The CBI Index: the individual programmes

The Antigua and Barbuda Citizenship by Investment Programme

The Antigua and Barbuda Citizenship by Investment Programme is a recent addition to the sphere of economic citizenship, having been established by the Antigua and Barbuda Citizenship by Investment Act, 2013. Antigua and Barbuda offers three investment alternatives for successful applicants.

The first alternative allows applicants to make a minimum contribution of $200,000 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. Such developments include leasehold schemes, hotels, and villas that add value to the nation’s tourism sector.

The last alternative entails an investment of $1,500,000 into an eligible, government-approved, business project. Applicants can apply as joint investors so long as each applicant makes a $400,000 investment into a project estimated to be worth at least $5,000,000.

Government and due diligence fees apply under each of the three alternatives to citizenship, with the former starting at $50,000 for a single applicant.

The programme’s application process takes approximately three months 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, but a number of nationalities are outright excluded from the application process.

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.

Antigua and Barbuda offers citizens close ties to the Americas, including visa-free travel to Canada. Citizenship also comes with access to over 130 countries and territories worldwide, as well as life in a tolerant nation that accepts dual nationality.

Citizenship by Investment in Austria

The particulars of Austria’s citizenship by investment procedures are not 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 an individual displays actual or expected outstanding achievements. Failure to fully codify the scheme has made it one of the least transparent processes in the economic citizenship arena.

The outstanding achievement underlined in Austria’s laws translates into a number of accepted avenues for investment, although it has been reported that a monetary donation of €8-10m ($8.9-11.2m) was sufficient to trigger the provision.

Exclusive and limited to those who can guarantee a positive attitude towards Austria and its government, the scheme has operated intermittently, and only rarely are aspiring applicants successful. The process involves significant communication with various government representatives, and usually takes about two years to complete. Under Article 10(a), knowledge of the German language, with due regard for the personal circumstances of the applicant, is required for the grant of nationality. However, this has at times been waived under the scheme.

Although Austria generally disallows dual nationality, applicants who apply to naturalise under Article 10, Paragraph 6 are permitted to retain their original citizenship, bringing the scheme in line with those of other jurisdictions offering economic citizenship. Other benefits of Austrian citizenship include visa-free access to all European Union member states, the United States, and Canada. A total of more than 170 nations have implemented visa waiver programmes for Austrian citizens.

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 programme does not require the investor to physically spend time in Bulgaria while waiting for citizenship to be issued. This feature makes Bulgaria 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 Programme, the first leading to citizenship in five years, with the latter doing so in three years. Under the first option, the applicant must make a BGN1m ($573,000) guaranteed investment in Government bonds, while under the second option the applicant must make a BGN2m 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 programme are first submitted to a local Bulgarian consulate, which redirects the application to the Ministry of Foreign Affairs and issues a first-stage visa for the applicant to enter Bulgaria and file for permanent residency. Thereafter, processing is conducted by the Ministry of Foreign Affairs.

The programme is only available to non-EU nationals, who must make two formal trips to Bulgaria; once to file for permanent residency, and once to register permanent residency 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, and visa-free access to more than 150 countries and territories. Bulgaria has yet to join the Schengen Area, although it is taking steps towards membership. Dual citizenship is allowed without restrictions.

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. As a member of the Association of Southeast Asian Nations (ASEAN), and the only nation to offer a direct citizenship programme in Asia, Cambodia provides a gateway for investors looking to bring capital to the continent while also obtaining citizenship rights.

Cambodia currently affords citizenship to those who invest 1.25 billion Cambodian riels (around $311,900) 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 1 billion Cambodian riels (approximately $249,500) 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 also 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 a citizen of Cambodia, the applicant may purchase real estate in the country – a privilege exclusive to Cambodians.

The Comoros Economic Investment Programme

The Comoros passed its first Law on Economic Citizenship on 27 November 2008, having found authority to do so in Articles 5 and 19 of the Constitution of 23 December 2001. The Economic Investment Programme was devised as a means of generating income for the nation, with the Gulf States as key target markets.

Shortly after its inception, the Comoros announced that more than $200m would be invested through the programme in return for the naturalisation of 4,000 families, each between six and eight family members. The families were all composed of Bedoon, stateless people who generally do not enjoy the same rights as those of the nationals of the countries they reside in, primarily the United Arab Emirates and Kuwait.

The programme has since sought to entice individual investors, with minimum required investments set each financial year by the relevant Finance Act. Furthermore, each naturalisation requires the payment of 1,000,000 Comorian francs (around $2,000) to the national Treasury.

The body responsible for processing all applications under the Comoros Economic Investment Programme is the Independent National Committee, which aims to process each application within a timeframe of 45 to 80 days. Economic citizenship is granted by a decree of the President of the Republic issued by the Council of Ministers.

