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NBLO: Bulgaria’s Investigation of Improperly Obtained CBI Citizenships a Welcome Development


The Bulgarian State Agency for National Security and Prosecutor General have recently published statements about their investigation into violations of Bulgarian CBI law and proposed the removal of citizenship from several individuals granted citizenship on the CBI basis.

Seen properly, this is a welcome announcement:

  1. it shows observance of the rule of law;
  2. it protects Bulgaria against political pressures that rely on the argument that it is the soft underbelly of Europe and that its processes are not robust; and
  3. it improves the value of Bulgarian citizenship for the vast majority of citizen-investors who are law-abiding.

In general, naturalized Bulgarians may have their citizenship revoked in several ways, including:

  • where a sentence for a grave criminal offence against the Bulgarian State against a naturalized citizen becomes effective;
  • where legal proceedings find that information supplied by the naturalized citizen and which serves as grounds for acquisition of Bulgarian citizenship were false; and/or
  • have concealed information or facts which, had they been known, would have been a ground for refusal of Bulgarian citizenship.

Immigrant investors are required to maintain the investment, regardless of whether the investor chooses the Standard Track (~six years and one tranche of ~ €513,000) or the Fast Track (~two years and two tranches, each of ~ €513,000), throughout the entire process of application. Fast track investors are required to maintain an eligible investment for an extra two years after grant.

Based on the information published, the three individuals whose citizenship has most recently been proposed for removal are said to have failed to maintain their investments at two relevant time points: at the date on which they were recommended and would have otherwise qualified and throughout the two-year period that followed (which applied to them as fast-track applicants).

Read also: Proposed Changes to Bulgarian Citizenship Law Would Make Program Similar to EB-5

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At the same time, these individuals are three out of more than a hundred who have received approvals from the Bulgarian Ministry of Justice for naturalization on a CBI basis since 2018. These investors would have opportunities to make representations to the authorities and may indeed be making such if they have grounds for doubt that the findings are either substantively or procedurally incorrect.

Moreover, if these individuals lost their original citizenships and are solely Bulgarian citizens at this time, the Bulgarian state would generally be unable to strip them of Bulgarian citizenship.

If the investments were not maintained, it is possible that the investors were not well-advised on their obligations. It is also vitally important for investors wishing to avoid the opprobrium involved in being suspected of such violations – and the frustrations involved in the loss of citizenship – to be advised by professionals including lawyers whom they have independently retained.

If an investor does not have a clear control over their investment or does not understand in detail how the investment is structured, there is a heightened risk that their investment may either not be made properly, or terminated prematurely exposing them to the above difficulties.

As professionals who adhere to high standards and have considerable experience in immigration and nationality matters, NBLO welcomes the news that the Government of Bulgaria is policing its CBI scheme to ensure that it is maintained beyond reproach.

Ivan Petrov AuthorSubscriberParticipant

Having studied, lived, and worked in China for almost 8 years, Ivan has strong intercultural skills and extensive knowledge of China and East Asia. Prior to joining NBLO, Ivan was a lecturer in the Chinese department at the University of Plovdiv, Bulgaria. His personal interests include current affairs and social media. He is fluent in English and has professional knowledge of Mandarin Chinese.