Regulatory pressure, demand reallocation, and the emergence of new geographies are changing how globally mobile families evaluate citizenship, residency, and jurisdictional risk.
Carlo Alberto Rovere IMCM, ICWIM
1. Context and purpose
This paper is based on direct observation of what changed in 2025 and what is rapidly taking shape toward 2026 in the world of Citizenship by Investment (CBI) and Residency by Investment (RBI). It is not a legal review, nor a catalogue of programs.
The goal is to offer a more narrative and strategic reading of a market that is changing its nature, driven by three main forces:
increasing regulatory pressure from the EU and the United States
a re-pricing of the real value of mobility, banking access, and stability
higher awareness among HNWI and UHNWI individuals
This text is written for professionals, intermediaries, and internationally mobile individuals who are not looking for standard solutions, but for options that can be defended over time.
2. 2025 as a breaking point
2025 was not just a transition year. It was a real point of disruption.
On the geopolitical side, the probability of sudden and hard-to-predict events increased: expanded sanctions, frozen assets, mobility restrictions, and selective access to financial systems. At the same time, political alignment became more closely linked to the ability to operate freely across borders.
On the regulatory side, tolerance for programs seen as “weakly integrated” dropped sharply. Deeper due diligence, stronger focus on reputation, and the overall narrative of a program are now central in decision-making.
A new element also became clear: narrative risk.
Today, it is not enough to ask what a program offers. What matters is whether it can be explained, defended, and sustained over time, especially for families with regulated wealth or public visibility.
3. The core issue for CBI: Schengen
Looking at 2026, one single factor remains the real balance point of the CBI market: Schengen visa-free access.
For many years, demand for citizenship by investment was supported by an implicit mobility premium. When this access is questioned, the perceived value of a passport changes very quickly.
If Schengen access becomes limited, uncertain, or suspended, the passport stops being a true “mobility asset” and turns into a contingency citizenship. At the same cost level, the addressable market shrinks and demand moves elsewhere.
This risk is now heightened following the EU's 2025 reforms to the visa suspension mechanism, which explicitly include the operation of CBI programs (without "genuine links") as grounds for temporary or permanent suspension.
Tools like ETIAS (launching late 2026, mandatory by 2027), pre-screening, and additional checks do not remove visa-free access formally, but they increase friction, uncertainty, and potential denials, especially for CBI holders, accelerating the re-pricing process.
The market is currently moving along three plausible paths:
Scenario 1 - Status quo with more friction: Higher compliance, longer timelines, and greater selectivity. The market remains active, but less permissive and more demanding on documentation, source-of-funds, and reputational clarity.
Scenario 2 - Targeted tightening: More rejections, stricter controls, and selective measures against certain jurisdictions or profiles (as seen in some recent Nordic and EU decisions). Demand starts shifting toward countries seen as less exposed to European political pressure.
Scenario 3 - Shock to Schengen access: A suspension of visa-free access for some CBI jurisdictions creates an immediate shock: price compression, loss of commercial appeal, and a fast rotation toward alternative programs and, above all, toward residency solutions.
For professionals, the key question is not which scenario is “most likely”, but whether their clients’ structures are robust across all three.
5. How demand is changing
Demand is no longer uniform. It is segmented by objective, wealth level, and regulatory profile.
Some still look mainly for mobility and simplicity.
Others prioritize banking access, redundancy, and lower systemic risk.
Others build true multi-jurisdictional structures to dilute political and regulatory exposure.
UHNWI clients are more willing to commit significant capital when a jurisdiction is seen as solid, geopolitically relevant, and defensible over the long term. HNWI clients, instead, are more price-sensitive. They look for functional, reliable solutions with clear processes, valuing execution and predictability over marketing narratives.
A growing share of sophisticated clients now distinguish between:
Visa mobility (where you can travel)
Settlement and lifestyle (where you can actually live)
Geopolitical and climate resilience (long-term safe havens)
Financial mobility (where you can bank, hold assets, and operate under pressure)
6. Where attention is moving
In a rotation scenario, interest tends to focus on programs that combine execution quality, geopolitical positioning, and lower exposure to EU pressure.
For UHNWI profiles, solutions such as Turkey, El Salvador, and potentially a future opening of Argentina should not be seen as simple alternatives, but as likely strategic replacements for traditional Caribbean programs. Alongside these, there is growing use of citizenship routes based on merit, exceptional contribution, or discretionary frameworks, allowing states to select high-value profiles without standardized schemes.
For HNWI clients, interest is growing in more flexible and lower-cost programs such as:
São Tomé e Príncipe: Around $90k, currently the fastest Portuguese-speaking option.
Nauru: Around $105k, a climate-focused Pacific contingency option.
Egypt: Consolidated at roughly $250-300k, with differentiated utility and multiple investment routes.
Sierra Leone: Around $140k for fast-track citizenship (~60-90 days) + ECOWAS mobility; unique gold-backed PR option (~$65k + 1kg gold) for asset preservation and diaspora discounts.
Vanuatu: Around $130k, among the fastest and most flexible CBI options, still fully remote, with 1-2 months processing and growing use as a pure de-risking/contingency tool despite permanent Schengen suspension.
Botswana (upcoming): Expected from early 2026 in the ~$75-90k range, positioned to be the cheapest credible CBI with relatively strong African stability.
These low-cost citizenships are increasingly combined with European residency programs (e.g., Greece Golden Visa, Portugal Golden Visa/D7, Latvia Golden Visa, Cyprus Permanent Residency - expected to join Schengen in 2026, Italy Investor Visa), creating hybrid structures that separate Schengen mobility and long-term stay (EU residency) from contingency and de-risking (CBI), reducing reliance on a single legal status.
