Five of the 13 active citizenship by investment (CBI) programs publish the nationalities they refuse. The other eight exclude applicants without naming them.
That gap decides where an application is worth filing. An Iranian applicant can read Grenada’s published conditions and work out the answer in an afternoon, and has nothing equivalent to read for Egypt or Jordan.
What this article covers
This article covers the 13 programs that IMI’s full overview of restricted nationalities follows.
Three other active programs, in Samoa, Sierra Leone, and Pakistan, are outside that tracker and outside this article.
Malta is out for a different reason. On April 29, 2025 the Court of Justice of the European Union ruled in Case C-181/23 that Malta’s investor route breached Article 20 TFEU, describing it as “the commercialisation of the grant of the nationality of a Member State”.
Act XXI of 2025 repealed that route on July 24, 2025, and Malta replaced its investor route with a discretionary merit process under Legal Notice 159 of 2025. No Maltese investment threshold remains for a nationality rule to attach to.
The programs that publish a list
Antigua and Barbuda
The Citizenship by Investment Unit publishes a Restricted Countries List on its FAQ page, updated by Cabinet decision on February 26, 2020: Afghanistan, Iran, North Korea, Somalia, Sudan, and Yemen.
All six come with the same exception. Nationals of those countries can apply if they were born there and migrated before the age of majority.
Ten years of permanent residence in a country off the list also qualifies, provided the applicant has no economic ties to a restricted country.
Two more nationalities are excluded somewhere other than that list. IMI reported in 2022 that the unit suspended Russian and Belarusian applications with effect from July 28 that year, after briefly reopening to both on July 8.
IMI’s banned-nationalities list records both as ineligible today. Neither appears on the Restricted Countries List, so a reader consulting that list would not learn that either exclusion exists.
Ukraine was a third case, and it shows these rules moving in the other direction. The unit suspended Ukrainian applications in March of that same year, citing an inability to vet applicants in the country.
It resumed accepting them during 2024. The unit’s own half-year report recorded 19 applications from people born in Ukraine.
No announcement marked that change, and the Restricted Countries List named Ukraine at no point.
Dominica
Dominica’s unit publishes a dedicated banned-nationalities page. Belarus, Russia, and Yemen face flat bans, and so does “Northern Iraq”, which the page illustrates with nine cities in the Kurdistan region: Erbil, Amedi, Dahuk, Kirkuk, Lalish, Raniya, Soran, Sulaymaniyah, and Zakho.
That sub-national definition is unusual, and IMI reported the nine cities Dominica names when the policy arrived in 2022.
Iranian, North Korean, and Sudanese applicants face a conditional refusal instead. Dominica turns them down unless they have been away from the country for at least ten years, own no substantial assets there, and have done no business in it or with it.
The Yemen ban has a dated circular behind it. Everything else on the page states policy without citing an instrument at all.
Grenada
Grenada’s Investment Migration Agency issued Circular No. 1 of 2024 on March 25, 2024, effective April 1. It names seven countries whose residents are ineligible “without exception”: Iran, North Korea, Russia, Belarus, Sudan, Yemen, and Afghanistan.
That wording is worth pausing on, because it restricts nationals residing in those countries rather than nationals of them. Grenada is testing where an applicant lives as much as their nationality.
The same circular then gives four of those seven a way back. Iranian, Sudanese, Yemeni, and Afghan applicants can qualify through migration before the age of maturity, or through ten years of permanent residence or a valid visa in Canada, the United Kingdom, a Schengen state, the United States, Australia, New Zealand, Saudi Arabia, or the United Arab Emirates.
Two further conditions apply on top. The applicant must maintain no economic ties to any restricted country, and due diligence providers must be able to conduct an in-country investigation, which the circular warns may cost the applicant considerably more.
Those two paragraphs together leave North Korea, Russia, and Belarus without a stated path back. Nothing in the circular flags the tension between them.
Grenada names the third countries where residence satisfies the exception. Antigua and Barbuda accepts residence in any country off its own list, and Saint Kitts and Nevis offers no exception at all.
