The Cambodia Citizenship by Investment Programme (CBI) was ranked 14th and closes the CBI Index rankings for 2021, while the Dominica CBI Programme topped the rankings for the third time. Let us have a closer look what Cambodia can offer and what improvements its CBI programme requires.
The CBI Index compares CBI programmes available all over the world by evaluating each on nine criteria in its Point Based Scoring (PBS) model:
• Freedom of Movement
• Standard of Living
• Minimum Investment Outlay
• Mandatory Travel or Residence
• Citizenship Timeline
• Ease of Processing
• Due Diligence
• Certainty of Product
The Index’s ranking system takes into account key factors investors consider before selecting a CBI programme.
Dominica was the winner for 2021 along with St Kitts and Nevis. Grenada took the third-place position and Cambodia ranked fourteenth from the 14 programmes evaluated.
The Caribbean programmes occupy top 5 positions of the CBI Index, primarily because they are the most affordable and offer balanced passport benefits. While in 2021, Dominica shared the crown with St Kitts and Nevis (same Total Points and Percentage), it also took the first place in 2020 and 2019, when Cambodia ranked at 11 and 13, respectively.
European programmes have over time declined in popularity due to their costs, and countries such as Cyprus and Moldova have already closed their doors. Bulgaria plans to end its golden passport programme, and Montenegro will stop accepting applications at the end of 2022.
The World Citizenship Report (WCR) is the first-ever endeavour investigating the value of citizenship through the lens of a global citizen. Successively from about five years of research, the culmination of data has resulted in a ranking of almost every country in the world to demonstrate how they fare on the five key components of:
• Global Mobility
• Quality of Life
• Financial Freedom
• Economic Opportunity
• Safety and Security
The 2022 World Citizenship Report measures 187 countries against five motivators that are relevant to High Net-Worth Individuals. Dominica and Cambodia are not in the top ten, but several European and Asian countries are.
Dominica takes 52nd place globally, and Cambodia lands at 123. However, in the Safety and Security component’s regional breakdown, Dominica comes in 3rd for Latin America & Caribbean, while Cambodia is not listed in any of those detailed rankings.
Unlike the Caribbean nation of Dominica, Cambodia lacks a formal, well-structured CBI programme. Cambodia’s Law on Nationality does, however, make provision for foreign nationals to obtain citizenship of Cambodia following an investment in the country.
In Cambodia, economic citizenship is afforded to persons who either invest KHR 1.25 billion (KHR- Khmer Riels which is equivalent to about US$312,500) into the country (to be approved either by the Cambodian Development Council or by the royal Government) or donate KHR 1 billion for the restoration and rebuilding of Cambodia’s economy.
|Amount||Investment Type||Required Official Approval|
|KHR 1.25 billion||Investment||Cambodian Development Council or royal Government|
|KHR 1 billion||Donation||n/a|
Applicants who seek to obtain citizenship of Cambodia will face a less clear and more complex process, than those who choose a more transparent and established CBI programme.
Dominica, for instance, has a Citizenship by Investment Unit (CBIU) – a body dedicated to managing and processing citizenship by investment applications. The CBIU maintains up-to-date websites containing all the information an applicant will need during the CBI process, including a list of agents authorised to submit an application on their behalf.
Cambodia, on the other hand, has no such dedicated body nor official website and applications are instead reviewed by the Ministry of Interior. This results in a process that is both a lot less efficient and uncertain.
|Citizenship by Investment Unit||No||Yes|
|Approved Agents to Guide Applications||No||Yes|
Additional hurdles faced by applicants in Cambodia include the fact that they must undertake a Khmer language and history test. Applicants must also fulfil a travel requirement to Cambodia to obtain good behaviour, police, and health certificates, and sign the citizenship oath.
