On September 21, a Vanuatu government spokesman confirmed to Australia’s public broadcaster that Andrew Tate’s citizenship had been revoked. Three days later, the Citizenship Commission, the body that holds the power under the Act, said no such decision had been made, that the evidence on file did not support one, and that revocation would require either a court finding of fraud in the original application or a prison sentence of ten years or more.
The episode exposed how little is understood, even inside governments, about when a citizenship acquired through investment can be withdrawn and by whom: the spokesman’s confirmation assumed it could be revoked on the facts as they stand, and the Commission, which alone holds the power, says the Act does not allow that.
Every citizenship by investment (CBI) program reserves the right to revoke. What separates them is the distance between that right and its exercise: the grounds a minister may invoke, the procedure that stands in the way, and whether the state has ever gone through with it.
Across 12 programs, this ranking scores the record first and the statute second.
How the Ranking Works
Two things decide where a program lands. One is latent exposure, meaning how wide the statutory grounds run and how much procedure stands between a minister’s decision and your passport.
Demonstrated appetite is the other: how many citizenships the state has actually taken back, on what grounds, and how recently.
The record carries more weight than the statute. A power never used in 12 years of operation says something about a government’s disposition that the text cannot, and a power used 6,000 times says more. Below, the tiers rank on demonstrated use first and fall back on the law where the record is empty.
Tier One: Revocation at Scale
🇹🇷 Turkey has done what no other program has. Its Interior Ministry cancelled or withdrew the citizenship of 6,134 people in a statement published on August 4, and a second operation announced on September 21 adds 1,070 more, with 1,757 in proceedings.
Most of the first 6,134 lost their status for fraud. Inspectors found 1,150 investors whose property purchases were collusive or irregular, which cancelled 5,391 citizenships once spouses and children were counted. Justice Minister Akın Gürlek put the money that should have entered Turkey and never did at approximately TL 2.5 billion (US$52.6 million).
The other cohort is the one that should concern a clean investor. Police and the intelligence service flagged 263 investors as objectionable on public order and national security grounds after they had been naturalized, and 743 people lost citizenship as a result. No fraud was alleged against any of them.
Turkey’s procedure is generous by the standards of this list. A cancelled citizen has 60 days to sue in the administrative courts, and Article 33(2) of Law No. 5901 suspends the liquidation of his assets while the case runs. He also keeps a year to sell his property; after that the Treasury sells it for him.
🇨🇾 Cyprus closed its program in November 2020 and has been unwinding it since. The government has revoked citizenship from 360 people, 101 investors and 259 family members, and a judicial inquiry found that 53% of the 6,779 citizenships granted between 2007 and August 2020 failed to meet legal requirements.
Its statute is the only one that makes suspicion a ground on its own. Article 113(3) of the Civil Registry Law allows deprivation where a person is wanted by Europol or Interpol for an offense punishable by five years or more, or appears on a sanctions list. Being sought is enough; a charge is not required.
That is the text rather than the practice, according to Vasilis Papangelodimou of Azzuro Nova in Nicosia, who cautions against reading the provision as automatic. Any deprivation, in his view, “remains subject to the applicable administrative procedures and must be considered on the individual circumstances of the case,” and the threshold is serious crime only, offenses carrying five years or more under Cypriot law.
His advice to an affected client is to test “both the underlying basis of the international notice and the legality and proportionality of any subsequent deprivation decision.”
Cyprus gives you 60 days from receipt of the notice, the longest window in the market, and then routes your objection to a committee whose three members all work for the government proposing to revoke you.
The money question is settled in advance by Article 113(1): nothing is refunded.
The courts have started to push back. In April, the Administrative Court annulled the revocation of Indian investor Anubhav Aggarwal because no official had considered that stripping him would leave him stateless, his Indian nationality having lapsed automatically when he naturalized.
Papangelodimou reads the judgment more narrowly than a precedent. It turned on “the particular circumstances and administrative handling of that individual case,” he says, and does not open “a general route for previously revoked investors to regain citizenship”; what it shows is that Cyprus has “functioning judicial safeguards,” with administrative decisions open to scrutiny, including on whether statelessness was properly weighed.
A larger question is pending: in January, the Administrative Court of Appeal asked the Supreme Constitutional Court whether revocation decisions can be challenged in court at all.
If the answer is no, every pending case loses the only forum that has yet ruled for an investor. Yet Papangelodimou warns against judging Cyprus by the headline count. Many of the 360 cases arise from “the authorities’ retrospective review of a programme that has already been terminated,” he notes, “and each deprivation has its own factual and legal background.”
Tier Two: Revocation by Name
These four have used the power, but in targeted actions against specific holders rather than in program-wide sweeps. Between them they account for fewer than 120 people.
🇩🇲 Dominica published a Citizenship Deprivation Order on June 6, 2024 covering 68 people. The Order cited fraud, false representation, or concealment, and added that it was “not conducive” for them to remain citizens; most had bought in through the discounted “underselling” arrangements the Citizenship by Investment Unit had declared unlawful in 2018 and again in 2022.
Its regulations reach further than its record. Regulation 6(5) of S.R.O. No. 8 of 2024 provides that anyone sentenced to 12 months or more, in any country and at any time after naturalization, “shall be deprived” of citizenship. Every neighbor caps that ground at five years; Dominica caps nothing, and regulation 6(2) rules out any refund.
🇰🇳 Saint Kitts and Nevis revoked 13 citizenships on April 12, 2025, again over underselling, and its announcement said the action reached the investors’ dependants as well. Two well-known marketing agents were blacklisted in the same breath.
The federation’s law contains a contradiction nobody has litigated. Its Citizenship Act says ministerial decisions “shall not be subject to any appeal or review in any court,” while section 94(d) of the Constitution protects a right of appeal on the fraud and treason grounds.
