investments in Austria are sufficient to trigger the provision.

Exclusive and limited to those who can guarantee a positive attitude towards Austria, and who do not pose a danger to law and order, public safety or other public interests, the scheme has operated intermittently and only rarely are aspiring applicants successful. Indeed, between 1985 and 2020, only 1436 persons were naturalised under Article 10(6).

The scheme is also mindful of Austria’s — and the applicant’s — associations with other states, barring persons whose relations with foreign states would be detrimental to Austria, or who, upon becoming Austrian nationals, would damage the country’s international relations. A person is also barred if they hold certain criminal convictions, immigration orders or affiliations with extremism.

The two-year process involves filing the application in person (unless the applicant is incompetent to act) and significant communication with various government representatives. Article 10(a)(2) exempts prospective economic citizens from having to demonstrate sufficient knowledge of the German language and basic knowledge of Austria’s history and democratic system. An applicant who lives outside of Austria must, however, travel to the relevant Austrian diplomatic or consular authority to give the oath of allegiance (with some exceptions for those who cannot reasonably be expected to appear to deliver the oath).

Although Austria generally disallows dual nationality, Article 10(6) specifies that applicants are permitted to retain their original citizenship, bringing the scheme in line with those of other jurisdictions offering economic citizenship. Benefits of Austrian citizenship include the right to live and work in any country in the European Economic Area (EEA) and Switzerland, as well as facilitated travel to the US and Canada.

The Bulgarian Immigrant Investor Programme

The Bulgarian Immigrant Investor Programme (BGIIP) was created in 2009 and finds its legal basis in Article 25(1) of the Foreigners in the Republic of Bulgaria Act and Article 14a of the Citizenship Act. Designed as a quick route to citizenship via a period of nominal permanent residence in Bulgaria, the BGIIP does not require the investor to physically spend time in Bulgaria while waiting for citizenship to be issued. This makes the BGIIP one of a handful of European citizenship programmes where prior physical residence in the nation is not compulsory.

After amendments passed in February 2021 (and now in force), there are several investment options under the BGIIP. Applicants can invest €1,024,000 in stocks traded in Bulgaria; €512,000 in undertakings for collective investment in transferable securities; €512,000 in alternative investment funds (partly focused on Bulgaria); €1,024,000 in a Bulgarian company carrying on a Certified Priority Investment Project; participate in and invest €257,000 in a Bulgarian company employing 10 or more Bulgarian nationals; participate in and invest €3,075,000 in a Bulgarian private company; or invest in a Certified Investment Project, with the investment amount depending on the project in question. These investments and thresholds allow an applicant to obtain citizenship after five years. However, applicants can fast-track their route to citizenship after one year by raising their investment.

Applications under the BGIIP are first submitted to a local Bulgarian consulate, which redirects them to the Ministry of Foreign Affairs and issues a first-stage visa for the applicant to enter Bulgaria and file for permanent residence. Thereafter, processing is conducted by the Ministry of Foreign Affairs. These entities do not test applicants on their knowledge of the Bulgarian language or local culture, and applicants need not sit a mandatory interview during the residence or citizenship application stages.

The BGIIP is only available to non-EU nationals who must make two formal trips to Bulgaria: once to file for permanent residence, and once to register permanent residence and receive the relevant identity documents, at which point biometrics are also taken. Permanent residence can be obtained within six to nine months of submission; citizenship rests on the option selected by the applicant, but can be expected within 18 to 24 months under the fast-track option.

Family members are unable to apply with the main applicant. Instead, they can apply for citizenship only after the main applicant has naturalised.

In 2019, in response to concerns regarding due diligence, Bulgaria began to demand criminal records from both an applicant’s home country and country of permanent residence. Further concerns led to various announcements that Bulgaria would end the BGIIP, yet such claims were put to bed with the 2021 amendments.

The benefits of Bulgarian citizenship include free movement rights throughout all EU member states. Starting 1 December 2017, citizens of Bulgaria were granted the right to visa-free travel to Canada for up to six months, provided they obtain an Electronic Travel Authorisation. Bulgaria has yet to join the Schengen Area, although it is taking steps towards membership. Persons wishing to obtain citizenship of Bulgaria must usually renounce any other nationality they hold; however, exceptions exist for native Bulgarians, citizens of the EU, EEA and Switzerland, along with spouses of Bulgarian citizens and, under Article 14a of the Citizenship Act, economic citizens.