Saint Kitts and Nevis
Six countries appear on the eligibility page of the Saint Kitts and Nevis unit: Afghanistan, Belarus, Iran, Iraq, North Korea, and Russia. The stated reason is “national security and public safety”.
Two things separate this list from the other three Caribbean ones. It offers no exception of any kind, and its Iraq entry covers the whole country rather than nine named cities.
El Salvador
El Salvador is the fifth program with a published list, and the only one outside the Caribbean. Its site calls them “Prohibited Jurisdictions” rather than nationalities, which is the more accurate label for what it names.
The list covers Cuba, North Korea, Iran, and Syria, then adds Crimea and the self-proclaimed Donetsk, Luhansk, Kherson, and Zaporizhzhia republics. Anyone on the OFAC sanctioned persons list is excluded as well.
Four of those entries are not countries. Naming occupied territory reaches an applicant by where inside a country they come from, which is the move Dominica makes with Northern Iraq.
No two lists agree
The four Caribbean lists are the ones worth setting side by side, because they cover comparable programs in one region. Nine nationalities appear across them, and not one of the nine appears on all four in the same form.
Iran and North Korea come closest, because all four programs name both. Saint Kitts and Nevis refuses each outright, Grenada refuses North Korea outright and gives Iran a route back, and the remaining two attach conditions to both.
Russia and Belarus are named by three of the four, and Antigua and Barbuda is the one leaving them out. Sudan and Yemen are also named by three, and there the odd one out is Saint Kitts and Nevis.
Somalia appears on a single list, Antigua and Barbuda’s. Iraq appears on two, and those two do not mean the same thing by it.
Saint Kitts and Nevis names the whole country. Dominica points at nine cities in the Kurdistan region.
What the four lists say is not everything the four programs do. Antigua and Barbuda shows the difference, because its circulars on Russia and Belarus never reached its list, and neither did its decision to start accepting Ukrainians again.
IMI reported in March 2026 that how the five Caribbean programs treat Iranian applicants divides the same way, with Saint Lucia joining Saint Kitts and Nevis on the outright refusal.
The programs that exclude without a list
Silence is not always evasion. A program that publishes its full vetting rules also tells an applicant how to dress a file to pass them, and sanctions designations move faster than a web page.
The cost lands on the applicant either way. Somebody choosing between programs cannot price a rule nobody will state.
Nauru adopts someone else’s list
Nauru’s eligibility criteria require that an applicant not be “a citizen of a country which is listed in the United Nations Security Council Resolution as a high-risk country”. Those criteria name no country.
That bar appears on the program’s website and not in its statute. The Naoero Economic and Climate Resilience Citizenship Act 2024 makes eligibility turn on age, contribution, and meeting the requirements of the program, with no nationality test in it.
A similar formula does appear in the Act, as a ground for cancelling citizenship after a grant. That limb catches someone who acquires a listed country’s citizenship later, and it does not reach an applicant who is already a citizen of one when the file opens.
The design moves the decision outside Nauru either way. Its restricted set changes when the Security Council’s designations change, with no circular from the program and no notice to anyone mid-application.
Turkey excludes by omission
Turkey publishes no excluded-nationality list for its citizenship route, because the restriction works upstream, inside the property law that the USD 400,000 route depends on.
Law No. 6302 of 2012 replaced a reciprocity test, and the Cabinet now decides which countries’ nationals may acquire property. A nationality the Cabinet leaves out is excluded without appearing on any restricted list.
The decision naming the permitted countries does not appear to be published anywhere. Turkey’s own investment office confirms only that the Cabinet of Ministers determines them.
Egypt, Jordan, and Saint Lucia
Egypt’s General Authority for Investment described the gate as approval from “the relevant security authorities, considering national security considerations”, naming no country. That page no longer resolves, and the wording survives in an archived capture.
Jordan’s Ministry of Investment publishes the full criteria for its investor citizenship route, and they name no nationality at all.
The program had benefited 685 investors by the middle of 2026, according to Investment Minister Tareq Abu Ghazaleh. His predecessor told Jordan News that Syrian and Iraqi investors top the list of recipients.
That inverts the Caribbean pattern. Iraqi applicants are barred outright by Saint Kitts and Nevis and restricted by Dominica, and in Jordan they top the list.
