Citizenship-by-Investment Programs and Their Restricted Nationalities

Five of the 13 active citizenship-by-investment (CBI) programs publicly identify the nationalities they will not accept. The remaining eight exclude certain applicants without publishing the relevant nationalities.

That distinction matters to anyone deciding where an application can be filed. An Iranian applicant, for example, can review Grenada’s published rules and determine the position relatively quickly. There is no equivalent public list for Egypt or Jordan.

Three other active CBI programs — in Samoa, Sierra Leone, and Pakistan — are not covered by the tracker on which this analysis is based and are therefore outside the scope of this article.

Malta is excluded for a separate legal reason. On April 29, 2025, the Court of Justice of the European Union ruled in Case C-181/23 that Malta’s investor citizenship route breached Article 20 TFEU, describing the scheme as “the commercialisation of the grant of the nationality of a Member State”.

Antigua and Barbuda

The Citizenship by Investment Unit maintains a Restricted Countries List on its FAQ page. The list was last updated following a Cabinet decision dated February 26, 2020, and includes Afghanistan, Iran, North Korea, Somalia, Sudan, and Yemen.

Applicants from all six countries may nevertheless qualify under the same exception: they must have been born in the restricted country but have emigrated before reaching the age of majority.

A further route is available to people who have held permanent residence for at least ten years in a country outside the restricted list, provided they have no economic ties to a restricted country.

Two additional nationalities are subject to restrictions that do not appear on that published list. Russian and Belarusian applications were suspended effective July 28, 2022, after a short reopening beginning July 8. Those nationalities are still treated as ineligible, even though neither appears on the Restricted Countries List.

Ukraine illustrates the opposite problem. Applications from Ukrainian nationals were suspended in March 2022 because the authorities said they could not adequately conduct applicant vetting in the country. Applications resumed in 2024, and the unit's own half-year report subsequently recorded 19 applications from people born in Ukraine.

Neither the suspension nor its reversal was reflected in the published Restricted Countries List. Ukraine was never added to it.

Dominica

Dominica maintains a separate page identifying banned nationalities. Belarus, Russia, and Yemen are subject to outright bans. The same applies to “Northern Iraq”, which the page defines by reference to nine cities in the Kurdistan region: Erbil, Amedi, Dahuk, Kirkuk, Lalish, Raniya, Soran, Sulaymaniyah, and Zakho.

The use of a sub-national geographic definition is unusual. Rather than excluding Iraqis as a nationality, the rule identifies specific locations within Iraq.

Applicants from Iran, North Korea, and Sudan face a conditional restriction. They may qualify if they have lived outside the relevant country for at least ten years, hold no substantial assets there, and have no business dealings either in the country or with it.

The prohibition on Yemeni applicants is supported by a dated circular. The other restrictions published on the page are stated as policy without reference to a specific legal instrument.

Grenada

Grenada's Investment Migration Agency issued Circular No. 1 of 2024 on March 25, 2024, with effect from April 1. It identifies seven countries whose residents are described as ineligible “without exception”: Iran, North Korea, Russia, Belarus, Sudan, Yemen, and Afghanistan.

The wording is significant. The restriction applies to people residing in those countries rather than simply to their nationals, making the applicant's place of residence relevant alongside nationality.

The same circular creates exceptions for four of the seven jurisdictions. Applicants from Iran, Sudan, Yemen, and Afghanistan may qualify if they emigrated before reaching adulthood or have maintained permanent residence or a valid visa for at least ten years in Canada, the United Kingdom, a Schengen state, the United States, Australia, New Zealand, Saudi Arabia, or the United Arab Emirates.

Additional requirements apply. The applicant must have no economic ties to any restricted country, and the due diligence providers must be able to conduct an investigation inside the relevant country. The circular notes that this may result in considerably higher costs for the applicant.

The rules do not specify a comparable route back for applicants from North Korea, Russia, or Belarus.

Grenada's approach also differs from the other Caribbean programs. It expressly identifies the countries where qualifying residence can satisfy the exception. Antigua and Barbuda, by contrast, refers generally to residence outside its restricted list, while Saint Kitts and Nevis provides no such exception.

Saint Kitts and Nevis

The Citizenship by Investment Unit lists six countries whose nationals are ineligible: Afghanistan, Belarus, Iran, Iraq, North Korea, and Russia. The stated basis for the restrictions is “national security and public safety”.

There are two notable differences between this list and those maintained by the other Caribbean programs discussed here.

First, the rules provide no exception for applicants who have subsequently established residence elsewhere. Second, Iraq is treated as a country in its entirety. This contrasts with Dominica's approach, which identifies nine specific cities in the Kurdistan region.

