Citizenship by Investment (CBI) programmes allow wealthy individuals to acquire a new nationality, often with minimal residency or language requirements. Put another way, these “second passports” are issued by smaller states in exchange for capital or investment.
This fast route to a passport can strengthen a country’s economy, but it also attracts criminals and corrupt actors. International supervisory bodies have repeatedly warned that CBI programmes, often referred to as “Golden Passports”, are being abused to launder money or conceal identities. A recent FATF/OECD report notes that while selling citizenship can promote economic growth, it simultaneously represents a multi-billion-pound gateway for money laundering, sanctions evasion and the concealment of illicit assets.
CBI passports are regarded by banks and regulators as a high-risk factor. They often originate from countries with weaker anti-money-laundering rules or political pressure to accept investors as smoothly as possible. The UK government has publicly stated that the CBI programmes of Dominica and Vanuatu were “clearly abused”, and that citizenship was granted to individuals who pose a risk to the United Kingdom.
In practice, that means: if someone turns up at a bank with a second passport from St Kitts or Malta, compliance teams pay particularly close attention. Such customers are often classified as higher risk, extensive evidence is requested, and enhanced checks are carried out.
How CBI programmes work and which countries are affected
Under a CBI programme, a person invests in a country’s economy—such as via a government donation, the purchase of property, bonds, or other approved forms of investment—and in return receives citizenship.
The following countries are currently under increased scrutiny in connection with second citizenships:
Antigua & Barbuda, Dominica, Grenada, Saint Kitts & Nevis, Saint Lucia, Vanuatu and Turkey.
Several states have since discontinued their programmes, including Malta, Cyprus, Bulgaria and Montenegro.
At the same time, some countries have introduced new programmes or are planning them: Argentina (from 2026, approx. USD 500,000 for a passport with Schengen access), Botswana (early 2026, about a USD 75,000 donation), El Salvador (since 2023, USD 1m in cryptocurrency for access to over 130 visa-free countries), as well as São Tomé & Príncipe (since August 2025, approx. USD 90,000 donation).
These countries are largely outside the EU’s direct influence, but could also come under increased regulatory scrutiny.
Money laundering, due diligence and country risk
Second passports from CBI states are considered a warning signal in anti-money-laundering work. Put simply, money laundering means that illegally obtained funds are moved through complex transactions so that they appear legitimate.
To counter this, banks carry out so-called Know Your Customer (KYC) checks as well as Enhanced Due Diligence (EDD). If a customer presents a CBI passport, additional questions are routinely asked:
- Multiple identity documents: All passports, ID documents and residence papers are reviewed. Inconsistencies—such as a Caribbean passport alongside tax residency in Europe—raise questions.
- Source of wealth: The customer must explain in a plausible way how the wealth was built up. Banks require a clear account of the origin of the wealth.
- Source of funds: For larger deposits, bank statements or transaction evidence is required to prove where the money came from.
- Sanctions and media screening: Cross-checking against sanctions lists, PEP lists (politically exposed persons) and international media databases.
- Tax plausibility: Tax declarations must align with nationality and place of residence. Anyone who is officially a citizen of one country but in reality lives in another and pays tax there must be able to explain this.
Ongoing monitoring also continues after the account is opened. Unusual transactions or new adverse information trigger a renewed review.
The key message is clear: with a second passport, the bank’s scrutiny increases, and the customer bears the burden of proof that their wealth and background are beyond reproach.
Conclusion
Second passports obtained through investment programmes offer mobility and flexibility, but they also bring legal and financial risks. Banks and regulators monitor holders of such passports particularly closely for signs of money laundering or identity concealment.
In plain terms: anyone who holds a “Golden Passport” should expect banks to ask how the citizenship was obtained and where the wealth comes from. Without clean documentation, this can quickly become problematic.
Since 2026, a noticeable tightening of regulation has been observed. EU bans, new control mechanisms and international co-operation are aimed at preventing abuse. Transparency is therefore crucial. Complete records and consistent information are essential, as CBI passports continue to be associated with heightened regulatory attention.
Before you apply for a second citizenship, book a free consultation to understand what impact this may have on your banking relationships and your global compliance position.