Citizenship by Investment in Cambodia

As early as 1996, provisions were made in Cambodia’s Law on Nationality to allow foreigners to naturalise following an investment in the country. These were further outlined, in their most recent form, by Sub-decree 287 of 2013. On 11 June 2018, the Cambodian senate approved a draft law aimed at modifying Cambodia’s economic citizenship landscape and, in particular, raising investment thresholds. The draft law, however, has yet to reach the final stages of approval.

Cambodia, therefore, continues to afford economic citizenship to persons who invest 1.25bn riels into the nation. The investment must be approved either by the Cambodian Development Council or by the royal government. Citizenship is also available to those who donate 1bn riels for the restoration and rebuilding of Cambodia’s economy.

Knowledge of Khmer history and language is required, and applicants must travel to Cambodia to obtain good behaviour, police and health certificates, as well as to sign the relevant citizenship oath. Applicants who choose the investment option must register a residence in Cambodia at the time of the application, although they need not live there. This requirement is waived for applicants who choose to donate.

Applications are reviewed by the Ministry of the Interior, although citizenship may only be granted by the King by royal decree. The entire process can take between three and six months to complete, with some evidence that speedier processing may be possible. In 2013, it was reported by the Cambodian Ministry of Interior that 700 foreign nationals had applied for Cambodian citizenship since 2000.

Citizenship of Cambodia brings visa-free travel rights to more than 50 countries and territories, the majority of which are located in southeast Asia. As a member of the Association of Southeast Asian Nations, Cambodia affords opportunities for facilitated trade and greater mobility among member states for certain professionals. For those wishing to retain their citizenship of birth, Cambodia allows dual citizenship. Finally, as Khmer citizens, successful applicants may purchase real estate in the country — a privilege exclusive to Cambodians.

The Dominica Citizenship by Investment Programme

Dominica’s CBI Programme was launched in 1993, and is known for being one of the world’s most efficient and transparent options for economic citizenship. It plays a major role in promoting social and environmental causes, particularly sustainable development.

The Programme was reshaped by the Commonwealth of Dominica Citizenship by Investment Regulations, 2014, to include diverse investment options and even stricter regulation processes. Changes to the Programme in 2020 modified investment thresholds and fees, and significantly expanded the scope of eligible dependants and post-citizenship additions.

The Programme offers two investment opportunities: a one-time contribution to the government, commonly known as the Economic Diversification Fund (EDF) option, or an investment in government-approved real estate. Funds transferred to the EDF have been instrumental in Dominica’s national development, particularly through the reconstruction of key infrastructure, sustainable housing and the agricultural sector.

The EDF option requires a contribution of US$100,000 for a single applicant — a value that increases as family members are added to an application. The real estate option requires an investment of at least US$200,000, to which a single applicant must add a US$25,000 real estate government fee. The real estate must be held for a period of three years, which increases to five years if the future purchaser is also an applicant for CBI. Other applicable fees include due diligence, minor processing and Certificate of Naturalisation fees.

The CBI Unit is the government authority tasked with managing and processing applications for economic citizenship. To qualify for Dominica’s CBI Programme, applicants must have a clean criminal record and prove they are of good character through a series of extensive due diligence checks, including regarding source of funds.

By regulation, the Unit must respond to an application within three months of its submission, helping it maintain one of the fastest processing times in the CBI industry.

The application process in Dominica is straightforward, with no interview, travel or residence requirements, either before or after the citizenship process. Applicants need not learn English, nor show a minimum level of education or business experience.

Benefits of citizenship of Dominica include visa-free travel to more than 140 foreign destinations, dual citizenship and the opportunity to experience an eco-friendly lifestyle in a lush environment. Several family members can join the main applicant and become citizens themselves, including, as of summer 2020, siblings of the main applicant or their spouse up to the age of 25, subject to conditions.