El Salvador

El Salvador is the only program in this group outside the Caribbean to publish a restricted list. Its website uses the term “Prohibited Jurisdictions”, which more precisely reflects the scope of the restrictions.

The list includes Cuba, North Korea, Iran, and Syria, as well as Crimea and the self-proclaimed Donetsk, Luhansk, Kherson, and Zaporizhzhia republics. Individuals appearing on the OFAC sanctioned persons list are also excluded.

Four of the listed entries are territories rather than countries. As a result, the restriction can depend on where within a country an applicant originates, an approach that is comparable to Dominica's treatment of Northern Iraq.

The Four Caribbean Lists Do Not Match

The four Caribbean programs are the most directly comparable because they operate in the same region and have published nationality restrictions. Across them, nine nationalities appear in total, but none is listed in exactly the same form by all four programs.

Iran and North Korea have the broadest overlap: all four programs identify both. Saint Kitts and Nevis imposes an outright refusal on each. Grenada applies an outright restriction to North Korean applicants but provides a route back for Iranians, while Antigua and Barbuda and Dominica impose conditions on both.

Russia and Belarus appear on three of the four lists, with Antigua and Barbuda being the exception. Sudan and Yemen are likewise listed by three programs, this time with Saint Kitts and Nevis as the outlier.

Somalia appears only on Antigua and Barbuda's list.

Iraq is included by two programs, but their definitions are materially different. Saint Kitts and Nevis excludes the entire country, whereas Dominica identifies nine cities within the Kurdistan region.

The published lists therefore do not capture every nationality-related decision made by these programs. Antigua and Barbuda demonstrates the gap particularly clearly: restrictions on Russian and Belarusian applications were introduced through separate measures and never incorporated into the Restricted Countries List. The same is true of the later resumption of applications from Ukrainian nationals.

In March 2026, the treatment of Iranian applicants across the five Caribbean CBI programs was also reported as divided along similar lines, with Saint Lucia joining Saint Kitts and Nevis in imposing an outright refusal.

Programs That Restrict Applicants Without Publishing a List

The absence of a public list does not necessarily mean that a program has no nationality restrictions.

Publishing detailed vetting rules can also reveal too much about how an application is assessed, while sanctions and other nationality-related designations can change more quickly than official websites are updated.

For applicants, however, the practical issue remains the same: an unpublished restriction is difficult to assess before filing an application, making it impossible to determine the cost and feasibility of a route from publicly available rules alone.

Nauru Relies on an External Definition

Nauru's eligibility criteria state that an applicant must not be “a citizen of a country which is listed in the United Nations Security Council Resolution as a high-risk country”. The criteria do not identify those countries individually.

This restriction appears on the program's website rather than in its governing legislation. The Naoero Economic and Climate Resilience Citizenship Act 2024 bases eligibility on factors including age, the required contribution, and compliance with program requirements, without establishing a nationality-based test.

A similar nationality provision does appear in the legislation, but in the context of revoking citizenship after it has been granted. It applies where a person subsequently acquires citizenship of a listed country and does not expressly address someone who was already a national of such a country when applying.

The practical effect is that the relevant restricted set can change when the underlying Security Council designations change. The program itself does not necessarily need to issue a new circular or notify applicants during the processing of an application.

Turkey Uses Property Eligibility Rules

Turkey does not maintain a separate excluded-nationality list for its citizenship-by-investment route. Instead, the restriction operates through the property rules underlying the USD 400,000 investment route.

Law No. 6302 of 2012 replaced the previous reciprocity test and transferred responsibility for determining which foreign nationals may acquire property to the Cabinet.

A nationality omitted from the permitted list is therefore effectively excluded from the citizenship route without appearing on a separate restricted-nationality list.

The decision identifying the permitted nationalities does not appear to be publicly available. The investment authorities confirm that the relevant determination is made by the Cabinet of Ministers.

Egypt, Jordan and Saint Lucia

Egypt's General Authority for Investment described eligibility as subject to approval from “the relevant security authorities, considering national security considerations”, without identifying particular nationalities. That page is no longer available, although the wording remains visible in an archived version.

Jordan's Ministry of Investment publishes detailed eligibility criteria for its investor citizenship route, but those criteria do not identify any nationality as excluded.

By the middle of 2026, the program had granted citizenship to 685 investors. Syrian and Iraqi investors were reported as the leading recipient groups.

That produces a notably different outcome from the Caribbean programs. Iraqi applicants are excluded outright by Saint Kitts and Nevis and subject to restrictions in Dominica, while Iraqi nationals were among the largest groups receiving Jordanian investor citizenship.

