What the law calls an agent, programme by programme
Each row gives the rule in that programme's law and a link to the official list of licensed or authorised agents. Search the list for the company name in your contract, not the brand on its website.
| Programme | What the rules say | Official list |
|---|---|---|
| Dominica | All applications must be submitted to the CBIU by an Authorised Agent, with the submission fees. Authorised Agents are licensed by the CBIU under a written agreement with the Government, pay a registration fee and an annual renewal fee, and are reviewed before each new licence. | Open the list |
| Grenada | Applications may only be submitted by a holder of a Local Agent's licence granted by the Minister (on application to the CBI Committee with the prescribed fee); licensed marketing agents may prepare applications but must pass them to a Local Agent. Applicants cannot submit on their own behalf. | Open the list |
| St Kitts and Nevis | CBI applications may be submitted to the CIU only by an Authorised Agent, on payment of the due diligence fees. Authorised Agents are authorised by the CIU Board of Governors (reg 28); they must be locally incorporated companies licensed to do business in St Kitts and Nevis as consultants. | Open the list |
| Saint Lucia | Applications must be submitted by an authorised agent. Authorised agents are licensed by the Citizenship by Investment Board (on the CIU's recommendation) under s.31 of the Act; the original 2015 definition referred to licensing by the Financial Services Regulatory Authority, replaced in 2019. | Open the list |
| Antigua and Barbuda | Applications may only be submitted by an Agent holding an Agent's Licence issued by the Minister (the Prime Minister acting in consultation with Cabinet). Licences go only to citizens of Antigua and Barbuda ordinarily resident there for at least 7 years. The CIU processes licence applications. | Open the list |
| Vanuatu | Under the DSP Regulations the Citizenship Commission designates agents, who must be Vanuatu citizens with a main registered office in Port Vila. Applications go through a designated agent, who first lodges documents with the FIU for due diligence and then files the application with the Citizenship Office. | Open the list |
| Türkiye | No licensed-agent requirement. The investor applies in person, or through a proxy appointed by a special power of attorney, to the determining institution for a certificate of conformity; residence-permit and citizenship applications are then taken by staff assigned by the Presidency of Migration Management and NVİ. | No list: no licensing regime |
| São Tomé and Príncipe | All applications must be submitted exclusively through an authorised Marketing Agent licensed under the programme (CIU states this is per government regulations); agents apply to the CIU for a licence via its Marketing Agent application form. | Open the list |
| Nauru | Applications must be made through a licensed Agent (s 8). The Program Office will not consider an application that is not; Agents are licensed by the Program Office under Part 5 (ss 15-16). | Open the list |
Government money and agent money
Two kinds of payment are easy to confuse. Government amounts are the contribution or investment, due diligence, processing and certificate fees: they are set in law and the same for everyone in the same position. Professional fees are whatever the agent charges for its own work, agreed privately in your contract.
In some programmes part of the government money already pays the agent. Grenada's fund contribution is split between an amount the government keeps and a commission paid to agents. In Nauru, the programme office deducts an agent fee and its own administration fee from the contribution before it reaches the treasury fund. Ask any agent which of its charges come out of the government amount and which are added on top, and get the answer in writing.
Warning signs, and the rule behind each
- A price below the floor. The five Caribbean states agreed in 2024 that no investment option would be sold below a common minimum. An offer to obtain one of their passports for less than the programme's starting price is either leaving out government money or describing something else.
- “Guaranteed” approval or timing. The decision belongs to the government, after its own due diligence. Grenada's rules list the grounds on which the government will refuse an application, and Dominica's unit says its timeline is an estimate, not a promise. Nobody outside government can promise either.
- An EU passport “by nomination” or “by investment”. On 29 April 2025 the EU Court of Justice ruled that Malta's investor citizenship scheme broke EU law. Malta has since replaced that route in its legislation. Treat any offer of a European passport for a payment as a reason to walk away.
- A name that is not on the list. If the company that signs your contract does not appear on the official list, it cannot file your application itself: the rules above reserve that to licensed agents. Saint Lucia also publishes a list of agents it has blacklisted.
Questions to ask before you sign
These are our suggestions, not official requirements.
- Under which licence will my application be filed, and can you show me your entry on the government list?
- Which government fees will I pay, to whom, and when? Ask for the official fee schedule, not a summary.
- What is your own fee, what does it cover, and what happens to it if the application is refused?
- Who sees my documents, and where are they stored?
- If you are not the licensed agent, who is, and what is your agreement with them?
How we work with licensed agents
We assess which programmes fit you and send a shortlist. If you decide to apply, we tell you which licensed partner agent would file your application, with its licence, before sharing anything about you. You can check that agent against the lists above yourself.