In 2025, the allure of citizenship by investment remains strong, offering affluent individuals a pathway to global mobility and new opportunities. 

However, recent developments have cast a shadow over the safety and legitimacy of these programs; notably, the European Court of Justice ruled Malta's 'golden passport' scheme illegal, citing violations of EU law and concerns over commodifying citizenship. This decision underscores the increasing scrutiny and potential risks associated with such programs.

For those considering this route, it's crucial to understand the evolving legal landscape and the implications of recent rulings, and our comprehensive guide will help you understand just that.

Continue reading to explore the complexities of CBI and determine whether it's the right choice for you…

What Is Citizenship by Investment (CBI)?

Citizenship by Investment (CBI) is a legal process whereby individuals can obtain citizenship in a foreign country by making a substantial financial contribution, typically through investment in real estate, government bonds, or national development funds.

Here’s what you need to know:

What Is Citizenship by Investment?

Citizenship by Investment (CBI) is a legal process allowing individuals to acquire a second nationality in exchange for a significant financial contribution to a country’s economy; this usually involves real estate investment, government bonds, or a donation to a national development fund.

CBI programs offer fast-track naturalization, with some countries granting passports in as little as 3–6 months, and unlike traditional immigration, there’s often no residency or language requirement.

Countries offering CBI typically undergo due diligence checks to verify the applicant’s background, source of funds, and criminal record.

Key benefits of CBI include:

1. Visa-free travel to 100+ countries.
   
2. Access to tax advantages in certain jurisdictions.
   
3. Greater global mobility and security for investors and their families.
   

How Do CBI Programs Operate Globally?

CBI programs are offered by a limited number of countries – mostly in the Caribbean, Europe, and the Pacific – and each has its own criteria, investment thresholds, and processing times.

Applications are processed by a citizenship unit or ministry, often through licensed agents. Governments conduct multi-tiered background checks, sometimes using third-party firms, before approval.

Globally, CBI faces increased scrutiny from the EU and OECD, pushing for more transparency and tighter due diligence to prevent misuse.

Popular CBI destinations include:

1. St. Kitts and Nevis: Minimum $250,000 donation or $400,000 real estate investment.
   
2. Dominica: From $100,000 donation or $200,000 real estate.
   
3. Malta: Offers naturalization after 12–36 months with investment starting at €738,000.
   

Programs are typically structured around one or more of the following:

1. Non-refundable government contributions.
   
2. Investment in approved real estate projects.
   
3. Creation of businesses or job opportunities.

How Safe Are CBI Programs?

CBI programs are generally safe when administered by reputable jurisdictions with strict due diligence processes, though the level of protection varies depending on the country and its regulatory enforcement.

Consider these risks:

What Are the Common Risks Associated with CBI?

Citizenship by Investment (CBI) programs carry several risks, both for applicants and host countries; a main concern is the potential for misuse, including money laundering, tax evasion, or passport fraud if due diligence is weak.

For applicants, risks include:

1. Revocation of citizenship if a country later amends its laws or finds irregularities in the application.
   
2. Scams or unlicensed agents offering fake programs or inflated fees.
   
3. Lack of transparency about timelines, processing, or government decisions.
   

For host nations, risks include:

1. Damage to international reputation, particularly if passports are granted to individuals with questionable backgrounds.
   
2. Increased pressure from the EU or FATF, which may result in visa restrictions or blacklisting.

How Do Countries Mitigate These Risks?

Many countries mitigate these risks by choosing to adopt multi-layered due diligence processes; additionally, governments work to ensure regulatory compliance with global standards, including cooperation with AML (Anti-Money Laundering) and CFT (Counter-Terrorism Financing) frameworks.

Reputable CBI programs publish transparency reports, enforce strict agent licensing, and review policies regularly to maintain credibility and avoid sanctions.

