Buying Passports — A World Tour

‘Citizenship by investment’ (CBI) calls out for more journalistic and academic attention

By David North on January 16, 2024

Rural Migration News, an affiliate of UC Davis, has just published a long, fascinating article about the purchase of some overseas citizenships through large investments from aliens seeking a refuge in another nation, or at least a secondary passport.

This is a useful introduction to an element of international migration by the rich (and sometimes the corrupt rich) that calls out for more journalistic and academic attention; a tiny minority of international migrants can buy their way around many nations’ immigration rules by simply filling in some forms and writing some checks, with some small island nations offering quick service, and other countries, such as the U.S. and the UK, providing the wanted relief only under some complex circumstances and after lengthy delays.

Often the motivation for getting the second passport is not to obtain admission to the country issuing it, mostly small island states, but to use the document to travel to other larger nations, such as the U.S. or members of the European Union.

The article is unsigned, as is the custom for that newsletter, and thus may well have been written by the publication’s editor, Philip Martin, an old friend of mine and a well-traveled global immigration scholar, some of whose work has been published by CIS. Martin is a professor emeritus at the University of California at Davis, which is the nation’s leading university on all things agricultural.

There are two layers of the so-called golden passports; some nations, particularly small ones, offer full citizenship in exchange for either an investment in the nation’s economy or a simple payment to the government concerned. Other nations, particularly larger ones such as this nation and the United Kingdom, provide a multi-step process to citizenship. The American EB-5 program, for example, moves the rich alien who follows all the rules from alien status to a short-term conditional legal status, then permanent legal status, and finally to full citizenship. That rich alien has to pony up $800,000 for an investment (usually in real estate) that has been accepted by the Department of Homeland Security, but not guaranteed. Such an investment in the U.S. brings a family-sized set of green cards to the investor, his or her spouse, and their children under 21.

Sometimes the alien’s money goes straight into the treasury of the nation involved, as a direct payment; sometimes it is a loan to the government (sometimes interest-free), sometimes it is the purchase of real estate, and sometimes (as with the U.S. program) an investment in the private sector. The price varies, often seemingly related to the country’s size; Antigua and Barbuda, and Dominica, both ex-Brit colonies in the Caribbean, are at the bottom of the scale at $100,000 each, while U.S. is near the top at $800,000.

I have been following CBI (citizenship by investment) for years but learned a lot from the article. For instance:

  • For those with a particular taste, an alien can buy citizenship in Russia;
  • The little Caribbean island nation of Dominica (not to be confused with the larger Dominican Republic) recently received half of its total government income from this source; and
  • Another island nation, a larger one, Vanuatu, the locus of the musical “South Pacific”, received 40 percent of its government income from CBI. It formerly was a condominium, run jointly by France and the UK, then known as the New Hebrides.

The article has a chart showing a (partial) list of 23 nations that either have had, or continue to have, one of these programs. Of the 23, 11 have dropped out under pressure from larger nations; of those leaving, six of the 11 formerly were in the British Empire, three were once in the German empire, two in the Ottoman Empire, and one each had been under the French and the Spanish flags, with multiple imperial ties in four cases. Most of the old, established European nations do not use the program and they are rarely seen in Africa.

Tonga, a Pacific nation, one of the first to sell its passports, was forced to abandon the program when the U.S. discovered that a Tonga investment passport was accepted in some nations, but not in Tonga itself. At that point the U.S. refused to honor these passports.

The European Union has a dim view of these programs, and has forced Montenegro to drop out.

What’s Missing The article says that there are about 25 golden passport countries (offering full citizenship) and about 50 golden visa ones (for less permanent arrangements). I would love to see a full listing of both categories that would carry a date, as these programs both come and go. It offered no such comprehensive lists.

Also missing for some reason was any discussion of the four large, English-speaking nations with these programs (Australia, New Zealand, the UK, and the U.S.) or of the Canadian experiment, now ended. The Australian program has been around for a long time and I was once retained by its government to study it (and encountered the highly dramatic Aussie rules football as a by-product).