Every citizenship by investment (CBI) program can take back what it granted. The power appears in the statute of every country in this article, and in most of them it was written long before the program existed.
One grounds is common to all of them, which is fraud. Past that point the programs separate, and they separate more widely than any program summary suggests.
Malta needs a prison sentence of twelve months or more before the minister can act on anything except fraud. Cyprus acts on suspicion, where being wanted by Interpol is itself the grounds.
Six programs go further again. In Antigua and Barbuda, Dominica, Saint Kitts and Nevis, Saint Lucia, Grenada and Turkey a minister can revoke on an opinion about you, with no crime alleged and no court involved.
Your protection comes from the procedure. The response window varies from seven days in Nauru to 60 days in Cyprus, and Egypt, Jordan and Vanuatu publish no window at all.
Four programs set 21 days, then let the minister replace that figure for anyone living abroad, which describes almost every citizen these programs create.
The Grounds Every Program Shares
Every statute IMI reviewed allows revocation where the applicant obtained citizenship by fraud, misrepresentation or concealment. The wording barely changes between countries.
Malta’s Citizenship Act says the Minister may deprive a citizen “if he is satisfied that the registration or certificate of naturalisation was obtained by means of fraud, false representation or the concealment of any material fact.” Grenada, Dominica, Antigua and Barbuda and Saint Kitts and Nevis use close to the same sentence.
Turkey writes the idea into a separate article. Article 31 of Citizenship Law No. 5901 applies where a person “acquires citizenship by misrepresentation or hiding the key issues, which form a basis for acquisition of Turkish citizenship.”
Concealment reaches further than a lie. A fact you never disclosed can support revocation years later, and in most of these countries the fraud grounds have no expiry date.
Where Living Abroad Is Itself a Ground
Malta
Malta no longer grants citizenship by investment. Act XXI of 2025 amended the Citizenship Act on 24 July 2025, addressing the Court of Justice of the European Union’s judgment in Case C-181/23, Commission v. Malta.
That Act ended the Granting of Citizenship for Exceptional Services program and removed every reference to it. Article 14 applies to any citizen “who is such by registration or naturalisation,” wording that covers the people the former program created.
Malta adds no grounds resting on a minister’s view of your reputation, and no equivalent of the prejudicial-activities limb that Antigua and Barbuda and Saint Kitts and Nevis use.
What Malta adds instead reaches the people these programs create. Article 14(2)(d) applies where a citizen has been “ordinarily resident in foreign countries for a continuous period of seven years” without either serving the Republic or an international organization of which Malta was a member.
The same paragraph gives you the way out. It does not apply if you have “given notice in writing to the Minister of his intention to retain citizenship of Malta.”
A citizen by naturalization who lives abroad and never files that notice becomes deprivable after seven continuous years.
Malta’s statelessness bar, in Article 14(3), covers the sentencing grounds in subarticle (2)(c) and nothing else.
The Article 14 wording quoted above comes from the consolidated Citizenship Act. Malta’s legislation portal did not return a consolidation published after the July 2025 amendment, and the published summaries of that amendment do not list Article 14 among the provisions it changed.
Where Suspicion of a Crime Is Enough
One program allows deprivation without a conviction, without a charge, and without any finding by a court. It is also where this machinery has been tested in court at scale.
Cyprus
Cyprus ended its investor program in November 2020, and Article 113(3) of its Civil Registry Law allows deprivation where a person is wanted by Europol or Interpol for an offence punishable by five years or more. The same article allows it separately where sanctions are imposed on them or their name is added to a sanctions list.
Being sought is the grounds. A charge is not required, and neither is a conviction.
That power applies within ten years of naturalization.
Cyprus gives 60 days to answer, and starts the clock later than the others. Article 113(5) gives the affected person 60 days “from the date of receipt of the written notification,” rather than from the date it was sent.
Cyprus is also unusual in naming its reviewers. Article 113(6) creates an “Independent Citizenship Deprivation Review Committee” of a president and two members.
Article 113(7) then names them. The president is a representative of the Legal Service of the Republic, and the two members are the Accountant General and the head of the Ministry of Justice and Public Order, or their representatives.
