What is happening in the CBI and Golden visa market in 2024? This year turns out to be a ‘game changer’ for the market, where a set of global events and policy changes that shook the $50 billion dollar industry to its core.
The Investment migration market faced dramatic shift, due to rising world tensions, international scrutiny, tightening regulations, government regulations. This year highlights a pivotal moment for the future of investor migration, having profound effects on both investors and the nations that host them.
Key Events that Reshaped
Ukraine War – Russia’s war on Ukraine had a major impact on the market, international sanctions were being imposed on Russia and Belarus. Nationals from these countries were barred from applying for investment migration.
EU Pressure – The European Union has long expressed concerns regarding the misuse of CBI and Golden Visa programs, particularly regarding issues of tax evasion, money laundering, and internal security risks due to poor vetting and governance and has called on phasing out CBI and Golden visas entirely by 2025. The EU has already suspended visa free access of Vanuatu for abusing the CBI program.
UK Visa Requirement -The United Kingdom has revoked visa waiver program of Dominica and Vanuatu due to security risks of the CBI program running in these countries.
Underselling/Discounting – Underselling and illegal discounting has been a major concern in the caribbean and governments have failed to tackle the problem of fraud.
Backlogs – Backlogs discourage investors from applying, many are tired of waiting on the outcome of applications. Governments struggle due to reform of immigration system, shortage of staff and tightening of rules,.Few investors have already filed lawsuit in a court.
US pressure – The US authorities, especially OFAC, FATF (backed by OECD) and other organizations have expressed concerns on CBI/GV programs in Caribbean and Europe on security loopholes , money laundering and tax evasion. USCIS has tightened rule on E-2 visa abuse through CBI, now requiring 3 years of residence before applying.
Correspondent Bank Abuse – US banks cause delay in transferring funds or refuse to process transactions related to CBI and Golden visa investments, requiring additional scrutiny and compliance checks. The Caribbean nations have been a victim, risking correspondent bank relationships for accepting dirty money from corruption, criminals, evading sanctions, poor vetting etc..,
Quick Summary
Let us take a look on quick summary in each country..
1. Portugal
Portugal GV program still open despite, removal of its real estate option in Oct 2023. Since then only cultural, artistic and investment fund option pathways available for GV investors. However the Europe’s most popular program hit by long waiting times 2+ years with 400,000+ applications pending with AIMA. To expedite cases, AIMA has already processed 250,000 pending applications on residence visas, family reunification or residence permits for investment (ARI) in one year. To calm investors, Portugal drafted a law, allowing waiting times, will count towards citizenship application after 5 years from the time of filing first residence application. The President of the Agency for Integration, Migration and Asylum (AIMA), Luís Goes Pinheiro, vowed that processes will be resolved by the summer of 2025.
The following investments qualify for ARI residence permit in Portugal ..
- Investment Fund – EUR 500,000 invested for 5 years
- Artistic/Cultural – EUR 250,000 invested for 5 years
- Scientific Research – EUR 500,000 invested for 5 years
- Commercial company – EUR 500,000 capital transfer. invested for 5 years
Portugal recently has been approved of E-2 visa status by State Department, as a result Portuguese citizens can now apply to get treaty benefits.
2. Greece
Greece has amended golden visa legislation, increased the minimum real estate investment to 400,000 euro from Sep 1, 2024. No changes made to bank deposit, bonds or company share option.
Real estate
Investors are restricted to single property with a minimum surface area of 120 square meters.
- Tier 1 – €800,000 will apply in the Region of Attica, the Regional Units of Thessaloniki, Mykonos, Santorini, Evia, Crete as well as islands with a population of more than 3,100 inhabitants.
- Tier 2 – €400,000 will apply in all other regions of Greece. up from the previous threshold of €250,000.
- Tier 3 – €250,000 properties will be allowed with the following conditions:
Tier3 – A minimum investment threshold of €250,000 will be applicable, regardless of the size and location of the property:
- Commercial to Residential Conversion – Acquisition of a commercial property and conversion into residential use; the investor must complete the conversion before submitting their Golden Visa application. This property should not be used a company seat office.
