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 passport programs.

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.

If your application has received a refusal under the citizenship by investment , it could be because of one of the following reasons (see below).

We provide you 25 most common reasons for application refusals under citizenship by investment programs.

  1. Background checks – Failing background check done by the Government and third party due diligence firms
  2. Wanted list – Wanted by Interpol or other law enforcement agencies.
  3. Fraudulent – Providing false information, failing to disclose all details or lying in your application (includes family members)
  4. Security threat – Threat to national security of the country.
  5. Disrepute – Bringing disrepute to the state.
  6. Terrorism / Crime – Applicant has ties to terrorism, previous criminal record or convictions or jailed abroad for more than 12 months.
  7. 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
  8. Blacklist – You are national of blacklisted country hit by sanctions  or trade embargo (Sudan, North Korea) ineligible to apply
  9.  Source of Funds –  Failed to provide evidence for source of funds or source of funds originated from country with sanctions.
  10.   PEP person – Reputation risk by Politically exposed persons (PEP). All PEPs are subjected to Enhanced due diligence checks
  11.  Health – Failing health or medical checkups or for HIV positive
  12.   Name conflict – Conflict of Identical names with criminals or blacklisted person.
  13.   Financial crimes – Involved in money laundering, embezzlement, financial crimes in other countries.
  14.   SIS Alert – Alert issued in Schengen information system (SIS) and other EU databases.
  15.   Failing to Disclose – Providing false information about visas issued by United States and Canada.
  16.   Securities fraud – Involved with SEC fraud in the United States
  17.   Extradition – Have extradition case filed by a country.
  18.   Bankruptcy – Involved in personal or corporate bankruptcy.
  19.   Court cases – Involved with civil actions pending against you in a court or threatened by creditors.
  20.   Previous refusals – Applied for citizenship in one country and was denied, automatically refused for other CBI countries that share applicant information.
  21.   Family dependants – Previous convictions of family members.
  22.   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
  23.   Ponzi scheme – Involved in cryptocurrency ponzi scams or frauds.
  24.   Sanctions – You are subjected to new sanctions or embargo imposed on a country.
  25.   Residence – You did not satisfy the residence requirement or visited the country before.
  26.  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.

Refusals

A 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.

Revocation

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 you are imprisoned abroad for more than 1 year.
  • Wanted person by international law enforcement agencies.

It is important to note that once the main applicant is revoked of citizenship, all the family members including spouse and chidlren

If you have any further questions on this topic, please contact us for a consultation with the experts.