The CBI Index: programme profiles

The Antigua and Barbuda Citizenship by Investment Programme

The Antigua and Barbuda Citizenship by Investment Programme was established by the Antigua and Barbuda Citizenship by Investment Act, 2013, and was last modified in May 2018. Antigua and Barbuda offers three investment alternatives for successful applicants.

The first alternative allows applicants (up to a family of four persons) to make a minimum contribution of $100,000 to the National Development Fund (NDF), a not-for-profit organisation created with the purpose of running both public and private projects as well as charitable initiatives such as improving access to healthcare and education.

The second alternative requires the applicant to make an investment of $400,000 or more into one of the government’s approved real estate projects for a period of five years. Such developments include leasehold schemes, hotels, and villas that add value to the nation’s tourism sector. From May 1, 2018, until October 31, 2018, under a limited time offer, 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 $200,000. A ‘related party’ is one with the same licenced agent as the applicant.

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

Government and due diligence fees apply for all three alternatives to citizenship, with the former starting at $25,000 for any application of up to four persons applying under the NDF. Fees increase with the number of persons included in an application, and are higher for applications under the real estate and business options. In all cases, 10 per cent of the government fees are due upon submission of the application and are deemed non-refundable.

In the past year, there have been some delays in application processing, resulting in six-month turnaround times from the date of submission to the Citizenship by Investment Unit (CIU), the government body responsible for reviewing all applications under the programme. Due diligence procedures are strict, and a number of nationalities are excluded outright from the application process.

Although there is no mandated interview or knowledge-based test, 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 Barbadian soil within five years of obtaining citizenship. This requirement is waived for children until after they reach the age of majority at 18.

In June 2017, Antigua and Barbuda lost visa-free access to Canada, one of its most significant selling points. There were, however, some additions to the list of countries and territories to which citizens of Antigua and Barbuda may travel, including Monaco and the Ukraine. Antigua and Barbuda accepts dual nationality.

Citizenship by Investment in Austria

The particulars of Austria’s citizenship by investment procedures are not clearly codified in the laws of the nation. Rather, the scheme draws broad legitimacy from Article 10, Paragraph 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, Paragraph 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. 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 given the existence of certain criminal convictions, immigration orders, and 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, Paragraph 6 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 United States and Canada.

The Bulgarian Immigrant Investor Programme

The Bulgarian Immigrant Investor Programme (BGIIP) was created in 2009 with an amendment to the Foreigners in the Republic of Bulgaria 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 feature makes the BGIIP one of a handful of European citizenship programmes where prior physical residence in the nation is not compulsory.

There are two investment options under the BGIIP, the first leading to citizenship in five years, while the latter doing so in three years. Under the first option, the applicant must make a BGN 1m ($600,000) guaranteed investment in government bonds, while under the second option the applicant must make a BGN 2m investment in government bonds or in a Bulgarian company. Either investment must be retained for a period of five years, after which time it is returned to the investor without any interest that may have accrued.

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 Bulgarian or of local culture, nor do they assess applicants through interviews.

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. Permanent residence may be expected within six to nine months of submission, while citizenship rests on the option selected by the applicant.

The benefits of Bulgarian citizenship include free movement rights throughout all the member states of the European Union. Starting December 1, 2017, citizens of Bulgaria were granted the right to travel visa-free to Canada for up to six months, provided they obtain an Electronic Travel Authorization (eTA). Bulgaria has yet to join the Schengen Area, although it is taking steps towards membership. Dual citizenship is allowed.

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 kingdom. These were further outlined, in their most recent form, by Sub-decree 287 of 2013. On June 11, 2018, the Cambodian senate approved a draft law that would, upon final approval by the constitutional council and assent by the monarch, alter Cambodia’s economic citizenship landscape. The most significant change is expected to be an increase in investment thresholds.

Until formalisation of these proposed amendments however, Cambodia continues to afford economic citizenship to persons who invest 1.25bn Cambodian riels ($295,000) 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 Cambodian 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.

Citizenship of Cambodia brings visa-free travel rights to around 50 countries and territories, the majority of which are located in south-east Asia. As a member of ASEAN, Cambodia affords opportunities for facilitated trade and mobility among member states, including the right to work and live abroad for certain professionals. For those wishing to retain their citizenship of birth, Cambodia allows dual citizenship. Finally, as Khmer citizens, applicants may purchase real estate in the country – a privilege exclusive to Cambodians.

