The IMI Citizenship by Investment Transparency Index 2024
In 2022, IMI launched the world’s first Citizenship by Investment (CBI) Transparency Index to encourage program integrity and address one of the most common criticisms of the industry; its tendency to be opaque.
Nearly two years later, we are updating the index to reflect recent changes to transparency measures.
The results are disappointing: Since our last survey in 2022, CBI programs have become less – not more – transparent. On average, the transparency ranking of the CBI sector has fallen from 37% to 33%.
To be sure, some programs have shown considerable improvement: Three Caribbean CIPs are quickly closing the gap to Malta’s MEIN, which has previously been the global benchmark for CBI transparency.
At the same time, the programs that were only somewhat transparent in 2022 have now become almost entirely opaque.
This is driving a divergence: The top four programs do a reasonable job of transparency, while the remaining seven appear to no longer even attempt to be anything but opaque.
Why a CBI Transparency Index is needed
On many past occasions, authors in IMI have lamented the lack of regularized reporting and data sharing on the part of citizenship by investment (CBI) programs. Apart from making the work of those reporting on the market (such as IMI) more of a challenge, a lack of transparency poses reputational risks for the industry.
We have often pointed out that, among the three most common categories of arguments brought against the business (that CBI is a “security threat”, is ethically “objectionable”, and is too opaque) the opacity argument is the one that holds the most water:
It is indeed the case that CBI programs could be a great deal more forthcoming as regards the timely disclosure of pertinent data. The industry is not sufficiently open to scrutiny. That criticism is not unfounded.
At the same time, the opacity argument is also the only category of criticism the industry has the power to easily deal with itself. There’s little the CBI industry can do to convince its detractors that CBI is morally justified or not a significant security threat; stakeholders have attempted to do just that for many years to no avail.
But it is within the industry’s power to demonstrate high levels of transparency and, thereby, to neutralize and invalidate at least one of the three main criticisms against it.
To that end, it is important to provide frank, objective, and measurable benchmarks and standards of transparency by which the 11 operating CBI programs can evaluate themselves (and each other).
The hope is that a quantitative index that compares CBI program transparency performance will engender public and private debate, self-reflection on the part of program administrators, and – ultimately – lead to lasting improvements in CBI program transparency.
Results by Dimension
Data Reporting Frequency
Unlike among golden visas, no CBI program provides monthly reports. Grenada’s CIP reports on a quarterly basis, giving it the highest score on this dimension.
Antigua & Barbuda’s CIP this year resumed its practice of bi-annual reporting, resulting in a 60% score. Last year, Antigua & Barbuda’s CIU had neglected its legal obligation to publish bi-annual statistical reports, which resulted in a score of just 20% in 2022.
Malta’s MEIN and Saint Lucia’s CIP report annually and receive a 40% score.
The CIPs of Dominica, Jordan, Saint Kitts & Nevis, Turkey, and Vanuatu have reported statistics on occasion in the past, but only ad-hoc and therefore receive a score of 20%.
Cambodia and Egypt have never reported statistics, and get a score of 0%.
How is Data Reporting Frequency scored?
Each program receives one of five possible scores for its reporting frequency:
- Monthly (5 points)
- Quarterly (4)
- Bi-annually (3)
- Annually (2)
- Ad-hoc (1)
- None (0)
How is Processing Data Richness scored?
Processing Data Richness is determined by the following ten criteria providing a maximum possible 16 points (weighting in parenthesis):
- Application volume – main applicants (2)
- Application volume – dependents (1)
- Application approval volume – main applicants (2)
- Application approval volume – dependents (1)
- Application rejection volume (2)
- Application volume by country of origin (2)
- Application approval volume by country of origin (2)
- Application rejection volume by country of origin (2)
- Average number of dependents per application (1)
- Average number of dependents per application by country of origin (1)
Processing Data Richness
In terms of the richness of processing data content, Saint Lucia’s CIP, once again, outperforms that of Grenada and even Malta’s MEIN (often considered an example of best practice).
While all three provide comprehensive statistics, Saint Lucia stands out for its willingness to share details on the nationalities of its investors, which neither Grenada nor Malta divulges (though the latter does disclose “region of origin”).
Antigua & Barbuda reports application volumes but not approvals or rejections, making it impossible to calculate, for example, rejection rates.
Jordan occasionally reports approval volumes, but on an irregular basis and invariably only in rough numbers. This year, for example, the country’s Ministry of Interior disclosed that the program had granted citizenship to “approximately 400 investors” since 2018, a figure that doesn’t enable long-term trend comparisons.