Citizenship by Investment in Egypt

In 2019, Egypt passed Parliament Law No. 190, which detailed conditions for the grant of citizenship to foreign nationals in exchange for investments or donations without the need to undergo a period of residence. The law was published in March 2020, giving the go-ahead for Egypt’s first CBI Programme.

There are four routes to citizenship under the Programme. First, the purchase of one or more government-owned properties or government-owned land, for at least US$500,000, to be held for a period of five years. Second, the acquisition of a minimum 40 per cent stake in either a new or previously established Egyptian company, in which the total invested capital must be a minimum of US$400,000. Third, a bank deposit of either US$750,000 to be returned after five years or US$1m to be returned after three years — both at zero per cent interest. Finally, a non-refundable contribution of US$250,000 to the CBI Unit account at the Central Bank of Egypt. Applicants need not make the contribution or investment until after their application has been approved.

A CBI Unit has been set up within the office of the prime minister to oversee the application process. As part of their application, applicants are required to pay a non-refundable US$10,000 government fee and submit several documents, including clean criminal records from an applicant’s country of citizenship and residence, and documents evidencing employment or company ownership.

Due diligence is performed by the General Intelligence Service, the Military Intelligence and Reconnaissance Administration, and the Financial Regulatory Authority. There are no banned nationalities under Egypt’s CBI Programme.

As part of the process, applicants need not take part in a formal interview, nor undergo mandatory testing, but they must make one visit to Egypt to obtain a National ID Card before the grant of citizenship. Biometrics are taken as part of this process.

Main applicants may also include certain family members in an application for citizenship. Any official spouse of the main applicant, for example, can be included in an application. However, it should be noted that such spouses will not obtain citizenship of Egypt until two years after the main applicant becomes a citizen. The main applicant can also include unmarried children below the age of 21 in an application for citizenship, but unlike spouses, children receive Egyptian citizenship at the same time as the main applicant.

Other benefits of Egyptian citizenship include eligibility to apply for an E-2 visa to the US and the ability to retain dual citizenship.

There is no cap or expiry date on Egypt’s CBI Programme.

The Grenada Citizenship by Investment Programme

Created in 2013 by the Grenada Citizenship by Investment Act, Grenada’s CBI Programme supports the nation’s renewable and sustainable development initiatives, and stimulates foreign investment to promote tourism, construction, agriculture and manufacturing. The Grenada CBI Programme has gained recognition and trust thanks to its due diligence processes.

The Grenada CBI Programme offers applicants two investment options. The first option is a contribution to the National Transformation Fund (NTF) — a government institution responsible for locating and financing alternative, economy-stimulating investments for the country. A single applicant must make a US$150,000 minimum donation to the NTF — an amount that increases as family members are added to an application.

The second option is an investment in a government-approved real estate project, which itself presents two choices. Applicants can invest US$350,000 in any pre-approved project. Alternatively, they can jointly invest US$220,000 in pre-approved tourism developments to which the developer has already committed 20 per cent of the total expected cost. All applicants who purchase real estate under the CBI Programme must hold it for five years.

Any application lodged by up to four family members requires payment of an additional US$50,000 government fee where the real estate option is selected. Additional moneys are required, however, when parents or grandparents under the age of 55 and siblings are included in an application. Applicants under either option are responsible for paying associated application, processing and due diligence fees.

Despite delays in 2018, the speed of application review has improved significantly over the past three years, with the country now approving successful applications in 60 business days. Grenada does not require applicants to sit an interview, demonstrate business experience or proficiency in the English language, or fulfil travel or residence requirements.

Grenadian citizenship can benefit successful applicants by providing them with options for global mobility, including to China, with which Grenada has an extradition treaty formalised in October 2018. Grenadian citizens are eligible to apply for a renewable E-2 visa for the US. Dual nationality is allowed.

Citizenship by Investment in Jordan

Jordan announced the commencement of its economic citizenship programme in February 2018, finding legal basis in the provisions of the Jordanian Nationality Law, 1954 (No. 6 of 1954). Article 13(2) removes the residence requirement for persons whose naturalisation is in the public interest or who are ‘Arab’ — that is, persons whose father was of Arab origin and who are nationals of a member of the League of Arab States. It is also possible, if less desirable, for persons to obtain citizenship under Article 5, although such persons must relinquish all other nationalities. No more than 500 persons are accepted for economic citizenship per year.

