Opinion: CBI Should Not Be Bespoke, Special, or Exclusive: Here’s Why 

Brian Greco
Istanbul

CBI is not a luxury, bespoke privilege. It’s a product. The clearer and more reliable the offering, the stronger the market.

In the wake of the European Court of Justice’s (ECJ) ruling on Malta’s citizenship by investment (CBI) program, the industry stands at a dangerous crossroads.

A month like this should make one thing very clear: We need to reset our assumptions regarding CBI. The industry needs to stop pretending CBI is some kind of elite, clubby rite of passage. It’s not. And more importantly, it shouldn’t be.

As I’ve written before, CBI is the win-win-win of globalization. It’s a tool for countries to attract capital, for investors to achieve mobility and security, and for the global economy to become more fluid, decentralized, and fair. 

But in recent years, and especially with the EU debate, I’ve argued that Citizenship by Investment 1.0 is dead. CBI must evolve, not devolve. 

Let’s be blunt: CBI is a product. It should be treated like one. The entire appeal of CBI is that if you meet the criteria, pay the fee, furnish clean documentation, pass a due diligence check, you get citizenship. End of story. That’s what makes it appealing. 

Imagine buying an iPhone, but instead of just paying $1,999 and getting the product, you also had to pass some vibe check, convince a panel of judges you were a “genuine user,” or somehow look creative enough so they allow you to unlock the features. Sound absurd? That’s where CBI is heading if we let this Malta ruling define the narrative. 

CBI is not a Rolls Royce or a Pagani. It’s not a luxury art piece. It’s not some inner-circle VIP experience reserved for people with the right look or pedigree. It’s a product. A structured, repeatable, legal process that provides citizenship in exchange for investment. 

If CBI loses its predictability, if the outcome becomes subjective, murky, or political, then why would clients invest at all?

Why should they go through the cost and trouble? Why should agents and advisors sell this solution with any confidence?

At this point, a savvy global citizen is better off just sitting in Canada for three years and getting a passport the old-fashioned way, with virtually no scrutiny.

If CBI is no longer a product, it becomes a club again. And clubs exclude people, especially people from the Global South. That is the opposite of what CBI was meant to disrupt.

Austria, often held up by many as the ideal, is not the benchmark. That’s citizenship by exception, not CBI.

What we are seeing now is a “Monaco-ization” of CBI: programs being remade in the image of some elite, opaque, multi-year, multi-million-dollar naturalization gauntlet. Massive fees, extreme documentation, physical presence rules, and still a vague, distant hope of approval.

The ECJ’s ruling on Malta is a bureaucratic theater masking as a legal judgment. It’s a misreading of citizenship law that ignores the reality that economic participation is a genuine link to a state.

Malta had already watered down its program and bloated it with concessions before the case ever went to court.

It was already more of an accelerated naturalization scheme than a true CBI product. It had already reformed. But to the EU, it’s never enough. As I say, all sticks and no carrots.

The irony is that anyone trying to commit financial crimes would never use CBI. The programs are some of the most vetted immigration channels in existence. There are 100 times more checks than what your average migrant faces before becoming a citizen of Germany, Belgium, or Sweden.

Every day, people abuse the EU residency and naturalization process by faking jobs, submitting fake pay slips, and exploiting loopholes; yet that’s somehow fine. So many complaints about “backdoors” yet the front door remains unguarded.

The bottom line is that the EU just doesn’t like the idea of rich, vetted outsiders entering their precious union on their own terms. So it makes up false threats, inflated risks, and politicized slander.

The ECJ ruling was not about protecting the integrity of citizenship. It was about gatekeeping some imagined concept of European citizenship. Quite ironic, I’d say, considering the demographic changes already at play on the continent.

This has been a horrible month for the CBI industry. Europe’s hostility, the misleading “Trump Card” optics to make programs look like clickbait headlines or competitions (yet questionably ever to go live anyway), and the strategic confusion about what CBI is actually for have all collided in a perfect storm.

We need to get back to basics. CBI is not a luxury, bespoke privilege. It’s a product. The clearer and more reliable the offering, the stronger the market. That’s how countries raise real money, and that’s how the industry can serve real clients who have needs, visions, and mobility goals that do not want to have to deal with moving goalposts.