Citizenship as a Service

In the Lesser Antilles of the Caribbean Sea sits the dual-island nation of Saint Kitts and Nevis. With a present population of just 50,000, the former British colony became one of the smallest sovereign states in the world when it acquired independence in 1983. To outsiders, it was once best known for a stop on luxury cruise lines and the birthplace of Alexander Hamilton—a minute’s walk from the Nevis ferry terminal. 

Today, it’s famous for its passport. Holders can travel to more than 150 countries without applying for a visa in advance. But you don’t need to be from Saint Kitts and Nevis to acquire one: for a one-time donation of $250,000, plus some additional fees and a few months of wait, almost anyone can be a Kittitian, at least in the eyes of the law, without ever setting foot in the country.

Saint Kitts is not alone in the ever-expanding “citizenship by investment” business. Its West Indian neighbors—Antigua and Barbuda, Dominica, Grenada, and Saint Lucia—all either launched or revived their economic citizenship programs in the early 2010s, followed in 2016 by Türkiye, which now grants citizenship to investors with a minimum qualified investment of $400,000. Similar programs are found in Vanuatu, a nation made up of around 80 islands in the South Pacific. Even citizenship in the exclusive EU can be bought, through investment-based naturalization programs offered by smaller member states such as Cyprus (until 2020) and Malta.

But there’s something special about Saint Kitts. Its government relies on passport sales as a primary contributor to revenue; in a way, passports are the country’s largest export. Between 2015 and 2022, the Saint Kitts government naturalized some 35,000 citizens through its investment program—meaning in a matter of years, their nation will likely have more economic citizens abroad than it does residents at home. Saint Kitts is a passport island: its prosperity is now intricately linked with the precarious marketplace of global mobility.

At the end of the 20th century, most of the farmland in Saint Kitts and Nevis still produced sugar cane. It made up some 20 percent of the country’s total exports, in a reminder of its colonial past. Its historical significance aside, sugar production had become vastly unprofitable across the Caribbean, where financial losses were only mitigated by preferential, subsidized access to the EU market. Brussels eventually ripped the band-aid in 2005, lowering the inflated price tag of imported sugar and forcing the industry’s closure in Saint Kitts. 

As the Saint Kitts and Nevis government sought economic relief, a Swiss lawyer named Christian Kälin came to the rescue. Born in Zurich, since the 1990s Kälin had been with Henley & Partners, a consultancy specializing in residence and citizenship planning. The firm had initially focused on helping wealthy clients optimize their tax situations through strategic residence planning, but Kälin—an obsessive reader of citizenship laws since a young age and himself the holder of at least five passports—recognized a broader opportunity to remake citizenship itself as fluid, flexible, and global. In Kälin’s view, citizenship was more than an inheritance: it ought to be a flexible instrument of personal agency. To get there, he wanted legal pathways that allowed individuals to pick and choose their national affiliations. By 2005, Saint Kitts and Nevis presented a viable laboratory for this vision—not just because the micro-nation needed the money, but also for the convenient fact that it’d already written citizenship by investment into law.

When Saint Kitts and Nevis declared independence from Great Britain in 1983, its sovereignty was in flux. The 1984 Citizenship Act, which minted former British subjects living on the islands citizens of the sovereign federation, also granted citizenship to any person who “has invested substantially” in the country. The concept was, even at the time, controversial: Former education minister Clarence Fitzroy Bryant, writing in The Labour Spokesman, warned in February 1984 that politicians would “make millions out of hawking St. Kitts citizenship and St. Kitts passports in the underworld marketplaces of the world, inhabited by kidnappers, drug-pushers, thieves and murderers.”

Is a timely, vital economic contribution to a hurricane-ridden island any less meaningful a way to connect to a country than earning US citizenship through birth tourism?

Bryant’s fear that international criminals would be the new federation’s flag-bearers was not unwarranted. The passport’s earliest buyers included drug smugglers who purchased Saint Kitts and Nevis passports—sometimes blank ones—from Dr. William V. “Billy” Herbert, the nation’s ambassador to the United Nations often credited with the program’s creation. But it was also advertised to less controversial client bases, such as the Hong Kong businessmen who, as Margaret Thatcher signed off the city’s handover to China in 1984, sought “Plan B” passports despite having no immediate desire to leave the city.

In the 1980s and 1990s, Saint Kitts and Nevis was hardly the only country advertising passports to the wealthy non-Western elites seeking political insurance. Investor visas for Canada were enticing, and the United States established its EB-5 immigrant investor program in 1990, but naturalization typically required physical residency. Passports from distant, lesser-known countries—Samoa, Belize, Honduras, Sierra Leone, and the Marshall Islands—were only a signed check away. In some cases, passports were sold without the legal rights attached to them: the Polynesian monarchy of Tonga issued passports to “protected persons” who weren’t granted citizenship at all. As Kristen Surak noted in her 2023 book The Golden Passport, many sales during this period were made by entrepreneurial diplomats, often without approval or legal basis from the authorities back home; a new ambassador, or a change in government, meant that these passports wouldn’t be renewed. 