All three work for the government that proposes to revoke. The committee decides for itself whether to hear you in person or to decide on the documents, under Article 113(8), provided it has invited a written position.
The government has revoked the citizenship of 360 people since the closure, made up of 101 investors and 259 family members. A judicial inquiry led by former Supreme Court judge Myron Nikolatos found that 53% of the 6,779 citizenships granted between 2007 and August 2020 failed to meet legal requirements.
The courts have gone both ways. In one case a Cypriot court annulled a revocation because the government never weighed whether it would leave the investor stateless, the investor having lost his Indian nationality automatically when he naturalized.
In another, a court refused an interim application by a Chinese investor wanted by Interpol who sought to suspend his revocation while his main case proceeded.
One question now hangs over all of them, which is whether any of these cases belong in court. In January 2026 the Administrative Court of Appeal asked the Supreme Constitutional Court to decide whether revocation decisions can be challenged at all, or whether they are sovereign acts beyond judicial review.
Cyprus also puts the money question in its statute. Article 113(1) provides that where citizenship granted under the investor route is taken away, no investment, contribution or donation is returned.
Where a Minister’s Opinion Is Enough, With No Crime at All
Six programs allow revocation on a judgment about you rather than on anything a court has found. No conviction is needed in any of them.
Antigua and Barbuda and Saint Kitts and Nevis use the same inherited wording, which reaches activities that are prejudicial to safety or public order in the minister’s opinion. Grenada reaches the same place through a national security clause, and Dominica and Saint Lucia each write a disrepute test of their own.
Saint Lucia
Saint Lucia writes the widest grounds of any program in this article. Section 38(1) of its Citizenship by Investment Act allows the Minister to revoke where “the person has been convicted of an offence,” with no minimum sentence and no category of offence named.
That grounds names no time limit either, so a conviction at any point in your life engages it.
The next paragraph goes further again. The Minister may also revoke where the person “has performed any other act which, within the opinion of the Minister, has the potential to bring disrepute to Saint Lucia.”
No conviction is needed there, and no act has to be proven harmful. The potential to cause disrepute, judged by one person, is the whole test.
Saint Lucia also builds its process in the opposite order to its neighbors. Section 38(3) requires that the Minister “shall in writing specify the grounds for the revocation of citizenship by investment,” and nothing in the section requires notice before the Order is made.
The country names a court instead. Section 38(4) grants “the right of appeal to the High Court,” and section 38(5) requires that notice of appeal be given “within 30 working days of the date that the Minister serves a copy of the Order on the person.”
Among the five Eastern Caribbean programs, Saint Lucia alone names a court in its citizenship statute instead of a committee. By the time you reach it, the revocation has already taken effect.
Dominica
Dominica reaches conduct that no court has ruled on, and it does so through the regulations rather than the Act.
Regulation 6(1)(h) of S.R.O. No. 8 of 2024 covers a person who “is or has been involved in activity likely to bring disrepute to Dominica.”
Regulation 6(1)(f) covers anyone “deemed a potential security risk to Dominica or to any other country.” Two further paragraphs reach a person who has been denied a visa by the European Union or the United Kingdom, or by a country Dominica has visa-free travel with.
A person in any of those categories “shall not be approved for citizenship of Dominica under the Citizenship by Investment Programme and if approved may be deprived of citizenship of Dominica pursuant to section 10 (2) or (3) of the Act.”
Dominica’s sentencing grounds differ from every neighbor, because they set no period after naturalization at all. Regulation 6(5) provides that a person “who has after becoming naturalised been sentenced in any country to imprisonment for a term of not less than 12 months shall be deprived of citizenship of Dominica.”
That wording obliges the government to act rather than permitting it. Grenada, Antigua and Barbuda and Saint Kitts and Nevis all cap their equivalent grounds at five years after naturalization, and Dominica caps nothing.
Changing your name within five years of naturalization is a separate grounds under regulation 6(4). Regulation 6(2) adds that where a person is deprived under regulation 6(1), “no refund shall be made of any fees, investments or other sums paid by or on behalf of that person.”
When Dominica deprived a group of citizens in 2024, the Order it published named two grounds. One was fraud, and the other was “that it is not conducive that a scheduled person continue to be a citizen of Dominica.”
