What should you check before applying to a new CBI programme?

What are the main risks of CBI?

One of the main risks of CBI is choosing a programme that does not provide the benefits you actually need. Depending on your requirements, this could include travel freedom, the ability to live or work in certain countries, access to business and investment opportunities, or the ability to include your spouse, children or other family members.

Applicants should also consider the stability and track record of the programme, the total cost, due diligence requirements and any conditions attached to the investment. Newer programmes may have less processing history, while changes to immigration policy or international travel arrangements can affect the benefits associated with a particular citizenship over time.

Can CBI be revoked after approval?

Yes. Citizenship obtained through an investment programme can be revoked in certain circumstances. The exact grounds for revocation depend on the laws of the country offering the programme, but may include providing false or misleading information, submitting fraudulent documents or failing to complete a required investment.

Applicants should keep copies of the documents submitted with their application, together with evidence that the required investment was completed and, where applicable, maintained for the required period.

How long does CBI really take?

Processing times vary considerably between CBI programmes and can also depend on the individual application. Published processing times should therefore be treated as estimates rather than guaranteed completion dates.

An application may take longer if additional documents or information are requested, or if further due diligence is required.

Is the investment refundable if the application is refused?

Whether money can be refunded depends on the programme and the type of payment that has been made. Government contributions, property investments, application fees and due diligence fees can all be subject to different rules.

Some application and due diligence fees may be non-refundable once they have been paid. Applicants should therefore understand which payments are required at each stage and what happens to those funds if the application is refused or does not proceed.

Why are some newer CBI programmes cheaper?

Newer CBI programmes may set a lower minimum investment or contribution to attract applicants and compete with more established programmes. A lower entry point can help a new programme attract potential applicants while it develops an international reputation and processing track record.

However, a lower investment requirement does not necessarily mean better value. Established programmes may have a longer history of processing applications, more familiar procedures and citizenship benefits that are particularly valuable to certain applicants.

The total cost should also be considered, including government, due diligence and family fees. Applicants should therefore compare both the cost and what they receive in return.

What happens if the rules change while my application is being processed?

This will depend on the programme and the nature of the rule change. In some cases, applications that have already been submitted may continue under the rules that applied at the time of filing, but this should not be assumed.

Any transitional provisions introduced with the new rules, together with guidance from the relevant authority, should be reviewed to determine how applications already in progress will be treated.

What changes when a CBI programme is new or recently amended?

When a CBI programme is new, there is a shorter track record for applicants to assess. It also may not be clear how applications will be handled, how long decisions will take or how the authorities will interpret certain requirements.

Recently amended programmes bring a different challenge. Changes can affect the minimum investment, eligibility criteria, family members who can be included, due diligence requirements, processing procedures and other conditions.

Applicants should therefore confirm which rules are currently in force, when any changes took effect and whether they apply only to new applications or also to those already being processed. This can be particularly important when an application is being planned around a specific budget, timeframe or family situation.

Which law and which authority govern the programme?

A CBI programme should have a clear legal basis and a government authority responsible for reviewing and deciding applications. Having these in place is important as they establish how the programme operates and who has the legal authority to approve citizenship applications.

For example, São Tomé and Príncipe's programme is established under Nationality Law No. 7/2022 and Decree-Law No. 07/2025. The decree also establishes the CBI and Donation Unit (UCID), which is responsible for administering the programme, and sets out the procedures for applications, due diligence and decisions.

Applicants interested in the programme can find more information on our São Tomé and Príncipe Citizenship by Investment page.

Why do programme rules change, and how often?

Governments may change the rules for their CBI programmes for several reasons, including strengthening or improving due diligence, introducing new eligibility requirements, adjusting investment thresholds or responding to wider immigration and international policy developments. There is no fixed timetable for these changes, and significant reforms can sometimes be introduced at relatively short notice.

St Kitts and Nevis, for example, operates its programme under the Citizenship Act, Cap. 1.05 and the Citizenship by Substantial Investment Regulations, as amended. In January 2026, the government also announced new residence and biometric requirements.

For applicants, however, an announcement of a proposed change does not always mean that a new requirement has already taken effect. Before submitting an application, it is important to check the final rules, their effective date and whether any transitional arrangements apply.

Does a rule change affect citizenship that has already been granted?

Changes to the requirements for new applicants do not automatically affect people who have already obtained citizenship, nor do they usually mean that existing citizens must meet the new application requirements.

However, some changes can affect existing citizens. The benefits associated with citizenship can change over time. For example, visa-free access may be affected if another country changes its immigration policy, even though the individual's citizenship remains unchanged.

