What recent changes have been made to Citizenship by Investment programmes?

What recent changes have been made to Citizenship by Investment programmes?

The end of Quarter One 2021 saw numerous changes in the investment immigration industry. With programmes effected by the pandemic and amendments made to better control intake of new citizens, the beginning of this year has seen some programmes thrive with others shutting down.

Antigua and Barbuda

Antigua and Barbuda has confirmed which of its overseas missions have been authorised to administer the Oath of Allegiance required for adults to become citizens of the country through the Citizenship by Investment Programme.

The list includes the Antigua and Barbuda embassies in Athens, Havana, Jordan, Lebanon, Madrid and Washington DC, the Antigua and Barbuda honorary consulates in Japan, Kuwait, Moscow, South Korea, Turkey and the UAE, the Antigua and Barbuda consulates general in Miami and Toronto, the Antigua and Barbuda High Commission in the United Kingdom and the embassies of the Eastern Caribbean States in Morocco.

However, due to COVID-19 this requirement remains suspended until 31 August 2021. Virtual administration of the Oath of Allegiance may take place via Zoom, Skype or another similar audio-visual platform that has been approved by the Unit. This procedure will cost US$500 for an individual with an additional US$100 for each additional individual at the same session.


In February 2021, Bulgaria amended its Citizenship Act to bring about changes to the Bulgarian Immigrant Investor Programme. These new changes mean that applicants under the Programme now have various options for citizenship. This includes investing in a local company and in alternative investment funds located in Bulgaria. Previously applicants could invest in Bulgarian bonds, but this is no longer the case.


President Nicos Anastasiades of Cyprus announced in February 2021, that the Cyprus Investment Programme will neither be relaunched nor replaced. The Programme was abolished on 1 November 2020. Cyprus is now a residence by investment jurisdiction only.


COVID-19 has caused the oath-taking process to be much more difficult to complete. Therefore, Grenada has put its new Consulate in Dubai, United Arab Emirates, at applicants’ disposal. This allows applicants to take the Grenada Oath of Allegiance at the Consulate, tendered by a Commissioner of Oaths.


CS Global Partners is proud to have registered as Referral Sub-Agent (licence number AKM-ACCA-21) under the Granting of Citizenship for Exceptional Services Regulations, 2020. The Regulations allow applications to obtain citizenship of Malta after a minimum residency period of 12 months.


Montenegro has announced that its Citizenship by Investment Programme will end on 31 December 2021. Montenegro began accepting applications in October 2019. This decision makes the Programme one of the shortest-lived CBI offerings in history.

North Macedonia

North Macedonia has announced that it will be launching a Citizenship by Investment Programme soon. This provides a new exciting opportunity for investors looking to become citizens of the Balkan state.

The minimum contribution under the Programme is set to €200,000, which is to be made to one of the two Government-approved funds. This CBI programme is one of the most affordable options in Europe. Applicants will not be required to reside in North Macedonia, take a language test or prove a prior connection to the country. However, there will be a travel requirement for the giving of biometrics.

St Kitts and Nevis

On 1 March 2021, the Saint Christopher and Nevis Citizenship (CBI Escrow Accounts) Regulations, 2020 entered into force. These Regulations aim to better control the way funds under the real estate branch of the CBI Programme are used by developers. This requires both existing and prospective developers and to submit a drawdown/payment schedule to the St Kitts Investment Promotion Agency (SKIPA). This change is sure to increase investor confidence in the many approved real estate projects St Kitts and Nevis has to offer.


Turkey has confirmed the rules concerning the resale of real estate purchased to acquire citizenship by investment in the nation. As well as being subject to a three-year hold period, real estate will also not be available for use in subsequent application for Turkish citizenship.

United Arab Emirates

The UAE has approved changes to its Executive Regulation of the Federal Law Concerning Nationality and Passports. The amendments allow professionals, investors, and special talents to obtain citizenship of the UAE. However, investors can still only be approved for citizenship on a ‘discretionary basis’, there is still no official programme for this process.


The Citizenship Commission of Vanuatu said it would “assert even more rigorous control and vetting over the [Development Support] Programme, the agents who represent it, and the applicants who seek Vanuatu citizenship”. This statement was made following promotion of citizenship by investment through aggressive marketing tactics by a Middle Eastern firm in January 2021, as these promotion tactics do not fit the ethos of the Vanuatu Development Support Programme.

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