So when Basseterre’s politicians and Kälin’s firm Henley sought to profit off Saint Kitts’ economic citizenship clause in the 2000s, they knew the program had to stand out in a messy, largely unregulated marketplace. Kälin’s secret sauce was formalization, to convince North Americans and Europeans that Saint Kitts’ investor citizens were not just wealthy, but also upright. To turn economic citizenship into a transparent, streamlined process, Henley designed application forms, built vetting mechanisms, and hired agents to source clients around the world. It was no longer government officials endorsing passports (and collecting checks) as they wished; a citizenship by investment unit handled due diligence, and the donations went to the Sugar Industry Diversification Foundation. After Saint Kitts and Nevis, today Henley has advised governments from Antigua and Barbuda to Malta and Cyprus, while quickly going down the list of all sovereign countries to replicate the pipeline. The success has earned Kälin an accolade, the “passport king.” 

In liberal societies, the eligibility for citizenship has traditionally been a debate of rights (to abode, suffrage, and benefits) and obligations (military service, taxes, and jury duty). To be a citizen is to be in a social contract with one’s political community, or to borrow Hannah Arendt’s words, “the right to have rights” within a nation’s borders. Since globalization, such exclusivity has been in flux: As Yossi Harpaz aptly noted in his study of dual nationals, citizenship status is increasingly viewed as an asset, “a domain for individual free choice and maximization of utility” divorced from traditionally sanctified connotations. 

Golden passport schemes further complicated the nature of citizenship by rendering what many consider a prized identity into a market commodity. Early objections to Saint Kitts and Nevis’ investor citizenship clause weren’t just concerned about criminality, but the nature of citizenship itself: Lee L. Moore, leader of the Saint Kitts and Nevis Labour opposition, warned in February 1984 that the proponents of the controversial Citizenship Act were “selling the birthright of the people in the marketplace.” The United States and Canada had investor visa programs, Moore said, but to become a full citizen one would have to live there and take an oath of allegiance. In 2016 Roberta Metsola, the Maltese president of the European Parliament, bashed her own country’s passport scheme. “The sale of citizenship without any tangible connection to a member state is something that is of concern,” she said. “European citizenship confers certain rights which should simply never just be put up for sale.” Whether it is Moore’s 1984 appeal to birthright, or Metsola’s call for “tangible connection” as a prerequisite for European citizenship, the repackaging of a modern polity’s fundamental membership into a price-tagged product is met with discontent.

In a digitally networked, increasingly financialized world, it doesn’t matter where these offshore havens are—au contraire, they’re defined by where they’re not.

But that “tangible connection” has always been liberally interpreted, argued Henley’s Kälin. He maintained in his doctoral dissertation that all bestowals of citizenship—whether by birth on a nation’s soil (ius soli) or by blood (ius sanguinis)—are arbitrary, as many have never lived in the country that issued them a passport. Economic citizenship, or ius doni, is no less arbitrary. Some countries naturalize athletes to recruit them to their teams at the Olympics; others confer citizenship to members of the diaspora whose ancestors left generations ago. Is a timely, vital economic contribution to a hurricane-ridden island any less meaningful a way to connect to a country than earning US citizenship through birth tourism, or applying for European passports by ancestry?

Implied in Kälin’s question, then, is a leap of faith—that “tangible connection” doesn’t have to be bodily. Economic citizens of the Caribbean shuttle between international airports in Europe and Asia with passports issued by a country they can’t pinpoint on a map; they rarely visit, let alone move to, their newly adopted homeland. The obscurity of Saint Kitts, Dominica, or Vanuatu on a world map doesn’t bother buyers, either. The passport merely serves as a springboard for another jurisdiction, a replacement for a hard-to-use document. In a few public cases, a Chinese restaurateur became a citizen of Saint Kitts and Nevis to take her company public in Hong Kong, as did an Egyptian travel YouTuber to avoid visa complications. Economic citizens I’ve known include expats in London, who desired visa-free access to the Schengen area, and those in Dubai, where naturalization is nearly impossible. Malta’s investor citizens aren’t there for Malta exactly—they’re eyeing Berlin and Paris. What is being sold, after all, isn’t status within the issuing country’s borders, but exemption in another’s.

Kälin’s industry has already turned passports, once a symbolic social contract with a nation-state, into collectibles for the wealthy—ones that can be acquired, quantified, and optimized. The consultants at Henley now publish global rankings of passports that allow you to compare your passport against the world’s most powerful (Singapore, with 193 visa-free destinations). Andrew Henderson, founder of the immigration consultancy Nomad Capitalist, advised his prospective clients to create a “passport portfolio”—by investment, descent, or naturalization—to maximize travel options, minimize tax obligations, mitigate geopolitical risks, and optimize for global mobility. In recent years, the Caribbean options are no longer exclusive to millionaires with weak passports; North Americans and Europeans are picking up economic citizenships too. Some do so to rid themselves of tax burdens—a common case for US expatriates trying to renounce their original citizenship—and others, like the Hong Kong businessmen in the 1980s, simply want a “Plan B.”

