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Understand Why Millionaires Seek Extra Citizenship in Remote Nations as a Global ‘Plan B’, and Why This Industry Now Faces Unprecedented Legal Crackdown.
The investment migration industry, known as the “golden passport” market, has become a central component in the strategic planning of global millionaires. The main motivation is not just mobility, but acquiring a “Plan B”, an insurance policy against political, economic, and social instability in their home countries.
However, this market is divided. On one side, low-cost programs in Caribbean nations, with values starting from US$ 100,000 in donations. On the other, high-investment programs, such as Turkey’s, which requires between US$ 400,000 and US$ 500,000 for access to a larger economy. A comparative analysis of Citizenship by Investment (CBI) programs details that these values vary drastically depending on the goal: pure mobility or access to strategic markets.
The ‘Plan B’ Strategy: More Than Mobility
The growing demand for second citizenships among high-net-worth individuals is fundamentally a risk mitigation strategy. The term “Plan B” defines the search for a legal safe harbor and asset protection in case of unexpected turbulence at home.
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While visa-free access to more countries, such as the EU Schengen Area, is a tactical benefit, the driving force is distrust in the long-term stability of domestic institutions. Interestingly, even citizens of countries with “premium” passports, such as the United States, seek this option. For them, it’s not about mobility, but about securing permanent rights (such as unrestricted access to healthcare and voting) that a temporary visa can never offer.
Instant ‘Citizenship’ vs. Residence: The Critical Difference
The market splits into two categories that are often confused but legally very distinct: CBI and RBI. Understanding this difference is crucial to grasping the regulatory crackdown currently happening.
Citizenship by Investment (CBI), or “Golden Passport”, is the most controversial product. It grants full citizenship and passport in a direct and rapid manner, usually in 3 to 12 months. According to the comparative analysis of CBI programs, the defining (and problematic) characteristic is the absence of physical residence requirements. The investor does not need to live in the country. Classic examples include Dominica, St. Kitts and Nevis, and Vanuatu.
Residency by Investment (RBI), or “Golden Visa”, is a different product. It grants residency status (long-term visa) in exchange for the investment. Citizenship is not immediate; RBI is merely a path to naturalization, which requires years of legal residence and physical presence (as in Greece, Spain, or the U.S. EB-5 program). RBI builds a “real bond” with the country over time, making it legally more defensible.
The Global Millionaire Market: Where and How Much Does It Cost?
The value of US$ 500,000 mentioned is a benchmark for mid-high tier programs, but the market starts much lower. The comparative analysis of CBI programs clearly maps out the cost landscape, showing that the price reflects the “premium” of the rights acquired.
At the entry level (US$ 100,000 – US$ 150,000), are Caribbean nations (like Dominica and St. Kitts) and Vanuatu. The most common option is a non-refundable donation to a national fund, starting at US$ 100,000. The product sold here is mobility: visa-free access to the EU Schengen Area.
At the mid-level (US$ 400,000 – US$ 500,000), is Turkey. This very popular program requires a US$ 400,000 real estate investment or a bank deposit/investment of US$ 500,000. The investor here buys access to a significant regional economy (G20), but without direct access to the EU or the U.S. Higher-end programs, like Malta’s (now under legal attack) or the U.S. EB-5, cost much more.
The End of an Era: The Collapse of Programs in the European Union
The era of transactional and “instant” citizenship in Europe has effectively ended, driven by fraud investigations and decisive legal actions. The collapse of Cyprus’ “golden passport” program was the first major warning sign.
An official investigation into Cyprus’ program revealed an alarming conclusion: 53% of the 6,779 passports issued throughout the program’s lifetime were illegally granted. The investigation highlighted systemic failures and serious issues with background checks (due diligence), operating under an “inadequate legal framework.” This set a dangerous precedent: purchased citizenship can be revoked retroactively if the government fails to follow its own laws.
The Judicial Decision That Hit Malta: ‘Commercialization of Citizenship’
The final blow against CBI programs within the EU came from the judiciary. The European Commission sued Malta, and the ruling changed the industry forever, as detailed in the European Court of Justice’s ruling (Case C-181/23).
In April 2025, the Court ruled that the Malta program violates EU Law. The ruling was clear: the practice undermines “mutual trust” among member states. The Court labeled the program a “commercialization of nationality grants” and concluded that by reducing citizenship to a commercial transaction without a “real bond”, Malta jeopardizes the entire EU system. This decision makes any “instant” CBI program within the bloc legally unsustainable.
Is It Worth It? The Systemic Risk of Purchased Citizenship
For millionaires, the risk landscape has changed drastically. Acquiring a cheap passport now carries significant reputational and banking risks. Global bodies such as the FATF and the OECD have identified these programs as high-risk vehicles for money laundering and tax evasion.
This global pressure puts Caribbean programs into survival mode. The main value of their US$ 100,000 passports is visa-free access to the Schengen Area, a privilege that the EU can revoke at any time (as it has already done with Vanuatu). The safest “Plan B”, therefore, is no longer the quickest or cheapest, but rather the slower Residency (RBI) programs that require a genuine bond with the new country.
The “golden passport” market is at a turning point, divided between the journey of millionaires seeking security and the crackdown from governments for integrity.
What do you think of this practice? Is it a legitimate investment in personal security or a global security flaw that allows rule evasion? Leave your opinion in the comments, we want to know what you think.
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