Applicants have five investment options, the thresholds and hold periods for which were reduced in a cabinet decision made in December 2019. First, applicants can decide to invest US$750,000 in Jordanian small and medium-sized enterprises, and must hold that investment for a period of at least three years. Second, they can deposit US$1m in a non-interest-bearing account at the Central Bank of Jordan for a period of at least three years. Third, they can invest in treasury bonds worth US$1m, to be held for at least six years at an interest rate determined by the Central Bank of Jordan. Fourth, they can purchase securities from an active investment portfolio priced at US$1m. Fifth, they can invest US$1.5m in any project across the country (or US$1m in projects that are located in governorates outside of Amman) that create a minimum of 20 local jobs and that remain active for no less than three years.

Applications for citizenship are lodged with the Jordan Investment Commission, an entity established in 2014 to succeed the Jordan Investment Board, which was first founded in 1995. Its role is to promote investment in Jordan and respond to emerging trends in the international and domestic economic environment. Successful applications must be approved by the Council of Ministers and the monarch, in a process that takes around three months.

Naturalised Jordanians are barred from political or diplomatic positions, from any public office prescribed by the Council of Ministers, and from becoming members of the state council for a period of ten years from the grant of citizenship. They are also excluded from participation in municipal or village councils for a period of five years from obtaining citizenship.

Loss of citizenship for naturalised persons is considered if a person commits or attempts to commit an act to endanger Jordan’s peace and security, or if a person is found to have misrepresented evidence during the naturalisation process. Revocation of citizenship is also possible in certain instances where a person enters foreign military or civil service, or the service of an enemy state.

Malta’s Granting of Citizenship for Exceptional Services Regulations

Following the discontinuation of the Individual Investor Programme in September 2020, Malta’s new citizenship by investment offering is moulded in its current form by the Granting of Citizenship for Exceptional Services Regulations, 2020. Malta’s new offering is subject to a cap of 400 Certificates of Naturalisation per annum and 1500 in total, excluding dependants.

Persons wishing to apply for citizenship under the Regulations must first complete a residence requirement of either 36 months or, for a higher investment amount, 12 months. During the residence period, applicants apply for an eligibility assessment and, if successful, may apply for citizenship upon completion of the residence requirement. Under Malta’s offering, therefore, citizenship is at best a 13-month endeavour. During this time, applicants are expected to live in Malta and build ‘connecting factors’ to the country.

All applicants under the Regulations must complete three forms of investment.

First, they must make either a €600,000 or a €750,000 exceptional direct investment, depending on the length of their stay in Malta. €10,000 of this must be remitted as a non-refundable deposit upon submission of the initial residence application.

Second, they must either purchase real estate in Malta, valued at €700,000 or more, or rent property at a cost of at least €16,000 per annum. In both instances, they must hold the real estate for a period of five years from the date of issue of the Certificate of Naturalisation. Furthermore, the property must be adequate and suitable for main applicants and any dependants to live in.

Finally, applicants must make a €10,000 donation to a registered philanthropic, cultural, sport, scientific, animal welfare, or artistic non-governmental organisation or society, or as otherwise approved by the Community Malta Agency.

As well as completing the three-part investment, applicants must also pay hefty due diligence and administrative fees.

Maltese citizenship brings several benefits, including the ability to retain dual nationality, which was allowed in 2000. Successful applicants under the policy can expect their names to be published in Malta’s Gazette, and to be identified as recipients of Maltese citizenship within 12 months of obtaining their citizenship. 

The Montenegro Citizenship by Investment Programme

Montenegro’s CBI Programme was launched on the basis of the Decision on criteria, method and procedure for selection of persons who may acquire Montenegrin citizenship by admission for the purpose of implementation of special investment programme of particular importance for the business and economic interest of Montenegro. The Decision was adopted on 22 November 2018, and entered into effect on 1 January 2019 before the country began accepting applications under its CBI Programme in October 2019. 

The Programme is limited both by application volume and time, being capped at 2000 applications and slated to run until 31 December 2021. In March 2021, the Montenegrin government announced that the Montenegro CBI Programme would not be extended past its expiration date.