The programme does not require applicants to reside in the archipelago, and is restricted to those foreigners whose habitual residence is outside Comorian territory. Unlike for other programmes, there is a requirement that the applicant not support principles contrary to Sunni Islam, the nation’s dominant religion. The applicant must also attend an interview and provide biometric data before an enrolment officer in Dubai, or anywhere in the world provided the applicant pays for the officer to travel.

The Comoros Programme for citizenship offers rewarding personal benefits, such as travel to more than 45 countries and territories, many of which are located in Africa and south-east Asia. The Union of the Comoros respects the applicants’ personal choice to retain their citizenship of origin by allowing dual nationality once Comorian citizenship is obtained. However, as a citizen who was naturalised through an investment in the Comoros, an applicant will not have the right to vote, become part of the country’s judicial branch, or join the army.

Scheme for Naturalisation of Investors in Cyprus by Exception

Grounded in Section 111 of the Civil Registry Laws of 2002-2013, the Scheme for Naturalisation of Investors in Cyprus by Exception had undergone several alterations. In its original form, it required a €15m ($16.8m) investment – an exorbitant price that discouraged applicant participation. The current scheme was unveiled in 2014, and last amended in late 2016 by the nation’s Council of Ministers.

Applicants under the Cypriot scheme 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 preserve those investments for a further three years following citizenship.

All applicants for citizenship must purchase real estate valued at €500,000, and declare that real estate as their permanent residence. They then have a choice of three options in which they must invest €2m.

The first option involves the purchase of or participation into 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 to diversify their investment may also purchase government bonds for a maximum value of €500,000.

Applications for citizenship under the scheme 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, otherwise an application for residency may be lodged at the same time as the application for naturalisation. The application process takes a minimum of three months and involves no language test or interview requirements.

Benefits for acquiring citizenship in Cyprus includes freedom of movement and residence in any other European Union member state, although it does not occasion membership of the Schengen Area. Citizens may avail themselves of visa-free travel to around 160 countries.

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 citizenship options. It plays a major role in promoting social and environmental causes, particularly sustainable development.

The programme was recently reshaped by the 2014 Citizenship by Investment Regulations to include diverse investment options and even stricter regulation processes, enabling stringent review of applicants.

The programme currently 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 $50,000 real estate government fee. The real estate must be held for a period of three years, increased to five years if the 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 citizenship under the programme. 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. There are no interview or travel requirements. Applicants under the programme are also exempt from residency requirements, whether before or after attaining citizenship. Applicants also need not learn English, or show a history of education or business experience. The programme is one of the most accessible in the world in that it does not impose any restriction based on the applicant’s nationality.

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

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 includes a contribution of $200,000 into the National Transformation Fund (NTF), a government institution responsible for locating and financing alternative, economically-stimulating investments for the country. The second option allows the applicant to purchase a $350,000 government-approved real estate project, which the applicant must hold for at least three years.

Applicants under either option are responsible for paying associated application, processing, and due diligence fees. An application by up to four family members requires an additional US$50,000 Government fee where the real estate option is selected.

The application process, showcasing an administration timeline of 60 business days, is also one of the most seamless, requiring no interview, no business experience, and no language requirement. Travel to Grenada or residence therein are also not necessary under the programme. Every application is vetted by the Citizenship by Investment Committee (CBIC), and must go through a series of external due diligence checks before it is readied for final review and for approval by cabinet.

Grenadian citizenship can benefit successful applicants by providing them with options for global mobility, particularly to China and the US, the latter of which allows Grenadian citizens to apply for a renewable visa through its E-2 Programme. Dual nationality is allowed.

The Malta Individual Investor Programme

As the European Commission’s first recognised citizenship by investment programme, Malta’s Individual Investor Programme is a strong contender on the European scene. Moulded in its current form by Legal Notice 47 of 2014, the programme is capped at 1,800 successful applicants.

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

First, the applicant must make a €650,000 ($728,000) non-refundable contribution to the Malta National Development and Social Fund, a separate legal entity administered by a board of governors charged with using the funds to advance education, research, innovation, social purposes, justice and the rule of law, employment initiatives, the environment, and public health.

Applicants can then either purchase real estate at a minimum value of €350,000 or rent property at a cost of at least €16,000 per annum.  Whether the applicant chooses to purchase or rent, the real estate must be maintained 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 meeting a qualifying contribution for investment, applicants must also pay due diligence fees, used to assess their suitability for citizenship. They must also purchase global health insurance, to be prolonged indefinitely.

