$500k Threshold “Fair and Competitive”: Specialists on How They Would Design Argentina’s CBI Program

Moustafa Daly
Cairo

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As Argentina’s category-defining CBI program takes shape, three industry experts weigh in on how to design it for maximum impact and benefit.

In May, Argentina announced plans to become the first Latin American country to launch a Citizenship by Investment (CBI) program, news that IMI had accurately predicted last year in its Q3 2024 Private Briefing.

Last week, the government approved the CBI framework through Decree 524/2025, establishing its legal foundation.

The decree didn’t define important features such as the exact investment amount and eligible sectors. Future regulations are set to clarify these critical points.

When it comes online, Argentina’s program will be playing in a league of its own. Compared to current industry offerings, Argentine passport holders enjoy a degree of global mobility only comparable to peers in Western Europe and the US, and have settlement rights in nine South American countries through the Mercosur Residency Agreement.

This potentially positions Argentina to set a new standard for investment migration programs, but it remains to be seen whether Argentina can craft a program that creates a meaningful economic impact while avoiding the pitfalls that have undermined similar programs elsewhere.

As the finer details remain pending, we examine what it could take to make this program a success through the perspectives of three industry experts.

A Framework for Real Impact

It remains uncertain whether Argentina’s model will be limited to active investments or if it will also incorporate real estate and donation options, which are typically popular among investors in other CBI programs.

Favio Drivet, founder of Drivet International Law Firm, notes that he expects the government to design a program that prioritizes genuine economic development rather than speculative capital inflows.

“Argentina welcomes foreign capital that helps build rather than just buy,” he explains, adding that the government’s challenge will be to create an efficient, transparent framework that attracts investors, establishes clear criteria for evaluating project eligibility, and ensures investments align with national priorities.

He points to effective inter-agency collaboration as a critical factor in maintaining the program’s credibility and viability.

David Lawrence Lincoln, CEO of Lincoln Global Partners, also underscores the need for investments to directly benefit local communities while also granting investors “flexible minimum stay requirements and compelling investment options.”  

He advocates for focusing on labor-intensive sectors such as agriculture, energy, and rural tourism, explaining that a sustainable program that “sits well” with Argentines must “genuinely contribute” to the local economy.

Excluding Donations and Open Real Estate: A Gamble?

If the program completely excludes real estate and donation, this may limit its appeal. But Drivet supports such a scenario which he says could help Argentina design a program that prioritizes the national economy’s interest.

Lincoln agrees but suggests that certain types of real estate investments, such as refurbishing urban properties or developing tourism infrastructure in underserved regions like Patagonia, could benefit local communities without jeopardizing housing affordability in high-demand areas.

“There are plenty of rundown buildings in Argentina’s many city centers which could use some investment and renovation,” he adds.

It remains unclear if real estate will be a qualifying asset class for the program.

Still, he warns that allowing unrestricted real estate purchases across the board could lead to housing tensions in sought-after districts such as Palermo, Recoleta, and San Telmo, where local residents might be priced out.

Philippe A. May, founder of EC Holdings, argues that demand for Argentina’s program will depend more on its competitive pricing and the strength of its passport rather than the investment vehicle.

“What matters to investors is the opportunity for great mobility and access to Mercosur, along with a credible and transparent process,” he explains.

Target Sectors: Where Investments Could Matter Most

The government has yet to finalize the list of eligible sectors, but Drivet says that he’s already receiving “numerous enquiries from international investors” interested in applying for the program. He says some of his clients come to him with “fully-developed projects” in technology, renewable energy, agro-industrial production, and knowledge-based services.

As such, he suggests that the government should capitalize on investors’ appetite for entry by offering tailored incentives for investments in underdeveloped provinces to promote equitable regional growth.

Lincoln says that sectors like energy and mining, which are currently booming under President Milei’s reform agenda, are likely to play a central role.

He also points to Argentina’s sizable wine industry and sustainable tourism as areas with high growth potential.

US$500,000: Competitive Threshold?

At US$500,000, Argentina’s minimum investment requirement is competitive by global standards. May sees the threshold as a “very attractive offer for investors,” yet argues that Argentina could generate “higher revenues in absolute terms” if the threshold is higher.

Still, he sees the touted threshold as “fair and competitive” given the country’s immense “geopolitical relevance and economic potential.”

Lincoln also sees the pricing as highly competitive, saying that Argentina might become “the ultimate Plan B” for many global investors, highlighting its strong passport and reputation as a “haven in times of global unrest and turmoil.”

Incoming EU Scrutiny?

Argentina’s CBI program could reshape the industry, but will the EU’s increasingly restrictive stance on CBI programs pose a challenge? Lincoln acknowledges potential tension but believes Argentina is unlikely to face the same scrutiny the EU has applied to the Caribbean and Malta.

“Argentina is a G20 country with 45 million people, strong institutions, and a European cultural identity,” he says, adding that its reputation and geopolitical weight make the likelihood of restricting its citizens’ EU visa-free access a “somewhat absurd” notion unless the program is “poorly structured.”

May does not anticipate the EU will “kick up a fuss with Argentina,” though he does not rule out the possibility that “some far-left MPs could make some noise, albeit to [minimal] effect.”

He further argues that the EU prefers to engage with countries “en bloc,” which he says reflects its broader tendency to encourage regional integration and supranational blocs over national sovereignty, effectively supporting its own model. May adds that this approach aligns with its desire for third countries to treat all EU citizens uniformly, making it unlikely the EU would “single out Argentina” and treat its citizens differently from other Mercosur countries

Implementation: The Key to Success

The program’s potential is clear, but its success will depend heavily on implementation. The government said that its newly established Agency for Citizenship by Investment Programs will play a central role in efficiently evaluating applications and set clear criteria and processes.

Lincoln calls for robust monitoring and clear guidelines to ensure credibility and minimal red tape, emphasizing the need for flexibility in policy design to accommodate different types of investors.

If the program is “implemented transparently and efficiently,” Drivet sees an opportunity for Argentina to “set a new benchmark” in the investment migration industry.