Variability in global mobility privileges is keyed to citizenship. For citizens of the Congo or Bangladesh or Honduras, there are few countries to which one can travel without first having to secure entry permission in the form of a visa. However, it is not just citizens of the poorest countries that face obstacles to mobility. Citizens—even rich ones—of more prosperous, non-OECD states such as Russia and China also need visas to travel to developed states, with all the ignominy and hassle that the visa process involves.
Enter: “citizenship by investment,” or CBI for short. In The Golden Passport: Global Mobility for Millionaires, sociologist Kristin Surak delivers a definitive account of the burgeoning practice by which states extend citizenship in return for cash. Investor citizenship has come a long way from its Wild West days in the 1980s and 1990s, a period that saw rogue agents selling passports out of suitcases and a patchwork of irregular programs through which one could purchase citizenship. Today, investor citizenship programs have been normalized and professionalized. The rise of investor citizenship is an interesting story in itself, carefully recounted by Surak, and The Golden Passport has much to say about citizenship as an institution more generally.
As the book sets out in chapter 1, individuals are now able to secure citizenship in an array of mostly smaller states in return for variable combinations of donations and investments ranging from a hundred thousand dollars (in the case of countries such as Dominica, Saint Lucia, and Antigua) to unspecified millions (as with Austria and New Zealand). The number of individuals who gain additional citizenship(s) on a financial basis every year remains relatively small, at around fifty thousand a year (p. 17). Regardless, it can be a big deal for the countries that are doing the selling, the wealthy who are doing the buying, and the brokers who are smoothing the path between them.
All states have a sovereign right to offer citizenship, and that right inheres regardless of size. Among several Caribbean states, investor citizenship has become an industry second only to tourism. For Saint Kitts and Nevis, which was a first mover in the recent wave of programs, investor citizenship accounts for 40 percent of its GDP (p. 28). In Malta, investor citizenship contributes about 2 percent of its GDP and 5 percent of its annual government revenues (p. 73). For these countries, citizenship can be minted at something close to zero marginal cost. This is perhaps as close as a sovereign can get to free money.
Citizenship on checkbook demand is a boon for buyers, too. Enhanced mobility is the leading benefit. Malta sets the gold standard among institutionalized programs with set sticker prices. Malta is a member state of the European Union; with Maltese citizenship comes visa-free access to most countries in the world, including the United States, as well as the right to work and live anywhere else in the EU. Maltese citizenship can be had for a package that includes a €650,000 donation to the National Development Fund; an investment of at least €150,000 in government bonds; and the purchase of real estate valued at €350,000 or the lease of property with a minimum €16,000 annual rent (pp. 176–77). Even citizenship in Saint Kitts and other Caribbean states comes with a visa waiver for travel to the EU.
In other contexts, the benefit is more focused and strategic. Citizenship in Grenada avails its holders of indefinitely renewable U.S. non-immigrant visas (so-called E-2 visas), pursuant to a bilateral investment treaty with the United States. Those buying citizenship are not actually looking to live in the country whose citizenship they are acquiring; they are looking to secure the external benefits that come with the status. There are important exceptions. For example, more than thirty-five thousand individuals have secured Turkish citizenship in return for a mere $250,000 property investment. Turkish citizens are eligible for multiple-entry visas for the EU as well as the E-2 visa in the United States, but they also have the right to live in Turkey, home to the thriving global city of Istanbul and a hub for global business (pp. 108–11). Similarly, wealthy refugees from Iraq, Yemen, Syria, and Palestine have looked to guarantee locational security through investor programs in Egypt and Jordan (pp. 93–95).
Finally, as described in chapter 5, investor citizenship programs have generated riches for intermediary private entities. “In this complex ecosystem,” writes Surak, “lawyers, migration agents, application assemblers, real estate developers, due diligence firms, and others interlink to make a buck off the business of citizenship” (p. 139). Central players in this “supply chain” of citizenship pitch programs to states, and then as concessionaires or licensed agents collect fees on program applications. The Global Passport puts Surak's field research to excellent use, highlighting conferences at which prime ministers pitch their countries to those in the business of advising “ultra-high net worth individuals” (p. 73). The Investor Migration Council, an industry trade group, boasts more than three hundred members. These entities understand that keeping programs “clean” is crucial to their sustainability, hence the emergence of robust due diligence mechanisms. Caribbean CBI states will float applicant names by U.S. authorities, free riding on the vastly better-resourced U.S. intelligence apparatus. Indeed, an important takeaway of Surak's account is how the major powers play an important—if silent—supporting role in making investor citizenship work.
However, due diligence has not always rooted out unsavory types seeking additional citizenship(s) to nefarious ends. When immigration inspectors discovered two Iranian businessmen trying to enter Toronto with Saint Kitts diplomatic passports in 2014 even though they had no official diplomatic business in the country, Canada yanked visa-free access for citizens of the island nation (p. 53). In 2020, Al Jazeera ran an expose on “high risk” individuals who had navigated their way to Cypriot citizenship, after which Cyprus shuttered the program. EU policymakers have taken a notably hard line against investor citizenship (pp. 88–90). They have long pressed Malta to end its program, now with a claim before the European Court of Justice that investor citizenship violates the principle of “sincere cooperation” enshrined in the Maastricht Treaty. Malta has persisted with the program, for now, but greater leverage over EU candidate states Moldova and Albania persuaded these governments to abandon their CBI plans.
So long as states orient admissions decisions on an individual's nationality, Surak suggests, investor citizenship is unlikely to fade away (p. 270). There are too many vested interests on all sides—of sellers, buyers, and brokers. States have sovereign discretion to extend citizenship to anyone they want, so long as it is volitional. In the wake of the COVID-19 pandemic and political turbulence, increasing numbers of people with premium citizenship, Americans included, are looking to add to their “citizenship portfolios” (pp. 254–56). The former CEO and chairman of Google Eric Schmidt, for example, secured Cypriot citizenship before the program was shuttered (p. 207). Investor citizenship has been assimilated in the wealth advisory ecosystem to the point that three of the Big Four accounting firms engage in “citizenship planning” and help guide their clients through the CBI process.
As Surak notes, investor citizenship programs “supply an opportune site for unpacking broader transformations in citizenship” (p. 258). Investor citizenship challenges the historical association of citizenship with solidarity. Investor citizens are hardly embedding themselves in the communities in which they now hold formal membership; “wealthy naturalizers seek the benefits the state secures . . . and show little interest in its imagined national community” (p. 256). In this respect, investor citizenship represents the tip of a broader trend in which individuals seek out citizenship for instrumental purposes. As documented by the sociologist Yossi Harpaz, individuals in a variety of contexts are seeking out second citizenships for strategic purposes mostly relating to enhanced mobility and settlement privileges: Chileans and Argentines securing EU citizenship on the basis of their Italian and Spanish grandparents; Israelis taking advantage of German, Polish, Romanian, and other citizenship “restoration” programs for descendants of Holocaust survivors; and wealthy Mexicans delivering babies in U.S. hospitals to secure U.S. citizenship. Investor citizenship, moreover, gives the lie to citizenship's equality ethos. Literally commodifying the status, investor citizenship is about securing privileges; it is obviously not available on the basis of equal access. While the rich buy access, the less well off remain fenced out. The Global Passport delivers a canonical treatment of a fascinating, novel element of the global migration landscape.
