Onur Sümer’s recent article on Argentina’s citizenship-by-investment (CBI) initiative raises several valid concerns. I particularly agree with the need to avoid speculative real estate, protect foreign-exchange inflows, preserve sovereign control, and ensure that the program does not become dependent on private consultants.
I differ on the broader conclusion. After more than three decades in business and investment immigration, I do not think Argentina’s real choice is between Turkey and the Caribbean. Those programs offer useful lessons, but Argentina has the opportunity to build a third model.
The wrong denominator
The first issue is economic.
Onur compares potential CBI proceeds to the approximately USD 259 billion reportedly held abroad by Argentine households and companies and concludes that CBI revenues would never be particularly significant for Argentina.
The comparison is rhetorically compelling, but economically I believe it uses the wrong denominator. Private wealth held abroad is not the same thing as sovereign liquidity. The key question is whether several billion dollars in non-debt, USD-denominated inflows can generate measurable value for the Argentine State and productive economy.
Argentina’s citizenship legislation expressly identifies attracting foreign capital and encouraging foreign direct investment as purposes of the Investment Citizenship Programs Agency. The better question is therefore: How much economic value can Argentina create from every citizenship it chooses to grant?
Application volume
The second issue is volume.
The proposed ceiling is often cited as 5,000 cases. But we should distinguish applications from applicants. Five thousand applications over four years equates to approximately 1,000–1,250 applications annually. If an average family application includes three or four people, the total could ultimately represent approximately 15,000–20,000 new citizens. For Argentina’s population, this is not a significant demographic number.
It is also modest compared with the experience of much smaller CBI jurisdictions. Caribbean states with populations in the tens or hundreds of thousands have historically processed thousands of applications annually across their programs.
The comparison therefore requires context. The real concern should not be whether 1,000 or 1,250 applications per year is excessive. It should be whether every application generates sufficient economic value.
Three-part structure
This is where Argentina should move beyond the traditional debate between donation and real estate. In 2020, I proposed a revised Canadian immigrant investor model based on three components: A non-refundable public contribution, a recoverable government investment, and a direct equity investment in an operating Canadian company.
A similar architecture could apply to Argentina. One part of the qualifying amount could provide direct fiscal or foreign-exchange benefit to the State. A second could enter a recoverable investment fund, bond, or productive-development vehicle. A third could be invested directly into an Argentine operating company.
That third component is particularly important. Instead of simply collecting money from the investor, Argentina could match each economic investor with an Argentine business operating in the same or a related industry.
A manufacturer from India, a logistics entrepreneur from the Gulf, or an agricultural investor from China may bring far more than capital. They may bring distribution channels, clients, technology, suppliers, and access to their home market.
The investor then becomes not merely an applicant but potentially an international partner for an Argentine company. That creates something investment migration too often overlooks: Economic connectivity.
Real estate
On real estate, I largely agree with Onur. Turkey demonstrated the danger of making property valuation central to citizenship qualification. But there is another weakness in the Turkish model: Most of the purchase price went to the private property owner or developer rather than to the government.
The Caribbean model at least captures a significant government payment in addition to the qualifying real-estate purchase. In Dominica today, for example, the real-estate minimum is USD 200,000, but government fees are USD 75,000 for a single applicant and USD 100,000 for a family of up to four.
Even then, one must ask whether building more hotels is necessarily the highest-value use of immigration capital. In many Caribbean programs, the straightforward government-contribution route has remained more attractive than property investment precisely because it is simpler. Argentina could instead prioritize productive firms.
Genuine link
The “genuine link” question can also be addressed differently.
Physical residence is useful, but days on a calendar do not automatically confer substance. An investor who owns equity in an Argentine company, participates in its strategy, develops export markets, employs Argentines, pays taxes, and maintains a residence in the country may establish a more credible connection than someone who merely satisfies a physical-presence formula.
One possibility would therefore be to combine productive investment with a requirement to maintain Argentine residence for several years, perhaps through a modest purchased or rented pied-à-terre, without making residency an artificial box-ticking exercise.
Argentina’s current framework already requires the Investment Citizenship Programs Agency to assess whether the investment is “relevant,” obtain reports from security and financial-intelligence bodies, and submit a recommendation before the National Directorate of Migration makes the final decision.
Pricing and exit
The structure should therefore be stable; the price should not. If Argentina later obtains US visa-waiver access or substantially improves its passport’s utility, the program should be able to raise its price.
The legislation should establish the structure, safeguards, and limits. The competent authority should retain controlled flexibility to respond to market conditions. The program should also include an exit strategy. CBI should not become a permanent fiscal dependency.
A finite four- or five-year citizenship window could generate front-loaded capital, while a longer-term residence-by-investment program continues to attract investment thereafter.
Industry capture
Finally, I believe the greatest long-term risk may not be the applicants at all. It may be our own industry. Many CBI programs were reasonably well designed at the outset. Problems arose when agents, developers, consultants, and commercial interests gradually gained too much influence.
Malta’s experience offers a similar warning. A residence requirement can look excellent on paper, but when intermediaries reduce it to artificial addresses and formal compliance, the rule’s objective disappears. That is why Argentina should regulate the actors involved in the program as carefully as it vets the applicants. Program designers, marketers, developers, fund managers, due-diligence firms, and the sovereign adjudicator should remain institutionally separated.
The government must control the industry. The industry must never control the program.
A third model
Argentina therefore need not choose between Turkey and the Caribbean. It can build something more sophisticated: A controlled program in which every approval generates sovereign revenue, productive capital, international business connections, and a genuine economic relationship with Argentina.
That, in my view, is the real opportunity.
