How citizenship obtained by investment is revoked, and how to avoid it

In 2025, citizenship by investment (CBI) programs remain a sought-after tool for global mobility and security. However, growing pressure from international organizations (OECD, EU) and the tightening of global transparency standards have led to an unprecedented increase in scrutiny of such programs. Investors are increasingly faced with alarming news about the revocation of previously issued passports. The loss of citizenship status not only means the collapse of investment plans (hundreds of thousands or millions of euros/dollars) but also entails serious legal and reputational consequences, including deportation and entry bans. Understanding the reasons for revocation and knowing preventive measures is critically important for any investor considering or having already obtained a second passport.

Main Reasons for Revocation of Citizenship by Investment

Revocation is not an arbitrary decision by the authorities but a consequence of serious violations. The main reasons include:

Fraud and Provision of False Information:

• Document falsification: fake police clearance certificates, forged documents on the origin of funds, fake diplomas, fictitious health certificates.
• Concealment of critical information: withholding facts of visa refusals (especially to EU countries, USA, Canada, UK), existence of criminal records in other jurisdictions, connections with sanctioned individuals, legal problems in the past.
• Illegal origin of investments: inability to prove the legality of the sources of capital invested in the program (connection to money laundering, corruption, tax evasion).

Criminal Offenses and Security Violations:

• Commission of serious crimes after obtaining a passport: especially relevant for crimes related to terrorism, terrorist financing, large-scale money laundering, international corruption, human trafficking. Countries may revoke citizenship as a national security measure.
• Falling under international sanctions: if the investor or the source of their funds falls under EU, US, or UN sanctions after obtaining the passport, this almost guarantees revocation.

Violation of Program Conditions:

• Withdrawal or non-fulfillment of the investment obligation: early sale of real estate before the minimum holding period expires (usually 5-7 years), failure to transfer the full investment amount or donation, bankruptcy of the project in which funds were invested.
• Violation of residency requirements (if applicable): some programs (for example, some stages of Malta) require proof of a genuine link with the country (residency requirement). Failure to meet these conditions may be grounds for revocation.
• Concealment of visa refusal/deportation AFTER obtaining the passport: the obligation to report such events often remains.

Systemic Clean-ups and Policy Changes:

• Reaction to international pressure: countries may conduct retrospective checks of previously issued passports and revoke them if violations are identified that were not initially detected due to weak Due Diligence. This is a direct response to EU or OECD demands.
• Program closure or reform: when a program is completely closed (as in Montenegro in 2022, although new applications were stopped earlier), issued passports are usually not revoked. However, a radical reform may include a review of previously approved cases for compliance with new, stricter rules.

Real Cases of Revocation: Lessons from 2023-2025

Cyprus (2020-2025, ongoing processes): the loudest scandal. Following journalistic investigations and EU pressure, Cyprus in 2020 officially revoked the citizenship of 39 investors (and their family members) from a list of 700+ suspicious cases reviewed by a special committee. Grounds: concealment of criminal past, provision of false data, falling under EU sanctions after obtaining the passport. In 2024, new investigations into other previously approved applications were initiated. The total amount of investments lost by the revoked investors amounts to tens of millions of euros.

Caribbean states (2023-2024):

• Dominica: in 2023, authorities revoked the citizenship of several dozen individuals (including family members) after discovering instances of providing fake documents (fake police clearance certificates from countries of origin) even after the passports were issued. This is a result of enhanced post-approval Due Diligence under pressure from the USA and the EU.
• Antigua and Barbuda, St. Kitts and Nevis: reported isolated cases of revocation in 2023-2024 for similar reasons (fake documents, concealment of criminal records, suspicions of money laundering). The processes are usually not publicized.
• Vanuatu: this program, criticized for weak checks, regularly publishes lists of individuals whose citizenship has been revoked (often dozens of names at a time). The grounds are standard: false information, criminal past, violations of conditions. In 2024, Australia tightened visa policies for citizens of Vanuatu, indirectly indicating persistent Due Diligence problems in the program.
• Malta (2024): although there were no mass revocations, the European Court in 2024 confirmed Malta's right to revoke citizenship obtained under the Individual Investor Programme (IIP) if it is proven that it was obtained based on substantially false information that influenced the decision. This sets an important legal precedent for the entire industry.

