The Citizenship Game: Investment Visas’ Evolving Landscape

Investment visa programs continue to evolve as powerful tools for countries seeking capital and for high-net-worth individuals pursuing greater security, mobility, and opportunity. They are reshaping global migration patterns, with over 100 nations having enacted legislation and several introducing innovative visa models.  As regulatory scrutiny increases, successful programs will strike a balance between investor appeal and national interest.


Why Wealthy Families Relocate

Migration by affluent families is accelerating. It is reported that 128,000 millionaire households will likely move abroad in 2024 alone.1 Key drivers include:
    • Security concerns in politically unstable countries
    • Financial considerations, such as taxes and the climate for investment
    • Lifestyle factors like education, healthcare, and weather

China, for example, saw 15,200 millionaires depart the country in 2024, the highest number globally, driven in large part by weak consumer sentiment and real estate turmoil.1


Genesis and Evolution of Investment Migration

Saint Kitts and Nevis launched the first Citizenship by Investment (CBI) program in 1984 to revitalize its economy following a collapse in sugar exports.2 Trading citizenship or residency for money gained momentum during the 2008–09 global financial crisis and the 2012 European debt crisis, prompting countries like Portugal and Greece to introduce “Golden Visas” to attract capital amid financial crises. 3

Henley & Partners, a leading advisory firm in residence and citizenship by investment, estimates over 100 countries have enacted investment migration legislation–currently only about 30 maintain active programs. A different estimate comes from the IMF, suggesting 55 countries that offer one form or another of these visas.4

At least 300,000 families have secured investment visas in the past decade. In 2024, the top destinations for millionaire migrants were the UAE, U.S., Singapore, and Canada.5

Investment minimums range from AED 2800 (less than USD 1,000) for the United Arab Emirates to SGD 10 million (over USD 7 million) for Singapore. 4


Citizenship or Residence: A Choice of Pathways

There are two different types of investment visas available to qualified, vetted candidates seeking to emigrate to another country; some countries offer both, while others only one.

Citizenship by Investment programs (CBI), common in Caribbean nations, Turkey, Egypt, Vanuatu, Nauru, and elsewhere grant citizenship directly for the payment of a defined fee, often with visa-free travel and dual nationality rights.

Residency by Investment (RBI) programs offer residence rights in exchange for a payment, typically with a path to citizenship. These are more common and include plans from the U.S., Brazil, Saudi Arabia, and Australia, among others.

Note: Precise data for wealthy households is elusive, and Golden Visa programs open and close on a relatively frequent basis.


The U.S. EB-5 Program: A Pillar of U.S. Investment-Based Immigration

Launched in 1990, EB-5 initially required a $500,000 investment in Targeted Employment Areas (TEAs) or $1 million elsewhere, coupled with the creation of at least 10 full-time jobs.6 While EB-5 has fueled major infrastructure projects (e.g., $200 million for the Pennsylvania Turnpike), it has also faced scrutiny—such as in the $16.5 million ski resort fraud case in Vermont. 7

The EB-5 Reform and Integrity Act of 2022 reauthorized the program through 2027, adding new compliance requirements and an $800,000 investment in TEAs or $1.05M elsewhere.8


Economic Impacts and Innovation

These programs generate an estimated $22 billion annually and have helped countries like Portugal stabilize their post-bailout economy in 2012, or the UAE to bolster its property market and diversify its economy.9,10

For investors, benefits include:

    • Pathways to residency and citizenship
    • Access to education, healthcare, and visa-free travel
    • Potential tax advantages

Greece, for instance, offers Schengen Area access to 29 countries for a €250,000 investment,11 while the U.S. EB-5 can result in a green card and eventual citizenship.

A new visa program has been floated this year. The “Gold Card” is under consideration by the current administration for ultra-wealthy applicants. It would introduce a $5 million visa without job creation requirements. This program aims to generate significant capital and reduce the budget deficit, but it is not without its implementation challenges.12

Another innovation being considered by U.S. members of Congress is a $1M visa to finance local disaster-recovery efforts. Proceeds from these visa payments in the form of low-cost, long-term loans would be deployed to finance states and regulated financial institutions. This proposed program’s proceeds would be managed by institutions regulated by FINRA and the SEC, diminishing any lingering fraud concerns. 13


Recent Trends

Multiple jurisdictions are instituting stricter immigration controls to reduce the occurrence of corruption, tax evasion, money laundering, and organized crime.

The following modifications highlight how countries are evolving their investment visa programs to compete for wealthy immigrants.

    • Portugal eliminated its real estate visa path in favor of fund investments, easing housing pressures. Notably, it also requires only seven days of annual residency.14
    • Greece expanded its RBI program by introducing an investment option in startups and raised its minimums in urban centers to support local housing needs.15
    • Canada’s 2013 Startup Visa encourages entrepreneurs to settle and create high-potential ventures; its migration component makes job creation and obtaining permanent residency easier.16
    • New Zealand’s “Active Investor Plus” visa prioritizes direct investments and recently instituted a lower residency requirement, lower investment minimums, a simplified investment process, more flexible investment options, and dropped an English language requirement.17
    • Several Caribbean nations have also agreed to share data to prevent misuse of CBI programs and reduce financial crime risks.18

Key Takeaway

Investment visas have become central to global mobility strategies for the affluent, offering residency or citizenship in return for capital. While they vary widely in structure, these programs have attracted hundreds of thousands of high-net-worth individuals and billions in foreign direct investment. One can expect that these programs will continue to evolve as nations adjust and refine their offerings, balancing investor appeal with national priorities under increasing regulatory scrutiny.

 

  1. Henley & Partners, “Private Wealth Migration Report 2024
    2. Council on Foreign Relations, “Golden Passports and Visas: How Investment Migration Works,” 2024
  2. Global Financial Integrity, Citizenship by Investment
    4. Henley & Partners, “The Henley Private Wealth Migration Report 2024”
  3. Henley & Partners, “Investment Migration Countries”
  4. USCIS, “About the EB-5 Visa Classification”
  5. Vermont Public Radio, “EB-5 Fraud Case in Vermont,” 2016
  6. Congressional Research Service, Legislative Changes to the EB-5 Immigrant Investor Program”
  7. BreakingAC.com, How Portugal’s Golden Visa Opened the Door to Europe for Thousands of Investors”
    10. Gulf Business, “How the UAE’s golden visa has made a positive impact” 2024
  8. Harvey Law Corporation, “European Residency: How €250,000 Opens Up a Pathway to EU
  9. KPMG, United States – Trump’s ‘Gold Card’ and Implications for Global Mobility Tax,” 2025
  10. Carofin, LLC
  11. Nomad Capitalist, Portugal Golden Visa 2025: The Ultimate Guide”
    15. Investmentvisa, “Greece’s Golden Visa Program Continues Despite Rumors” 2024
  12. Government of Canada, “Start-Up Visa Program,” 2024.
  13. Henley & Partners, New Zealand
  14. IMI, “4 of 5 Caribbean CIPs Sign MoU on $200,000 Price Floor, Discounts-Prevention, Closer Regulatory Integration” 2024

 

 

Image by Judit Herbert from Pixabay

 

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