Choosing an agent is the single most consequential decision an applicant makes in a citizenship by investment (CBI) process. The wrong one can cost you the application, the investment, or both.
In April 2025, Saint Kitts and Nevis revoked thirteen citizenships after investigators found the marketing agents had sold the program below statutory minimums. Identifying the right agent is harder than most applicants assume.
CBI programs are not uniform. Some operate through dedicated citizenship by investment units (CIUs) that license agents, publish official lists, and revoke authorization for misconduct. Others run their programs through ministries with looser oversight and no central registry of agents.
The checklist below is general guidance, not a scoring system. Use it to surface the right questions to ask, the right documents to demand, and the right concerns to raise before committing capital.
Licensing and track record
In licensed regimes, the official list is the only list that matters. In open markets, you are looking for verifiable history through bar admissions, regulatory registrations, and track record.
1. The agent is not on the official approved-agent list, where one exists.
The five Caribbean CBI programs, São Tomé and Príncipe, Vanuatu, and Nauru publish current lists of authorized agents and, in several cases, separate lists of international promoters. Absence from a published list typically means one of three things: the agent lost authorization, never held it, or is operating as a sub-agent under someone who does. (IMI’s aggregated index of approved and blacklisted agents is a useful starting point.)
In open-market programs, no central list exists, and this item does not apply. The items on documentation, money handling, and accuracy below carry more weight there.
2. The agent has refused or avoided showing proof of licensing or credentials when asked.
Bar admissions, professional registrations, and government accreditations are documents licensed practitioners hand over without hesitation. Reluctance or refusal usually means the credentials do not exist, do not match the claim, or would not survive direct verification.
3. The firm has no verifiable physical office address.
A PO box or virtual office is not, on its own, disqualifying. Combined with vague answers about who actually works there, it usually indicates a firm with no operational presence behind the website.
4. The firm operates under multiple names or rebrands frequently.
Patterns of dissolved entities and renamed websites usually trace back to reputational problems the operator wanted to leave behind.
Sales tactics and promises
Investment migration runs on long timelines and serious capital. Anyone selling it like a timeshare is selling something else.
5. The agent manufactures urgency.
“The price goes up next week” and “this allocation closes Friday” are negotiation tactics imported from industries the practitioner should have left behind. Real program changes come with public announcements and notice periods, most of the time.
6. The agent guarantees approval.
No legitimate practitioner can do this. Approval rests with the CIU or relevant ministry, which conducts its own due diligence. An agent who guarantees the outcome is either lying about the process or, more rarely, suggesting they have improper influence over it.
7. The agent promises faster processing because they “know people in the government.”
Either the claim is false, or the agent is suggesting a corrupt relationship. CIU processing times are functions of workload and due diligence depth, not of the relationships individual agents hold with officials.
8. The agent promises returns on the investment without putting them in writing.
Some routes (real estate, qualifying funds) involve genuine investment performance. If projected returns exist, they belong in a prospectus or written investment memorandum, not in a sales call.
Documentation and money handling
Paper trails protect both sides. Their absence almost always protects only one.
9. The agent refuses to provide a written engagement letter.
Without one, you have no enforceable agreement on scope, fees, deliverables, or refund terms. The engagement letter is the document that distinguishes professional service from a verbal arrangement; without it, any later dispute over what was promised, paid, or delivered has no anchor.
10. The agent refuses to provide an itemized fee breakdown.
You should see, in writing, what portion goes to the government, to due diligence providers, to the agent, to lawyers, and to any other party. Without an itemized breakdown, the total figure is just a number; with one, each component can be checked against the program’s published rates.
11. The agent avoids putting any commitments in writing.
Recording timelines, fee structures, and process steps via email is standard practice. Reluctance to do so is rarely innocent.
12. The agent asks you to wire funds to a destination you cannot independently verify.
In licensed regimes, government contributions go to designated official accounts published by the program authority. Fund subscriptions, developer payments, and escrow flows have their own legitimate channels.
Open-market programs route the investment differently. Turkey channels real estate purchases through Turkish banks under central bank monitoring, with the property seller as direct counterparty and no government escrow. The verification problem there is also different: Confirming that the property exists, that title transfers properly, and that the valuation independently supports the program threshold.
Some structures are unusual without being improper. Vanuatu has accepted cryptocurrency contributions routed through licensed intermediaries; some agents hold equity in the developments they recommend; some firms pool client payments through escrow facilities for regulatory reasons. None of this is automatically a problem.
The problem is not the destination of the wire but the absence of documentation around it. A written, traceable chain showing where the money goes, who holds it, and how it reaches the program’s qualifying account is what separates an unusual but legitimate structure from an unsubstantiated one. Without that chain, what nominally appears as an unusual flow becomes indistinguishable from an improper one.