The Cyprus Investment Programme

Grounded in Section 111 of the Civil Registry Laws of 2002-2013, the Cyprus Investment Programme has undergone several alterations. In its original form, it required a €15m ($17.5m) investment – an exorbitant price that discouraged applicant participation. Many of the core aspects of the current programme were unveiled in 2014, and last amended in late 2016 by the nation’s Council of Ministers. Finally, in January and May 2018, the Council of Ministers outlined new requirements for service providers, limited inflows to 700 applicants per year, and instituted more stringent forms of due diligence for applicants, resulting in longer processing times of six months.

Applicants under the Cyprus Investment Programme may apply either as individuals or through one or more companies, so long as they complete all required investments at most three years prior to applying, and hold those investments for a further three years following citizenship.

All applicants for economic citizenship must purchase real estate valued at €500,000 and declare that real estate as their permanent residence. They then must choose one of four €2m investment options.

The first option involves the purchase of or participation in a Cypriot company, resulting in the creation of five jobs for citizens of Cyprus or of the European Union who legally resided on the island for five years prior to the investment.

The second option entails transferring €2m in alternative investment funds (AIFs) established and investing in Cyprus. The AIFs must both be licensed and supervised by the Cyprus Securities and Exchange Commission (CySec).

The third option involves purchasing buildings, land under development, or infrastructure valued at €2m, whether these be residential or commercial. Applicants who select residential real estate under this option, however, need not spend the additional €500,000 to establish a permanent residence in Cyprus.

Combination investments – so long as they amount to €2m – are allowed, and applicants who select this diversification option may also purchase government bonds valued at a maximum of €500,000.

Applications for economic citizenship are processed by the Ministry of Interior and are further subject to application and processing fees. The applicant must be a resident permit holder at the time of application. If not, an application for residency may be lodged at the same time as the application for naturalisation. Cyprus neither requires the taking of tests nor the sitting of formal interviews, but travel is compulsory.

Citizenship of Cyprus triggers the right to work and reside within the European Union, but it does not occasion membership of the Schengen Area. Citizens may avail themselves of visa-free travel to markets such as Canada and the United Arab Emirates, but not the United States.

The Dominica Citizenship by Investment Programme

Dominica’s Citizenship by Investment 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. The Programme’s most recent regulations, issued in August 2017, modified some investment thresholds and fees.

The programme offers two investment opportunities: a one-time contribution into the Economic Diversification Fund (EDF), or an investment in government-approved real estate. Funds transferred to the EDF have been instrumental in Dominica’s national development, particularly by the reconstruction of key infrastructure and public buildings, as well as by the financing of Dominica’s offshore and agricultural sectors.

The EDF option requires a contribution of $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 amounting to at least $200,000, to which a single applicant must add a $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 citizenship by investment. Other applicable fees include due diligence and processing fees.

The Citizenship by Investment Unit (CBIU) is the government authority tasked with managing and processing applications for economic citizenship. To qualify for Dominica’s Citizenship by Investment Programme, applicants must have a clean criminal record and prove they are of good character, as well as pass a series of due diligence checks.

By regulation, the CBIU must respond to an application within three months of its submission. Application processing is however often much faster, taking between 45 and 60 days. The CBIU maintained high competence levels even in the aftermath of Hurricane Maria in September 2017, garnering praise among industry specialists.

The application process in Dominica is straightforward, as there are no interview, travel, or residence requirements, either before or after attaining citizenship. Applicants also need not learn English, or show an education history or business experience.

Benefits of citizenship of Dominica include visa-free travel to more than 120 foreign destinations, dual citizenship, and the opportunity to experience a different, eco-friendly lifestyle.

The Grenada Citizenship by Investment Programme

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

The Grenada Citizenship by Investment Programme offers applicants two investment options. The first option is a contribution into the National Transformation Fund (NTF), a government institution responsible for locating and financing alternative, economy-stimulating investments for the country. The second option is a $350,000 investment in a government-approved real estate project, which applicants must retain for at least three years.

Applicants under either option are responsible for paying associated application, processing, and due diligence fees. A single applicant must make a $150,000 minimum donation to the NTF, while families are responsible for making larger payments. Any application lodged by up to four family members requires payment of an additional $50,000 government fee where the real estate option is selected.

Application review has slowed significantly in Grenada, with the Citizenship by Investment Committee (CBIC) – the entity responsible for processing all applications for economic citizenship – having to issue circulars to apprise stakeholders of “prolonged delays”. Use of new application forms became mandatory on March 1, 2018, but no change was made to Grenada’s policy of not requiring an interview, business experience, proficiency in the English language, and travel or residence.

