Red Flags: How to Spot CBI Scams Before It’s Too Late

Investment migration, sadly, has its fair share of scams, which could lead to loss of money, or worse. Here is how to spot some of them.
IMI
• Amman

The investment migration market faces a growing threat that has already cost investors hundreds of thousands of dollars while jeopardizing their citizenship prospects. 

Fraudulent Citizenship by Investment (CBI) schemes have proliferated globally, leaving victims with revoked citizenships, forfeited investments, and potential legal consequences.

These scams exploit investors’ desire for alternative citizenship through seemingly legitimate channels. The financial damage extends far beyond the initial loss. Citizenship revocation results in the complete forfeiture of upfront payments, often two to three times the attempted savings from fraudulent discounting schemes.

CBI programs worldwide have become prime targets for sophisticated fraud operations, with Caribbean jurisdictions facing particular vulnerability.

The proliferation of these schemes reflects broader challenges within the investment migration sector. Government oversight varies significantly between jurisdictions, creating gaps that fraudulent operators exploit. Meanwhile, investor education remains insufficient, leaving many vulnerable to sophisticated deception tactics.

Webinar banner

The $70,000 Financing Trap

The most prevalent scam involves unauthorized financing arrangements that circumvent official investment requirements. These schemes allegedly allow investors to pay as little as $70,000 to $100,000 upfront instead of the required $200,000 minimum investment for Caribbean real estate options.

Developers operating these schemes use foreign bank accounts outside Caribbean government jurisdiction to deceive Citizenship by Investment Units (CIUs) about full payment receipt. The practice creates artificial paper trails suggesting complete investment while investors maintain significant outstanding balances.

“Caribbean governments have repeatedly published notices that unauthorized discounting is illegal,” explains Anastasia Barna, CEO of One World Migration. “Yet investors continue falling for these schemes, often losing everything when citizenship gets revoked.”

Anastasia Barna at IMI Connect Cairo speaks about the risks of illegal financing

The consequences prove severe and multifaceted. Citizenship revocation results in complete loss of upfront payments, effectively doubling or tripling investors’ financial losses compared to legitimate program participation. Additionally, revoked applicants may face restrictions on future CBI applications across multiple jurisdictions.

Some developers operating financing schemes never intend to complete construction projects, essentially selling non-existent properties. These fraudulent operations collect initial payments before disappearing, leaving investors with neither citizenship nor recoverable assets.

events banner

Investments Outside Approved Lists

Fraudulent operators sometimes promote investment opportunities that appear legitimate but lack official government approval. These schemes target investors unfamiliar with specific program requirements and approved investment lists.

CBI programs maintain strict lists of approved real estate developments and economic diversification fund options. Investments outside these approved categories automatically disqualify applications, regardless of investment amounts or developer reputations.

The approval process involves rigorous government vetting of developers, projects, and financial structures. Unapproved investments often reflect developers’ inability or unwillingness to meet regulatory standards, creating additional risks for investors.

Joseph Rowe Law emphasizes the importance of verification through official government channels. “Every legitimate investment option appears on government-published lists. Investors should never rely solely on developer representations about approval status.”

Below-Threshold Pricing Red Flags

Investment thresholds serve as fundamental program parameters that fraudulent operators routinely ignore or misrepresent. Programs establish minimum investments and publish them on official websites.

Schemes offering citizenship for significantly lower amounts operate outside legal frameworks, regardless of marketing sophistication or apparent legitimacy. These operations often target price-sensitive investors through aggressive marketing campaigns emphasizing affordability over compliance.

The mathematical impossibility of legitimate discounting should alert potential investors to fraudulent operations. Government fees, due diligence costs, and administrative expenses alone approach or exceed fraudulent operators’ total pricing.

Fake Government Representatives

Sophisticated fraud operations often masquerade as official government programs or authorized representatives. These schemes exploit investors’ trust in governmental authority through professional websites, official-looking documentation, and government-style branding.

Legitimate CBI programs operate through clearly identified government agencies with official websites, contact information, and published procedures. Authorized agents maintain official licenses and appear on government-published lists of approved representatives.

Verification requires direct contact with official government sources rather than reliance on third-party representations. Governments maintain updated lists of authorized agents and approved service providers accessible through official websites.

