The 2020 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 alternatives for successful applicants.

The first alternative 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 alternative, the minimum threshold for which was introduced in March 2020, requires the applicant to make an investment of US$200,000 or more 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 alternative 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 alternative, 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 alternatives 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, ten per cent of the Government Fees are due upon submission of the application and are deemed non-refundable.

There continue to be delays in application processing by the CBI Unit, the government body responsible for reviewing all applications under the programme. Due diligence procedures in Antigua and Barbuda are strict, with a May 2019 passport recall (whose deadline was extended to 30 June 2020) being ascribed to ensuring that all economic citizens hold e-passports. Several nationalities are excluded outright from the application process, although citizens of Iraq were removed from this list on 1 April 2020.

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.

In June 2017, Antigua and Barbuda lost visa-free access to Canada, one of its most significant selling points. In recent years, however, additions have been made to the list of countries and territories to which citizens of Antigua and Barbuda may travel, including the Republic of Kosovo and the Russian Federation. Antigua and Barbuda accepts dual nationality.

Citizenship by Investment in Austria

The particulars of Austria’s CBI 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 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 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 14(a) 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 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, the latter doing so in three. Under the first option, the applicant must make a BGN1m (US$600,000) guaranteed investment in government bonds, while under the second option the applicant must make a BGN2m (US$1.2m) investment in government bonds or in a Bulgarian company. As of 2019, it is not possible for applicants to combine government bonds and company investments – they must choose between one type of investment or the other. Under both the BGN1m and the BGN2m routes, the 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 the Bulgarian language or local culture.  Since 2019, applicants are required to sit an interview when they submit their application.

The BGIIP is only available to non-European Union 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.

In 2019, in response to concern regarding due diligence, Bulgaria began to demand criminal records both from an applicant’s home country and country of permanent residence. Further concerns led to an announcement that Bulgaria would end its BGIIP in early 2019, yet contrary to such announcement, the Bulgarian government published a draft bill proposing changes to the programme in March 2020.

The benefits of Bulgarian citizenship include free movement rights throughout all European Union (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 Authorization. Bulgaria has yet to join the Schengen Area, although it is taking steps towards membership. Dual citizenship is allowed under the laws of Bulgaria.

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 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 KHR1.25bn (US$304,000) 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 KHR1bn (US$243,000) 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.

Citizenship of Cambodia brings visa-free travel rights to around 50 countries and territories, the majority of which are located in southeast Asia. As a member of ASEAN, 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 Cyprus Investment Programme

Grounded in Section 111A of the Civil Registry Laws of 2002–2019, the Cyprus Investment Programme has undergone several alterations. In its original form, it required a €15m, (US$18m) investment – a price that discouraged applicant participation. The rules for the current programme, which is capped at 700 applications per year, came into effect in May 2019.

Any non-Cypriot can apply under the programme using personal, spousal, or corporate funds to make the necessary donations and investments. Such investments must be made at most three years prior to applying and held for five years following citizenship.

Applicants must purchase real estate valued at €500,000 (US$591,000) plus V.A.T. and declare it as their permanent residence. They must then make two €75,000 (US$89,000) donations – one to the Research and Innovation Foundation and one to the Cyprus Land Development Corporation. Applicants have some flexibility with regards to the first donation. For example, they can show alternative investments in a certified innovative or social enterprise. Finally, applicants must choose one of four €2m (US$2.4m) investment options.

The first and most popular option involves purchasing or constructing buildings, land development projects, or infrastructure. Applicants who select residential real estate need not spend the additional €500,000 (US$591,000) to establish a permanent residence in Cyprus, so long as the chosen real estate had not previously been used in relation to Cypriot CBI.

The second option involves the purchase or establishment of, or participation in, a Cypriot company with significant activity and turnover, and employing at least five Cypriot or EU citizens. Shipping sector investments are eligible under this option.

The third option entails transferring moneys to Alternative Investment Funds (AIF) or Registered Alternative Investment Funds (RAIF) established and investing exclusively in Cyprus. The AIF or RAIF must be licensed, registered, and supervised by the Cyprus Securities and Exchange Commission. There are some limitations on the investments that selected AIF and RAIF can make.

The fourth option is a combination of any of the above.

Application and Naturalisation Certificate Issuing Fees apply, and are levied by the Ministry of Interior, which manages the programme.

Cyprus’ six-month long due diligence checks integrate Schengen Area and other EU controls, as applicants must show a valid Schengen visa and must not have been rejected for citizenship in other EU member states. Applicants’ EU assets must also not have been frozen as a result of sanctions.

Applicants must be resident permit holders for at least six months prior to obtaining citizenship. Permit applications can be made at the same time as citizenship applications and must be lodged in person with the Civil Registry and Migration Department, which records applicant biometrics. Travel to Cyprus is also required for applicants who are approved and take the Oath of Faith. Cyprus does not impose tests or the passing of formal interviews.

Citizenship of Cyprus triggers the right to live and work within the EU, but it does not occasion membership of the Schengen Area. Citizens may avail themselves of visa-free travel to business hubs such as Canada and the United Arab Emirates, but not the US. 