It is therefore important to understand exactly what has changed and who the new rules apply to. A change to the application process is different from a new obligation for existing citizens or a change to benefits such as visa-free travel.

Who can be included, and can family members be added later?

The family members who can be included in a citizenship application will depend on the rules of the particular programme and how it defines an eligible dependant. It is therefore important to confirm each family member's eligibility before submitting the application.

Age is not always the only consideration. Depending on the programme, factors such as financial dependency, education and marital status may also determine whether a family member can be included.

Does citizenship extend to my spouse and children?

Eligible spouses and children can often be included in the same application as the main applicant. However, each family member must meet the programme's eligibility requirements for dependants and complete the relevant due diligence and other checks.

Applicants may also need to provide documents confirming their relationship to the main applicant and, where required, evidence of financial dependency.

The cost of including family members also varies between programmes. Some programmes include a certain number of dependants within the main investment or contribution amount, with additional fees applying where more family members are included. Applicants should therefore consider both eligibility and the total cost for their family when comparing programmes.

Can an adult child who is still studying, or a parent, be included?

Whether adult children or parents can be included as dependants will depend on the rules of the particular programme. Some CBI programmes allow adult children to be included where they meet certain conditions, such as being financially dependant on the main applicant or continuing their education. Age limits may also apply.

Parents may also qualify as dependants, although they may need to meet specific requirements relating to age, financial dependency or other circumstances. Some programmes also allow siblings to be included, subject to their own eligibility requirements.

Families should therefore confirm the requirements for each proposed dependant before applying, particularly where the application includes adult children, parents or other relatives.

Can a family member be added after citizenship is granted?

Some CBI programmes allow eligible family members to be added after the main applicant has obtained citizenship. The rules again depend on the programme chosen, however, including which relatives can be added and when their eligibility is assessed.

Post-citizenship addition arrangements for dependants are available under several Caribbean programmes, including Antigua and Barbuda, Dominica and St Kitts and Nevis. The relatives who can be added and the conditions that apply differ between programmes, so the current rules should be checked before relying on a later addition.

Additional government fees, due diligence and supporting documents may also be required when adding a family member at a later stage.

What disqualifies an applicant or a dependant?

CBI programmes require applicants and their dependants to pass due diligence and background checks. An application may be refused where an applicant provides false or misleading information, fails to disclose relevant criminal history or cannot satisfactorily explain the source of their funds.

Previous visa, immigration or citizenship refusals may also need to be disclosed. These do not necessarily result in an application being refused, but the circumstances will need to be considered under the rules of the particular programme.

Applicants should raise any potential concerns before submitting their application so they can be properly assessed and addressed where possible.

What does CBI really cost beyond the headline figure?

The minimum investment or contribution is only one part of the overall cost of obtaining CBI. Applicants may also need to pay government processing fees, due diligence fees, professional fees and other costs associated with preparing and submitting the application.

The total cost will also depend on the size of the family and the investment option selected. Where the programme requires an investment rather than a contribution, applicants should also consider how long their capital must remain invested and any conditions that apply before it can be sold or recovered.

What does the advertised minimum investment leave out?

The minimum investment usually refers to the qualifying investment or contribution rather than the full cost of the application.

Additional costs can include government processing and application fees, due diligence, interviews, document certification, translations, notarisation and professional fees. The amount may also increase when a spouse, children, parents or other eligible dependants are included.

Applicants should therefore consider the total cost for their particular family and chosen investment option rather than comparing programmes based only on the headline figure.

Is the investment refundable, and can it be financed?

Whether an investment is refundable depends on the option chosen. A non-refundable contribution or donation is a payment made to the government or an approved fund and should not be considered capital that can later be recovered.

Property and other investment options work differently. Applicants may be required to hold the investment for a minimum period before it can be sold. Once this period has ended, the investment may be sold subject to the programme's requirements. However, there is no guarantee that the applicant will recover the original amount invested or make a return on the investment.

Whether financing is permitted will also depend on the rules of the particular programme. For example, São Tomé and Príncipe allows an applicant's qualifying contribution to be funded by a benefactor. The benefactor must be declared as part of the application and will be subject to the programme's due diligence and source-of-funds requirements.

Applicants must be able to satisfy the applicable source-of-funds requirements, including where borrowed funds are allowed.

Before making an investment, applicants should have a clear understanding of the payment terms, minimum holding period and any conditions that apply to a future sale or disposal. Selling or changing a qualifying investment before the required holding period has ended, or otherwise failing to maintain it in accordance with the programme's rules, could put the applicant's citizenship at risk.

