El Salvador is the only country where the government takes Bitcoin as the qualifying payment for citizenship. Almost every other residence or citizenship by investment program expects the money in US dollars, euros or another national currency.
For a crypto investor, the application depends on proof that the coins came from a lawful source. It also depends on the paper trail you create when you convert them to cash.
An earlier IMI analysis mapped which programs take crypto directly, and this article looks at the checks your crypto faces before a government accepts the money.
Three ways crypto meets an investment program
El Salvador accepts crypto as payment for citizenship. Most programs accept the cash that an agent or an exchange produces from it, and some count crypto as evidence of wealth alone.
Vanuatu follows the second model. In an undated notice that also covers oath arrangements during the COVID pandemic, its Citizenship Office told agents that it “does not recognize and will not accept any payments made under these three Programs by Bitcoin or Cryptocurrency.”
The same notice names the US dollar as the only currency in the regulations under the Citizenship Act. An earlier IMI report found that agents could receive Bitcoin but had to convert it to US dollars before they paid the government.
São Tomé and Príncipe works in a similar way. Its Citizenship by Investment Unit says that applications “must be initiated through a licensed Marketing Agent authorized by the program.”
The program’s decree-law requires that contributions go into a bank account that belongs to the National Transformation Fund.
CitizenX is one of the program’s licensed agents. Its CEO, Alex Recouso, notes that São Tomé “can also be done with cryptocurrency (even if regular bank statements are also required).”
He explains that this works “since the licensed agents have to pay to the authorities directly.” Recouso sees the model as “a great compromise for countries who are not ready to accept cryptocurrency directly.”
Recouso argues that stablecoins and Bitcoin are “just better money (faster and cheaper).” He believes that many countries “could benefit from accepting them directly.”
The UAE golden visa has no crypto route. For its property investor golden visa, the Dubai Land Department lists bank transfer, credit card and cash as payment methods.
In 2025, the UAE’s identity and citizenship authority said golden visa criteria “do not include digital currency investors,” according to The National.
El Salvador takes Bitcoin, and its own laws leave a question open
El Salvador’s Freedom Passport program requires that applicants make a one-time donation of US$1 million in BTC or USDT. Applicants also pay an initial application fee of US$999 in BTC or USDT.
The program admits up to 1,000 participants per year.
The program appears to rest on Legislative Decree No. 918 of 2023. That decree lets foreign investors or donors who inject capital en moneda de curso legal, meaning in legal tender, qualify for naturalization.
The decree’s preamble names donations of Bitcoin from foreigners who want to support El Salvador’s development.
On January 29, 2025, the Legislative Assembly amended the Bitcoin Law with Decree No. 199. The amended law continues to treat Bitcoin as legal tender, with voluntary acceptance.
The amended article 7 limits the acceptance of Bitcoin as payment to individuals and to companies with wholly private ownership. The Freedom Passport is a government program that takes Bitcoin, and neither decree explains how it fits under that article.
IMI found no official statement on the question. If you plan to apply, ask the program for its legal position in writing before you transfer any coins.
Proving where the coins came from
Due diligence teams must trace your money back to a lawful origin. For crypto, that trail passes through exchanges, wallets and conversions that no bank statement shows.
Adam Juchniewicz, founder of 21 CBI, notes that “the blockchain can show where Bitcoin moved.” He argues that it “cannot, by itself, explain whether the original purchase was funded by a salary, a business sale, or an inheritance.”
In his view, “that connection comes from supporting records.” Juchniewicz believes that “self-custody gives you control of your money; good documentation makes its history understandable to the person reviewing your application.”
Saint Kitts and Nevis publishes its rule on the program website. Its Citizenship by Investment Unit (CIU) says it “now accepts cryptocurrency as a partial source of wealth.”
The CIU also asks for a separate proof of wealth that did not come from crypto, and it charges additional due diligence fees. IMI covered the change.
Hong Kong’s New Capital Investment Entrant program (New CIES) asks applicants to show net assets of at least HK$30 million. The applicant must own those assets throughout the six months before the application.
The program’s published FAQ does not mention crypto. According to IMI’s reporting, the Hong Kong Investment Promotion Agency confirmed two cases where applicants used crypto to meet the threshold.
One applicant used Bitcoin in October 2024, and the other used Ethereum in February 2025.
Stephen Barnes, founder of the Hong Kong Visa Center, told IMI that applicants can use crypto “as part of the due diligence process but not to secure the status.”
The US put its position in a proposed rule
On July 2, 2026, the Department of Homeland Security (DHS) published a proposed rule for the EB-5 immigrant investor program. It includes a section on digital assets, and IMI covered the rest of the proposal.
Under the proposal, digital assets that are not tangible “may not be directly invested as ‘capital’ into a new commercial enterprise.” An investor may use them as the source of the cash that goes into the investment.
DHS said it “has a practice of permitting digital assets as a valid source of funding,” with the same evidence standards as other money.
A general rule on currency exchangers of every kind lets USCIS treat money from a licensed exchanger as lawfully derived, unless it has reason to doubt it. That rule covers the exchanger’s side of the conversion, and you must also show how you acquired the coins.
The comment period ended on August 31, 2026, and IMI found no final rule at the time of publication. DHS says it prefers to set out crypto-specific detail in guidance, outside the regulation.
Converting your coins leaves a record
The EU’s Anti-Money Laundering Regulation, which applies from July 2027, names “anonymous crypto-asset accounts” among the accounts that crypto-asset service providers may not maintain.
Tax authorities are also preparing to exchange crypto data under the OECD’s Crypto-Asset Reporting Framework (CARF). The OECD updated its list of committed jurisdictions in September 2026.
On that list, Portugal, Greece, Malta and the Cayman Islands plan their first exchanges by 2027. Hong Kong, the UAE, Türkiye and Panama plan theirs by 2028, and the United States by 2029.
El Salvador is one of four jurisdictions that the OECD’s Global Forum identified as relevant but that have not yet committed. The list does not name Saint Kitts and Nevis, Antigua and Barbuda, Dominica, Grenada, Saint Lucia or Vanuatu in any category.
Speak to a tax adviser in each country involved before you convert. IMI’s list of countries that do not tax crypto gains covers the tax side of a move.
What to prepare before you apply
Juchniewicz says his perspective comes from “over a decade at the US Department of Homeland Security on immigration policy.” His advice is to “build the evidence before you move the money.”
“Establish what the program and receiving bank require while you can still obtain the records,” he adds. He warns that a gap found after you convert the Bitcoin “creates a problem that preparation could have prevented.”
Save the records that show how you acquired each coin, with the dates and the price you paid. Export the full transaction history from every exchange you used, and list the wallet addresses that connect them.
Convert through a licensed exchange so that the cash arrives with a clear record. Before you start, ask your agent whether the program accepts crypto as a source of funds.
In Saint Kitts and Nevis, plan for a second proof of wealth that has nothing to do with crypto.
The EB-5 guidance that DHS promised will be the next official statement on crypto as a source of funds. IMI will also report changes to the CARF list as more jurisdictions commit.