7. South America as a structural Plan B
Outside the European Union and far from major geopolitical fault lines, South America is emerging as a key pillar of a global Plan B.
In this context, Paraguay stands out for simplicity, low costs, flexibility, and the ability to obtain residency without continuous presence requirements. Once the value of this tool is understood, many individuals reinforce their position by adding multiple residencies, building a real architecture of options.
Key points of Paraguayan residency, in brief:
Territorial taxation: foreign-source income is currently not taxed.
No strict minimum stay for tax residency (periodic short visits recommended)
Low entry threshold: no large investment or strict income tests
Maquila regime: 1% tax on value added for export-oriented goods or services
Future optionality: eligibility for naturalization after three years of permanent residency (subject to legal and practical criteria)
For regional diversification, other residency options remain relevant, such as:
Panama: Particularly suitable for European (including Italian) profiles, with established legal structures and a long banking tradition.
Uruguay: Valued for institutional stability, predictable rules, and a more “OECD-compatible” narrative for regulated individuals.
Bahamas: Higher cost but geographically ideal for US-centric profiles needing frequent access to the US without full-time residence there, offering strong privacy, no income tax, and seamless North American connectivity.
8. A new approach to selection
In 2026, choosing a program no longer means buying a product. It means designing a risk structure.
What matters is:
Redundancy and diversification of jurisdictions.
Real banking access and financial-system optionality.
The ability to support one’s choices over time, even under changing political and regulatory conditions.
A “clean story” that advisors, banks, and regulators can understand and defend in a few sentences.
For serious clients, the right question is no longer “Which is the best passport?” but “Which combination of statuses gives my family the highest probability of being free to move, live, and operate under stress?”
9. My hierarchy of relocation tools
From a strategic point of view, four main tools form the core of a robust personal and financial sovereignty architecture:
Second citizenship:
A robust personal sovereignty architecture typically stacks four layers:
High-quality residency (e.g., Greece Golden Visa, Portugal Golden Visa/D7, UAE Golden Visa, Latvia Golden Visa, Cyprus Permanent Residency): Real lifestyle, stable banking, primary mobility (Schengen or GCC). Strong daily integration, but sensitive to policy shifts.
Fiscal residency in territorial-tax jurisdiction (e.g., Paraguay)
Second citizenship (mid-tier/strategic CBI, e.g., Turkey ~$400-500k): Long-term contingency and political home.
116+ visa-free countries, E-2 US eligibility, relatively clean banking narrative (facilitates premium accounts, e.g., in Switzerland).
Third citizenship (low-cost/emerging CBI, e.g., Vanuatu $130k, Sierra Leone $140k, São Tomé $90k):
Pure “break-glass” backup for de-risking.
Fast/affordable, but limited mobility and higher narrative risk (may complicate Swiss banking; easier for offshore optionality, e.g., Bahamas accounts).
Premium stable banking (e.g., Swiss, Bahamas or Singapore private banks) requires a clean profile and high AUM (USD 500k-2M+), with strict source-of-wealth checks.
Offshore redundancy (e.g., Bahamas, Cayman, non-resident accounts) provides remote opening, multi-currency options, and strong privacy, but remains selective for pure CBI clients.
Complementing these, global fintech and neobanks provide lower-threshold, fully remote accounts with multi-currency wallets, instant transfers, cards, and growing crypto services, making day-to-day and backup banking far more accessible and flexible for hybrid CBI/residency profiles.
The optimal stack separates lifestyle/banking, tax optimization, solid contingency, and ultimate redundancy, eliminating single points of failure.
A mature 2026+ strategy usually starts from three questions:
Where do you want to be able to live and bank safely, even in a crisis?
Which citizenship mix gives you structural resilience and geopolitical diversification?
Which residency and visa tools efficiently close the remaining gaps in mobility and lifestyle?
The “best” tool is rarely a single passport or residency. It is the combination that fits the client’s risk profile, regulation, family structure, and time horizon.
10. Conclusion
Demand is not shrinking. It is maturing.
In 2026, value will no longer come from the promise of mobility alone, but from the ability to reduce systemic risk, diversify jurisdictions, maintain access to financial systems, and preserve flexibility over time.
Personal and financial sovereignty is not a slogan. It is a practical construction, built step by step, with a clear understanding of trade-offs, execution constraints, and narrative exposure.
That said, in my view, Antigua & Barbuda and Grenada remain, today, the strongest and most balanced Citizenship by Investment programs in the market.
However, if Caribbean programs want to avoid progressive marginalization under EU pressure, they will need to evolve. The challenge is not compliance per se, but designing a framework that maintains efficient processing and commercial sustainability, while aligning with evolving European expectations around integration and narrative credibility.
Upcoming initiatives, such as the announced CBI framework in Saint Vincent and the Grenadines, will face this challenge immediately. If their structure does not materially differ from legacy Caribbean models, they risk starting from a position of disadvantage, particularly in the context of existing and future Schengen-related restrictions.
This paper serves as the foundation for a shorter public synthesis, designed to support professional reflection on where the sector is heading and which programs are structurally positioned to remain relevant.
Author
Alberto Rovere is the Managing Partner of Allie International, an advisory firm focused on Citizenship by Investment, Residency by Investment, and international wealth planning for HNWI and UHNWI clients.
He is also the co-founder of TaxNomadism, a strategic platform and analytical framework dedicated to personal and financial sovereignty, jurisdictional diversification, and geopolitical risk management in an increasingly complex global environment.
DISCLAIMER
This document is for informational purposes only and does not constitute legal, tax, or investment advice. Program conditions, regulations, and outcomes may change and are subject to government discretion. Readers should seek independent professional advice before making any decisions. The author and Allie International and TaxNomadism accept no liability for actions taken based on this document.