- Restoration of Historical Buildings – Acquisition and full restoration of a property in listed buildings of historical and cultural importance; the investor must complete the restoration by the fifth year of residency in order to renew their Golden Visa.
3. Hungary
Hungary has restarted the Golden residence scheme for real estate investment. A 10 year Guest investor visa will be granted to foreign investors who make the following investments
Real Estate Fund – EUR 250,000 (from Jul 1, 2024)
Real Estate Property – EUR 500,000 (opens from Jan 1, 2025)
Public donation – EUR 1 million (education, research, public benefit)
Family members (spouse and children) can also receive hungarian residence permits. They can also apply for Hungarian citizenship after 8 years of living in Hungary.
Guest Investors and family members will also receive full working rights in Hungary.
4. Malta
Malta runs both versions citizenship and residency program. Malta has made no specific changes or amendments to residence and citizenship programs. Malta remains the only running citizenship by investment program in Europe after Cyprus and Bulgaria have terminated their golden passport programs.
Malta Residency
Malta PR (Donation) – EUR 100,000 plus fees
Malta PR (Real Estate) – EUR 300,000 property plus fees
Malta Exceptional Citizenship
Route 1 (Normal) – EUR 600,000 donation (citizenship after 36 months)
Route 2 (Fast) – EUR 750,000 donation (citizenship after 12 months)
Malta Vs European Commission
Malta’s moral victory over the landmark citizenship case against European Commission has given “revived hope” for other countries in Europe (eg. in Cyprus, Bulgaria, Montenegro, Moldova) to reopen economic citizenship programs for real estate investments. The calls are getting loud from industry experts and stakeholders, a subject of debate.
In a landmark case this month, the Advocate General of the Court of Justice of the European Union, issued an “Opinion” to dismiss the European Commission case against Malta. EU law does not prevent Malta from granting its citizenship to wealthy foreign investors. The Commission had not proven that EU citizenship law requires any “genuine” or “prior genuine” connection between the member state and the individual, apart from what is necessary under national law to legally grant citizenship. Should the final judgment favor Malta, it could pave the way for more golden passport programs opening in Europe, especially in Bulgaria, Cyprus, Croatia, Moldova, Montenegro and Albania.
Caribbean
The MoA signed by five nations will empower to implement harmonized framework and operating principles for citizenship by investment programs in the Eastern Caribbean
UK ETA – Starting Jan 8, 2025, All citizens of St.Kitts, Saint Lucia, Antigua, Grenada will require ETA pre-authorization to visit United Kingdom.
MoA Framework
- share information on CBIP applicants;
- implement enhanced transparency measures such as the disclosure of funds received by CBIPs, the use of the proceeds of CBIs and to conduct independent financial and operational audits to assess CBIs compliance with best practice standards;
- assign or establish a regional competent authority to set standards in accordance with international requirements and best practices and to regulate the CBIPs;
- establish common standards to manage the communications and promotion of the CBIPs;
- establish common standards for the regulation of agents operating in the CBIPs; and
- facilitate joint training programs and capacity-building initiatives for their respective officials and agencies involved in the administration of CBIPs
Six Principles
The Six Principles agreed in US-Caribbean Round table conference are geared toward strengthening the governance of the CBI Programmes and mitigating money laundering and terrorist financing risks.
- Collective Denials (established): Not to process applications from persons whose applications have been denied in another CBI jurisdiction, by proactively sharing information on denials.
- Interviews (established): Conduct interviews with applicants, whether virtual or in-person.
- FIU checks (established): Each jurisdiction will run checks on each application with the Financial Intelligence Unit of its respective country.
- Audits (pending): Audit the Programme annually or every two years in accordance with internationally accepted standards.
- Retrieval of passports (pending): Request law enforcement assistance to retrieve revoked/recalled passports.
- Russians and Belarusians (established): Suspend processing applications from Russians and Belarusians.
Regulatory Commission
The Five Caribbean CIP nations have setup a “Interim” regional regulator (IRC), to set common standards, monitor and regulate the CIP Programmes in the Easter Caribbean OECS nations, in accordance with international best practices, as per the Memorandum of Agreement signed in March 2024.
The main tasks of the Regional regulator is tasked with:
- Develop, issue and enforce regional standards for CBI Programmes.
