In the history of citizenship by investment, a similar puzzle lingers beneath every policy debate, every investment migration conference, and every sovereignty-themed analysis. Did governments invent citizenship-by-investment programs, or did the world’s citizens force their creation through evolving needs? What came first? The chicken or the egg?
Was CBI pushed into existence by small, vulnerable nations seeking new economic lifelines? Or was it pulled into being by globally minded individuals who outgrew the constraints of a world built on single, inherited, territorially determined identities?
Citizenship itself is a human invention. Borders are inventions.
Passports, visas, taxes, restrictions, entry and exit rights: every rule governing how humans move, live, and work across the planet is manmade. So when we discuss CBI as a tool, we must understand it inside the architecture of other tools humans created: the nation-state, the passport system, immigration controls, global inequality in mobility rights, economic vulnerability among small states, and the uneven geography of opportunity.
CBI is not an anomaly. It represents the predictable outcome of a world where states control movement, but humans increasingly need to move.
This tension between rigid political structures and fluid human aspirations birthed modern CBI. And it continues to shape the industry today.
Ancient Origins: Rome and the First Membership-for-Value System
The story begins not in the 20th century, but in antiquity.
Rome didn’t operate CBI programs in any modern sense. It had something more fundamental: an understanding that citizenship functioned as a tool for integration, reward, and strategic advantage.
Citizenship as Reward
Rome granted citizenship for military service, contributions of land or wealth, political loyalty, and public service to the Empire. Citizenship brought legal protections, tax benefits, mobility within the Empire, commercial rights, and elevated status.
Julius Caesar employed citizenship strategically throughout his political career. He extended Roman citizenship to select provincial communities, particularly elites and entire cities in Cisalpine Gaul and other regions where he sought political support. This wasn’t philanthropy but calculated statecraft.
Caesar understood something modern politicians still recognize: citizenship creates political power. These new citizens could participate in Roman political life, vote in assemblies, and provide crucial backing for his political ambitions. By granting citizenship to strategically chosen individuals and communities, he built a vast base of supporters who owed their elevated status to him personally.
The Parallel to Modern CBI
The logic remains identical across millennia.
The state benefits from resources, allegiance, or contribution. The individual benefits from rights, protections, and mobility.
Rome invented the framework; modern states formalized it. The concept of exchanging value for membership predates contemporary debate by two thousand years.
The Long Dormancy: When Citizenship Became Less Flexible
After Rome’s fall, citizenship evolved differently across regions and eras. Medieval systems tied people to land, lords, and lineage, though Renaissance city-states occasionally granted citizenship for economic contribution.
Early modern Europe saw various forms of naturalization, often involving wealth or service. Colonial powers experimented with different forms of subjecthood that could sometimes be purchased or negotiated.
The rise of modern nation-states in the 18th and 19th centuries gradually standardized citizenship around birth, ancestry, and long-term residence. Nationality became increasingly fixed at birth, determined by geography or bloodline.
Yet for much of human history, borders remained more porous than today. People moved across kingdoms and territories with varying degrees of freedom. Merchants traveled trade routes spanning continents. Artisans relocated to find work.
Documentation requirements existed but varied enormously. Some borders required papers; others did not. Some nations tracked foreigners carefully; others barely noticed.
The Evolution of Hard Borders
The early 20th century marked a turning point.
World War I accelerated border control systems already emerging in some nations. The United States had implemented immigration restrictions decades earlier: the Chinese Exclusion Act (1882), contract labor prohibitions, and systematic inspections at Ellis Island. Russia maintained internal passport systems. The Ottoman Empire controlled movement through various administrative means.
But comprehensive, universal passport requirements as we know them today crystallized during and after WWI. Nations needed to track citizens, prevent espionage, control labor flows, and manage security threats. The passport system expanded from a patchwork of local practices into a global standard.
By 1920, the League of Nations began coordinating international passport standards. What had been inconsistent became systematic. Nations established comprehensive immigration controls, standardized visa systems, and formalized border checkpoints.
The Passport as Universal Gatekeeper
The interwar period and post-WWII era solidified the modern passport regime. For the first time in human history, virtually all movement across borders required documentation, permission, and state approval.
Your nationality determined where you could go, how long you could stay, and what rights you possessed abroad. The system solved certain problems related to security, labor management, and national defense but created new challenges.
It concentrated unprecedented power in the hands of governments over individual mobility. It limited economic opportunity based on birthplace. It made nationality the single most important determinant of individual freedom in an increasingly connected world.
