Investors who acquire citizenship through a Caribbean or Pacific program want to know whether a bank will open an account on the new passport.
A refusal or a closure costs time and money. It can also leave you explaining the new passport at every bank you approach afterwards, and at the one you already use.
IMI reviewed the published account documents of UBS, Standard Chartered, and Citi, and searched for similar policies at other large banks. None of the documents IMI found states a rule refusing people who acquired citizenship through investment.
The documents focus on where you pay tax and whether you got your residence rights through an investment program. Those checks trace back to the Organization for Economic Cooperation and Development (OECD).
UBS, Standard Chartered, and Citi each tie their checks to the OECD’s list of potentially high-risk citizenship by investment (CBI) and residence by investment (RBI) programs. OECD guidance lets a bank raise further questions when you claim tax residence in a country with a listed program.
The OECD’s list mixes citizenship programs with residence programs, so the same checks reach investors who took a residence permit instead.
A separate report from November 2023 suggests that banks look for your earlier passports when a CBI document is your proof of identity.
An adviser on the extra questions banks ask
Elena Ruda, Co-Founder and Managing Partner at Immigrant Invest, notes that banks ask more of clients who have investment citizenship or several residence permits.
In her account, the bank establishes “your tax residence, source of wealth, the nature of your business, and the kinds of transactions you expect to run through the account.”
She believes that this “extra layer is easier to clear than it sounds.” Every investment program checks applicants before it grants the status, she notes.
That check “establishes the source of the wealth behind the investment upfront, in a single file,” Ruda argues. A bank “assembles the same picture transaction by transaction” during the early months of the relationship.
Her advice is to save that file after approval. It contains the due diligence reports, the documents behind each source of funds, and an explanation of your asset structure.
A client who saves it, she argues, “comes to the bank with most of the answers already written down.” Immigrant Invest prepares that documentation with clients during the application, according to Ruda.
She gives one example, a client with Saint Kitts and Nevis citizenship by investment and a Greek residence permit. That client, she notes, “rarely runs into problems opening an account with a Greek bank.”
What three banks publish
UBS publishes a table of CBI and RBI programs for its tax due diligence, last updated in July 2026. The bank says the table follows “the OECD-published information,” and its entries match the OECD’s current list plus three residence permits in Panama.
Standard Chartered’s 2026 self-certification form for individuals puts the question to you directly. It asks, “Did the Individual obtain residence rights under a CBI/RBI scheme?” and gives a box for yes and a box for no.
Citi’s private bank in Singapore published a form that sets out when its extra checks begin. The form calls for additional due diligence “where the sole tax residence on the CRS self-certification form is a CBI or RBI jurisdiction (per the OECD list).”
Citi’s form lists its jurisdictions as of August 2022 and names Malta. An earlier version of the OECD’s own table named two Maltese programs, which the current version leaves out.
None of the three documents says the bank will refuse a customer because of how that customer acquired citizenship.
The tax question comes from the OECD list
The Common Reporting Standard (CRS) requires that banks collect and report information about each account holder’s tax residence. The OECD’s model form defines a reportable person as “an individual who is tax resident in a Reportable Jurisdiction.”
The same form says that “Each jurisdiction has its own rules for defining tax residence.” In general, it adds, “tax residence is the country/jurisdiction in which you live.”
When the OECD consulted on this issue, its paper said that “Reporting under the CRS is based on tax residence, not on citizenship or the legal right to reside in a jurisdiction,” IMI reported.
The OECD analyzed more than 100 programs for its list of potentially high-risk programs. A program qualifies when it gives access to a personal income tax rate “of less than 10% on offshore financial assets” and does not require that you spend “at least 90 days” in the country.
The list names the citizenship programs of Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia. Vanuatu’s Development Support Program is on it too.
Cyprus’s citizenship program also appears, although Cyprus phased that program out in November 2020. Every other entry is a residence program, in Antigua and Barbuda, the Bahamas, Bahrain, Barbados, Cyprus, Seychelles, the Turks and Caicos Islands, the United Arab Emirates, and Vanuatu.
The OECD says the table reflects “the current state of the OECD’s analysis” and will be updated on an ongoing basis.
When you claim tax residence in a country with a listed program, the OECD says a bank “may consider raising further questions.” These include whether you obtained residence rights under such a program, and whether you “spent more than 90 days in any other jurisdiction(s) during the previous year.”
Another suggested question asks where you filed personal income tax returns that year.
A 2023 report suggests checks on earlier passports
The Financial Action Task Force (FATF) and the OECD published a joint report on the misuse of CBI and RBI programs in November 2023. It says that financial institutions “should consider enhancing their policies to establish that all nationalities and passports are disclosed when onboarding a client.”