Despite a promising start, issuing its first application approval in February 2020 within three months of submission and entering the market with one of the world’s fastest application processing times, Montenegro failed to secure investor interest. As of March 2021, it had issued only 37 approvals.

The investment structure in Montenegro consists of two tiers, with applicants being required to make a non-refundable donation and choose between two real estate options. Under the first option, applicants must invest €250,000 in government-approved development projects in tourism, agriculture or processing, located in northern and central Montenegro. Under the second option, applicants must invest €450,000 in government-approved development projects in any of the same three industries, located in Podgorica or along the coastline. Regardless of the real estate option chosen, applicants must also make a €100,000 donation to be used by the government to assist underdeveloped communities in Montenegro.

In addition to the required investment, hefty processing fees apply, starting at €15,000 for a single applicant. Due diligence fees also apply, reflecting the fact that due diligence is performed both by agents and third-party due diligence firms.

In December 2019, an important change to Montenegro’s Programme was implemented after issues surfaced with respect to dependants. Article 12 of the Montenegrin Citizenship Act makes provision for ‘a person over 18 years of age’ to obtain Montenegrin citizenship to the benefit of the state, thereby precluding minor dependants obtaining economic citizenship. To rectify this, the government issued a decree specifying that dependants may be included in a CBI application. As a result, Montenegro permits the inclusion of a spouse, minor children and adult children who are dependent on the main applicant.

Under the Programme, applicants need not fulfil any mandatory residence requirements before or after the grant of citizenship. However, applicants must travel to Montenegro to receive their final decision and supply biometrics.

Montenegro is an attractive destination for second citizenship, with one of the fastest growing economies in the Balkans and the prospect of becoming an EU member state in 2025. Montenegro is also party to an E-2 visa treaty with the US, allowing Montenegrin citizens to obtain E-2 visas to work in the US.

Successful applicants are exempt from Montenegro’s restrictions on dual nationality.

The St Kitts and Nevis Citizenship by Investment Programme

Home to the world’s most longstanding economic citizenship programme, the Federation of St Kitts and Nevis has a more than 35-year history of leading the field of economic citizenship. Indeed, its CBI Programme has earned multiple awards and a reputation as the ‘platinum standard’ of CBI. 

To qualify for economic citizenship, applicants now have four investment options to choose from, following the introduction of two new investment options in March 2021. Due diligence fees apply under all options, as do minor processing and Certificate of Registration fees. The country’s first-ever option for economic citizenship — a donation to the Sugar Industry Diversification Foundation — remains in existence in relevant regulations, but has, in practice, been superseded by the Sustainable Growth Fund (SGF).

The SGF is a permanent feature of the Programme that was established in March 2018. The SGF substituted the temporary Hurricane Relief Fund (HRF), whose establishment in 2017 resulted in elevated application numbers. Under the SGF, a single applicant must make a minimum donation of US$150,000. This option is also attractive for families, and, under a limited-time offer set to expire on 31 December 2021, families of up to four persons (excluding siblings) can obtain citizenship under the SGF for the same cost as a single applicant.

The second option is an investment in pre-authorised real estate, of which there are two branches. Under the first branch, the applicant must buy property worth at least US$400,000 and keep it for five years. Under the second branch, the applicant must make a joint investment with another applicant, with each investment worth at least US$200,000. The joint investment must be retained for a period of seven years.

Under the third option, which is only available until 1 November 2022, applicants can purchase a private home worth at least US$400,000 (not including the value of the land on which the home sits). Limitations exist with respect to the type of property that can be used under this option, as the private home must be sold as a single unit and not divided into apartments or condominiums. Property purchased under this option cannot be re-used in a subsequent application for CBI and is subject to a hold period of five years.

Finally, the ‘Alternative Investment Option’ allows applicants to invest either in an approved infrastructural project or other approved development project. The cost of the investment varies according to whether St Kitts and Nevis owns the project at the end of the agreement, in which case the minimum investment amount is US$175,000, or whether the project is privately owned, in which case the minimum investment amount is US$200,000.

A US$35,000 government fee is applicable for single applicants under the pre-approved real estate and private home options, while a government fee of US$50,000 applies for single applicants and families of up to four under the Alternative Investment Option.

