Argentina’s Ministry of Economy has recommended awarding its citizenship by investment (CBI) master agent contract to Asesorías Legal Advisor Limitada – UT Consorcio AAPA, a consortium of Apex Capital Partners, AIM Global, Passport Legacy, and Arton Capital.
A bid evaluation report dated March 5 on Argentina’s COMPR.AR procurement system places the group first with 88 points; Henley & Partners finished second with 48.0889.
Four of the six firms that submitted offers for Tender 34-0001-CPU25 were declared inadmissible. Only the consortium and Henley survived.
Why Four Bidders Were Eliminated
The Ministry’s Legal and Administrative Secretariat, in its technical-economic report (IF-2026-22913277-APN-SLYA#MEC), detailed the reasons for each disqualification.
Hong Kong Qian Cheng Business Co., Ltd. and Salzburg International For Law LLC were eliminated at the threshold stage: bid maintenance guarantees. Citing the guarantees status report (IF-2026-11998157-APN-DC#MEC), the evaluation found that both firms “have not complied with the presentation of said guarantees within the regulatory deadlines, said defect not being rectifiable, and analysis of their submitted offers is not warranted.”
Hong Kong Qian Cheng deposited its $1.25 million guarantee into its own account at China Construction Bank (Asia) rather than into the Ministry of Economy’s designated Banco Nación account. The funds did not arrive until January 30, ten days after the January 20 deadline.
Salzburg International (Reach Immigration) uploaded a bank guarantee via SWIFT to the COMPR.AR system but never presented the physical document with the required translation and certification.
Latitude Consultancy Limited was knocked out on financial solvency grounds. Evaluators found that Latitude “fails to comply with the Economic Solvency indices established in Points 2 (Indebtedness) and Point 4 (Solvency)” of the technical specifications.
Its indebtedness ratio came in at 1.36 against a maximum threshold of 0.50. Its solvency ratio registered at 1.73 against a minimum requirement of 2.00.
Ancova Associates FZCO was disqualified on two grounds. When asked for clarifications, the firm submitted a document titled “Rectification of the Technical and Financial Proposal,” which evaluators ruled constituted a modification of the original bid, something that “violates the principle of immutability of offers in administrative contracting, normatively established in Article 15 of the General Terms and Conditions,” approved by Resolution ONC N° 63/2016.
Ancova also failed the minimum profit-to-sales ratio and did not report its contracting capacity. Even setting aside these defects, the report adds, “the offer would be economically inconvenient, a reason that would eventually exclude it from the order of merit.”
How the Two Finalists Scored
Both admissible bidders met all eight content and admissibility requirements. Technical evaluations, weighted at 60% of the total score, produced identical raw scores of 80 out of 100, yielding 48 points each after applying the coefficient.
The consortium scored HIGH on singularity, expertise, and international network, and MEDIUM on experience and business plan. Evaluators praised the interdisciplinary approach of combining four specialized firms, noting that “the proposal to associate among several companies in the sector” was “considered an added value for the contracting party.”
Senior leadership across the consortium showed between ten and 30 years of experience in the residence and citizenship by investment space.
Evaluators observed, however, that experience documentation from some consortium members consisted largely of “generic, non-exclusive licensing” arrangements and marketing agent roles.
Asesorías Legal Advisor Limitada itself “did not report documented experience” in that regard, though this was not disqualifying because the pliego (tender specifications) assessed the consortium as a whole. Arton Capital Holdings Ltd. and Passport Legacy PTE. LTD. were credited as having recently developed and implemented programs.
Henley & Partners scored HIGH on expertise, experience, and international network, but MEDIUM on singularity and business plan. Contracts and certifications from at least seven governments, dating to 2017, substantiated its experience claim.
On singularity, evaluators found that Henley’s proposed financial execution model “would be cumbersome in terms of execution within the framework of the National Public Sector Financial Administration.” Its business plan was described as “coherent, structured, and of global scope,” though projected total costs “would be elevated.”
The Price Gap Decided It
Where the bids diverged was in price. The economic evaluation, weighted at 40% of the total score, overwhelmed Henley’s position.
The consortium bid $10,000 per tranche across all five tranches of 1,000 applications each, totaling $50,000 for the entire contract. Henley bid $2 million for the first tranche, escalating to $8 million for the fifth, totaling $25 million.
After applying the weighted coefficients specified in the tender, the consortium’s offer produced a weighted total of $75,000; Henley’s came to $33.75 million. Under the scoring formula, which divides the lowest weighted bid by each bidder’s and multiplies by 100, the consortium received a perfect 100 on the economic component (reduced to 40 after the 40% coefficient). Henley received 0.2222, reduced to 0.0889.
Final scores: Consortium 88.00, Henley 48.0889.
Three evaluation commissioners, María Cristina Castillo, Claudia Silvana Cochello, and Martín Alexis Salomón, authorized the recommendation. José García Hamilton, Secretary of the Legal and Administrative Secretariat at the Ministry of Economy, signed the technical-economic report.
The recommendation is not yet a final award. Under Article 73 of Decree 1030/2016, bidders may challenge the evaluation report within three days of its communication.
Once any challenges are resolved and the contracting authority issues a formal adjudicación, the winning consortium will have four years, with an option to extend for a fifth, or until 5,000 citizenship approval recommendations are issued, to design, launch, promote, and operate Argentina’s first CBI program under the Agencia de Programas de Ciudadanía por Inversión (APCI).
Program parameters, including investment thresholds, eligible sectors, and processing routes, remain undefined. The consortium will build these from scratch.