IMI could not verify Dominica’s remaining deprivation grounds, because every published copy of the Citizenship Act itself is a scanned image with no machine-readable text.
Antigua and Barbuda
Antigua and Barbuda writes the broadest of the inherited grounds into section 9(1)(e) of its Citizenship Act. The Minister may deprive a citizen who has “engaged in activities, whether within or outside of Antigua and Barbuda, which, in the opinion of the Minister, are prejudicial to the safety of Antigua and Barbuda or to the maintenance of law and public order in Antigua and Barbuda.”
Nothing in that paragraph requires a charge, a conviction or a finding by a court. Section 9(1)(c) reaches further into conduct that is not criminal at all, covering a person who has “shown himself by act or speech to be disloyal or disaffected towards Antigua and Barbuda.”
The sentencing grounds in section 9(1)(b) are narrower. They apply where a court has convicted the person within five years after naturalization and sentenced them to imprisonment for a term of not less than twelve months.
Treason and sedition have no time limit under section 9(1)(a), and neither does a conviction for an offence punishable by death or by seven years or more.
Antigua and Barbuda then adds a condition that has nothing to do with conduct. Its Citizenship by Investment Act allows the Minister to deprive a person of citizenship granted under that Act “if that person does not spend a minimum of five (5) days in Antigua and Barbuda during the period of five calendar years after his registration.”
The country’s Citizenship by Investment Unit states the same rule on its own website, and adds that the investment is not repaid.
Section 13 of the Citizenship Act then closes the courts. It provides that the Minister need not give reasons, and that a decision at his discretion “shall not be subject to any appeal or review in any court.”
The statelessness bar in section 9(2) protects you on the sentencing grounds alone. It does not reach the ministerial-opinion grounds, the disloyalty grounds or fraud.
Saint Kitts and Nevis
Saint Kitts and Nevis uses the same two open grounds as Antigua and Barbuda, in the same order. Section 9(1)(e) reaches a person who has, “whether within or outside of Saint Christopher and Nevis, engaged in activities, which, in the opinion of the Minister, are prejudicial to the safety of Saint Christopher and Nevis or to the maintenance of law and public order in Saint Christopher and Nevis.”
Section 9(1)(c) covers a citizen who has “by act or speech shown himself or herself to be disloyal or disaffected towards Saint Christopher and Nevis.”
Its sentencing grounds match Antigua’s, at a term of not less than twelve months imposed within five years after naturalization, and its statelessness bar in section 9(2) again covers that paragraph and nothing else.
Saint Kitts and Nevis also writes an investment condition into its deprivation section for citizens by registration. Where a person divests the qualifying investment within five years, or transfers the property, the Minister may deprive them of citizenship.
The federation has the same ouster clause as Antigua and Barbuda, and a constitution that appears to contradict it. Section 94(d) includes a proviso protecting a right of appeal to a court or independent authority for the fraud and treason deprivation grounds.
Which one governs has not been decided. IMI flags the tension rather than resolving it, because no court has ruled on it.
Grenada
Grenada’s Citizenship Act gives the Minister power to revoke where “it is in the interest of national security to do so,” and then adds seven words that remove the rest of the process.
Section 9(2)(b) provides that in that case “subsections (5) and (6) shall not apply.” Those two subsections are the duty to give written notice of the grounds and the right to an inquiry.
On a national security grounds, Grenada owes you no warning and no hearing, so the Order itself would be your notice.
Grenada’s sentencing grounds, in section 9(3)(c), apply where a court has sentenced the person “in any country to a term of imprisonment of twelve months or more” within five years after becoming naturalized.
Where Grenada does give notice, it allows more time than its neighbors. Section 12(6) of its Citizenship by Investment Act requires that the Minister give notice of the grounds and require written objections “within a specified period being not less than thirty days.”
IMI could find no statelessness bar anywhere in Grenada’s revocation provisions.
Turkey
Turkey acted on a scale nothing else in this market approaches. Its Interior Ministry cancelled or withdrew the citizenship of 6,134 people who acquired it through investment, according to a written statement published on August 4.
