The number of locally accredited citizenship by investment program agents, among the programs that mandate such accreditation, has grown by nine agents in the four months that have passed since the last count in August and by 49 since the closure of Cyprus’ program.
Global CBI agent ranks have swelled from the nadir of 307 it reached immediately upon the November 2020 closure of Cyprus' CIP, which had the largest absolute number of agents (more, in fact, than all other CIPs combined), to 356 today. That represents a 16% year-on-year expansion.
Licensees for Malta's MEIN and MPRP programs now number 79, up from 37 in March this year, the highest rate of growth among all programs, both in relative and absolute terms. Vanuatu's roster grew by three agents and Grenada's by one, while there were no changes to the numbers among other programs.
Saint Kitts & Nevis, the "grandfather" of citizenship by investment, remains the most CBI agent-dense country; nearly 0.1% of the country's inhabitants are CBI agents.
Blacklists growing (slowly)
Finding themselves with few other means by which to prevent agent malfeasance abroad, three citizenship by investment programs have recently taken to publicly pillorying CBI promoters engaged in unlicensed behavior (such as selling CBI programs below the government-mandated minimum) by naming them in official blacklists.
|Saint Kitts & Nevis CIP Blacklist||Malta MEIN and PRP Blacklist||Dominica CIP Blacklist|
|Alt Air Travel & Tourism||Interbest International Investments LTD||Unican Immigration|
|Alt Group Citizenship and Residency||Malta Passport|
|Bye Bye Group Citizenship and Residency||Invest Immigration|
|Dina Sky Travel|
|Take Off Company-Travel Co.Ltd|
|Vision Immigration Advisors|
|Count: 12||Count: 3||Count: 1|
The three government Units that keep public blacklists - those of Saint Kitts & Nevis, Dominica, and Malta - currently list 17 companies combined, a number that has grown by just one additional name since October. [Update Dec. 6th, 2021: The 17th blacklisted firm has since been removed from the list.] That number, say seasoned industry veterans, is "way too low":
“With all we know about the trickery happening with the real estate options in some countries, for example, how can a program have just one blacklisted firm? That can’t be right. I could name five or six companies, just offhand, that should be blacklisted for gross misbehavior," said Philippe May in October.
Sam Bayat, another multi-decade doyen of the industry, was of the same opinion: "To see just a handful of companies being blacklisted while we know so many are operating improperly with impunity; it’s sad,” said Bayat in a comment for the same article.
Their reactions to the apparently low number of blacklisted companies compared to the observed high rate of unauthorized discounting instances occasioned an interview with Les Khan, head of Saint Kitts & Nevis' CIU, whose bureau has been the most prolific blacklister in the business.
During an exclusive interview with IMI in October, Khan vowed to take action against illegal discounters by blacklisting them, and even encouraged those who observed such behavior to report it directly to himself.
“First things first," said Khan in the interview. "Anyone who advertises a price that is not the government-regulated price of US$200,000, US$400,000 [real estate], or the fund – of US$150,000 for a single applicant – is illegal, as far as I’m concerned, if they are advertising. They will get blacklisted.”
The Saint Kitts & Nevis CIU's blacklist, however, has remained steady at 12 named companies since then.
Christian Henrik Nesheim is the founder and editor of Investment Migration Insider, the #1 magazine - online or offline - for residency and citizenship by investment. He is an internationally recognized expert, speaker, documentary producer, and writer on the subject of investment migration, whose work is cited in the Economist, Bloomberg, Fortune, Forbes, Newsweek, and Business Insider. Norwegian by birth, Christian has spent the last 16 years in the United States, China, Spain, and Portugal.