- Monitor compliance of legislation, regulations and standards.
- Monitor compliance with international agreements.
- Investigate complaints.
- Facilitate information sharing and engagements with regional and international stakeholders.
5. St.Kitts and Nevis
The Government of St.Kitts (St.Christopher) and Nevis has made a substantial changes, amending the pricing structure for the citizenship by investment program, setting common pricing standards in the caribbean region aligning with other CBI nations. The new changes affects SISC donation and Real estate investment options.
As of Oct 25, 2024, the new investment minimums are as follows:
- SISC donation – USD 250,000 (upto family of four)
- Real Estate – USD 325,000 (condos or hotels) or USD 600,000 (private family homes)
Other reforms implemented by the authorities are..
- St Kitts has formed a new CIU unit as corporation and a specialized due diligence team for vetting of applications.
- The Age limit of parents applying has been increased to 55 years (from 65).
- The Application processing time has been streamlined and efficiently processed in 10 weeks.
6. Antigua and Barbuda
The Antigua and Barbuda government has implemented price increase for the citizenship by investment program, accordance with Memorandum of Agreement signed with four other caribbean nations effective from Aug 1, 2024. Antigua and Barbuda has received record number of applications during first half of 2024.
- NDF Donation – USD 230,000
- Real Estate – USD 300,000
Antigua and Barbuda and China signed Agreement of Mutual Visa Exemption on January 25, 2024, for short stays of maximum 30 days for tourism, business and visiting family/friends.
Antigua amended CIP law on family dependents to permit inclusion of grandchildren, and nomination of family member (in case of death) to pass citizenship down to family. Unmarried siblings have no age limit, along with their spouse can be added to family application. Thus making Antigua & Barbuda most affordable and family friendly citizenship for families.
7. Commonwealth of Dominica
Dominica has made key changes to the citizenship by investment regulations in 2024 announcing new prices from June 8, 2024.
- EDF Donation – US$200,000 for the main applicant or US$250,000 for the main applicant and up to three qualifying dependants
- Real Estate – USD 200,000 (Government fee USD 100,000 applies for upto family of 4)
Among other changes made to CBIP program were
- Name change prohibited for citizenship
- Established Financial Intelligence Unit ensure that all due diligence background checks and interviews are comprehensive and complete.
- Post citizenship additions are permitted for child, spouse and dependent (subject to fee)
- Iranians can apply but subjected to enhanced due diligence check.
The Visa waiver agreement still remains suspended for Dominica citizens visiting United Kingdom and Ireland. As a result Dominican nationals do not qualify for ETA starting from 2025.
8. Saint Lucia
St.Lucia joined other Caribbean OECS nations implementing common framework on pricing, on citizenship by investment program.
- NEF Donation – USD 240,000 (non-refundable)
- Real Estate – USD 300,000 (share in a approved resort)
- Government bonds – USD 300,000 (fully refunded back in 5 years)
Changes to CIP Regulations
- Name change is prohibited under new rules.
- Due diligence fee increased to $8000
Due to backlog, processing times for new applications now takes 10-12 months. Saint Lucia government has published annual reports on the CIP program from 2016 to 2023.
Due to the political unrest in these regions – Russia, Belarus and Iran. , the Citizenship by Investment Unit was unable to conduct proper due diligence and accept funds from applicants within these jurisdictions. Applications are vetted through Joint Regional Communication Center (JRCC), the Royal Saint Lucia Police Force (RSLPF), and reputable third-party Due Diligence firms
9. Grenada
Grenada Citizenship by Investment Unit (IMA) through Circular No. 2 of 2024 has announced new prices for CBI programme in accordance with the Memorandum of Agreement (MoA) among the Member States of the Organisation of Eastern Caribbean States offering Citizenship by Investment Programmes (CBIPs), a new pricing structure for the Investment Migration Agency Grenada (IMA) implemented effective July 1, 2024. Under the new framework, the minimum investment requirement for the Grenada Citizenship by Investment Programme will become US$235,000.00. The threshold was increased from current old prices $150,000 (NTF donation) and $200,000 (real estate).