Grenadian citizenship can benefit successful applicants by providing them with options for global mobility, particularly to China and the United States. Indeed, Grenadian citizens are eligible to apply for a renewable US visa through the country’s restricted E-2 programme. 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), and particularly in Article 13(2), which 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 state 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 options. First, they can decide to invest $1m in Jordanian small and medium-sized enterprises, and hold that investment for a period of at least five years. Second, they can deposit $1.5m in a non-interest-bearing account at the Central Bank of Jordan, again for a period of at least five years. Third, they can invest in treasury bonds worth $1.5m, to be held for 10 years at an interest rate determined by the Central Bank of Jordan. Fourth, they can purchase securities from an active investment portfolio priced at $1.5m. Fifth, they can invest $2m in any project across the country, or $1.5m in projects that are located in governorates outside of that 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 (JIC), an entity established in 2014 to succeed the Jordan Investment Board, which was first founded in 1995. The role of the JIC 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 two 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 10 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 whenever a person commits or attempts to commit an act to endanger Jordan’s peace and security, or when 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.

The Malta Individual Investor Programme

As the European Commission’s first recognised citizenship by investment programme, Malta’s Individual Investor Programme (IIP) is a strong contender on the European scene. Moulded in its current form by Legal Notice 47 of 2014, the IIP must not exceed 1,800 successful main applicants.

The IIP has a single three-tier investment strategy for applicants interested in obtaining citizenship of the island.

First, the applicant commits to making a €650,000 ($760,000) non-refundable contribution, of which €10,000 must be deposited prior to submission of the application. Of the €650,000 contribution, 4 per cent is given to the IIP’s sole concessionaire, and 6 per cent is delivered to Identity Malta, which processes applications. Of the remainder, 70 per cent is distributed to the National Development and Social Fund, a separate legal entity administered by a board of governors which is tasked with using funds to advance education, research, innovation, social purposes, justice and the rule of law, employment initiatives, the environment, and public health. Finally, the residual 30 percent is paid into the country’s consolidated fund.

Second, the applicant either purchases real estate at a minimum value of €350,000 or rents property at a cost of at least €16,000 per annum.  Whether the applicant chooses to purchase or rent, the real estate must be held for a period of five years, during which time it may not be let or sublet.

To complete the investment portfolio, the applicant must also acquire government bonds, stocks, or special purpose vehicles for a value of €150,000, to be retained for a period of five years.

As well as completing the three-part investment, an applicant must also pay the due diligence fees used to assess suitability for citizenship, and purchase global health insurance (to be prolonged indefinitely).

Under the IIP, citizenship is – at best – a one-year endeavour, as applicants must show 12 months’ residence on Malta. A residence card is issued to enable applicants to live on the island during this time.

Maltese citizenship does not come at the price of one’s previous nationality, as dual nationality was allowed in 2000. It brings a number of benefits including the right to live and work in the European Union, and visa-free travel to the Schengen Area and the United States.

The St Kitts and Nevis Citizenship by Investment Programme

As home to the world’s most longstanding economic citizenship programme, the Federation of St Kitts and Nevis has a 34-year history of leading the field of economic citizenship. Indeed, the St Kitts and Nevis Citizenship by Investment Programme has earned multiple awards and a reputation as the ‘platinum standard’ of citizenship by investment.

To qualify for economic citizenship, applicants are invited to invest in either the Sustainable Growth Fund (SGF), the Sugar Industry Diversification Foundation (SIDF), or pre-authorised real estate. Due diligence fees apply under all options.

The SGF is a new and permanent feature of the programme, having been established by regulation in March 2018. The SGF substituted the Federation’s Hurricane Relief Fund (HRF), a temporary citizenship route that came into existence to tackle damage caused by the September 2017 hurricanes that struck the Caribbean. Under the SGF, a single applicant must make a minimum donation of $150,000.

SIDF applicants who prefer to pursue St Kitts and Nevis’ traditional route to economic citizenship can continue to contribute a non-refundable sum of $250,000. Contributions are redirected to projects that facilitate the country’s transition from an economy specialised in sugar production, to one that offers a variety of services and products.

There are two branches to St Kitts and Nevis’ real estate option. Under the first branch, the applicant must buy property worth at least $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 $200,000. The investment must be retained for a period of seven years and is exempted from stamp duty. A $35,000 real estate government fee is applicable for single applicants irrespective of the branch they select.

The Citizenship by Investment Unit (CIU), which processes all applications for citizenship by investment, normally issues approvals or denials within two months. Because of the extraordinary success of the HRF however, the CIU is currently registering delays of around six months. These are expected to be short-lived, and unlikely to characterise the programme in the long run. A VIP Accelerated Application Process (AAP), available at a premium fee, allows applicants to receive their passport within 60 days of submitting their application. There is no interview, language, education, or business requirement for 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.