The CIPs of Dominica, Turkey, and Vanuatu – which in previous years at least provided irregular and ad-hoc data sets – have given up on reporting altogether.
It has now been at least two years since any meaningful statistical report emerged from these programs. As a consequence, they receive a processing data richness score of 0% this year.
Financial Data Disclosure
Malta is the most forthcoming in terms of disclosing the movement of capital into (and out of) its program, obtaining a score of 11 out 13, falling short of full marks only because of its reluctance to report on investor nationality.
Saint Lucia’s and Antigua & Barbuda’s CIPs share a close second position on this metric, thanks to their willingness to disclose details of the disbursements of program proceed. While Antigua & Barbuda, but not Saint Lucia, reports on the investment/donation patterns according to applicant nationality, Saint Lucia, but not Antigua & Barbuda, discloses total government fee receipts.
In third place, Grenada’s CIP scores lower than it would have on this dimension if only it were not so reticent about applicant nationality. The program also does not divulge in detail on how funds raised through the program are disbursed.
The remaining CIPs have not disclosed any financial data whatsoever this year, and therefore see their scores reduced to 0% on this dimension.
How is Processing Data Richness scored?
Financial Data Disclosure scores are based on eight criteria with a maximum score of 13 points:
- Total investment amounts published (2)
- Total donation amounts published (2)
- Total government fee amounts published (2)
- Application volume by investment category (2)
- Application volume by investment category and country of origin (1)
- Average investment amounts (1)
- Average investment amount by applicant country of origin (1)
- Details of government disbursement/retention of program proceeds published (2)
How is Processing Data Richness scored?
Programs receive a Historical Data Availability Score based on how much of its history it publishes data for:
- Data for all periods since inception (3 points)
- Data for most periods since inception (2)
- Data available for some periods since inception (1)
- No historical data available for any periods (0)
Historical Data Availability
Thanks to its decision to resume the publication of bi-annual statistical reports, Antigua & Barbuda’s CIP this year joins Malta’s MEIN and the Saint Lucia CIP in becoming the third program to offer historical data sets covering all periods since inception to the public.
Grenada’s CIP, an otherwise quite transparent program, inexplicably continues its persistence in not publishing numbers for the first half of 2017, and suffers a needless deduction in points as a consequence.
Dominica, Saint Kitts, Turkey, and Vanuatu remain at 33% on this dimension because their ad-hoc and irregular reporting means we only have data for some years.
Once again, the CIPs of Cambodia and Egypt have never published any data.
Integrity Safeguards
The average score for Integrity Safeguards has remained consistent at 36%, though the rankings have changed, chiefly thanks to the introduction and discontinuation of blacklists.
Malta has seen its perfect score slip by one point this year due to its discontinuation of a public blacklist of misbehaving agents.
Saint Kitts & Nevis’ CIP has similarly seen its score reduced by one-fifth for the same reason; discontinuing its blacklisting practice.
Saint Lucia’s and Grenada’s CIPs, meanwhile, have now begun to publish blacklists.
Only Malta and Saint Lucia disclose figures paid by the government to private-sector actors, like locally accredited agents and concessionaires.
All programs except those of Turkey, Jordan, and Egypt maintain public lists of accredited agents.
Malta’s MEIN is the only program for which program reporting is delegated to an independent authority.
How is Processing Data Richness scored?
Certain procedural measures are crucial to preventing the blights of favoritism, nepotism, equal-opportunity public procurement, and downright graft. In our Index, we have chosen to focus on the following five criteria, granting each program one point for each criterion they fulfill:
- Government payments to private sector entities disclosed
- Names of agents published
- Agent appointment terms are clearly defined and published
- Reports compiled by an independent authority
- Agent blacklists are published
Overall Scores
On the whole, citizenship by investment programs became more opaque this year, losing 4 percentage points of transparency.
Pulling down the average is the tendency among several programs that released some data to now forgo program reporting altogether. This is the case for Turkey, Dominica, Saint Kitts & Nevis, and Vanuatu.
Saint Lucia’s CIP this year shares the top spot with Malta’s MEIN, while the CIPs of both Grenada and Antigua & Barbuda have made headway in closing the gap to the two leaders.
Beneath Antigua & Barbuda, the gap to program number four on the list has widened considerably. For all practical purposes, only four CIPs – Malta MEIN, the Saint Lucia CIP, the Grenada CIP, and the Antigua & Barbuda CIP can appropriately be termed “transparent”.
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