EU Citizenship for $50,000 and Other Fantasies

Investment migration scams frequently exploit investor psychology through promises of exceptional value or exclusive opportunities. These schemes position fraudulent offers as limited-time deals or insider arrangements unavailable through conventional channels.

Fraudulent operations commonly promote “EU citizenship” without specifying any member state, capitalizing on investor confusion about European programs. The European Union currently has no active citizenship by investment programs following Malta’s termination of its program and Cyprus’s closure of its scheme in 2020.

Claims of obtaining EU citizenship for $50,000 or similar amounts invariably represent scams rather than legitimate opportunities. European residence programs that do exist require actual physical presence, substantial business investments, or both. These programs never involve simple capital transfers leading directly to citizenship. 

The investment migration market operates within established economic parameters that make certain promises mathematically impossible, with legitimate programs reflecting genuine costs of due diligence, government processing, and economic contribution requirements.

When Merit Programs Masquerade as Investment Routes

Some fraudulent schemes exploit confusion between CBI programs and exceptional citizenship provisions available through citizenship by merit or presidential decree. These arrangements promise CBI-style processing for merit-based applications that follow entirely different procedures and criteria.

Merit-based citizenship typically requires extraordinary contributions to national development, exceptional achievements, or strategic importance to national interests. These programs operate through discretionary government decisions rather than standardized investment criteria.

Investors participating in misrepresented merit programs face approval uncertainty and potential investment losses when applications fail to meet unstated criteria. Recovery of investments becomes complicated when programs operate outside established CBI frameworks.

Pay Now, Apply Later Demands

Legitimate CBI programs follow standardized payment schedules that protect investors through conditional arrangements. Real estate investments typically require limited deposits before approval, with full payment due only after citizenship approval.

Fraudulent schemes often demand full upfront payments before application submission or during processing phases. These arrangements eliminate investor protections and create opportunities for fraud through premature fund collection.

The payment timing serves as a crucial differentiator between legitimate programs and fraudulent operations. Legitimate programs align payment schedules with approval milestones, while scams prioritize immediate fund collection regardless of approval prospects.

Inflated Valuations in Turkey and Egypt

Real estate-based CBI programs require independent property valuations to ensure investment minimums are met. Fraudulent schemes in markets like Turkey and Egypt exploit inadequate valuation processes or present manipulated appraisals to unsuspecting investors.

Pre-purchase valuations protect investors from overpaying for properties that fail to meet program requirements. Properties valued below minimum thresholds disqualify applications regardless of purchase prices paid.

Egypt recently expanded qualifying CIP real estate to the open market

The valuation requirement reflects government efforts to ensure genuine economic contributions rather than artificial transactions designed to circumvent investment requirements. Professional valuations provide investor protection and program integrity.

Protecting Against Investment Migration Fraud

Investors considering citizenship by investment programs should engage qualified immigration attorneys and licensed investment migration consultants who maintain proper regulatory credentials in relevant jurisdictions. 

Professional advisors can verify program legitimacy, confirm developer approvals, and review documentation before financial commitments occur.

Due diligence extends beyond professional consultation to include direct verification with government agencies administering CBI programs. 

Official government websites publish current program requirements, approved investment options, authorized agent lists, and program updates that investors should review independently.

Disclaimer: This article provides general information about citizenship by investment fraud for educational purposes only and does not constitute legal, immigration, or investment advice. Investment Migration Insider does not provide immigration services, legal representation, or consulting of any kind. Citizenship by investment requirements and regulations vary by jurisdiction and change frequently. Readers must consult qualified, licensed immigration attorneys or authorized migration agents in relevant jurisdictions before making any financial commitments or application decisions. Investment Migration Insider makes no representations regarding accuracy or completeness of information and disclaims all liability for decisions made based on content herein. Mention of specific companies, practitioners, or programs does not constitute endorsement or recommendation.

Subscribe to the IMI Newsletter

Get investment opportunities, policy updates, and high-signal news from directly in your inbox each week.

As a special gift, we’ll even send you a free copy of 13 Special Regimes for Low-Tax Living in High-Tax Europe.

13 Special Regimes for Low-Tax Living in High-Tax Europe

Trusted by 300,000+ investors, professionals, and global citizens