Saint Lucia's website contains one nationality-related statement: a 2022 notice referring to a memorandum dated March 18, 2022, which suspended applications from Russian and Belarusian nationals and stated that the measure remained in force. The published legislation does not identify any nationality.

Iranian applicants are also reportedly subject to an outright restriction in Saint Lucia, although that restriction does not appear on the program's own website. The practical consequence is that an Iranian applicant may be subject to a rule that cannot be identified from the publicly available program materials.

Vanuatu

Vanuatu's Citizenship Office does not publish an eligibility page identifying restricted nationalities.

Its legislative framework page links to the Citizenship (Development Support Program) Regulations Order No. 33 of 2019 and Orders No. 38 and 39 of 2020. These documents are available as scanned PDFs without searchable text.

As a result, a reader cannot readily establish from the published material whether those orders contain a nationality-based restriction.

Cambodia and Sao Tome and Principe

Cambodia's nationality law does not prohibit applicants on the basis of nationality. Instead, it states that naturalization is “not a right of the applicant, but only a favour of the Kingdom of Cambodia”, leaving the decision to the government's discretion without specifying where the relevant boundary lies.

The sub-decree establishing the investment route is also available only as a scanned image. It is therefore not possible to determine from the published version whether it introduces a separate nationality restriction.

Sao Tome and Principe takes a different legislative approach. Article 17 of its 2025 decree-law, titled Limitacoes por Nacionalidade, gives the Government authority to declare applicants inadmissible if they originate from countries subject to sanctions it has ratified or from countries without effective judicial cooperation.

The provision itself does not identify any countries. Instead, it leaves the actual list to a resolution of the Council of Ministers, and no such resolution appears to have been published.

Restricted Lists Can Change Quickly

On March 10, 2026, a restriction reportedly appeared in Vanuatu covering Russian and Sudanese nationals. The Citizenship Office withdrew the addition the following day, describing the memo that introduced it as a clerical error.

Grenada experienced a similar episode in December 2023. A government minister told the Senate that the program was open to applicants of every nationality. The unit corrected that statement the next day, confirming that Russia, Belarus, North Korea, and Iran remained restricted.

By March of the following year, the list had expanded from four countries to seven, while Iran had moved from an outright restriction to a conditional route.

Antigua and Barbuda demonstrates how the same problem can persist for years. Its Cabinet last updated the published list in February 2020. Separate restrictions affecting Russia, Belarus, and Ukraine were introduced in 2022 without being added to that list, and the subsequent resumption of Ukrainian applications was likewise not reflected there.

What Is Driving the Changes

The European Union introduced an additional consideration in December 2025. Regulation (EU) 2025/2441, published in the Official Journal on December 10, 2025 and effective from December 30, provides for a citizenship-by-investment program to constitute an independent ground for suspending a country's visa-free access to the European Union.

On June 25, 2026, Magnus Brunner, the European Commissioner for Internal Affairs and Migration, wrote requesting that the relevant programs be phased out by June 1, 2028. Antigua and Barbuda confirmed receipt of the letter and stated that the other four Eastern Caribbean programs had received one as well.

The letter constitutes a request rather than a legal requirement.

The United States took a different approach. Draft measures circulated in March and June 2025 identified several citizenship-by-investment jurisdictions, including Saint Kitts and Nevis, Saint Lucia, Vanuatu, and Cambodia.

The proclamation issued on December 16, 2025 removed those countries from the measure while retaining citizenship-by-investment language concerning Antigua and Barbuda and Dominica, which had also appeared in the earlier drafts.

The five Eastern Caribbean programs subsequently established a joint regulatory framework. In September 2025, all five signed the agreement creating the Eastern Caribbean Citizenship by Investment Regulatory Authority and subsequently enacted it domestically.

The authority had not yet commenced operations at the time of publication.

If Your Nationality Is Restricted

The first step is to examine the program's own published rules rather than relying solely on summaries elsewhere. For the five programs that publish nationality restrictions, those materials are the documents available to applicants when assessing eligibility.

The exceptions can be just as important as the prohibitions. Three of the four Caribbean lists provide a route for certain restricted nationals based on the length of time spent outside the restricted country, while Grenada specifically identifies the eight jurisdictions in which qualifying residence can be established.

Where a program publishes no nationality list, the position must instead be determined through the program's own eligibility and vetting process. The absence of a published restriction does not itself guarantee eligibility. At the same time, Jordan's experience with Syrian and Iraqi applicants illustrates that an unpublished nationality policy may also operate in an applicant's favor.

Four of the five programs that publish restricted-nationality lists are based in the Eastern Caribbean. All four fall within the group addressed by the European Commission's request for a phase-out by June 1, 2028. If that date remains in place, it would affect a substantial portion of the publicly documented CBI market.

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