CBI Programme Risks and Pitfalls: What Can Go Wrong with Citizenship by Investment

Citizenship by investment is marketed as a clean, process-driven transaction: pay the contribution, pass due diligence, receive the passport. For legitimate applicants working through reputable authorised agents with well-established programmes, this description is broadly accurate. But the industry has generated its share of failures, scandals, and policy reversals — and investors who did not understand the risks before committing have suffered the consequences.

This guide is not intended to discourage CBI investment. The majority of transactions through established Caribbean programmes proceed without incident. But it is intended to provide a clear-eyed view of what can go wrong, how to assess programme stability, and what investor-side due diligence should cover before committing significant funds.

Programme Closure

The most fundamental risk is that a programme ceases to exist — either before the investor's application is complete or, in some cases, affecting citizenships already granted.

Historical Closures and Suspensions

Cyprus: Cyprus operated a citizenship by investment programme that granted Cypriot (and therefore EU) citizenship for substantial property investment. The programme was suspended by the Cypriot government in November 2020 following reporting by Al Jazeera that suggested senior Cypriot politicians and officials had facilitated applications for individuals who should have been disqualified. The programme was terminated immediately. Investors who had committed funds were generally able to complete or withdraw; no retrospective revocation of granted citizenships has occurred, but the programme itself no longer exists.

Bulgaria: Bulgaria operated an Immigrant Investor Programme offering residency and an accelerated citizenship pathway. The EU Commission's pressure resulted in Bulgaria's programme being effectively closed to new applicants by 2022 for the expedited citizenship route, though the investment residency route continued.

Malta: Malta's citizenship by naturalisation programme (MEIN — Malta Exceptional Investor Naturalisation) was challenged by the European Commission at the Court of Justice of the European Union (CJEU). On 29 April 2025 the CJEU ruled that Malta's scheme was incompatible with EU law and had to be discontinued. Malta has since closed MEIN to new applicants and introduced a separate, contribution- and merit-based "citizenship by merit" framework that is not a direct investment route. Citizenships already granted under MEIN remained valid — the ruling addressed the ongoing programme, not retrospective revocation of existing citizenships. However, investors who were mid-application faced significant uncertainty.

The key lesson: even for EU-level programmes with significant institutional backing, programme closure is a real risk. Investors should not assume that a programme current when they apply will necessarily be current when they complete.

Assessment: Programme Stability

When evaluating a programme, consider:

• How long has the programme operated? St Kitts & Nevis (established 1984) has a track record of more than 40 years. A programme established in 2021 has not been tested through political cycles.
• Is the programme enabled by specific legislation? Programmes embedded in primary legislation are harder to close quickly than those operating under executive order or ministerial regulation.
• What is the fiscal significance of the programme to the country? A Caribbean small-island country for which CBI revenues represent 20-30% of government income has a strong structural incentive to maintain the programme.
• Is the country under external pressure to close the programme? EU countries (and aspirant EU members) face EU-level scrutiny; Caribbean countries face US and Schengen waiver programme monitoring.

Visa-Free Access Withdrawal

A citizenship by investment passport is valuable largely because of its visa-free access. If that access is withdrawn — by a Schengen country removing visa-free arrangements, or by the UK changing its visa waiver policy — the practical value of the passport diminishes.

Vanuatu: The Warning

The most significant recent example is Vanuatu. The European Union began suspending Vanuatu's visa-free access to Schengen countries in 2022 (partial suspension from March 2022, full suspension from February 2023), citing concerns about Vanuatu's due diligence standards for its citizenship programme. Specifically, the EU concluded that Vanuatu had granted citizenship to individuals who posed risks that would have been identified by more rigorous due diligence.

For investors who had acquired Vanuatu citizenship partly or primarily for Schengen visa-free access, this represented a significant reduction in the passport's value. Rather than being restored, the suspension was subsequently made permanent — the EU moved Vanuatu to the visa-required list in late 2024 — demonstrating that visa-free arrangements are not permanent and can be withdrawn entirely.

Caribbean Programmes and US Waiver

Caribbean CBI passports do not provide automatic US entry — holders must apply for a US visa in the normal way (with the exception of Grenada's E-2 Treaty route). However, some Caribbean countries have recently pursued US Visa Waiver Programme (VWP) eligibility, which would allow their citizens to visit the US under ESTA. Any country in the VWP is subject to ongoing compliance monitoring by the US government; failure to meet VWP conditions can result in removal.

Separately, the US has expressed concern about Caribbean CBI programmes potentially enabling individuals to exploit Schengen visa-free access in ways that circumvent US security interests. This has led to informal pressure on Caribbean programmes to maintain rigorous due diligence.

