My CBI Whitelist: Good Programs, Right Way

Hello everyone. Today marks the final episode of my Citizenship by Investment (CBI) series. Over the past three updates, I have shared several cautionary tales regarding industry risks and non-compliant practices. Today, we will shift our focus to the positive side of the industry: identifying legitimate programs and outlining the correct, compliant way to apply.

The CBI Whitelist

When clients ask me what constitutes a "good" program, I refer them to this whitelist. These are statutory, government-legislated programs that operate with clear legal frameworks. Currently, my whitelist consists of 12 primary countries, alongside two specific exceptions.

● The Classic Caribbean Five:

● Saint Kitts and Nevis

● Antigua and Barbuda

● Dominica

● Grenada

● Saint Lucia

Eurasia, Middle East, and the Americas:

● Turkey (Currently the highest-volume market for CBI)

● Egypt

● Jordan

● El Salvador

Emerging Programs:

● São Tomé and Príncipe

● Nauru

● Vanuatu

Finally, there are rare, highly regulated Citizenship by Merit (CbM) programs—such as those in Austria and Morocco—which can be included on this list, provided they are navigated through strict legal compliance.

The "Right Way" to Apply: Three Core Principles

Identifying a good program is only the first step; you must also apply the right way. This comes down to three straightforward operational principles:

1. Respect the Documentation Requirements

Today, verifying official requirements is simple. You can use AI tools or check official government websites directly to find the exact document checklists. Follow these procedures strictly. If an agency claims they have a way to bypass mandatory documents—such as telling you that a Police Clearance Certificate (PCC) is not needed—they are lying to you. Respect the law and never engage with anyone offering falsified documents.

2. Pay the Exact Statutory Investment Amount

The required financial investment for every legitimate CBI program is publicly listed on the respective government’s official website. Pay exactly that amount. Do not buy into stories from agencies claiming they have "special channels" that offer discounted investments. Fulfilling the exact statutory requirement is the only safe, correct, and long-term way to secure your citizenship.

3. Conduct Strict Due Diligence on Financial Vehicles

You must be cautious with how your investment is structured. For instance, while Turkey is a premier CBI destination, many of the commercial investment funds operating under its program fail to pass Globevisa's internal compliance checks. Always prioritize operational transparency over convenience.

The Broader Perspective: Mutual Benefit

I have worked in this industry for 27 years. For most of that time, my focus has been entirely on how CBI programs benefit my clients. However, a conversation I had in London three years ago shifted my perspective.

A contact reminded me that we must also view these programs from the perspective of the host countries. Over the past two decades, CBI funds have fundamentally transformed the Caribbean nations, financing new airports, highways, hotels, and critical infrastructure. As industry practitioners, we must recognize that a sustainable CBI sector relies on mutual benefit—it cannot just be about the client's interests.

This concept of mutual benefit is a central theme of our upcoming Globevisa Global Citizen Conference, taking place this October in Hong Kong. We have invited government leaders, ministers, and CEOs from seven CBI jurisdictions to join us.

During the conference, I plan to ask these leaders two specific questions:

1. The Impact: Can you share practical examples of how CBI investment funds have been used to improve your country over the past few years?

2. The Future: What new opportunities exist in your jurisdiction for our clients to make investments and create local jobs?

My goal is to foster an environment where clients are satisfied, host countries benefit economically, and everyone plays by the rules in a strictly compliant manner. I realize that aiming for a perfectly compliant, mutually beneficial ecosystem might sound slightly idealistic, but as long as I am in this industry, this is the standard we will strive for.

Thank you for reading this series.