13. The agent offers suspiciously large discounts, or the government fees quoted do not match the published rate.
Government and due diligence fees are publicly listed; agents have no authority to discount what they do not control. A “discount” on government contributions is the agent absorbing fee margin, or, in worse cases, intending not to remit the full amount.
Real estate financing schemes have driven some of the most damaging scandals in the Caribbean CBI market. Investors arrive with quotes as low as $70,000 to $100,000 against statutory minimums of $200,000 or more, with developers showing the unit full payment through offshore bank accounts the unit cannot effectively audit.
In April 2025, Saint Kitts and Nevis revoked thirteen citizenships and blacklisted two international marketing agents who had marketed the program below statutory minimums and offered false “special discounts.” The investors lost their citizenship and their investment, with no refund.
Turkey’s $400,000 real estate threshold is statutory and non-negotiable, but agent and developer markups stacked on top can be substantial. The citizenship-buyer property market often trades above the open market for identical units. The main issue with that is the property failing official evaluation, and hence not qualifying for citizenship. The right question in open-market programs is not “what’s my discount” but “what would this property sell for to a non-citizenship buyer, and would it still qualify.”
Advisory discipline
Good agents run an intake process before recommending anything. Bad agents run a sales pitch.
14. The agent pushes one specific program without exploring your profile.
A serious initial consultation covers your tax residency, family situation, travel patterns, source of funds, professional commitments, and what you actually want from the second status. If the program recommendation arrives before the questions, the recommendation is about the agent’s commercial relationships, not about you.
15. The agent presents a single project as the obvious or only choice.
Each Caribbean CBI program approves multiple qualifying real estate developments alongside its donation route, and several offer additional alternatives such as public benefit or fund options.
An agent steering every client toward the same project, regardless of profile, is operating closer to a developer’s sales arm than to an independent adviser. Project economics, exit terms, developer track records, and program-status risk all vary. Matching them to your goals is the work.
16. The agent discourages you from seeking independent legal or tax advice.
A practitioner confident in their work welcomes a second opinion. One who actively warns against it is protecting something.
17. The agent cannot or will not provide a detailed process breakdown.
You should receive a written timeline of the steps from engagement to passport, including who does what at each stage. Vagueness here usually means the agent does not know the process well enough to describe it, or does not want you to know it well enough to question them.
18. The agent suggests shortcuts on source-of-funds documentation.
Source of funds is the spine of every modern CBI application. Suggestions to “simplify,” to leave certain transactions out, or to use an alternative narrative about the funds’ origin are the most common application rejections and a precursor to citizenship revocations five and ten years later.
Accuracy and strategic depth
The best agents are encyclopedic about programs, including the parts that complicate the sale. Bad ones are vague where it matters most.
19. The agent makes claims that contradict official government websites.
The CIU, immigration authority, or program ministry publishes the rules. If your agent’s pitch deviates from the official source, the official source is right.
20. The agent refuses or evades requests to point you to official government sources.
“I’ll handle that for you” is not an answer when you ask for a link to the program legislation or the CIU’s approved-agent list. A legitimate practitioner sends the link.
21. The agent has not addressed post-approval obligations.
Citizenship and the tax positions that follow are not granted once and forgotten. Reporting obligations, dual-citizenship restrictions in the home country, and the practical mechanics of using the new passport all attach to the new status. An agent who stops talking after the document arrives leaves the applicant alone for the decade that matters most.
22. The agent has not discussed what happens if a program is suspended or shut down.
Cyprus, Bulgaria, and Malta have all ended their CBI programs in recent years, the latter following an April 2025 European Court of Justice ruling. A serious adviser walks you through what suspension would mean for your investment, your application status, and any acquired rights, before you commit.
23. The agent has not disclosed all sub-agents, promoters, and intermediaries.
Your file may pass through introducers, marketing partners, sub-promoters, and lawyers in different jurisdictions before it reaches the CIU. Each is paid by someone. You are entitled to know who is in the chain and how each party earns its fee.
How to use this list
Used carefully, the items above help surface where to ask harder questions and where to demand more documentation. A red flag is a prompt for further investigation, not an automatic disqualification. Where the agent’s response to your questions does not satisfy you, the red flag stands.
For a structured, interactive version of these and other criteria, the Agent Risk Checker is one of the tools available for IMI Sovereigns. Current official lists across the licensing jurisdictions live in the Approved and Blacklisted CBI Agents database. The CBI Transparency Index ranks programs themselves on the disclosures and safeguards they offer applicants.
This article is general information for educational purposes only and does not constitute legal, tax, investment, or immigration advice; readers should consult appropriately licensed professionals in the relevant jurisdiction before acting on its contents.
