Migration, Residency & Citizenship

    What Do You Prefer? Citizenship Or Residency By Investment

The 21st century has brought an immense expansion of the investment migration industry. Just in the Investment Migration Insider’s online directory, about one thousand firms are listed and, probably, there are thousands more minor businesses providing a wide range of cross-border services, including helping the rich to obtain so-called ‘golden visas’ and ‘second passports.

It is one of the trends of globalization that people are increasingly seeking alternative residency or citizenship options. Mostly, wealthy people from Asia, the Middle East, and Africa, as well as Russia, sustained the demand for services provided by the immigration firms. It was used to be the need to enhance international mobility, along with opportunities to develop business internationally, that motivated the rich to sign retaining agreements with all these immigration firms, but the Covid-19 pandemic, political uncertainties, and civil unrests all over the world made shifts in these motivations. Currently, it can be said that the driving force for the industry is the willingness of people to have a ‘Plan B’ in case of turmoil in their homelands, find a ‘safe heaven’ for the whole family by securing an alternative residency or citizenship.

What Is A Citizenship By Investment?

According to rough estimates, nowadays, about 100 jurisdictions have well-structured and administered Residency by Investment (RBI) or Citizenship by Investment (CBI) programs.

Citizenship by investment (CBI) is a concept describing policies, which allow individuals to obtain foreign citizenship in exchange for investment. CBI programs legally grant citizenship status to foreign investors in a short period of time compared to the traditional naturalization processes. Frequently, media outlets call these schemes ‘golden passport’ programs.

What Is A Residency By Investment?

A residence by investment (RBI) is the same as citizenship by investment, but instead of giving citizenship rights, investors are gaining the residence permit, referred to as ‘golden visas’ in a foreign jurisdiction. As usual, first, a temporary residence permit is issued, and after a while, a status of a permanent resident is granted. Permanent residents after a certain period of time are eligible to apply for citizenship through naturalization, but the rules and procedures differ according to the states.

Countries with CBI Program

The CBI Index 2021 by the Professional Wealth Management, a publication of the Financial Times, evaluates 14 countries with citizenship by investment programs. Five of them are in the Caribbean – St. Kitts & Nevis (the pioneer of the CBI scheme), Antigua and Barbuda, St. Lucia, Commonwealth of Dominica, and Grenada. Four are from Europe: Austria, Bulgaria, Montenegro, and Malta. Probably, in the next year’s edition, North Macedonia will also be presented in the report, as the country has recently launched the citizenship by investment program. The remaining countries are Turkey, Cambodia, Jordan, Egypt, and Vanuatu.

Caribbean CBI programs are probably, the most affordable ones. The minimum investment requirement starts from USD 100,000, in case of a non-refundable contribution to the special governmental fund, and from USD 200,000 if a CBI applicant prefers to make a real estate investment. In addition, application processing, due diligence, administrative, and some other fees also imply. The main can include family members in the citizenship application for increased investment threshold and extra fees. These can be a spouse, children, parents and grandparents, and siblings as well.

Remarkably, the CBI Index puts the Caribbean CBI programs at the top of the ranking in 2021 ranking Dominica and St. Kitts and Nevis share the leading positions with the highest scores, followed by Grenada, St Lucia, and Antigua and Barbuda.

The CBI index allows making comparisons between active CBI programs and specific aspects of each of them. These aspects are reflected by the CBI Index’s nine pillars, which are: Freedom of Movement, Standard of Living, Minimum Investment Outlay, Mandatory Travel or Residence, Citizenship Timeline, Ease of Processing, Due Diligence, Family and Certainty of Product.

Vanuatu’s CBI program follows the Caribbean states in the 2021 ranking and holds the sixth position. The investment threshold for its two active CBI programs starts from USD 130,000 for the single applicant.

Vanuatu is followed by the Maltese new CBI scheme (seventh in the ranking), which is much expensive, as, along with a real estate investment (rent for at least EUR16,000 per annum or purchase for at least EUR700,000), applicants are required to make a non-refundable contribution of at least EUR 600,000 and a philanthropic donation of at least EUR 10,000. Maltese passport is one of the strongest in the world, and actually, it is the only country with an active CBI scheme, which has a visa-waiver with the USA, thus allowing visa-free travel to the USA to its citizens. Applicants for the Maltese CBI program, first, are granting either 12- or 36-months residency, depending on the size of the investment, and only after that period they are applying for citizenship.