The figure includes 1,413 principal investors, with spouses and children making up the rest.
The action divided into two groups on different legal grounds. Inspectors identified 1,150 investors who had completed collusive or irregular transactions, and 5,391 people lost citizenship in that group.
Police and the National Intelligence Organization flagged a second group of 263 investors as objectionable on public order and national security grounds after they were naturalized. In that group 743 people lost citizenship.
No fraud was alleged against them. Their status went on vetting grounds rather than for any defect in the investment.
Aran Hawker, co-founder at CIP Turkey, names two possible reasons for this group. One is national security.
In his account, the other is an outside regulator, such as the Financial Action Task Force (FATF), raising concerns with the Turkish government at a later date.
He also notes that the Turkish government “doesn’t use any external third-party due diligence providers,” and says most firms in the market do use them.
His advice is to tell your lawyers everything, so they can warn you if a refusal or a revocation is possible.
Turkey sets no special response period in its citizenship law, so the general administrative rule applies. Article 7 of Law No. 2577 allows 60 days to file suit in the administrative courts.
Article 33(2) gives those people one protection the others lack. It provides that where such persons “resort to jurisdiction against the decision of cancellation, the procedure to liquidate their belongings shall be suspended until the case is concluded.”
Hawker argues that Turkey “gives investors the opportunity to exit their investment and not lose their money, which is a lot better than circumstances on other programs.”
Four Programs Give You 21 Days, Then Let the Minister Change It
Antigua and Barbuda, Dominica, Saint Kitts and Nevis and Malta inherited the same pre-independence British drafting, so they share a procedure as well as a vocabulary.
All four apply a public good test before any Order can be made. Grenada states that test most plainly in section 9(4), where the Minister “shall not deprive a person of his or her citizenship under this section unless he or she is satisfied that it is not conducive to the public good that that person should continue to be a citizen of Grenada.”
Malta writes the same sentence into Article 14(3), and Antigua and Barbuda includes a version of it. Dominica’s 2024 deprivation Order words the test as “not conducive” without the phrase “public good.” The same minister who proposes the revocation applies the test, and no statute here names anybody who reviews that judgment.
The four also share a 21-day response deadline, and it has a second limb that most summaries of these rules omit.
Malta’s version, in regulation 5(2) of Subsidiary Legislation 188.01, requires that an application for an inquiry be made “if that person is in Malta at the time when the notice is given to him, within twenty-one days from the giving of the notice.”
The regulation then continues, “in any other case, within such time, being not less than twenty-one days from the giving of the notice, as the Minister may determine.”
Dominica’s regulation 16(2), Antigua’s regulation 10(2) and Saint Kitts and Nevis’ regulation 8(2) say the same thing about their own countries, down to the proviso letting the minister extend the period “in special circumstances.”
Read that second limb against the people these programs naturalize. A citizen by investment usually lives somewhere else, so 21 days is the figure that applies to residents.
For everybody else the minister who proposes to revoke your citizenship also decides how long you get to answer. The 21 days is a floor, and nothing in the text sets a ceiling.
The committee that hears you comes from the same drafting. Its chair must have judicial experience, and the minister appoints the chair and every other member.
Dominica and Antigua publish these regulations as scanned images with no searchable text, so IMI read the figures above off the page itself.
Where Seven Days Is the Whole Window
One program compresses the entire answer period into a single week, and the same country wrote a statelessness protection into its general citizenship law before dropping it from the investor one.
Nauru
Nauru sets the tightest deadline in this article. Section 23(3) of its Economic and Climate Resilience Citizenship Act 2024 provides that where a person fails to show cause “within 7 days after the service of the notice, the Minister shall in consultation with the Cabinet shall make his or her decision without any further notice to the person.”
That gives seven days from service. The doubled “shall” appears in the statute as published.
Nauru’s Naoero Citizenship Act 2017 requires that Cabinet take statelessness into account. The 2024 Act, which governs citizens by investment, drops that requirement.
Where No Statute Names a Notice or an Appeal
Three countries publish revocation powers with no procedure attached. Their statutes name no duty to warn you, no period in which to answer, and no route of appeal.
