If most of your wealth comes from crypto, your citizenship by investment (CBI) application matches a red flag in global anti-money laundering standards.
The Financial Action Task Force (FATF), which sets those standards, lists a source of wealth drawn mostly from crypto among its warning signs. It wrote them for banks, crypto exchanges, and other firms that must report money laundering.
“A risk indicator should trigger a proportionate inquiry, not a presumption of wrongdoing,” argues Adam Juchniewicz, CEO of Bitcoin Lawyer. He adds that “the right question is whether the applicant can document how the wealth arose, who owns it, and how it reaches the investment.”
Saint Kitts and Nevis and Dominica publish guidance on crypto wealth. In Saint Kitts and Nevis, crypto can count as part of your wealth, but you must prove other wealth as well.
Dominica asks for a sworn affidavit on how you built your crypto wealth.
Only El Salvador takes crypto as the investment itself.
FATF’s red flags
FATF is the intergovernmental body that sets the standards for fighting money laundering. Its 2020 report on red flags for virtual assets, its term for crypto, has a section on the source of funds or wealth.
One flag in that section reads: “Bulk of a customer’s source of wealth is derived from investments in VAs, ICOs, or fraudulent ICOs, etc.” VAs are virtual assets, and ICOs are initial coin offerings.
Another flag covers wealth drawn disproportionately from crypto that came from exchanges or similar providers that lack anti-money laundering controls.
Both flags concern where the wealth came from, which can differ from the asset you have today.
Dominica’s Citizenship by Investment Unit (CBIU) tells applicants that source of wealth is how they built their wealth over time. It treats the money used for the investment as a separate question, the source of funds.
Juchniewicz notes that “a business sale may be the main source of wealth even when the proceeds are held in Bitcoin.”
He points to the reverse case as well: “Someone holding only dollars may still owe most of their wealth to Bitcoin appreciation.”
FATF does not treat a flag as proof of a crime. The report says that “the mere presence of a red flag indicator is not necessarily a basis for a suspicion,” and that a client “may be able to provide an explanation.”
How the coins moved
FATF’s list also flags the use of mixing and tumbling services, which FATF says suggests “an intent to obscure the flow of illicit funds.”
Privacy coins, peer-to-peer platforms, and unhosted wallets used to transport crypto across borders appear on the list too. So do transfers with exchanges whose customer checks are “demonstrably weak or non-existent.”
According to FATF, a single indicator “does not necessarily indicate criminal activity.” FATF adds that it is often “the presence of multiple indicators in a transaction with no logical business explanation” that raises suspicion.
A 2023 report by FATF and the Organisation for Economic Co-operation and Development on misuse of CBI and residence programs has a section on crypto. It found “some information to suggest” that the programs attract people who want to get around national rules on crypto.
The report’s case study on crypto and CBI comes from Antigua and Barbuda, which supplied it. A founder of a dark web criminal marketplace obtained Antiguan citizenship through the CBI program, along with a spouse.
According to the report, the founder “generated and moved their wealth via the acquisition of virtual assets.”
Program guidance
At the time of publication, the Citizenship by Investment Unit (CIU) of Saint Kitts and Nevis accepts crypto as a partial source of wealth. Its published answer on crypto adds that “a separate proof of wealth not derived from crypto will be required.”
The CIU also warns of “additional due diligence fees” for crypto wealth but gives no amount.
In Dominica, the CBIU has published guidance for agents on crypto wealth. It says an applicant whose wealth came from crypto “must show the origin of the funds they invested in a sworn affidavit.”
Applicants explain in the affidavit how they bought the coins, what they are worth in US dollars, and how they made a profit. They must also show a record of their crypto purchases and sales.
Dominica does not ask for proof of wealth from outside crypto.
Payment in fiat money
Almost everywhere, your crypto must become fiat money before a government will accept it. Banks and crypto exchanges handle that conversion, and FATF wrote its red flag list for them.
“Selling Bitcoin into dollars changes the payment asset. It does not rewrite the history of the wealth,” Juchniewicz points out. He believes that “a bank statement is one part of the evidence; it is not a substitute for the acquisition records and transaction trail behind it.”
El Salvador. The Freedom Passport program requires a one-time donation of US$1 million in Bitcoin (BTC) or Tether (USDT).
Antigua and Barbuda. In 2018, Parliament amended the Citizenship by Investment Act so that applicants could pay in crypto.
Prime Minister Gaston Browne said the government would convert any crypto it received to US dollars every day. He told IMI in 2019 that interest in the option had been “very low so far.”
Antigua’s Citizenship by Investment Unit now quotes all its fees in US dollars, and its website does not mention crypto.
Türkiye. The citizenship regulation requires that the foreign currency for the property route be sold to a bank in Türkiye.
That bank then sells it to the central bank, whose instruction for these sales names four currencies. They are the US dollar, the euro, the pound sterling, and the Swiss franc.
A separate 2021 central bank regulation bans the direct or indirect use of crypto assets in payments.
Vanuatu. In an undated notice from the COVID-19 period, the Citizenship Office told agents it “will not accept any payments” by Bitcoin or cryptocurrency under its three programs.
Agents in Vanuatu once took Bitcoin but had to convert it to dollars before they paid the government.
São Tomé and Príncipe. Contributions must go into an exclusive bank account of the National Transformation Fund, under a 2025 decree-law.
The blockchain record
Pavel Jakovlev, a venture capitalist, told IMI in a 2021 interview that “pretty much everything can be tracked on the ledger and, therefore, should have an explanation.”
He named Chainalysis and Merkle Science as firms that can trace transactions across blockchains. Asked whether due diligence firms were ready for crypto wealth, he said he lacked the data to answer, but pointed to “a certain stigma that surrounds crypto.”
A ledger shows each transfer of the coins, since every transaction “is still recorded,” Jakovlev noted. The record starts at the purchase, though, and Jakovlev said the client should explain “where he got the funds to make the initial purchase.”
FATF also flags a customer who “purchases large amounts of VA not substantiated by available wealth.”
Selling crypto for an application
For Juchniewicz, the checks start before any coins are sold. “Before selling Bitcoin for a citizenship application, check the program’s wealth requirements, the receiving bank’s conditions, and the tax consequences,” he advises.
He argues that “those answers belong in the initial comparison, alongside family rights and ongoing obligations, before money is committed.”
ECCIRA and the EU
The five Eastern Caribbean states with CBI programs agreed to create a joint regulator, the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA). Each enacted the agreement into national law in 2025.
ECCIRA plans to begin its work in Grenada in late 2026. Its founding agreement takes effect on the 30th day after the fifth state deposits its ratification.
That agreement defines a due diligence firm as one that checks an applicant’s source of funds “in accordance with international best practices” and anti-money laundering standards. Those firms must work to “guidelines and directives issued by the Authority.”
The agreement’s minimum checks include “verification of remittance of investment funds through a licensed financial institution that has completed customer due diligence on the Applicant.”
Each state must also see that the investment goes into an escrow account, which the agreement defines as “a secure, segregated bank account.”
Crypto gets no mention in the agreement.
ECCIRA will publish its standards on its website once the Authority approves them. Those standards will show whether the five programs adopt a common rule on crypto wealth.
Dominica’s government says the European Union asked the five governments to end their CBI programs by June 2028. Without that step, their citizens could lose visa-free access to the Schengen Area.
Antigua and Barbuda offered in October to end its program by 2030, if the EU agrees to a longer transition and helps pay for it.