- NTF Donation – USD 235,000 (upto family of four)
- Real Estate – USD 270,000
Siblings, parents, grandparents can also apply subjected to additional fee. Nationals of Iran, Russia, Yemen, Sudan, Afghanistan are barred from applying for Grenada CBI programme with some exceptions.
Citizens of Grenada enjoy visa free travel to People’s Republic of China for upto 30 days.
The Investment Migration Agency Grenada (“CBI Unit”) will implement a Delinquency Policy for CBI applications effective October 1st, 2024 to maintain the highest standards of financial management to address issues related to the timely payment of investment sums.
All passports under the CBI application process, must be valid for more than six months to ensure smooth and efficient processing of applications.
10. Vanuatu
Vanuatu has made groundbreaking changes to the citizenship by investment program imposing mandatory requirement to travel to Vanuatu embassy to collect passports starting Dec 1. Bitcoin or Cryptocurrency widely accepted in Vanuatu.
Vanuatu introduced the Capital Investment Immigration Plan (CIIP) with a lower contribution requirement than the Development Support Program (DSP).
- Vanuatu CIIP (Donation) – USD $115,000
- Vanuatu CIIP (investment) – USD $155,000
- Vanuatu DSP (Donation) – $130,000
- Vanuatu REO (Real Estate) – USD $180,000
Vanuatu nationals still require visa to visit United Kingdom and EU Schengen area. The visa waiver agreements remain suspended and not restored as of today.
11. Solomon Islands
The Pacific country of Solomon Islands has announced draft bill to open a citizenship by investment program similar to Vanuatu. The draft law completed by the AG’s chambers and is undergoing further peer review before submission to Cabinet for its consideration
The program involves the issuance of the Solomon Islands Ordinary Passport to individuals and their family members that have fulfilled the strict due diligence requirements that will be implemented to ensure the program is transparent and accountable.
The exact investment requirements, eligibility will be known in 2025.
12. Türkiye
Turkey has made key changes to the citizenship by investment program tightening rules for real estate investors buying property for $400,000. Property buyers are given one year residence permit for their investment and fast tracked to citizenship.
The CBI program in Turkey faces pressure from within the country to scrap the program entirely or increase the minimum to $600,000
Here are the important changes to the Turkiye CBI below.
- Personal visit – Principal investor and spouse must attend the appointments in person for filing the short term residence permit and citizenship application in person to provide biometric data.
- Police record – Criminal record certificates must be provided from home country for investor/spouse.
- Land restriction – Purchase of land or fields restricted under new rules. Only “apartments/buildings” are allowed for acquiring properties for the purpose of becoming turkish citizen..
- Health insurance – Valid health insurance (Insurance period must cover the duration of the intended residence permit. Private insurance also accepted.
- Expert evaluation report – All Property transactions in Turkey, there is mandatory expertise report which shows current market value of the Property according to governmental regulations and market facts. This amount in the sales value has to be min $400.000 or above.
- Payments – All payments must come directly to the bank account from abroad. No requirement to open bank account in Turkey. The down payment amount has to be as min $400.000 usd to apply nationality. If paid in installment, only after completion of the payment, it is possible to file citizenship application.
All nationalities can buy property in Turkey except nationals of North Korea, Armenia, Nigeria, Cuba, Yemen, and Syria.
13. El Salvador
El Salvador became the first country to open the first bitcoin citizenship by investment program. El Salvador freedom passport is issued to crypto investors within 3-4 months who make $1 million donation equivalent to Bitcoin/USDT for the welfare of the country.
15. Spain
Spain announced scrapping of issuing golden visas for real estate (the law is still pending) to ease pressure on housing market. If the law is passed, only real estate investment will be removed, and the golden visa program itself, will not close.
Spain golden visa program is still running, attracting HNWI people interested in property.
- Real Estate – EUR 500,000
- Bonds – EUR 2 million
The Spanish authorities process applications very fast usually 30-40 days on investment applications.
Conclusion
New investors face a more complex landscape of bureaucracy, heightened scrutiny, pay higher investment and stricter eligibility criteria. The “golden age” of easy access of CBI and Golden Visa programs may be fading, but interest and opportunities for those seeking alternative citizenships and residencies still remain high.