Mitigation

The primary mitigation is choosing programmes with strong, established due diligence records. A passport's visa-free access is only as secure as the programme's reputation. A programme that allows bad actors to obtain citizenship invites the withdrawal of access that those bad actors would exploit.

Agent Fraud and Misrepresentation

The CBI industry's intermediary layer — agents, "citizenship planners," and "migration consultants" — includes both reputable authorised firms and individuals who operate without proper licensing, misrepresent programme terms, or, in some cases, commit outright fraud.

Common Agent-Side Failures

Unlicensed agents: most CBI programmes require agents to be formally licensed by the programme authority. Unlicensed agents cannot legitimately represent clients to the programme and have no accountability to the programme country if problems arise.

Misrepresentation of costs: programmes sometimes offer agents commercial flexibility; unscrupulous agents collect higher fees from clients than the programme requires without disclosure. The investor pays more than necessary.

False representation of eligibility: an agent who tells a client with a criminal conviction that they can "manage" the due diligence process is either lying or representing that the programme's standards are corruptible — neither of which is in the client's interest.

Misrepresentation of programme terms: promising faster processing than the programme actually delivers; overstating visa-free access (including destinations that require visas in practice); failing to disclose residency requirements (Antigua's five-day requirement).

Fee fraud: agents have been known to collect fees without processing applications — a form of straightforward fraud that is more common in newer or less regulated markets.

Protection

• Work only with agents who are formally authorised by the programme. Request written confirmation of their authorisation status and verify it independently with the programme authority's published authorised agent list.
• Obtain an itemised fee breakdown that separately identifies government fees, due diligence fees, and agent fees.
• Do not make payments to personal accounts or accounts in jurisdictions without proper financial regulation.
• Obtain independent legal advice (from a lawyer who represents you, not the agent's in-house lawyer) on the terms of the engagement.

Policy Reversal: Investment Route Changes

Investment requirements, contribution levels, qualifying investment categories, and family inclusion rules can change between application and completion — or after completion in ways that affect the cost of maintaining the investment.

Portugal's golden visa programme closed its real estate investment route mid-programme, affecting investors who had committed to property purchases that were no longer qualifying investments. Most were grandfathered but the uncertainty was significant.

Greece raised its property thresholds from €250,000 to €800,000 in specific high-demand areas (Athens, central islands) with transitional provisions, but investors who had not yet committed found their budget assumptions changed significantly.

For real estate routes particularly, price changes, market movements, and regulatory changes can affect both the qualifying investment and the exit value.

Retroactive Changes to Granted Citizenships

The question investors most want answered: can a citizenship already granted be taken away?

In general, citizenship legally granted is a constitutional right in most countries and cannot be revoked without cause. The normal causes for revocation are: fraud or misrepresentation in the original application; subsequent acquisition of a disqualifying criminal record; renunciation by the citizen.

However, programme closures and external pressure have tested this. Malta's ECJ case did not result in revocation of existing citizenships. The Cyprus closure did not result in revocations. The theoretical risk exists — particularly in politically unstable programme countries — but there is no clear historical precedent of mass revocation of legitimately granted CBI citizenships.

The strongest protection: apply through a programme that issues citizenship under primary legislation, in a politically stable country with an independent judicial system that would be the forum for any challenge to revocation.

Family Inclusion and Inheritance Risks

CBI citizenship typically extends to dependent family members (spouse, dependent children) at the time of application or for an additional fee. The subsequent ability to add family members born after the citizenship — and to pass the citizenship to descendants — depends on the programme's specific rules.

Investors should verify:

• Can children born after the citizenship is granted be included or registered?
• At what age do dependent children cease to qualify for the dependent extension?
• Are adult children (18+) excluded from the original application?
• Does the citizenship pass by descent to grandchildren in the same way as a birth citizenship?

These details are programme-specific and should be confirmed in writing.

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This guide covers the risk landscape of citizenship by investment as understood at the date of publication. Programme terms, regulatory status, and external geopolitical pressures change frequently. Nothing in this guide is legal or investment advice. All CBI transactions should be undertaken with qualified independent legal advice and through authorised, licensed agents. Investments can fall in value as well as rise; citizenship programmes may be amended, suspended, or closed.

How Global Investments Can Help

Global Investments works with clients on CBI programme selection with a specific focus on programme stability, due diligence quality, and the mitigation of the risks described in this guide. We use only authorised agents, provide independent legal oversight of all transactions, and give clients a clear, honest assessment of programme risks before any commitment is made. Contact our team for a confidential consultation.