The Passport That Costs More Than a Flight: Inside the Quiet Global Boom in Citizenship-by-Investment

About 25 countries sell citizenship outright and 50 more sell residency. The market is mature, the due diligence is brutal, and the buyers are no longer just oligarchs.

By the Jester Desk · September 26, 2026

In April 2025, the Court of Justice of the European Union ruled that Malta's citizenship-by-investment scheme was contrary to EU law. The court held that granting citizenship in exchange for predetermined investments, absent a genuine link to Malta, unlawfully commercialises Union citizenship and breaches the principle of sincere cooperation, according to globalinvestments.net. No other EU member state operated a programme that led directly to citizenship by investment. The ruling did not end the global market. It just redrew the map.^[12]

A Market With Two Tiers

About 25 countries have citizenship-by-investment (CBI) programmes and 50 have residence-by-investment (RBI) programmes, according to migration.ucdavis.edu. The distinction matters. CBI programmes enable individuals to become citizens by economic contribution, often without residency periods, local language knowledge, or civic tests. RBI programmes grant residency rights by purchasing a house, making a financial investment, or creating jobs, per migrationpolicy.org. Unlike RBI, which frequently requires investors to actually migrate, CBI documents are often used only for international mobility or as insurance.^[4][5]

The price range is wide. The minimum investment can be as low as USD 100,000, as in Dominica, and as high as 3 million euros, as was required in Cyprus in 2014 and 2015, according to migrationpolicy.org. Many small island nations offer golden passports granting citizenship in exchange for donations or investments of $100,000 to $1 million, per migration.ucdavis.edu. St Kitts and Nevis launched the longest-running programme in 1984, offering citizenship for a real estate investment of at least $75,000. By 2009, St Kitts passport holders could enter Canada, the Schengen countries, the UK, and US without visas, and passport sales generated 30 to 50 percent of St Kitts government revenue.^[4][5]

Annually, an estimated 50,000 people, including family members of those who apply, obtain citizenship through investment programs, worldwide.

The Due Diligence Gauntlet

Due diligence is a comprehensive background check carried out before entering a financial or legal relationship — whether opening a bank account, purchasing real estate, or applying for a second citizenship or residency by investment, according to immigrantinvest.com. In investment immigration programmes, it assesses origin and legality of wealth, business activities, tax compliance, public reputation, and personal conduct. The procedure is designed to combat money laundering, tax evasion, and the financing of terrorism in line with FATF and EU Anti-Money Laundering Directive No. 2024/1640. The strictness and duration vary significantly by jurisdiction — from a few days in Vanuatu to up to 6–8 months in Malta. In Malta, due diligence applies to applicants aged 12+, while Caribbean countries mostly check applicants aged 16+.^[6]

Enhanced Due Diligence applies when a file presents elevated risk indicators: links to a Politically Exposed Person, complex multi-jurisdictional wealth structures, residence or business activity in sensitive or high-risk countries, significant adverse media coverage, unresolved litigation, or prior immigration refusals, per immigrantinvest.com. The FATF and OECD released a joint report in November 2023 titled 'Misuse of Citizenship and Residency by Investment Programmes'. The report acknowledges investment migration can potentially lead to economic growth while arguing CBI and RBI are prone to corruption and misuse. Criminals have exploited vulnerabilities to perpetrate massive frauds and launder proceeds of crime and corruption reaching into the billions of dollars, according to the report.^[6][7]

CBI pathways are particularly vulnerable because they allow illicit actors more global mobility, the ability to open bank accounts and establish shell companies in other jurisdictions, and to disguise their identity, per the FATF/OECD report. The report states elevated risks relate not only to the applicant but also to professional enablers and intermediaries. It recommends multi-layered due diligence, public disclosure of pathway details, financial audits, and establishing a specialised agency devoid of political influence to oversee a pathway's end-to-end operation.^[7]

Who Buys, and Why

The main customers of golden passport programmes are Chinese citizens, followed by citizens of Russia, the ex-USSR, and Middle Eastern countries from Afghanistan to Syria, according to migration.ucdavis.edu. But the client base is shifting. Henley & Partners onboarded clients from 94 different nationalities in 2024 and received enquiries from over 180 countries. US nationals accounted for 23% of all applications processed by Henley & Partners in 2024. Comparing 2024 US-American client numbers to 2019, there has been a staggering increase of over 1,000%. There was a 57% increase in the number of applications submitted by British citizens in 2024 versus 2023, according to henleyglobal.com.^[1][4]

Motivations go beyond mobility. A second passport can mean banking access, visa-free travel, and a Plan B in times of crisis. Malta retained 1st place in the 2025 Global Citizenship Program Index for the 10th consecutive year, while Greece reached the top of the 2025 Global Residence Program Index for the first time, per henleyglobal.com. For Americans and Brits, the calculus has shifted from luxury to insurance.^[1]

The Portuguese Experiment

Portugal introduced its residence-by-investment programme, the Golden Visa, in October 2012 during a deep economic crisis that followed the sovereign debt crisis, according to immigrantinvest.com. In its first 10 years, it brought in more than €7.3 billion in investment, about 88% of which went into real estate. A 2022 reform limited new residential property investments to inland areas and the autonomous regions, excluding Lisbon, Porto, and other high-demand coastal zones. The October 2023 'Mais Habitação' law removed real estate purchases and large capital transfers as eligible investment options for new applicants.^[13]

The programme is still active in 2025, with applications going through the Agency for Integration, Migration and Asylum (AIMA), according to imin-portugal.com. 4,987 Golden Visas were granted in 2024, a record, up 72% year-on-year. Since 2012, there have been 12,000+ main applicants and 20,000+ family members, with €7+ billion invested into Portugal's economy. Portugal offers eligibility for citizenship after just 5 years of legal residence. In late 2023, Portugal dissolved its immigration and borders service (SEF) and transferred responsibility to AIMA.^[13][14]

The EU Crackdown and What Comes Next

EU pushback against CBI schemes has been driven by three main concerns: that national citizenship is a gateway to rights such as free movement across the bloc, that these programmes often lead to corruption of public officials, and that investors do not have a genuine connection with their new country, according to migrationpolicy.org. Bulgaria and Cyprus have discontinued their CBI programmes, and Malta has fully abolished it for Russian and Belarussian citizens. The Cyprus Investment Program was closed on 1 November 2020, and a later review found that 53% of the passports were illegally issued, per Wikipedia. Montenegro's programme ended in 2022. The CJEU ruling against Malta in April 2025 confirmed that no other EU member state operated a programme leading directly to citizenship by investment. Greece, Portugal and Spain offer residency, with citizenship available only after years of qualifying physical presence and language testing.^[3][5][12]

The FATF/OECD report recommends multi-layered due diligence and emphasises that elevated risks relate not only to the applicant but also to professional enablers and intermediaries. Governments can incorporate risk mitigation measures in the design of their investment migration programmes. For now, the market persists — smaller, more expensive, more scrutinised, but still selling the same product: a second chance, priced in euros or dollars.^[8]

Reported with AI assistance using internet sources.