The comprehensive global border control system as we know it today is roughly a century old. Yet it shapes every aspect of human mobility, determines life outcomes, and creates the inequality CBI now helps navigate.
But the 20th century reshaped everything beyond border control. Mass travel became normal.
Global trade exploded. Wealth became mobile.
Geopolitical shocks created instability, and millions realized their rights and freedoms were restricted by their passport. The world began producing global individuals, but the political system still treated people as local subjects.
The stage was set for a radical reimagining of citizenship options.
The Modern Origin Story: Tonga, St Kitts & Nevis, and the Birth of an Industry
Tonga 1982: The Prototype
In 1982, Tonga began issuing Tongan Protected Person Passports (TPPPs). These documents did not grant full citizenship or extensive protection, but they offered limited travel documentation to people seeking alternative options.
The program generated tens of millions of dollars for the kingdom between 1982 and 1996, with over 8,400 passports issued during that period. While exact revenue figures remain uncertain due to incomplete records and corruption issues that plagued the program, the economic impact on a small Pacific nation with limited natural resources was substantial.
Was the program elegant? No.
Was it structured? Barely.
Did it prove demand existed? Unequivocally.
Tonga’s experiment revealed that people around the world actively sought alternative nationality options. The program demonstrated that citizenship-adjacent documents could be monetized, that individuals would pay for access, and that small nations could generate meaningful revenue through sovereignty design.
St Kitts & Nevis 1984: The First Continuous Program
Two years later, newly independent St Kitts & Nevis launched what remains the world’s oldest continuously operating CBI program. Over 40 years later, it still functions.
This was the first professionalized attempt: legislated, formal, clearly priced, tied to real economic contribution. The program included proper legal frameworks, defined investment thresholds, and structured application processes.
Over four decades, St Kitts & Nevis’ CBI program helped stabilize the economy, financed infrastructure development, influenced regional adoption, and became a global brand. The program proved a small nation could punch far above its economic weight through smart sovereignty design.
Tonga revealed hidden demand. St Kitts & Nevis proved CBI could be an industry.
Phase One: Supply-Led Experimentation in the 1980s and 1990s
In the early years, CBI was a product searching for customers.
Government Motives
Small nations pursued CBI for straightforward reasons: revenue generation, economic stabilization, capital attraction, and balance sheet strengthening. Caribbean islands faced regular hurricanes requiring reconstruction funding.
Pacific nations struggled with geographic isolation and limited export opportunities. Traditional revenue sources (agriculture, fishing, tourism) proved vulnerable to weather, market fluctuations, and global economic shifts.
CBI offered an alternative. It generated foreign exchange, attracted investment, created employment in legal and financial services sectors, and provided fiscal flexibility.
Investor Motives
Early adopters typically sought backup identities, escape from regional instability, and access to travel options unavailable with their birth passport. Many came from countries experiencing political turbulence, economic crises, or restrictive emigration policies.
A second passport meant an exit option. It provided insurance against government overreach, economic collapse, or civil unrest.
The investment required was substantial but the value proposition was clear: mobility, security, optionality.
Program Characteristics
Early programs operated with minimal due diligence, limited transparency, and small markets. Global attention remained negligible outside niche legal and financial circles.
Processing was often informal. Background checks were rudimentary.
Regulatory frameworks remained underdeveloped. Despite these imperfections, this phase answered an essential question: Is citizenship something people will actively choose if given the option?
The answer was yes. Demand existed, revenue flowed, and governments began recognizing CBI as a viable policy tool.
Phase Two: Professionalization and Global Adoption in the 2000s Through Mid-2010s
Globalization turbocharged the forces behind CBI.
The Human Needs Shift
People no longer sought only shelter from conflict or escape from political instability. New needs emerged: mobility for global business, relocation options for children, tax and regulatory flexibility, and multiple legal identities to support multi-country lives.
The internet enabled remote work. Air travel became affordable.
International education became common. People built businesses across borders, maintained homes in multiple countries, and conducted financial affairs through global networks.
A single citizenship increasingly felt like a constraint rather than an identity.
Caribbean Optimization
Countries including Dominica, Antigua & Barbuda, Grenada, and St Lucia professionalized their programs. They introduced structured application vetting, real estate investment pathways, national development fund donations, and sophisticated marketing frameworks.
These nations learned from St Kitts & Nevis’ decades of experience. They refined processes, strengthened due diligence, improved transparency, and created competitive offerings tailored to different investor profiles.