Where are the current official figures published?

Current investment requirements and government fees should be checked against the relevant programme's official fee schedule and current requirements. These figures can change, particularly where a programme is new or has recently been amended.

Applicants should therefore use current figures rather than relying on an earlier announcement or an outdated fee schedule.

How long does CBI take, and why do timelines slip?

Processing times for CBI are not the same between each programme. While governments may publish an estimated timeframe, the actual process can take longer depending on the complexity of the application, whether all required documents have been provided and the due diligence checks required.

A properly prepared application that includes all the required information and supporting documents can help avoid unnecessary delays. Incomplete applications are more likely to result in follow-up questions or requests for additional information, which can extend the overall processing time.

Timelines can be less predictable for newer programmes because there may be fewer completed applications available to show how closely actual processing times match the government's published estimates.

What are the steps from application to citizenship?

A CBI application will usually involve the following steps:

1. Initial assessment and programme selection: The applicant's circumstances, objectives and family requirements are reviewed to confirm eligibility and identify the most suitable programme and investment option. Any potential issues that could affect the application, such as previous visa refusals, criminal history or complex sources of funds, should also be identified at this stage.
2. Document preparation: The applicant and any dependants gather the documents required for the application. These may include passports and identity documents, birth and marriage certificates, police clearance certificates, proof of address, medical documents and evidence of the applicant's source of funds and source of wealth. Depending on where the documents were issued, notarisation, legalisation, apostille or certified translations may also be required.
3. Application submission: Once the application is complete, it is submitted to the relevant citizenship authority through the required channel, together with the applicable government, processing and due diligence fees. Some programmes require applications to be submitted through an authorised agent rather than directly by the applicant.
4. Due diligence and background checks: The citizenship authority carries out due diligence on the main applicant and relevant family members. This can include checks on criminal history, business activities, source of funds and source of wealth, as well as international sanctions and other background screening. An interview may also be required. If further information or clarification is needed, the authority may request additional documents during this stage.
5. Decision and qualifying investment: If the application is successful, the applicant will receive the relevant approval or approval in principle. Depending on the programme, the qualifying contribution or investment may then need to be completed within a specified period. Some programmes require all or part of the investment at an earlier stage, so applicants should confirm the payment structure before proceeding.
6. Citizenship and final formalities: Once all programme requirements have been satisfied, the applicant and approved family members complete any remaining formalities, which may include taking an oath of allegiance. Citizenship certificates or other evidence of citizenship are then issued. Where applicable, the new citizens can proceed with their passport applications in accordance with the country's requirements.

The order and requirements can differ considerably between programmes, so applicants should check their chosen programme’s requirements before proceeding.

Why do official and observed processing times differ?

Published processing times are estimates and should not be viewed as guaranteed completion dates. Even a well-prepared application may take longer than expected if further checks are required or additional information needs to be provided.

During the review process, the government authority responsible for the programme will carry out its own assessment and work with independent due diligence firms, law enforcement agencies, financial intelligence units or other government bodies to verify the information provided by the applicant. Depending on the programme and the applicant's circumstances, these checks can cover criminal history, business activities, source of wealth and funds, sanctions, adverse media and previous immigration or citizenship applications.

If any part of the application requires further clarification, the applicant may be asked to provide additional documents or information. The time needed to obtain and review this information can extend the overall processing period.

It is also important to understand what the published timeframe actually covers. Some estimates begin only once a complete application has been formally accepted, rather than when the applicant begins preparing their documents. The subsequent issuance of citizenship certificates, passports or other documents may also fall outside the quoted processing period.

Each application is different, and factors such as family size, nationality, residence history and the complexity of the applicant's source of wealth and funds can also affect how long the process takes.

What most often delays due diligence?

Document issues are a common cause of delays. In HLG's experience, police clearance certificates, proof of address and HIV test results can cause particular problems because they are usually only valid for a limited period. Obtaining them too early can therefore result in documents expiring before the application is submitted or reviewed.

Photographs can also cause delays because citizenship units apply specific standards that can differ between programmes. HLG recommends using digital photographs where possible, as these can be easier to verify against the requirements of the relevant citizenship unit or passport office.

Source-of-funds evidence is another important part of due diligence. Applicants may need to show both where their funds originated and how the money moved between accounts before reaching the account used for the investment or contribution. Gaps in this evidence can lead to requests for further information and additional processing time.

Careful preparation can reduce the risk of avoidable delays. Applicants should check the validity and document requirements for their chosen programme and make sure that the information provided for each family member is complete and consistent before the application is submitted.

