Bulgaria Has Revoked the Citizenships of 17 CBI Investors for Failing to Make or Maintain Investments

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Bulgarian caretaker Justice Minister Krum Zarkov today told the country’s Parliament that the government had revoked the citizenships of at least 17 participants in the country’s erstwhile semi-direct citizenship by investment program in the period since abolishing the scheme in March last year, according to the Sofia Globe.

Among the 17 individuals whose citizenships have been rescinded were four Russians, four Kazakhs, four Egyptians, three Chinese, two Pakistanis, and one Jordanian.

After the program’s closure, the government had discovered that a number of investors who had initially qualified as residents and later citizens on the basis of investments in approved asset classes had not actually made the requisite investments. Since then, the State Agency for National Security and other institutions have been combing through files to learn the true extent of the problem.

Already a year ago, in our May 2022 IMI Private Briefing, we alerted our Pro members to the risk of precisely this turn of events:

Bulgaria’s recently closed semi-direct citizenship program was not particularly popular and had lax oversight from authorities. A number of individuals obtained citizenship in the country but divested before the prescribed minimum time had elapsed, not expecting the government to do anything about it. Somewhere between 100 and 200 individuals are estimated to have received citizenship through this route, many of which would be affected. Our source for this news indicates it’s “a done deal, policy-wise, and they are going after many CBI applicants.”

Considering that the number of individuals who obtained citizenship through investment in Bulgaria numbered only 100 to 200, the 17 instances of malfeasance uncovered represent a startlingly large share of the total, indicating the impropriety may not have been limited to a few cases but, instead, may have been systemic. If the fraudulent behavior were confined to a few isolated incidents, one might chalk it up to individual rogue investors. The large number of such examples uncovered thus far, however, indicates the problem originates at the advisor level. This raises serious questions about the conduct of these investors’ investment migration consultants.

And the number of revoked citizenships may yet rise further: Zarkov told the national assembly that security agencies are still reviewing cases and that “any violations found will trigger the appropriate actions.”

He also hinted family members of the offending investors could also see their citizenships revoked:

“Regarding the family members of these investors, they are assessed on a case-by-case basis to see if the application for citizenship was made on a non-existent legal basis. The problem with the golden passports has been resolved.”