Where a CBI document is the proof of identity, the report says a bank could ask for “the original birth certificate from birth country and any passports held in that original identity.” It also lists tagging personal accounts “opened using a CBI passport” as one option for monitoring them over time.
IMI analyzed the report, which the FATF presented as a study of money laundering and financial crime risks in investment migration programs.
The report also says that countries could consider a ban on name changes in CBI documents. Its stated aim is to stop criminals using a program “to create new identities to conceal offending or evade capture.”
Antigua and Barbuda’s Cabinet decided in 2014 that successful applicants may not change their name for the issue of an Antigua and Barbuda passport. Dominica requires that applicants certify in writing that, if granted citizenship, they will not change their name within five years of naturalization, other than by marriage.
Saint Lucia put a five-year ban on name changes into its Citizenship by Investment (Amendment) Act in 2025.
A US presidential proclamation restricted entry for nationals of Antigua and Barbuda and Dominica from January 1, 2026.
The proclamation says US law enforcement and the Department of State found CBI programs open to several risks, including “allowing an individual to conceal his or her identity and assets to circumvent travel restrictions or financial or banking restrictions.”
What anti-money laundering law names
The EU’s anti-money laundering directive, as amended in 2018, lists a higher-risk factor for a customer who is a third-country national and applies for residence rights or citizenship “in the Member State” in exchange for investment. A passport from a Caribbean or Vanuatu program falls outside that wording.
The EU’s Anti-Money Laundering Regulation applies from July 2027 and removes citizenship from that factor. Its preamble says investor citizenship programs undermine “the fundamental status of Union citizenship,” so the regulation covers investor residence instead.
The European Banking Authority issued its guidelines on risk factors under the current directive, and they do not mention investment citizenship. Singapore’s central bank does not mention it in the guidelines to its anti-money laundering notice for banks either.
The UK’s Money Laundering Regulations use wider wording. They list as a higher-risk factor a customer who is a third-country national “applying for residence rights in or citizenship of a state” in exchange for investment.
The regulation uses the words “a state” under an amendment made in 2020, so the factor covers a program in any country. It describes a customer who is in the process of applying.
In the US, the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advisory on Saint Kitts and Nevis’s program in 2014. It warned banks that some people were abusing the program to obtain passports “for the purpose of engaging in illicit financial activity.”
FinCEN rescinded that advisory on February 24, 2026, as IMI reported. The advisory page on FinCEN’s website marks the rescission and gives no reason for it.
Reported restrictions in Singapore and Vanuatu
In August 2023, Singapore police arrested ten people in a money laundering case. Many of them had passports from CBI countries, including Vanuatu, Turkey, Cambodia, Cyprus, and Dominica, IMI reported.
Bloomberg reported in 2023 that at least one international bank was closing some accounts of clients with citizenship from Cambodia, Cyprus, Turkey, and Vanuatu. Its source was a person who asked not to be identified.
DBS said at the time that Singapore’s rules did not oblige banks to discriminate against clients on nationality alone, according to IMI’s report.
The Monetary Authority of Singapore (MAS) fined nine financial institutions a total of S$27.45 million over the case in July 2025. Passports appear nowhere in its notice, which cites shortcomings in customer risk assessment and in establishing customers’ source of wealth.
In Vanuatu, the Commonwealth Bank of Australia told the National Bank of Vanuatu that it would stop Australian dollar transfers for designated agents of the country’s citizenship programs at the end of September 2025. The stop also covered the Commonwealth Bank’s New Zealand subsidiary, the Vanuatu Daily Post reported.
The National Bank of Vanuatu said the payments would go through other correspondent banks. In 2021, IMI reported that the National Australia Bank had ended its correspondent relationship with the National Bank of Vanuatu.
What to bring when you open the account
Saint Kitts and Nevis's Inland Revenue Department said in a 2026 bulletin that banks "must not rely solely on the presentation of a passport or residence card from a CBI/RBI jurisdiction."
For people who acquired citizenship through investment, the bulletin tells the country's banks to apply enhanced due diligence. It lists proof such as a lease agreement, a local utility bill, or a tax assessment.
The department also plans CRS compliance reviews in 2026 that target accounts linked to CBI and RBI jurisdictions.
Tell the bank every nationality you have, including the one you had at birth. If a CBI passport is your proof of identity, bring your birth certificate and any passports from your original nationality.
Check how each country where you spend time defines tax residence before you sign the self-certification form. If you claim tax residence in a listed country, a bank may ask the OECD's questions about days abroad and tax returns.