Benefits of citizenship of St Kitts and Nevis include visa-free travel to a growing number of worldwide destinations – now the highest of any citizenship by investment 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 Citizenship by Investment Programme is the newest economic citizenship programme to emerge from the Caribbean, and is its most politically divisive. Early changes to the contribution thresholds under the Programme, as well as the removal of unique features such as the $3m net worth requirement and the 500-applicant annual cap, opened the programme to criticism within St Lucia’s political establishment. It also generated uncertainty, as the opposition pledged to review all successful applications for citizenship – and potentially ask for larger contributions – upon returning to power. 

St Lucia has four investment options. The fastest option is a contribution to St Lucia’s National Economic Fund (NEF). Moneys deposited into the NEF are funnelled into progressive local development projects, selected by the minister of finance with the approval of parliament. Originally set at a $200,000 contribution, on January 1, 2017, the government reduced the entry threshold to $100,000.

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

Applicants may also acquire government bonds worth at least US$500,000. The bonds must be held for five years and cannot return a rate of interest.

Under the Programme’s final option, applicants can make a minimum investment of US$3,500,000 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 $6m is made, with each investor contributing no less than $1m. At least six permanent jobs must be generated as a result of the joint venture.

Due diligence and processing fees apply under all options, while administration fees apply only to the real estate, government bond, and enterprise project options. The latter start at $50,000 for a single applicant.

Applications are processed by the Citizenship by Investment Unit (CIU), and are returned with an approval or denial within three to five months of submission. There is no need for applicants to learn English, or to prove any business skills or education. Applicants are also not required to attend an interview, reside in St Lucia, or travel to the island.

Citizenship of St Lucia offers a viable alternative for anyone seeking a relaxing lifestyle and global access to around 130 countries and territories. St Lucia has no restrictions on holding dual nationality.

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, as amended, and in Regulation 2016/9601, passed by the Council of Minister on December 12, 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”.

Applicants interested in obtaining citizenship of Turkey may do so by choosing one of five routes. The first three routes each entail retention of the investment for a period of three years. They are: purchasing property valued at $1m, depositing $3m in a Turkish bank, or investing $3m 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 Undersecretariat of the Treasury, according to the nature of the chosen investment. The remaining two routes to citizenship are an investment of $2m in fixed capital, to be acknowledged by the Ministry of the Economy, or the creation of 100 jobs in Turkey, to be acknowledged by the Ministry of Labour and Social Security.

Although there are plans to reduce the $1m real estate investment threshold to $300,000, these have yet to become law.

The application process, which normally takes three months, does not require applicants to learn Turkish or to attend a mandatory interview. There is also no requirement to reside in Turkey, and the applicant may apply remotely. There are no restrictions on an applicant’s country of origin, making the Turkish citizenship by investment route a popular option for those who are banned from partaking in the programmes of other nations.

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 European Union 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 United States.

The Vanuatu Contribution Programme

The Vanuatu Contribution Programme (VCP) is one of two active citizenship by investment schemes in the Pacific island of Vanuatu. Codified in 2016, it became operational in 2017 following the closure of the Vanuatu Economic Rehabilitation Programme (VERP). The VCP coexists with the Development Support Programme (DSP), but while the former offers full citizenship, the DSP offers honorary citizenship only, meaning that DSP citizens cannot vote or participate in political life.

A single applicant under the VCP, and up to a family of four, must make a minimum contribution of $130,000. To that, they must add $25,000 in other processing and due diligence fees due to the government. Twenty-five per cent of the total is due prior to submission. Additionally, the applicant must show a minimum net worth of no less than $250,000.

Applications under the VCP are processed by the Citizenship Commission, which normally takes between six and eight weeks to return an application, although it may legally take up to a period of three months. Applicants need not learn any of Vanuatu’s three official languages (English, French, and Bislama), sit an interview, or study the culture or history of the island. They must, however, travel either to Vanuatu or to Hong Kong to take the required oath of allegiance. Receipt of the citizenship certificate and passport is normally scheduled for the same day.

Despite its youth, the VCP has already been the subject of some criticism. At home, it has been denounced by some locals for being controlled and marketed by a single agent and its affiliated exclusive marketing agent, based in Hong Kong. Internationally, Vanuatu made headlines in late 2017, when it was suggested that the country would accept bitcoin payments in exchange for economic citizenship – a development that was later denied by the government.

Vanuatu allows its VCP citizens to hold dual citizenship, and is the only provider of citizenship by investment in Oceania. Its citizens may travel without a visa to the Schengen Area and Hong Kong, although a visa is required for mainland China.