The disembodiment of sovereign rights is hardly confined to citizenship alone. Today, more than 8,000 cargo ships traversing international waters fly Panama’s flag of convenience; the world’s most profitable companies have Cayman Islands bank accounts, thanks to its status as a tax-free jurisdiction. In lucky places like Anguilla and Tuvalu, internet domain names—.ai and .tv—have created new sources of income. In a digitally networked, increasingly financialized world, it doesn’t matter where these offshore havens are—au contraire, they’re defined by where they’re not. New York and London’s multinational companies operate inside Bermuda’s postal boxes; their business transactions are carried out in Ireland; it only made sense that their owners, too, are under the jurisdiction of governments that have little physical jurisdiction over them. The territories are, by design, virtual.

For small, postcolonial island nations, being a pass-through node in the global economy is not just lucrative, but often critical to their survival. In Saint Kitts and Nevis, the citizenship unit earned $5.26 million in 2009, amounting to less than 3 percent of the government’s total revenue that year; by 2012, those proceeds reached $52.22 million, or 24 percent of total revenue. A decade later, in 2022, the passport program collected $247.91 million, responsible for nearly 60 percent of the government’s annual income. (For every donation, the exclusive marketing agent—first Henley, and later its competitors—took a cut from every donation that was made to the government.) After Dominica was severely hit by Tropical Storm Erika in 2015, citizenship by investment income financed its reconstruction; the same went for the island of Barbuda, where residents evacuated after Hurricane Irma destroyed most of the buildings in 2017. 

But the business might prove difficult down the line. Political scandals around these programs are rampant: Cyprus shut down its program in 2020 following revelations that its officials naturalized criminals and fugitives; citizenship by investment stakeholders in Saint Kitts and Saint Lucia are involved in a RICO (Racketeer Influenced and Corrupt Organizations Act) lawsuit in the US for alleged instances of fraud, corruption, and kickbacks. Jho Low, the Malaysian fugitive who embezzled billions from a government fund, held citizenships from Cyprus and Saint Kitts before both authorities revoked them; in Singapore’s largest money laundering case, convicts held passports from Turkey, Vanuatu, and Dominica. The European Union took Malta to court for selling EU citizenship in 2022. And in 2023, the United Kingdom suspended visa-free travel for citizens of Vanuatu and Dominica, citing their citizenship by investment schemes; most recently, in 2024, the EU permanently ended its visa-free agreement with Vanuatu. 

These risks, substantiated or otherwise, have left passport islands—whose economies heavily rely on passport sales—in a precarious position. Since the value of these passports lies in their travel freedom, governments and their citizenship units responded by remolding their programs to mitigate international concerns. Caribbean governments, for example, signed a memorandum last year to increase prices—to a minimum investment of $200,000—and strengthen the screening process of applicants, having already barred Russian and Belarusian nationals from applying after Putin’s invasion of Ukraine. 

Ironically, European and North American concerns only highlight the asymmetries of the postcolonial liberal world order—one that gave birth to economic citizenship programs in the first place. The fear that wealthy foreign criminals may travel to Frankfurt without a visa is understandable, but America and England produce plenty of born-and-bred lawbreakers endowed with visa-free privileges. Mobility and sovereignty are granted automatically to the West; for both the Hong Kong entrepreneur and the Antiguan politician, they require careful, creative negotiation. In a world with unfair borders, citizenship by investment is but a service for a wealthy minority among the global majority—a $250,000 tax that puts them on equal footing.

Despite all the normative doubts, buying one’s way in will remain possible. President Donald Trump has vowed to replace the EB-5 investor visa program, which currently requires a minimum investment of $800,000, with a “gold card” scheme that will sell US permanent residency for at least $5 million. Its discontents aside, it’s unlikely that the commodification of mobility will go away; instead, regulatory pressures on these programs—along with increased geopolitical uncertainty and the financial lucrativeness for the industry—will only turn them into more exclusive products, raising the threshold for participation in the global marketplace of mobility.

In the Pacific, the Republic of Nauru is facing existential threat from rising sea levels. Its government has recently decided that it will sell passports to foreigners to fund the relocation of its citizens. It has fewer visa-free countries, ranked 55th worldwide in Henley’s index, but it’s also cheaper than the Caribbean options, starting at $105,000. But what will virtual citizenship look like when the land itself goes under water? As Nauru’s natives expect their descendants to truly become citizens of nowhere, what will remain of the “Plan B” passports that their government has granted to gracious donors?