Saint Lucia’s site has one statement on applicant nationality, a 2022 press notice referring to a memorandum of March 18, 2022, which suspended Russian and Belarusian applications and said the policy remains in effect. Its published legislation names no country.
IMI reports that Saint Lucia refuses Iranian applicants outright, a restriction that appears nowhere on the program’s own site. The rule deciding an Iranian application exists somewhere the applicant cannot read it.
Vanuatu
Vanuatu’s Citizenship Office publishes no eligibility page naming any country. Its legislative framework page links the Citizenship (Development Support Program) Regulations Order No. 33 of 2019 and Orders No. 38 and 39 of 2020, all as scanned PDFs with no text layer.
Whether a restricted-nationality clause exists inside those orders is not something a reader can check from the published documents.
Cambodia and Sao Tome and Principe
Cambodia’s nationality law bars nobody by nationality. It says instead that naturalization is “not a right of the applicant, but only a favour of the Kingdom of Cambodia”, which puts every applicant at the government’s discretion without telling any of them where the line falls.
The sub-decree that created the investment route is published only as a scanned image, so whether it adds a nationality rule of its own is not something a reader can check.
Sao Tome and Principe wrote the power to exclude into its law and has not used it. Article 17 of its 2025 decree-law, headed Limitacoes por Nacionalidade, lets the Government declare applicants inadmissible if they come from countries under sanctions it has ratified, or from countries without working judicial cooperation.
That article names no country. It defers the list itself to a resolution of the Council of Ministers, and no such resolution appears to have been published.
A restricted list can reverse overnight
On March 10, 2026 IMI reported that Vanuatu had added Russia and Sudan to its restricted list. The Citizenship Office withdrew the addition the next day, calling its own memo a clerical error.
Grenada produced the same pattern in December 2023. A government minister told the Senate the program was open to every nationality, and Grenada’s unit corrected its own government minister the next day, confirming that Russia, Belarus, North Korea, and Iran remained barred.
That list of four had grown to seven by the following March, and Iran had moved from a flat ban to a conditional one.
Antigua and Barbuda shows the slower version of the same problem. Cabinet last updated its list in February 2020, the circulars on Russia, Belarus, and Ukraine followed in 2022 without ever reaching it, and the Ukrainian suspension was lifted two years later without reaching it either.
What is moving the lists
The European Union changed the stakes in December 2025. Regulation (EU) 2025/2441, published in the Official Journal on December 10, 2025 and in force from December 30, makes an investor citizenship program a stand-alone ground for suspending a country’s visa-free access to the European Union.
On June 25, 2026 Magnus Brunner, the European Commissioner for Internal Affairs and Migration, wrote asking for a phase-out by June 1, 2028. Antigua and Barbuda confirmed receiving that letter, and says the other four Eastern Caribbean programs received one as well.
The letter is a request, and it is not law.
The United States moved the other way. Leaked drafts in March and June 2025 named several citizenship by investment countries between them, among them Saint Kitts and Nevis, Saint Lucia, Vanuatu, and Cambodia.
The proclamation issued on December 16, 2025 dropped every one of those, and retained citizenship-by-investment language for Antigua and Barbuda and Dominica, which the drafts had named as well.
Caribbean governments answered with a shared regulator. All five signed the agreement establishing the Eastern Caribbean Citizenship by Investment Regulatory Authority in September 2025 and enacted it domestically.
That authority had not begun work by the time of publication.
If your nationality appears on one of these lists
Read the program’s own page before you read anybody else’s summary. Those five pages are the documents that bind the unit deciding a file.
The exception paths deserve more attention than the bans. Three of the four Caribbean lists let a restricted national qualify on time spent outside the country, and Grenada names the eight jurisdictions where that residence counts.
Where no list exists, the answer comes from the unit and not from the website. A program that publishes nothing has promised nothing either, and Jordan’s Syrian and Iraqi applicants show that an unpublished policy can work in an applicant’s favor.
Four of the five programs that publish a list are Eastern Caribbean, and all four fall inside the group the Commission asked to phase out by June 1, 2028. If that date survives, most of the documented part of this market goes with it.