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. Recent changes to the Programme 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 amounting to 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 those regarding source of funds.

By regulation, the Unit must respond to an application within three months of its submission. The Unit maintains 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 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 the summer of 2020, siblings of the main applicant or his or her spouse, up to the age of 25, subject to conditions.

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 from previous economic citizens must hold their real estate 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.

The speed of application review has improved over the past two years, with the CBI Committee no longer experiencing the “prolonged delays” of 2018. 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 the US’ renewable E-2 visa. 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 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 investment options. First, they can decide to invest US$1m in Jordanian small and medium-sized enterprises and must hold that investment for a period of at least five years. Second, they can deposit US$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 US$1.5m, to be held for ten 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$1.5m. Fifth, they can invest US$2m in any project across the country (or US$1.5m 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 (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 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.

The Malta Individual Investor Programme

Moulded in its current form by Legal Notice 47 of 2014 and its 2018 amendment, the Malta Individual Investor Programme (IIP) is nearing its cap of 1,800 successful main applicants. The agency responsible for application processing since 2018, the Malta Individual Investor Programme Agency (MIIPA), has announced that it will halt receipt of applications on 30 September 2020, at which point a new iteration of the programme will begin.

The IIP presents a single three-tier investment strategy for applicants interested in obtaining citizenship of Malta.

First, the applicant commits to making a €650,000 (US$768,000)
non-refundable contribution, of which €10,000 (US$12,000) must be remitted as a non-refundable deposit upon submission of the application. Of the €650,000 contribution, four per cent is given to the IIP’s sole concessionaire and six per cent is delivered to the MIIPA. Of the remainder, before Covid-19, 70 per cent was distributed to the country’s National Development and Social Fund and 30 per cent was paid into the Consolidated Fund. This distribution was recently altered, with 80 per cent of funds being placed in the Consolidated Fund – a move that enables the Maltese government to spend quickly as part of its Covid-19 rescue package.

Second, the applicant either purchases real estate at a minimum value of €350,000 (US$413,000) or rents property at a cost of at least €16,000 (US$19,000) 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, debentures, or special purpose vehicles for a value of €150,000 (US$177,000), to be retained for a period of five years.

As well as completing the three-part investment, applicants must also pay Due Diligence Fees and Bank Charges, and purchase global health insurance of at least €50,000 (US$59,000; to be held indefinitely).

Under the IIP, citizenship is – at best – a one-year endeavour, as applicants must show 12 months’ residence on Malta. An e-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 EU as well as visa-free travel to Canada, the Schengen Area, and the US. Successful applicants under the IIP can expect their names to be published on 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, adopted on 22 November 2018. The Decision entered into effect on 1 January 2019 and, in October 2019, Montenegro began accepting applications under its CBI Programme. The programme is limited both by application volume and time, being capped at 2,000 applications and slated to run until 31 December 2021.

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 (US$295,000) 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 (US$532,000) in government-approved development projects in any of the same three industries, located in the capital, Podgorica, or along the coastline. Regardless of the real estate option chosen, applicants must also make a €100,000 (US$118,000) 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 (US$18,000) 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 now permits the inclusion of a spouse, minor children, and adult children who are dependent on the main applicant.

Montenegro issued its first application approval within three months of the submission of the application, entering the market with one of the world’s fastest application processing times. Under the Programme, applicants need not fulfil any mandatory residence requirements either 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 (SKN) has a more than 35-year history of leading the field of economic citizenship. Indeed, the SKN CBI Programme has earned multiple awards and a reputation as the ‘platinum standard’ of CBI.

To qualify for economic citizenship, applicants can invest in either the Sustainable Growth Fund (SGF) or pre-authorised real estate. 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 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.

There are two branches to SKN’s real estate option. 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. A US$35,000 real estate Government Fee is applicable for single applicants irrespective of the real estate branch they select.

The CBI Unit, which processes all applications for CBI, normally issues approvals or denials within three months. A VIP Accelerated Application Process, available at a premium fee, allows applicants to receive citizenship within 60 days of submitting an application. Currently, SKN 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 SKN 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. In 2020, as in previous years, there remain concerns with respect to the real estate arm of the programme, which has seen project cancellations and suspensions, and which currently only features two approved developments. There are also continued claims by the St Lucia opposition party that past amendments to the programme will “have to be repealed” and that a “policy decision” must be taken as to whether the country should retain the programme. 

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 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 on 1 January 2017.

The second option 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 2020, 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 constrains. 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 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 around 145 countries and territories. The St Lucia Citizenship by Investment (Amendment) Act, 2020 significantly improved opportunities for family inclusion under the programme, including by expanding the meaning of ‘dependant’ to include siblings. 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 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 routes 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.

Application processing has improved despite increasing 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

The Pacific island of Vanuatu has two concurrent CBI programmes: the Development Support Programme (DSP) and the Vanuatu Contribution Programme (VCP). Until 2018, the DSP had been limited in scope, offering honorary citizenship that reduced one’s ability to vote and partake in public life. 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 the capital, 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. Due Diligence, Application, and Certificate Fees apply. 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.

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, which is defined as in excess of six months.

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). Applicants also need not sit an interview, or 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 United Kingdom.