CBI revenues began forming considerable portions of national budgets. Caribbean CBI states averaged 6.5% of GDP from these programs between 2019 and 2023.
Some individual countries exceeded 10% to 20% at peak moments. The economic impact extended beyond direct revenue: CBI financed infrastructure projects, created professional services jobs, attracted real estate development, and enhanced international visibility.
Europe Enters the Arena
Malta and Cyprus brought prestige, European Union mobility, regulatory complexity, and global attention. Suddenly, citizenship wasn’t just about convenience. It became geopolitical access.
A Maltese or Cypriot passport opened the entire European Union for living, working, studying, and conducting business. The value proposition shifted from “alternative travel document” to “membership in the world’s largest economic bloc.”
Investment thresholds rose accordingly. Malta’s program required over one million euros in combined contributions and investments.
Cyprus structured its program around real estate purchases of two million euros or more. These programs attracted ultra-high-net-worth individuals seeking premium mobility and lifestyle options.
The industry matured from niche to mainstream. International media coverage increased.
Advisory firms specializing in investment migration proliferated. Legal frameworks became more sophisticated, due diligence intensified, and governments began treating CBI as strategic economic policy rather than opportunistic revenue generation.
Phase Three: The Sovereignty Portfolio Era from the Late 2010s Through the 2020s
This period marks a psychological shift among investors.
People stopped looking for “Plan B.” They started building sovereignty portfolios: multiple jurisdictions offering diversified rights, interlinked identities, and strategic optionality.
CBI as a Global Market
The investment migration industry now generates approximately $22 billion annually. This figure encompasses citizenship programs, golden visa schemes, residency by investment pathways, and related professional services.
The market includes government fees, real estate purchases, business investments, legal advisory, financial planning, relocation services, and ongoing compliance management. Dozens of firms now specialize exclusively in investment migration, from boutique consultancies to large international practices.
The Middle Class Joins
Demand is no longer dominated by ultra-high-net-worth buyers fleeing instability. The upper-middle class has entered the market: entrepreneurs, digital workers, globally minded families seeking educational opportunities for children, and professionals building international careers.
Lower-cost Caribbean programs made CBI accessible to successful professionals rather than only billionaires. Investment thresholds starting around US$100,000 to US$150,000 opened the market to a much broader demographic.
These buyers aren’t fleeing danger. They’re seeking autonomy, optionality, and leverage in an interconnected world.
A New Category of Individual
Modern CBI applicants often maintain multiple residences, conduct business across jurisdictions, hold diversified investment portfolios, educate children internationally, and view citizenship as infrastructure rather than identity. They’re not rejecting their birth countries. They’re supplementing limited mobility with additional access.
This represents a fundamental shift. Citizenship has become a tool for navigating global complexity rather than a marker of exclusive national belonging.
Due Diligence Becomes Non-Negotiable
The global system now requires deep background checks, multi-level vetting, anti-money laundering and counter-financing of terrorism (AML/CFT) protocols, identity verification reform, and cooperation with supranational entities. Caribbean nations are establishing the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA) to harmonize standards, share intelligence, and strengthen regional credibility.
Background verification reports (BVRs) examine applicants through INTERPOL databases, financial intelligence units, international sanctions lists, and media screening. Source of funds documentation requires extensive proof of wealth accumulation through legitimate means.
Biometric data collection ensures identity verification. Reference checks confirm professional and personal backgrounds.
The process can take six months to over a year depending on complexity. CBI has transformed from a loosely regulated market into a sophisticated, compliance-heavy industry requiring professional expertise at every stage.
The Data Tells the Story
Dominica’s CBI revenue reached approximately 37% of GDP in fiscal year 2022/23, one of the highest proportions ever recorded by any nation from an investment migration program. This revenue stream funded reconstruction after Hurricane Maria devastated the island in 2017, financed new housing developments, upgraded infrastructure, expanded tourism capacity, and strengthened public finances.
Several CBI-funded resorts, airports, hospitals, and housing projects reshaped national landscapes across the Caribbean. Antigua built a new university.
Grenada expanded its marina capacity. St Lucia developed tourism infrastructure that attracted international hotel brands. CBI moved from supplementary income to economic architecture. These programs became foundational elements of national development strategy, particularly for small island developing states (SIDS) facing climate vulnerabilities and limited economic alternatives.
(end of part I, you can read part II here)