The CBI Unit, which processes all CBI applications, normally issues approvals or denials within three months. The Accelerated Application Process, available at a premium fee, allows successful applicants to receive citizenship within 60 days of applying. Currently, St Kitts and Nevis is the only CBI nation to offer a secure, guaranteed fast-track route. There is no interview, language, education or business requirement applicable to any of the options chosen. Travel to the twin-islands is not obligatory, and no minimum residence stays apply either prior to or after citizenship is obtained.

Due diligence procedures remain among the industry’s most robust and are expected to be further strengthened by upcoming processes focusing on fingerprinting and biometrics. 

Benefits of citizenship of St Kitts and Nevis include visa-free travel to a growing number of worldwide destinations — the highest of any CBI country in the Caribbean. Citizens are allowed to hold multiple nationalities.

The St Lucia Citizenship by Investment Programme

Inaugurated in January 2016, St Lucia’s CBI Programme is the Caribbean’s newest economic citizenship programme. The Programme has four investment options. The fastest option is a contribution to St Lucia’s National Economic Fund (NEF). Moneys deposited into the NEF are intended for progressive local development projects selected by the Minister of Finance with the approval of parliament. Originally set at a US$200,000 contribution, the government reduced the minimum threshold to US$100,000 inJanuary 2017.

The second option under the Programme asks applicants to make a minimum investment of US$300,000 into a government-approved real estate project. To date, the government has designated two real estate projects for selection under this option, which, upon purchase, must be held for a period of five years.

Applicants may also acquire government bonds. A limited-time offer, in place until 31 December 2021, allows a single applicant (or a main applicant with up to four dependants) to purchase bonds worth US$200,000 to be held for between five to seven years, depending on the family structure. There are also opportunities for an applicant to purchase bonds worth more, but with reduced hold-period constraints. Outside the limited-time offer, single applicants are required to purchase bonds worth at least US$500,000 and to hold them for five years. Qualifying government bonds cannot return a rate of interest.

Under the Programme’s final option, applicants can make a minimum investment of US$3.5m into a government-approved enterprise project. Projects, which may be initiated by applicants themselves, can range from the building of a port to the establishment of a university, and must result in the creation of at least three permanent jobs. Applicants may partner with others to launch a joint venture, so long as a total minimum investment of US$6m is made, with each investor contributing no less than US$1m. At least six permanent jobs must be generated as a result of the joint venture.

Due diligence fees are always levied. Processing fees apply under all options, except for investments in real estate and the government bonds limited-time offer, while administration fees apply only to the real estate, government bonds and enterprise project options. The latter start at US$30,000 for real estate investors, and at US$50,000 for single applicants choosing the government bond or enterprise project routes.

Applications are processed by the CBI Unit and are usually returned with an approval or denial within three months of submission. There is no need for applicants to learn English, or to prove any business skills or education. Applicants need not attend an interview, reside in St Lucia, nor travel to the island.

Citizenship of St Lucia offers a viable alternative for anyone seeking a relaxing lifestyle and global access to more than 145 countries and territories. St Lucia has no restrictions on holding dual nationality. Despite these benefits, there remain concerns linked to calls for past amendments to the Programme “to be repealed” and for a “policy decision” on whether the country should retain the Programme.

Citizenship by Investment in Turkey

Turkey’s economic citizenship programme was launched in January 2017. It finds its basis in Turkey’s Citizenship Law, Act No. 5901 and in Regulation 2016/9601, passed by the council of ministers on 12 December 2016. Article 12 of the Act specifies that a person may obtain Turkish citizenship for “outstanding service in the social or economic arena”, provided this creates no obstacle to “national security and public order.” Regulation 2016/9601 was amended by Regulation 2018/30540 and Presidential Decree 106, made on 18 September 2018 and gazetted a day later. It was further amended by Regulation 2018/418, made in December 2018.