Applications typically undergo:

1. Background checks by international security firms.
   
2. Verification of source of funds and financial integrity.
   
3. Screening through INTERPOL, Europol, and global watchlists.
   

Some programs also require:

1. Personal interviews or enhanced scrutiny for high-risk applicants.
   
2. Delays or denial powers held by the Prime Minister or a special committee.
   

What Does the Regulatory Landscape Look Like in 2025?

The regulatory landscape for CBI in 2025 is increasingly stringent, with heightened international scrutiny, particularly from the EU and OECD, prompting countries to strengthen compliance, transparency, and reporting standards.

Think about these legal considerations:

What Are the Recent Legal Developments Affecting CBI?

In recent years, CBI programs have come under growing legal and political pressure–particularly from the European Union and the United States–with the EU urging countries offering CBI to tighten screening, and in some cases, to wind down their programs entirely.

These legal shifts are reshaping the CBI landscape, favoring programs with stronger governance and reputational safeguards.

Key developments include:

1. Malta’s Individual Investor Programme has been limited, with the EU initiating infringement procedures over concerns of “EU citizenship for sale.”
   
2. Cyprus terminated its CBI scheme in 2020 following corruption scandals and EU scrutiny.
   
3. Caribbean nations like St. Kitts & Nevis, Antigua, and Grenada agreed in 2024 to standardize minimum investment levels and strengthen due diligence under pressure from the U.S. Treasury.
   

New reforms focus on:

1. Enhancing background checks and transparency.
   
2. Reducing fast-track pathways seen as too lenient.
   
3. Increasing government oversight of licensed agents and intermediaries.
   

How Do International Bodies Influence CBI Regulations?

International bodies significantly influence how CBI programs operate; the European Union, OECD, and Financial Action Task Force (FATF) are particularly active in promoting tighter controls and standardization.

These bodies influence national policy through blacklisting or greylisting jurisdictions seen as non-compliant, publishing compliance guidelines and best practices, and applying diplomatic and financial pressure on non-cooperative countries.

As a result, compliant programs increasingly emphasize integrity, security, and alignment with global norms to remain viable and credible.

These are the ways in which controls are being tightened:

1. The EU views CBI as a security risk, especially when non-EU nationals obtain EU mobility through member-state programs. It has called for mandatory suspension of schemes that pose integrity threats.
   
2. The OECD warns that CBI can undermine tax transparency, especially when applicants use citizenships to avoid Common Reporting Standard (CRS) obligations.
   
3. The FATF urges countries to apply rigorous anti-money laundering (AML) standards, pushing for enhanced due diligence and monitoring.
   

What Due Diligence & Security Measures Are in Place?

The due diligence and security measures in place for CBI programs include comprehensive background checks, anti-money laundering (AML) screening, and verification of financial sources. 

Let’s look closely at the processes in place:

What Due Diligence Processes Are in Place for Applicants?

Most CBI programs apply multi-tiered due diligence checks to verify the identity, background, and financial standing of applicants, which are all  essential to prevent illegal activity and maintain international trust.

In addition to standard checks, many programs also require sworn declarations, police clearance certificates, and enhanced checks for politically exposed persons (PEPs) or applicants from high-risk jurisdictions.

Standard processes include:

1. Background screening through global databases like INTERPOL, World-Check, and sanctions lists.
   
2. Verification of identity documents, educational records, and previous citizenships.
   
3. Source of funds checks, often involving audits of bank statements, business records, and tax filings.
   
4. Use of third-party due diligence firms, often based in the UK or U.S., to independently investigate applicants.
   

How Effective Are These Measures in Ensuring Program Integrity?

Due diligence procedures are generally effective when rigorously applied, and programs that work with international firms and conduct multi-level screening are better positioned to detect fraud or high-risk profiles.

For example; Malta and St. Kitts & Nevis are often cited for having among the most stringent CBI checks, including in-person interviews and multi-agency reviews, and reputable programs typically use 4 or more levels of verification.

Effectiveness varies, however; past scandals—such as Cyprus granting citizenship to individuals under EU sanctions—highlight that political pressure, poor oversight, or weak enforcement can undermine the system.