Is a newer programme or an established one the better choice?

The age of a CBI programme should not be the deciding factor when choosing where to apply. Established programmes have a longer history of processing applications and applying their rules, which can provide applicants with greater visibility over how the programme operates in practice.

However, newer programmes can also be attractive, particularly where they offer a competitive investment threshold, broader family eligibility or other benefits that better match the applicant's objectives. However, there may be less information available about actual processing times and how certain requirements are applied in practice.

The right choice will depend on the applicant's priorities, family circumstances, budget and reasons for seeking a second citizenship.

Which programme suits which applicant profile?

There is no single citizenship by investment programme that will be the best option for every applicant.

Someone who has a particular deadline may place greater importance on processing times and the programme's track record. A family applying together may prioritise a programme that allows a spouse, adult children or parents to be included, while another applicant may be more concerned with mobility, future residence options or the overall cost.

A newer programme can still be a suitable option where its requirements and benefits meet the applicant's objectives. However, a lower investment threshold should not be the deciding factor if there are questions about eligibility or whether the programme provides the benefits the applicant actually needs.

What should I compare besides price?

The minimum investment is only one factor when comparing CBI programmes. Applicants should also consider:

1. which family members can be included and the additional costs for dependants;
2. visa-free or visa-on-arrival travel available with the citizenship;
3. whether citizenship provides residence or other rights in countries that are important to the applicant;
4. processing times and due diligence requirements;
5. whether the qualifying investment is refundable or must be held for a minimum period;
6. any residence, physical presence or ongoing requirements; and
7. the stability of the programme and any recent or proposed changes to its rules.

For applicants considering Caribbean citizenship programmes, recent and proposed regional policy changes should also be considered alongside the requirements and benefits of each individual programme.

Where relocation is the main objective, a residence by investment programme in the intended destination may therefore be more appropriate than CBI in another country.

What happens in specific applicant situations?

Individual circumstances can affect how CBI rules apply, particularly where programme requirements change, an issue arises during due diligence or an applicant already holds another citizenship. The following are some of the situations applicants may need to consider.

If the rules change after I file, do I follow the old rules or the new ones?

This will depend on the terms of the rule change and any transitional arrangements introduced by the government. However, HLG's experience has been that applications already submitted have typically continued under the rules that were in force at the time of filing.

For example, when Caribbean CBI jurisdictions increased their minimum investment requirements in July 2024, applications submitted before the change continued under the previous investment requirements, including applications that remained in processing after the new requirements took effect.

This treatment should not be assumed for every future amendment. Applicants should still check the effective date of the new rules, any transitional provisions and how they apply to applications already in progress.

Can my citizenship be revoked later if a property valuation or document is challenged?

Citizenship obtained through an investment programme can, in certain circumstances, be revoked after it has been granted. This can happen when citizenship was obtained using fraudulent or misleading documents, important information was withheld or the qualifying investment did not meet the programme's requirements.

Issues can also arise if an applicant pays less than the required investment amount or if the value of an investment is overstated to make it appear that the minimum requirement has been met. In some cases, applicants may be given an opportunity to address an investment shortfall, but this should not be assumed.

Applicants should make sure that the investment and supporting documents fully comply with the programme requirements.

Does a US citizen risk US citizenship by acquiring a second one?

A US citizen does not automatically lose US citizenship by acquiring another nationality. The United States permits dual nationality, although US citizens must use a US passport when entering and leaving the United States.

Acquiring a second citizenship should also be distinguished from formally relinquishing or renouncing US citizenship, which involves a separate legal process.

US applicants should also consider the tax and reporting implications of acquiring assets or making investments overseas and obtain appropriate US tax advice where required.

If one family member fails due diligence, is everyone refused?

Not necessarily. The effect on the application will depend on the programme, the family member involved and the reason they did not satisfy the due diligence requirements.

Some programmes may allow a dependant to be removed from the application so that the main applicant and other eligible family members can continue. However, this may not be possible where the due diligence issue also affects the main applicant or raises wider concerns about the application.

Government application and due diligence fees already paid may be non-refundable. Removing a dependant can also affect the required investment. For example, if an investment option is available only to families of a particular size, removing one family member may mean that the family no longer qualifies for that option and must use a different investment route.

The financial consequences should therefore be checked before a dependant is removed from an application.

Can I hold citizenship from two investment programmes at the same time?

It may be possible to hold citizenship obtained through more than one CBI programme, provided the countries allow multiple citizenship and the applicant satisfies the requirements of the new programme.

However, approval under one programme does not guarantee approval under another. Each application is subject to its own eligibility requirements and due diligence process.

