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Parviz Malakouti-Fitzgerald, Esq.

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Writer's pictureParviz Malakouti-Fitzgerald, Esq.

What is Citizenship by Investment? 


By Parviz Malakouti-Fitzgerald, Esq. 

A magical St. Lucian waterfall


Did you know that in a few countries, you can naturalize as a citizen right away, by making a monetary investment or donation to the country?


There’s typically no minimum period of residency - just a straight path to citizenship, with a price tag, of course. 


By naturalizing, you get the citizenship, passport eligibility, immediate indefinite right of residence in that country and all the other benefits (and obligations) bestowed on a citizen of that country.


This is known as citizenship by investment or “CBI” for short. 


Article Outline:


Being able to apply for naturalization immediately, without first being resident in the country for years, can be a powerful tool. 


Here’s how citizenship by investment works, what its benefits are and the countries that offer it. 


How Citizenship by Investment Works 


Citizenship by investment refers to a country’s naturalization of foreigners in exchange for either a monetary donation to the country, or a recoupable investment of some sort in the country. The recoupable investment can take the form of real estate, bonds, bank deposits, business acquisition, or otherwise, depending on the country. 


There exist both formal and “informal” citizenship by investment programs. By formal, we mean that there is a clearly established published law, regulations, protocol, cost, and predictable process to apply. Informal programs are much more arcane and “under the radar.” 


This article covers the formal programs. In a nutshell, the most important eligibility criteria for formal CBI programs tends to be: 


  • Sufficient financial means of the applicant 

  • Absence of criminal history 

  • Ability to prove source of funds for the investment

  • Absence of previous visa denials, especially to the EU, UK, or USA


Tens of thousands of people have obtained citizenship by investment through the years, across these ten formal programs.


One of the hallmark features of citizenship through investment is a super high standard of due diligence of the applicants. These countries run several different background checks on applicants, and reject applicants who have criminal records. 


Which Countries Offer Citizenship by Investment? 


Currently there are about ten programs that offer citizenship by investment. 


  • St. Lucia 

  • St. Kitts & Nevis 

  • Grenada

  • Dominica

  • Antigua & Barbuda 

  • Turkey

  • Malta

  • Vanuatu 

  • El Salvador

  • Egypt

  • Jordan


Five of them are in the Caribbean: 


  • St. Lucia 

  • St. Kitts & Nevis 

  • Grenada

  • Dominica

  • Antigua & Barbuda 


These countries, besides pricier St. Kitts, offer citizenship by investment for a range of prices, in the $130k-$190k depending on the country, the number of applicants in your family, and a few other factors. This figure represents the donation option amounts, meaning you don’t get to see that money again.


Effectively, we’re talking about the purchase of citizenship. 


Many of these countries are zero-tax jurisdictions, and they all have stunning scenery and beaches, making them attractive CBI options. 


Beautiful Antigua


Europe has two well-known CBI countries: 


  • Malta 

  • Turkey 


Malta, a mediterranean island country, is the only CBI country in the European Union. Citizenship in an EU country is highly sought after because it gives its holder the right to live, work, or study indefinitely in any of the 28 EU countries. 


Stunning Malta, a European Union country


This is a right given by citizenship in one country to be able to live in another country is an incredible springboarding tool, and European citizens use it liberally. Malta is tied with El Salvador (mentioned below) for the most expensive formal CBI program, requiring a total capital outlay of around $1 million dollars. 


Turkey has the world’s most popular CBI program by number of applicants. Turkey’s program is attractive because the investment is a true recoupable investment of real estate worth at least $400,000 USD. In other words, it’s not a donation. Most importantly, the real estate purchase can be made on the open market.


Istanbul, Turkey is a world class metropolis straddling Europe and Asia


Vanuatu, the tiny southwest pacific island nation offers citizenship by investment. The cost is in the range of about $130,000 USD. 


Recently, Vanuatu’s program has been under fire from the European Union with accusations of lax due diligence on its applicants. As a result, Nivanuatu citizens (that’s what citizens of Vanuatu are called!) lost visa-free access to Europe’s schengen zone in the fall of 2022. Vanuatu is currently working to get it back. 


El Salvador finally rolled out its new citizenship by investment program in December, 2023, asking for a steep $1 million dollars in bitcoin. While El Salvador is experiencing an inspiring renaissance in recent years, the juice must be worth the squeeze. 


According to El Salvadorian President Nayib Buckle, you do not have enough bitcoin


As I told Forbes back in December, I don’t believe El Salvador’s program will be that attractive to Americans at this price. There are many attractive alternatives at 1/5th the price (like St. Lucian citizenship for about $140k). 



Egypt just launched a brand new citizenship by investment program, offering options based on both true recoupable investment and donation. 


Jordan also has naturalized about a score of people through its citizenship by investment program. Jordan’s program is not viewed as very desirable in the industry for applicants who are not already investing heavily in Jordan. 


Citizenship by Investment for Americans 


American citizens are pursuing citizenship by investment much more since the beginning of the pandemic, due to an overarching urge for a plan B citizenship by whatever means available to them. 


As I wrote in the Las Vegas Sun in September, 2022: 


“Most of my American clients pursuing second citizenship reject the notion that we are exempt. They pursue a second citizenship to have a predetermined landing zone to safety as part of a plan B.” 


In my practice, we screen Americans for European citizenship by descent first to see if they qualify for dual citizenship through this more cost-effective route. If they don’t qualify, we pursue citizenship by investment - at least for the Americans who can afford it. Even some of those who qualify for European citizenship by descent still want to pursue CBI to become not just a dual citizen, but a triple citizen. 


Many undocumented people in the United States are also eligible to apply for citizenship by investment, if they have the financial means. At present, most CBI programs do not require an in-person visit to the country in order to naturalize. 


This is a key factor for undocumented people in the U.S. who have “unlawful presence” which prevents them from leaving the United States without the consequence of being unable to return. 


On the other hand, one factor that some undocumented people may face is that some CBI programs view previous visa denials as a negative, or even entirely disqualifying factor for eligibility. 


Request a Consultation with Malakouti Law


At Malakouti Law, we help people become dual and triple citizens, whether through investment, descent, or otherwise. 


Click here to book a consultation right away and find out what path is right for you. 


Each immigration and citizenship case is particular and you should consult with a qualified immigration and citizenship lawyer about your case before taking any steps. The Law Office of Parviz Malakouti does not guarantee the accuracy of information presented nor assume responsibility for actions taken in reliance of this information. The information in this page could become outdated. Attorney marketing. 


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