What Are the Financial Implications of CBI?

Financial implications of CBI include a substantial upfront investment, legal and processing fees, and possible ongoing tax obligations depending on the chosen jurisdiction’s policies and your tax residency status.

Consider these fees and financial obligations:

What Are the Costs Involved in Obtaining Citizenship by Investment?

The total cost of obtaining CBI varies significantly by country and investment route, though the minimum threshold typically starts at $100,000, often for a non-refundable donation to a national development fund.

Real estate options usually begin around $200,000 to $400,000, though some countries also charge processing, due diligence, and legal fees on top; for example, St. Kitts & Nevis requires a $250,000 donation under its Sustainable Island State Contribution, while Dominica offers a $100,000 donation option but adds fees that raise the final cost.

Family size directly affects total cost, with larger households incurring higher charges for each additional dependent.

Applicants should also expect to pay for:

1. Due diligence checks (often $7,500+ per adult).
   
2. Government application fees ($1,000 to $5,000 per person).
   
3. Legal or agent fees, which can add $10,000 or more depending on complexity.
   

Are There Hidden Financial Risks or Obligations?

While most reputable CBI programs are transparent, applicants should be aware of potential hidden financial risks or ongoing obligations; one common risk is maintenance costs tied to real estate investments, such as property taxes, upkeep, or resale restrictions that may lock funds for 5 years or longer.

In some cases, exit strategies are limited, meaning the property can’t be sold easily or at full market value. Non-refundable contributions also mean there’s no capital return on part of the investment.

Other financial risks include currency exchange fluctuations during cross-border payments, additional fees from unregulated agents or brokers inflating service charges, and future tax implications—especially if the new citizenship creates ties to tax-residency rules or reporting obligations.

What Are the Alternatives to Citizenship by Investment?

Alternatives to CBI include residency-by-investment (Golden Visas), naturalisation through long-term residence, employment or family-based immigration, and special talent or business visa programmes.

These are your options:

What Other Residency or Citizenship Options Exist?

Beyond CBI, several countries offer Residency by Investment (RBI) programs, often referred to as “Golden Visas.” 

These schemes grant long-term residence rights in exchange for qualifying investments—commonly in real estate, business, or government bonds.

Popular RBI programs include:

1. Portugal’s Golden Visa, offering EU residency with a path to citizenship after 5 years.
   
2. Spain and Greece, which allow property investment for renewable residency.
   
3. The U.S. EB-5 Immigrant Investor Program, granting a green card for a $800,000–$1,050,000 investment tied to job creation.
   

Other options include:

1. Naturalization through long-term residence, common in countries like Canada and Australia.
   
2. Citizenship by descent or marriage, often faster and less costly if eligible.
   
3. Special talent-based or exceptional contribution schemes, such as Austria’s discretionary naturalization for notable individuals.
   

How Do These Alternatives Compare in Terms of Safety & Benefits?

Residency programs generally offer lower political and reputational risk than direct citizenship schemes, particularly within the EU or OECD countries; additionally, RBI often requires physical presence or integration, making it less prone to international scrutiny than fast-track CBI programs.

Safety-wise, RBI programs undergo more rigorous vetting and compliance with EU and FATF standards, offering applicants greater long-term stability and fewer chances of policy reversals.

However, CBI typically offers faster timelines (as little as 3–6 months) and full citizenship rights, including visa-free travel and inheritance of status.

In contrast

RBI requires multi-year commitments, renewal fees, and sometimes permanent relocation. The ideal choice depends on personal goals—whether it’s mobility, long-term relocation, or security of second nationality.

Common Questions

In Conclusion

In 2025, the safety of citizenship by investment depends on careful planning, due diligence, and choosing reputable programmes. 

While the benefits can be significant, risks still exist, especially with lesser-known schemes or poor legal guidance, so if you’re thinking of taking the next step, consider partnering with a trusted adviser to navigate the process securely and make a sound investment in your global mobility.

To protect your future, prioritise transparency, regulatory compliance, and expert advice.