Two CBI Red Flags I Never Ignore
- Henry Fan
- 58 minutes ago
- 3 min read
Hello everyone. Today, I would like to address a few highly problematic practices within the Citizenship by Investment (CBI) sector. This is the third update in my series discussing the operational realities of CBI programs.

Recently, while reviewing industry marketing on social media, I noticed a trend of advertisements making claims that require immediate correction. If you are evaluating a second citizenship, here are two major red flags you should never ignore.
Red Flag 1: "No Police Clearance Certificate (PCC) Needed"
I have seen numerous advertisements promising a fast-track citizenship process with the tagline: "No PCC needed."
PCC stands for Police Clearance Certificate. Let me state this as a matter of operational fact: every legitimate, government-legislated CBI program in the world requires a valid Police Clearance Certificate. There are zero exceptions to this rule.
When an agency claims they can bypass this requirement for you, they are not utilizing a legal loophole. In practice, they are fabricating the clearance documents.
Some applicants might assume that if the agency handles the paperwork, the applicant is insulated from the liability. This is legally incorrect. As the applicant, you are the direct beneficiary of the submission. Presenting falsified background checks to a sovereign government is a criminal offense. My advice here is straightforward: stay far away from these offers. You must have a legitimate Police Clearance Certificate to apply for any credible CBI program.
Red Flag 2: The "Discounted" Investment
The second common practice is the promotion of "discounted investments." This occurs when an agency claims they can secure your citizenship for a financial contribution lower than the official statutory amount required by the host government.
There is a saying that once a scar heals, we forget the pain. However, anyone familiar with the recent history of this industry knows exactly how this ends. Just a year or two ago, a significant number of individuals had their newly acquired citizenships formally revoked specifically because they participated in discounted investment schemes.
When an applicant pursues a discounted route, the agency makes a quick fee, and the applicant believes they saved money in the short term. However, in the long term, the outcome is often disastrous. Having a citizenship revoked can lead to the very real risk of becoming stateless.
The correct approach is simple: verify the required investment amount on the host government’s official website and fulfill that exact financial requirement.
Why Compliance Matters: The Broader Picture
Maintaining strict compliance is about more than just following the rules; it is about protecting the viability of these programs for people who genuinely need them.
About a month ago, one of our consultants in Indonesia, Hani, assisted a client from Brunei who was residing in Hong Kong. While working on this case, I learned about the complex realities of patrilineal citizenship laws and how easily individuals can fall through the administrative cracks of their home countries.
Currently, there are an estimated five million stateless individuals globally, spanning from Southeast Asia to the Middle East. For many people, CBI programs are not simply a matter of convenience or tax planning; they are a critical, practical solution to severe jurisdictional challenges. In some situations, accessing a legal citizenship pathway is life-changing.
I may sound a bit idealistic, but I firmly believe that practitioners in this industry have a professional responsibility to protect the integrity of these programs. Engaging in non-compliant practices for short-term financial gain actively threatens the existence of legal frameworks that many people rely on.
We must operate compliantly, not just for our own business security, but to preserve the integrity of the industry as a whole.
Thank you for reading, and I hope this provides a clear perspective on how to evaluate CBI opportunities safely.


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