Video Briefing

Wealthy Expat: The New Terrible Citizenship by Investment Program

Nov 6, 2022Video Briefing5:14Watch on YouTube

Armenia and Albania have recently introduced citizenship‑by‑investment (CBI) schemes, but both programs face significant practical and political drawbacks that make them unattractive for most investors.

Armenia’s CBI program

  • Investment requirement: US $150,000, payable as a donation to the government, a real‑estate purchase, or a business investment.
  • Passport strength: Visa‑free or visa‑on‑arrival access to roughly 65 countries, placing the Armenian passport in the “low‑mobility” tier.
  • Local opposition: A citizen‑wide vote on the program resulted in an overwhelming “no.” Residents fear that the scheme could allow individuals from neighboring adversaries—particularly Azerbaijan and Turkey—to obtain Armenian citizenship and potentially act as intelligence assets.
  • Security context: Armenia is engaged in an ongoing conflict, and there are reports of an “exit ban” for men under 60, similar to measures seen in Ukraine.
  • Financial controls: The government has begun restricting bank transfers to tax‑haven jurisdictions, indicating a desire to curb capital flight.
  • Demographic pressure: A sizable influx of Russian nationals, many fleeing mobilization, is seeking Armenian citizenship as a cheaper alternative to other destinations (e.g., Dubai, Georgia). This has raised concerns among locals about the long‑term social and economic impact.

Overall, the combination of a weak passport, domestic resistance, security concerns, and limited financial freedom makes Armenia’s CBI scheme a high‑risk option.

Albania’s emerging CBI scheme

  • Program status: Albania has announced plans to launch a CBI program but has not yet implemented it fully.
  • Investment threshold: Details have not been finalized, but the cost is expected to be comparable to other European‑style programs (potentially €100,000–€200,000).
  • Passport strength: Visa‑free access to over 100 countries, notably stronger than Armenia but still below the Caribbean and some European programs.
  • EU accession concerns: Albania is a candidate for European Union membership. The EU has historically opposed CBI schemes, citing risks of money laundering, security breaches, and reputational damage (e.g., the Cyprus and Malta controversies). Continued EU pressure could force Albania to abandon or heavily restrict the program.
  • Local sentiment: Surveys of Albanian citizens show a preference for EU integration over a CBI program, fearing that selling citizenship could jeopardize accession prospects.

Given the uncertain regulatory environment and the likelihood of EU pushback, Albania’s CBI program remains speculative and may not materialize into a stable offering.

Practical considerations for investors

  • Passport utility: When evaluating CBI options, prioritize the number of visa‑free destinations and the geopolitical stability of the issuing country.
  • Regulatory risk: Programs in countries seeking EU membership or those involved in active conflicts are prone to sudden policy changes, including exit bans or transfer restrictions.
  • Local acceptance: Strong domestic opposition can lead to program suspension or additional scrutiny from international authorities.
  • Alternative options: Established CBI programs in the Caribbean (e.g., Saint Kitts and Nevis, Saint Lucia) and Turkey offer broader travel freedom and more predictable regulatory frameworks. For high‑net‑worth investors, European programs such as Malta’s Individual Investor Programme provide stronger passports, albeit at higher cost (often > €1 million).

Investors should weigh the total cost—including investment, processing fees, and ongoing compliance—against the passport’s practical value and the political stability of the host nation before committing to a citizenship‑by‑investment scheme.