Applications for citizenship of Malta are processed by Identity Malta, a procedure that takes at least one year as applicants must show 12 months’ residence on the island. A residence card is issued to enable applicants to live on the island prior to gaining citizenship.

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 a total of more than 165 countries and territories.

The Saint Lucia Citizenship by Investment Programme

The newest economic citizenship programme to emerge on the world stage, inaugurated in January 2016, is Saint Lucia’s Citizenship by Investment Programme.

Saint Lucia has four investment options available to applicants preferring to invest under this Programme. The fastest option is a contribution to Saint 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 – causing some local criticism and speculation that the programme was not sufficiently popular.

The second option under the programme asks applicants to make a minimum investment of $300,000 into a government-approved real estate project. Real estate projects are expected to be boutique properties or fractions of branded hotels and resorts, and must be maintained by the applicant for a period of five years.

Applicants may also purchase government bonds worth at least $500,000. The bonds must be held for five years, and may not return a rate of interest to the applicant.

Under the final option of the programme, applicants can make a minimum investment of $3,500,000 into a government-approved enterprise project, which may be brought to the attention of the Government by the applicant. The project may 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.

Application are processed by the Citizenship by Investment Unit (CIU), with the first year of the programme's existence seeing applications returned to applicants with an approval or denial within three months of submission. There is no need for applicants to learn any language, or to prove any business or education skill. Further, applicants are not required to attend an interview.

Citizenship of Saint Lucia offers a viable alternative for anyone seeking a relaxing lifestyle and global access to around 125 countries and territories. Saint Lucia has no restrictions on holding dual nationality.

The St Kitts and Nevis Citizenship by Investment Programme

As home to the world’s longest-standing Citizenship by Investment Programme, the Federation of St Kitts and Nevis has a 33 year-long history of leading the field of economic citizenship. Today, the programme has earned a reputation as the ‘platinum standard’ of citizenship by investment, offering applicants the opportunity to partake in one of the most diversified economies of the Caribbean.

To qualify for citizenship under this programme, applicants are invited to invest in either the Sugar Industry Diversification Foundation (SIDF) or pre-authorised real estate. SIDF applicants can contribute a non-refundable sum of $250,000 – a minimum threshold that increases as more individuals are included in an application. 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 produce.

As an alternative investment option, applicants can purchase real estate worth at least $400,000. A $50,000 real estate government fee is applicable for single applicants. The property must be retained for a minimum of five years. Due diligence fees apply under both options.

The Citizenship by Investment Unit (CIU) is responsible for processing all applications for citizenship by investment. Processing of each application can take between 45 days and three months, and a VIP Accelerated Option, available at a premium fee, allows applicants to receive their passport within 60 days of date of submitting their application. The process entails neither an interview, nor a language, education, or business requirement. Travel to the twin-islands is not obligatory, and no minimum residence stays apply either prior to or after citizenship is obtained.

Benefits of the St Kitts and Nevis Citizenship by Investment Programme include visa-free travel to more than 130 countries and territories, the option to maintain multiple nationalities, and the opportunity to become a citizen of one of today’s fastest growing nations.

The Vanuatu Economic Rehabilitation Programme

Introduced by Honorary Citizenship (Vanuatu Economic Rehabilitation Program[me]) Regulation Order No. 34 of 2015, the Vanuatu Economic Rehabilitation Programme (VERP) was launched as a means of reinvigorating the South Pacific island nation’s economy following the passage of Cyclone Pam on 15 March 2015, which resulted in severe infrastructural damage.

There is a single route available under the VERP: a contribution to the Vanuatu Government VERP Account in the amount of $130,000, which includes a family of four with a main applicant, a spouse, and two children under the age of 18. To this sum, applicants must add citizenship, passport, Vanuatu Investment Promotion Authority (VIPA), and due diligence fees.

Offering one of the quickest processing times, at only one month following receipt of all documentation, the VERP has no language, residence, or minimum education requirements. To take the citizenship oath and obtain finalised citizenship papers, the applicant may choose between travelling to Vanuatu, waiting until the relevant Commissioner for Oaths visits the nearest Diplomatic Mission, or paying a fee to cover the cost of the Commissioner traveling to the applicant’s place of residence.

Applications are received by the Citizenship Commission and due diligence checks are performed by the Financial Intelligence Unit working closely with Interpol. The final grant of citizenship rests in the hands of the president, who acts upon the advice of the prime minister.

Although Vanuatu recognises dual citizenship as of 2013, citizens who are dual nationals may not vote, hold or serve in any public office, or be politically involved in Vanuatu – such as by affiliating with a political party or funding activity that may cause political instability. Any citizen of Vanuatu may however benefit from visa-free travel rights to around 110 territories, including, as of 28 May 2015, the Schengen Area.