São Tomé and Príncipe’s Citizenship Investment Unit (CIU) has revoked a marketing agent’s license after confirming the agent offered the country’s citizenship by investment (CBI) program below the prescribed price.
The revocation, which the CIU announced in a formal notice to all licensed agents, marks the first known enforcement action against an intermediary in the five-month-old program.
According to the CIU, the agent “marketed, promoted, offered, and contracted the Program at USD 89,000, below the prescribed cost,” constituting “a material breach under Clause 5.1(h) of the Marketing Agent License Agreement.”
The CIU confirmed to IMI that the breach involved a single applicant. São Tomé requires that single applicants donate $90,000 to the National Transformation Fund (NTF), but the total prescribed cost reaches $95,750 once the $5,000 submission fee and $750 in administrative fees are included.
At $89,000, the agent’s offer fell $6,750 short of the full amount, absorbing not only the entire fee structure but also undercutting the base donation itself.
Licensed marketing agents earn a flat $20,000 commission per approved application, regardless of family size. An agent pocketing the full commission while offering a $6,750 discount would still net $13,250 on the file, explaining the possible decision making process behind the undercut.
The CIU framed the enforcement as a precedent. Its notice warned that the action “underscores the CIU’s zero-tolerance approach to violations of the Agreement and applicable Regulations,” and reminded all licensed agents of their obligation to “act in a manner that safeguards the integrity, reputation, and credibility of the Program.”
Price undercutting remains a persistent issue across the investment migration industry. CBI fraud analysis has shown that discounted offers frequently serve as red flags for illegitimate operations, ranging from unauthorized agents to outright scams.
Below-market pricing can lure applicants into risking their entire investment on processes that fall outside official channels.
The program only launched in September 2025 under Decreto-Lei n.º 07/2025, and has operated for fewer than five months.
In that time, 98 investors from 27 countries have applied, authorities have approved all 27 files they have processed, and the CIU issued its first passport in January 2026.
CIU Chief Operating Officer Alfredo Trindade has previously acknowledged the tension between growth and governance, explaining that while the government wants to process as many applications as possible, it needs “to protect the country’s reputation as well” because “otherwise they will lose the opportunity to continue operating.”
The CIU concluded its notice by affirming it “will continue to actively monitor compliance and will take all necessary measures to ensure the transparency, consistency, and long-term sustainability of the Program.”
The CIU did not name the agent.