The eights in the ranking are Montenegro’s and Turkey’s CBI schemes. Like the Maltese program, the Montenegrin scheme has a donation plus investment structure, and it requires a non-refundable contribution of at least EUR 100,000, in addition to the real estate investment. The threshold for a real estate investment is EUR 250,000 if the property is located in the North part of the country, or EUR 450,000, if it is in the Southern, Coastal area and the capital city Podgorica. As Montenegro is soon expected to join the European Union, its citizenship will become more valuable. Although, one should keep in mind that by the end of 2021, the Montenegrin CBI program will expire. Initially, it was launched back in 2019 with 3 year period and capped with just 2000 applications.

The Turkish CBI scheme is really a story of success. The initial program was very expensive, but in 2019 the government drastically lowered the threshold for a real estate option – from USD 1 million to just USD 250,000. This move fueled the demand for Turkish citizenship, and according to the official data, about 35,000 foreigners obtained Turkish passports through the CBI scheme in just past 3 years.

The tenth spot is occupied by Egypt, but its CBI scheme is not much popular due to the weakness of the Egyptian passport, which allows visa-free travel to just 51 destinations. The financial threshold starts from USD 250,000, but for a real estate option, it stands at USD 500,000.

Bulgaria and Austria stand at twelfth and thirteenth positions respectively. In order to obtain Bulgarian citizenship, one should make an investment of at least BGN 1 million (about EUR512,000) in the country, while the Austrian scheme is the least transparent and most expensive, with no defined financial threshold, but practice shows that investment of at least EUR 20 million is needed to qualify for the Austrian citizenship. Austria grants economic citizenships since 1985 and only 1436 persons have been naturalized from that date till 2020 under the program.

Countries with RBI Program

Probably, most of the countries globally have provisions in the legislation that gives a path to a foreigner to obtain a residence permit. But there are about 30 states, which have elaborated a special program, with a government-appointed administering body and clear guidelines to grant ‘golden visas’ or status of the resident to foreigners in exchange for investment. The most distinguished programs are in the EU: Portugal, Greece, Spain, Ireland, Malta, and Cyprus. All of them, except the Irish program, envisage a real estate acquisition as a qualified investment for ‘golden visas,’ but the financial thresholds vary from country to country.

The Portuguese ‘golden visa’ program is considered a leader in the investment migration industry. The investment threshold starts from EUR280,000, and it gives a route to citizenship. If certain residency requirements are met, Portuguese ‘golden visa’ holders can obtain citizenship and passports.

Greek ‘golden visa’ program is also very popular, allowing foreigners to obtain a residence permit in Greece if they invest at least EUR 250,000 in Greek real estate. The ongoing pandemic and global lockdowns have tremendously reduced the number of issued Greek ‘golden visas’, but as travel restrictions are lifted, the demand will again rise.

The financial threshold for Spanish ‘golden visas’ starts from EUR500,000 into a realty, while Malta and Cyprus require about EUR350,000.

Separately, should be mentioned the UK’s Tier 1 Investor visas and the American EB-5 program. The UK required investment of at least GPB 2 million to grant the investor an Indefinite Leave to Remain (ILR), which an equivalent to permanent resident status in other countries. As per the EB-5 program, it is implemented through the Regional Centers and requires an investment of at least USD 500,000 in the specially approved project to qualify for the American ‘green card.’


Companies involved in the RCBI industry say that the global turnout of the industry is about USD 25 billion, and the number will definitely rise in the coming years. Reports about the increased interest toward the alternative residency and citizenship options started to appear as soon as the Covid 19 pandemic hit the world.

Correlation between the jump in demand for ‘golden’ visas or passports and civil unrests in Hong Kong and the USA, as well as wars and some natural catastrophes, are vivid. Wealthy people from all over the world and, especially, from Asia, the Middle East, and Africa are eager to secure future insurance for the whole family.

That is why they actively invest overseas with the purpose of obtaining residency or citizenship rights. As before, concerns about the children’s education and access to better healthcare also play an important role in their motives. And last, not but least, the visa-free travel opportunities should also be considered – high-net-worth individuals from countries with weak passports are interested in obtaining a second passport, and the Caribbean CBI programs are a good solution for that, which give visa-free access to all the major economic and financial hubs of the world.

But if an investor is interested in obtaining real estate overseas, which along with other perks, gives the status of resident, then Portuguese and Greek programs are the best. Starting from 2022, Porto, Lisbon, and most of the coastal area will be expected from qualifying under Portuguese ‘golden visas’. Hence, if investors want to buy a realty in an area with a high potential of return on investment (ROI) in Portugal, then they have to rush.

Investors should know that each program, whether citizenship by investment or residency by investment, always has some unique features. Laws are structured in the same manner, but they are different in all countries; that is why a consultation with immigration professionals is always recommended.

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