Egypt
Egypt’s Law No. 26 of 1975 allows the Council of Ministers to withdraw nationality by justified decree under Article 15, and to declare forfeiture under Article 16.
IMI read the law’s provisions on withdrawal and forfeiture and found no clause requiring notice to the person, and no period for a response.
Egypt is also the one country here that limits the fraud grounds in time. Article 15 sets a ten-year limit for withdrawal on fraud grounds and five years for the other naturalization grounds.
Jordan
Jordan’s Law No. 6 of 1954 works the same way. The Council of Ministers decides with the approval of the King, and the law names no notice duty, no response window and no appeal.
Egypt and Jordan both have general administrative courts, and a challenge would go there under ordinary public law. Neither citizenship statute grants a route of its own.
Vanuatu
Vanuatu’s Citizenship Act is silent on the question. It contains three separate revocation mechanisms, and no appeal clause attached to any of them.
Your Family’s Position Depends on Which Clause the Government Uses
Turkey addresses dependants directly, and answers differently for each mechanism. Article 30(2) provides that revocation decisions “shall not affect the spouse and children of the concerned person.” The articles that cancel a citizenship for fraud do reach dependants granted at the same time.
Cyprus is explicit in the other direction. Article 113(1) provides that family members who acquired citizenship as family members of the investor may also be deprived of it.
Egypt splits the same way as Turkey. Article 17 lets withdrawal extend to dependants by a separate decree, and forfeiture under Article 16 never reaches beyond the individual.
Most Caribbean statutes say nothing. Antigua and Barbuda, Saint Lucia and Grenada contain no clause stating whether a dependant granted citizenship on the same application loses it when the main applicant does.
Practice suggests they do. When Saint Kitts and Nevis revoked 13 citizenships on April 12, 2025, its own announcement described the action as reaching those individuals and their dependants.
The Statelessness Bar Usually Covers One Grounds and No More
Most of these statutes contain a statelessness bar, and most apply it to the sentencing grounds alone.
Antigua and Barbuda bars deprivation that would cause statelessness where the grounds are the twelve-month sentence within five years of naturalization, and nowhere else. Saint Kitts and Nevis’ section 9(2) and Malta’s Article 14(3) draw the line in the same narrow place.
None of them covers fraud, disloyalty, wartime trading with an enemy, the ministerial-opinion grounds, or the investment-specific grounds.
Grenada, Saint Lucia, Vanuatu, Jordan and Turkey’s revocation articles contain no statelessness bar that IMI could find, and Nauru removed the one its general citizenship law had written in.
When the Risk Ends, and Where It Never Does
The sentencing grounds expire in most of these countries. Antigua and Barbuda, Grenada and Saint Kitts and Nevis limit theirs to a sentence imposed within five years of naturalization, and Malta allows seven.
Dominica is the exception, because regulation 6(5) attaches no period to the sentence at all.
Nothing else in these statutes expires with it. Treason, sedition, disloyalty, wartime trading and the ministerial-opinion grounds apply at any point after naturalization, with no period attached to any of them.
The fraud grounds mostly have no expiry either. In almost every country here, nothing in the statute prevents revocation for concealment decades after the grant.
Egypt is the exception, with its ten-year limit under Article 15.
Saint Lucia goes the other way, because the conviction grounds it writes into section 38(1) name no period at all.
What to Check Before You Commit
Read the revocation section of the statute before you read the program summary. It is usually a short section, and it describes what the government can do to you later.
Three things decide how exposed you are. One is whether the statute stops at a criminal sentence or reaches an opinion about your conduct, which in four of these countries it does.
Another is the response deadline, along with whether that figure changes because you live abroad. The third is the reach of the statelessness bar, which in most programs covers a prison sentence and leaves fraud and the ministerial grounds untouched.
If you have a second nationality, the statelessness protection that saved the investor in Cyprus does not apply to you. That case turned on the investor having lost his previous nationality when he naturalized, and most applicants to these programs never lose theirs.
Watch the countries where the same office sets the deadline and issues the notice. Antigua and Barbuda, Dominica, Saint Kitts and Nevis and Malta all do that for a citizen living abroad.
That describes most of the people these programs exist to serve.