Additionally, although there is no requirement to actually reside in Cambodia, applicants choosing the KHR 1.25 billion investment option must register a place of residence in Cambodia upon application. Under the Dominica CBI Programme, applicants need not undergo onerous requirements, such as language tests, history tests, or travel and residence obligations.
|Travel Requirement||Applicant must obtain good behaviour, police, and health certificates, and sign the citizenship oath||No|
|Residence Established||Applicant must register a residence in Cambodia (KHR 1.25 billion investment option only)||No|
Over the years, Dominica has implemented highly streamlined processes that meet the needs of investors. This is due to the fact that the CBI Programme of Dominica is one of the most longstanding in the industry, being implemented in 1993.
By contrast, Cambodia’s CBI provisions, in their current form, were implemented in 2013. Longevity plays an important role in ensuring both reputation and stability, but also in ensuring a programme develops the initiative to keep abreast of industry trends. In Dominica this initiative is reflected in recent changes to the programme.
Detecting increasing investor interest in family reunification following Covid-19, Dominica expanded the scope of family eligibility under its programme and it is now one of the most family-friendly CBI programmes in the world. On the contrary, Cambodia makes provision for only the spouse of the main applicant and children under 18 years of age.
• Children under 18 years of age
• Children of the main applicant or of the spouse, if:
– Under the age of 18
– Aged between 18-30 and substantially supported by the main applicant or the main applicant’s spouse
– Aged 18 or over, physically or mentally challenged, and substantially supported by the main applicant or the main applicant’s spouse
• Parents or grandparents of the main applicant or the main applicant’s spouse who are substantially supported by the main applicant or the main applicant’s spouse
• Spouses of qualifying parents or grandparents who are themselves substantially supported by the main applicant or the main applicant’s spouse
• Siblings of the main applicant or the main applicant’s spouse, aged 25 or under, single, childless, and, if under 18, in receipt of consent to make an application from all persons with parental responsibility
Like Dominica, Cambodia is a member of a free movement regime. Thanks to membership of ASEAN, citizens of Cambodia in certain professions are afforded greater mobility opportunities among member states. Despite this, however, citizens of Cambodia are limited in terms of the number of countries to which they can travel without a visa. Indeed, citizens of Dominica can travel to more than double the number of countries.
|Free Movement Regime||ASEAN||CSME|
|Visa-Free or Visa-on-Arrival Destinations||Less than 55||More than 140|
Finally, CBI applicants in Cambodia are subject to lax due diligence, with no external checks and a lack of emphasis on an applicant’s source of funds. The due diligence process in Dominica is far more stringent, with initial checks by agents, internal checks by the CBIU, and external checks by specialist firms and regional and international entities, including Interpol and the JRCC. Dominica’s multi-tiered approach to due diligence is one of the key reasons the island is a highly reputable destination for second citizenship.
Taking into account the above it sems obvious why Dominica is the first and Cambodia the last in the CBI Index ranking, but Cambodian citizenship may offer other benefits that can be worth consideration including:
• Cambodian citizen’s rights – ability to live and work in Cambodia, to own landed property and apply for concessions and licenses from the Cambodian government that are only available to nationals.
• Free flow of capital – Cambodia is a part of the ASEAN Economic Community, a region with free movement of goods, services, investment, and skilled labour.
• Untapped natural resources and fertile land
• Privacy, diversification, and asset protection – an investor and their family members can choose a new Khmer name and transfer part of their wealth into it and use new Cambodian documents for banking.
|Religion:||Christianity – 90%, Other-10%||Buddhism – 97.1%, Islam – 2%, Christianity – 0.3%, Other – 0.5%|
0-14 years: 21.62%
15-64 years: 66.65%
65 years and more: 11.43%
0-14 years: 30.92%
15-64 years: 64.22%
65 years and more: 4.85%
|Area:||751 km2||181,035 km2|
|Investment sectors:||Agriculture, Tourism, Manufacturing||Tourism, Agriculture, Textiles, Transport, Energy|
To get advice on investor immigration options, feel free to contact us for a consultation.
CS Global Partners has a team of experts with heaps of industry knowledge to help you decide what country and citizenship or residence programme may suit you best.