How to Avoid Revocation: Strategies to Protect Your Investment Passport

Obtaining citizenship is just the beginning. Its preservation is guaranteed by constant vigilance and compliance with the rules:

• Thorough vetting of intermediaries (Agents/Providers);
  • License: does the agency work directly under a license from the program's government? Check its status on the program's official website.
  • Reputation: look for reviews, work history, membership in professional organizations (IMC, iCAC). Avoid agents promising "guarantees" or "acceleration" through dubious schemes.
  • Transparency: the agent must clearly explain all stages, requirements, risks, and their fees. Secrecy is a red flag.
  • Independent legal advice: hire your own lawyer (not connected to the agent) to review the contract and process.

Strictest compliance with program conditions:

• Absolute honesty: provide 100% accurate and complete information in all forms and documents. Disclose ALL requested information, even if it seems insignificant or negative (old visa refusals, expunged criminal records). It's better to explain the history than to hide it.
• Understanding the investment: know exactly where your money is going, the investment lock-in periods (especially for real estate), refund conditions (if applicable). Do not violate these terms.
• Tracking obligations: know if you have an obligation to inform the authorities about changes of address, criminal incidents, visa refusals from other countries after obtaining the passport.

Financial transparency and clean capital:

• Documenting the origin of funds: prepare not only basic bank statements but also documents confirming the source of income from which the investment funds were formed (tax returns, business/asset purchase and sale agreements, inheritance certificates, dividend documents). The chain must be clear and legal.
• Compliance with international standards: ensure your funds and their origin comply with FATF (anti-money laundering), FATCA/CRS (automatic tax information exchange) requirements.
• Openness with tax authorities: paying taxes in the country of residence and origin in accordance with the law. Remember that tax evasion in one of the countries can be a reason for revocation.

Lawyers' Recommendations: Professional Insurance for Your Status

Do not rely solely on the Due Diligence conducted by the authorities of the host country. It is critically important to conduct your own proactive verification (self-due diligence) even before applying. For this, you can use the services of our experts. Proper and detailed expertise will help identify potential "red flags" in your biography or the origin of investment funds, which, if unnoticed at the initial stage, could become a reason for citizenship revocation in the future.

Given that the situation around citizenship by investment (CBI) programs is extremely dynamic, continuous monitoring of changes becomes mandatory. Hire lawyers to track both innovations in the legislation of your new country of citizenship and the evolution of international requirements (especially from the EU and OECD). This vigilance is particularly critical after high-profile scandals or revocations in other jurisdictions, as they often provoke a tightening of rules everywhere.

Develop a clear plan of action with a lawyer in advance in case the authorities initiate a review of your file after the passport has been issued. It is important to know your rights and the legally established procedure for appealing a revocation decision thoroughly. Remember that although such a process exists in almost all jurisdictions, the time limits for filing an appeal are usually extremely limited, and delay can be fatal.

Systematic and indefinite storage of all documentation is your main line of defense in any dispute. This includes not only the complete set of documents initially submitted for the program but also irrefutable evidence of fulfilling your investment obligations, as well as detailed confirmation of the legal origin of the invested funds. These archives must be kept permanently.

It is important to understand that obtaining citizenship is not an indulgence. Honesty and law-abiding behavior must be maintained forever. Any serious offense committed after obtaining the passport – especially related to financial fraud, national security issues, or providing knowingly false information to other states when applying for visas – can serve as a valid reason for its revocation. Business and personal life must be conducted in strict accordance with high standards of legality.

Conclusion

Citizenship by investment is a significant and legitimate opportunity, but it comes with serious obligations. In an era of global transparency and enhanced oversight (2025), the key to preserving a second passport is an impeccable reputation, absolute honesty at all stages, thorough vetting of intermediaries, strict adherence to investment conditions, and impeccable documentary confirmation of the legality of capital. Consider professional legal support not as an expense but as necessary insurance for your investments and future security. Remember: revocation is not an accident but almost always a consequence of violations that can and should be avoided.