We tell our clients to be very careful and disclose all facts to the agent when filing application for CBI programs. You have to remember that Citizenship by investment schemes have more strict background checks compared to residency programs (golden visas). This is a very important subject cannot be ignored by clients applying for CBI programs. Please be open and communicate properly with your citizenship advisor. Licensed Agents and Law firms that file applications for Citizenship by investment usually have over 95% approval rate, but are required to keep the refusal rates very low to protect the reputation of the firm. Under the CIP regulations, Agents are supposed to do the initial background checks and KYC for clients. They should be able to tell clients whether they and their families are eligible or not before forwarding the files to the citizenship office of the government.
There are many reasons for rejections by authorities, from disclosure to security checks.
1.Disclosure
Clients are required to fully disclose all information asked in the application forms. Concealment or false information are immediate grounds of rejection by authorities. Clients must fully disclose their background with the agent handling the file before submission of application. For example, court cases, criminality, immigration status etc. If in doubt licensed agents can pre-check with the authorities with the case file. Please refer to the KYC client checks, we do before accepting clients.
2.Eligibility Check
The following pre eligibility checks based on their case file.
- Must be over 18 years of age (Main applicant)
- No criminal record
- Previous visa rejection
- Family members (age and status and financial support)
2.Security Checks
There are several lawyers of background checks done before boarding a client. These are
- KYC (Know your customer)
- Primary due diligence check (lawyer, agent)
- Third Party due diligence providers (eg. Thomson reuters, World check)
- Checks done by Government and Local police and national security agency
- Banks compliance checks for source of funds and sanctioned persons and entities.
If your application has received a refusal under the citizenship by investment , it could be because of one of the following reasons (see below).
2.Top Reasons for Refusal
We provide you 30+ most common reasons (red flags) for application refusals under citizenship by investment programs.
- Criminal Record – If you have criminal record or a conviction which shows up in police report, you cannot apply for CBI programs.
- Background checks – Failing background check done by the Government and third party due diligence firms.
- Bank compliance – Banks receiving funds at CIP countries may not receipt funds if you fail compliance checks and KYC. If you cannot prove your identity (eg. valid ID) banks may refuse funds. This can be a problem with stateless people.
- Sanction person or company – If you are on sanctioned by western countries (US, UK, EU), your application automatically refused
- Interpol Wanted list – Wanted by Interpol or other law enforcement agencies.
- Fraudulent – Providing false information, failing to disclose all details or lying in your application (includes family members)
- Security threat – Threat to national security of the country.
- Disrepute – Bringing disrepute to the state.
- Terrorism / Crime – Applicant has ties to terrorism, previous criminal record or convictions or jailed abroad for more than 12 months.
- Visa denials – Visa denials raise red flags being tagged as high risk applicant. Any previous visa denials from EU Schengen countries, US, United Kingdom etc or any other country signed visa waiver with the country where you are applying for citizenship
- Blacklist – You are national of blacklisted country hit by sanctions or trade embargo (Sudan, North Korea) ineligible to apply
- Source of Funds – Failed to provide evidence for source of funds or source of funds originated from country with sanctions.
- PEP person – Reputation risk by Politically exposed persons (PEP). All PEPs are subjected to Enhanced due diligence checks
- Health – Failing health or medical checkups or for HIV positive
- Name conflict – Conflict of Identical names with criminals or blacklisted person.
- Financial crimes – Involved in money laundering, embezzlement, financial crimes in other countries.
- SIS Alert – Alert issued in Schengen information system (SIS) and other EU databases.
- Failing to Disclose – Providing false information about visas issued by United States and Canada.
- Securities fraud – Involved with SEC fraud in the United States
- Extradition – Have extradition case filed by a country.
- Bankruptcy – Involved in personal or corporate bankruptcy.
- Court cases – Involved with civil actions pending against you in a court or threatened by creditors.
- Previous refusals – Applied for citizenship in one country and was denied, automatically refused for other CBI countries that share applicant information.
- Family dependants – Previous convictions of family members.
- Minimum investments – Your investment is not paid fully or you paid Undercutting the minimum required investment or You do not maintain the requirement investments (real estate, bonds, business etc) for the minimum number of years
- Ponzi scheme – Involved in cryptocurrency ponzi scams or frauds.
- Sanctions – You are subjected to new sanctions or embargo imposed on a country.
- Residence – You did not satisfy the residence requirement or visited the country before.
- Age limit – You do not meet the basic eligibility criteria such as main applicant below 18 years of age and children above 30 years cannot apply together in a family application.
- Name Change – If you have changed your name in the past and not disclosed the information
- Deported / Repatriated – Any deported or repatriation orders served by the country must be disclosed.
- Military record– If you have done military service with the enemy state, your application can be denied.
- Birth certificate – Original Birth certificate must produced issued with certification from origin country.
- Police certificate – Must have no criminal history and be issued within six months.
- Cryptocurrency fraud – Paying with Bitcoin or crypto is not legal tender, not accepted by governments. If you are convicted of crypto fraud or arrest warrant, you will be denied for citizenship.
Refusal Aftermath
One refusal is shared by many countries make it very difficult to apply for CBI programs in other countries. The reputation of citizenship consultant takes a damage when receiving a denial for a submitted client. But you will be able to appeal or reapply through your authorised agent if you think its a mistake by authorities and have a valid reason. The Citizenship by Investment Unit will provide you a reason in writing through your authorised agent. It is important to note that citizenship approved only at the sole discretion of the Government and Council of Ministers. If you have already approved for citizenship and passport but later found to be a wanted person, CIP regulations have provisions for revoking citizenship and passport. If the citizenship is revoked for main applicant, all family members are also automatically revoked. It is a long complicated legal process.
What you should know?
We provide you some important tips on what you should know about the citizenship programs
- Malta has the highest refusal rates of all the passport programs. Nearly one in three applications are refused.
- Grenada automatically refuses applicants if refused by another CBI program.
- Antigua and Barbuda is one country that requires 5 day residence requirement to renew the passport. You will not be able to renew passports after 5 years without visiting the country for 5 days. It is the only country that has residence requirement in the Caribbean may not be appealing to many clients.
- Many countries do not accept applications from blacklisted nationals from North Korea, Iran due to sanctions. These nationals can apply if they have lived outside these countries and have no economic connections and are permanent residents in another country living for more than 5 years.
- Cyprus and Bulgaria requires investments to be maintained for 5 years even after acquiring passports.
- You must obtain police clearance certificate in all the countries where you have lived in past 10 years to apply for CBI programs.
- US citizens must obtain FBI clearance certificate not local police certificate when gathering documents.
Citizenship Loss
CBI laws are very strict when it comes to clean record of applications. All CBI programs have legislation to strip citizenship and revoke passports immediately. If the passport of main investor is revoked, all family members will also lose their citizenship and passport status.
- If you are imprisoned abroad for more than 1 year.
- Wanted person by Interpol or law enforcement agencies.
It is important to note that once the main applicant is revoked of citizenship, all the family members including spouse and children.
If you have any further questions on this topic, please contact us for a consultation with the experts.