Until someone forces the point, assume the ouster clause is what the government will cite.
🇻🇺 Vanuatu belongs here for a quieter reason than the Tate headlines. The Citizenship Office’s own website records that the current Commission has revoked “around almost 30” citizenships found to have been granted contrary to the Act and the Constitution, in a notice it does not date. That ground, a grant that should never have been made, is the one Vanuatu has actually used.
Its high-profile cases have run the other way. The Prime Minister’s Office announced in March 2025 that the Commission had been instructed to cancel Lalit Modi’s citizenship and had begun establishing the facts, and no completion has been announced since; in September, the Commission declined to act against Tate for want of a court finding or a ten-year sentence.
The Act attaches no notice period, no appeal, and no statelessness bar to any of its grounds, but on the Commission’s account it reads those grounds narrowly.
The screening side is where the larger numbers sit. An EU implementing regulation from 2022, the first step toward ending the visa waiver, recorded that Vanuatu had issued more than 10,500 investment passports by March 2021 and had rejected one application through the end of 2020. Roughly 30 revocations against that intake is the record to date; neither Modi nor Tate is yet on it.
🇱🇨 Saint Lucia revoked the citizenship of six named participants in 2018 on the ground that their conduct had the potential to bring the country into disrepute. The Gazette did not say what they had done.
Its statute is the widest in the market. Section 38(1) of the CBI Act allows revocation for conviction of any offense, with no minimum sentence and no time limit, and separately for any act that “within the opinion of the Minister” could cause disrepute. You get a High Court appeal, but the Order takes effect before you file it.
Tier Three: Broad Powers, No Record
Five programs carry some of the thinnest procedural protection in the market and, as far as IMI could establish, have never published a revocation of a citizenship by investment. An empty record is not a clean one. It means the machinery is untested, and untested machinery has no case law telling you how it will run.
🇦🇬 Antigua and Barbuda can deprive you for spending fewer than five days in the country during your first five years, a rule stated on the Citizenship by Investment Unit’s own website alongside the news that nothing is refunded. Section 13 of its Citizenship Act says the Minister need not give reasons and that his discretionary decisions are “not subject to any appeal or review in any court.”
🇬🇩 Grenada owes you nothing at all on a national security ground. On that ground, section 9(2)(b) of its Citizenship Act switches off the duty to give notice and the right to an inquiry, so the Order itself would be the first you hear of it. IMI could find no statelessness bar anywhere in Grenada’s revocation provisions.
🇳🇷 Nauru gives you seven days from service to show cause under section 23(3) of its 2024 Act, the shortest window in this article, and dropped the requirement that Cabinet weigh statelessness that its 2017 general citizenship law contains. 🇪🇬 Egypt and 🇯🇴 Jordan publish revocation powers with no notice duty, no window, and no appeal route; a challenge goes to the ordinary administrative courts, if it goes anywhere.
Every sweep in this article followed outside pressure: a television sting in Cyprus, a fraud investigation in Turkey, and the underselling scandal in the Eastern Caribbean. Vanuatu shows the limit of that pattern, where two rounds of international headlines produced announcements but, on the Commission’s account, no revocation. The five in this tier have so far been spared even the announcements, and their statutes are ready for the day the attention arrives.
Tier Four: Narrow Grounds, No Record
🇲🇹 Malta sits alone at the bottom of the ranking, which is the good end. Outside fraud, Article 14 of its Citizenship Act needs a prison sentence of 12 months or more, imposed within seven years of naturalization, before the minister can act.
There is no disrepute test, no ministerial-opinion ground, and no equivalent of the Caribbean “prejudicial activities” limb.
IMI found no revocation of a citizenship granted under the Individual Investor Programme or its successor. When the Court of Justice of the European Union (CJEU) ended the program in April 2025, the government’s position was that citizenships already granted remain valid.
Any Maltese deprivation must also survive the proportionality test the CJEU laid down in Rottmann and Tjebbes, because losing Maltese nationality means losing EU citizenship with it; of the programs here, only Cyprus shares that constraint.
The trap in Malta is quieter. Article 14(2)(d) makes a naturalized citizen deprivable after seven continuous years of ordinary residence abroad unless he has filed written notice of his intention to retain citizenship. Almost every investor lives abroad, so file the notice.
What to Do When Revoked
Read the deprivation section before you read the brochure. It is usually one page, and it tells you what the state can do to you after it has your money. Then check whether the state has ever done it; this article is a starting point, and the Gazette of the country in question is the finishing one.
Keep the transaction clean, because underselling is the trigger with the longest record: 68 in Dominica, 13 in Saint Kitts, and 5,391 in Turkey lost their status over the price they paid or the valuation on their deed.
If an agent offers a discount on the statutory minimum, the discount is the evidence that will be used against you later, and this guide to vetting an agent explains what else to look for.
Know your window and who sets it. Cyprus gives 60 days from receipt; Nauru gives seven from service; Antigua, Dominica, Saint Kitts, and Malta give 21 days to residents and let the minister choose the figure for anyone abroad, which is nearly everyone. In Vanuatu, Egypt, and Jordan there is no published window at all.
Do the small compliance things the statutes name: five days in Antigua before your fifth anniversary, the full holding period on Turkish or Caribbean property, no name change within five years of a Dominican grant, and Malta’s retention notice before year seven. None of them costs much. Each has its own paragraph in a deprivation section somewhere.
Finally, keep a second nationality, and be clear about what it does. The statelessness bar that saved Aggarwal in Cyprus applies only to someone who would be left with no citizenship at all, and in most programs it covers the sentencing ground alone.
A second passport will not protect the citizenship you bought; it protects you from being stateless if that citizenship is taken.