Applicants will need to disclose their existing nationalities and may also need to provide details of previous citizenship, immigration or visa applications and refusals.

For Caribbean CBI programmes in particular, previous refusals can have important consequences. A refusal under one Caribbean citizenship programme can affect eligibility for another. A previous visa refusal from a country to which the relevant Caribbean jurisdiction has visa-free access may also affect eligibility, although the position may be different where the applicant subsequently obtained a visa for that country.

An applicant's full immigration and citizenship history should therefore be reviewed before a further application is submitted.

What are the main risks, and when should you not apply?

CBI can provide significant benefits, but applicants should understand the requirements and potential risks before proceeding. Choosing a programme based only on its price, advertised processing time or travel benefits can lead to problems later if important eligibility or investment requirements have not been considered.

On what grounds can CBI be revoked?

Citizenship obtained through an investment programme may be at risk where the application involved fraudulent or misleading information, important information was withheld or the qualifying investment did not meet the programme's requirements.

Issues may also arise where applicants have participated in discounted investment arrangements that did not satisfy the required minimum investment. In some cases, applicants have been given an opportunity to rectify an investment shortfall, but this should not be assumed.

Applicants should therefore make sure that both the investment and the information provided in support of the application fully comply with the programme's requirements.

Can visa-free travel be withdrawn after I become a citizen?

Yes. Visa-free travel is determined by the policies of the country being visited and can change after citizenship has been granted.

If a country removes visa-free access for citizens of a particular country, this does not affect the underlying citizenship or the other rights attached to it. The change will normally apply to citizens of that country more widely rather than only to people who obtained citizenship through investment.

Loss of visa-free access also does not necessarily prevent future travel to that destination. Depending on the country's immigration rules, citizens may still be able to apply for long-term or multiple-entry visas.

Applicants seeking a second citizenship primarily for improved mobility should therefore consider its wider benefits rather than relying on visa-free access to one particular country or region.

Which mistakes most often lead to refusal or delay?

Many delays and potential problems can be reduced and avoided through careful preparation. Common mistakes include:

1. relying on a programme announcement without confirming the rules that are actually in force;
2. treating an advertised processing time as a guaranteed completion date;
3. assuming that a spouse, child, parent or other family member qualifies without checking the programme's dependant requirements;
4. providing incomplete or unclear evidence of source of funds or source of wealth;
5. submitting documents that have expired or do not meet the programme's requirements;
6. failing to disclose previous visa, immigration or citizenship refusals; and
7. making an investment or payment without confirming that it meets the programme's requirements.

A complete and properly prepared application can reduce the risk of unnecessary delays and requests for further information.

When is a new programme the wrong choice?

A new CBI programme may not be the right choice if it does not provide the benefits the applicant is looking for or if there are questions about eligibility, investment requirements or processing.

For example, a programme may offer an attractive investment threshold but not allow all the applicant's family members to be included. It may provide useful visa-free travel but not the residence rights the applicant actually needs. An applicant may also find that the source of funds or investment structure does not meet the programme's requirements.

Timing can also be important. Where an applicant needs citizenship by a particular date, a newer programme with limited processing history may provide less certainty than a more established alternative.

How does Harvey Law Group approach a new programme application?

Harvey Law Group (HLG) starts by establishing what the client wants to achieve through a second citizenship. This includes their reasons for applying, family circumstances, preferred timeframe, budget and any particular travel or residence objectives.

HLG then assesses the available options against the client's circumstances. This includes reviewing eligibility, the proposed source of funds, family members to be included and the documents required to support the application. The aim is not simply to identify a programme the client can apply for, but to find the programme that is most suitable for their needs and whether the application can be properly supported.

This is particularly important with a newer programme, where there may be less practical experience of how certain requirements are applied.

What does HLG check before accepting an instruction?

Before proceeding with an application, HLG reviews the client's circumstances and supporting information to identify any issues that could affect eligibility or due diligence.

This can include previous criminal, immigration or citizenship matters, the applicant's source of funds and source of wealth, and whether the proposed investment complies with the programme's requirements. Where family members are being included, their eligibility and any additional due diligence requirements are also considered.

The firm may decline to act where an applicant has failed to disclose relevant criminal history or cannot provide a credible explanation for the source of their funds. Identifying these issues before an application is submitted helps avoid proceeding with a case that does not meet the programme's requirements.

HLG also reviews the proposed investment itself. If an applicant is offered a discounted or alternative arrangement that appears to reduce the investment below the amount required by the programme, this should be carefully reviewed before any funds are committed.