Applicants interested in obtaining citizenship of Turkey may do so by choosing one of five routes. The first three each entail retention of the investment for a period of three years. They are purchasing property valued at US$250,000, depositing US$500,000 in a Turkish bank, or investing US$500,000 in government bonds. The applicant must ensure recognition of the investment by either the Ministry of Environment and Urbanisation, the Council of Bank Audit and Regulation, or the Ministry of Treasury and Finance, depending on the chosen investment. The remaining two routes to citizenship are an investment of US$500,000 in fixed capital, to be acknowledged by the Ministry of Industry and Technology, or the creation of 50 jobs in Turkey, to be acknowledged by the Ministry of Family, Labour, and Social Security. Applicants who purchase property may not re-sell that property to someone for use in a future CBI application.

Application processing remains steady despite record application numbers, taking between three to six months on average. There is no requirement for applicants to learn Turkish or to attend a mandatory interview. There is also no requirement to establish residence by physical presence. However, the applicant will need to obtain an investor residence card and provide biometrics.

There are no restrictions on an applicant’s country of origin, making the Turkish CBI route a popular option for those who are banned from partaking in the programmes of other nations.

While the ultimate decision on the grant of economic citizenship originally rested with the council of ministers, following the 2018 amendments it is now in the hands of Turkey’s president.

Turkey allows dual nationality and is considered a moderate country within the context of the Middle East. Despite various attempts at obtaining visa-free travel to the Schengen Area, including by the making of an agreement with the EU on the flow of refugees, Turkish nationals must obtain visas to enter the Schengen member states. They must also apply for visas to Canada and the US.

The Vanuatu Development Support Programme

Vanuatu currently has two concurrent CBI programmes: the Development Support Programme (DSP) and the Vanuatu Contribution Programme (VCP). In April 2021, the Vanuatu government also approved a bill that would instate a third programme, the Real Estate Option Programme.

Until 2018, the DSP had been limited in scope, offering honorary citizenship. This changed with the Citizenship (Amendment) Act (No. 34 of 2018). The DSP was further enhanced by the Citizenship (Development Support Programme) Regulations Order No. 33 of 2019, which improved the programme’s competitiveness, bringing applicant costs in line with the VCP while also enabling participation by Ni-Vanuatu designated agents with an office registered in Port Vila. 

The VCP, on the other hand, remains the purview of a single agent and its affiliated exclusive marketing agent, based in Hong Kong. There has been some indication, however, that Vanuatu’s new administration is looking to reform the current structure as, in May 2020, the sole agent for the VCP was issued with a three-month notice for the termination of its contract with Vanuatu.

Applications under the DSP are processed by the Citizenship Office and Commission, an entity established under the Vanuatu Citizenship Act.

The minimum sale price for a single applicant under the DSP is US$130,000, of which the government retains US$80,000. Applicants must commit 25 per cent of this value prior to the application being considered and in the knowledge that this amount would be lost should the applicant fail to pass scrutiny. Due diligence, application and certificate fees apply, with due diligence fees having been increased to US$5000 per application by the Citizenship (Development Support Program) (Amendment) Regulations Order No. 39 of 2020. This amendment also mandated the use of an international specialist firm to perform due diligence checks. Despite this new requirement, it seems Vanuatu currently only makes use of third-party firms to conduct desktop checks, rather than comprehensive on-the-ground due diligence.

Applications are processed rapidly, although slowdowns are sometimes recorded as a result of the oath of allegiance procedure having to be completed in the physical presence of a Commissioner for Oaths located in Vanuatu, Dubai, Hong Kong or Singapore. With the onset of Covid-19, however, temporary provision was made for applicants to take the oath of allegiance via video conference link. Citizenship certificates may be received by a designated agent and do not require additional travelling.

Limitations also exist with respect to the applicant’s choice of designated agent, as applicants cannot decide to change their representative agent unless their application is progressing at an unreasonably slow pace (defined as in excess of six months).

In practice, applicants benefit from the government not imposing a language test, which could otherwise require mastering any of Vanuatu’s three official languages (English, French, and Bislama) or a vernacular of Vanuatu. Applicants also need not sit an interview, nor study the culture or history of the island.

There is a close rapport between Vanuatu and China, something that made headlines in June 2019 when certain Chinese-born DSP citizens were repatriated — allegedly without due process. Despite this, citizens of Vanuatu cannot access China visa-free. They can, however, travel without a visa to Hong Kong, Russia, the Schengen Area and the UK.