Golden visas and investor citizenship
How can golden visas and citizenship by investment be used for money laundering?
Golden visas and citizenship by investment trade residence or a passport for money. Most applicants are legitimate, but weak checks on the source of funds let people with illicit wealth gain a new identity, easier banking, and a cover story for large transfers. The UK closed its scheme in 2022, and the EU's top court struck down Malta's in 2025.
As of October 2026: Legal and policy positions are stated as of October 2026. The OECD's list of schemes of concern changes over time and addresses tax transparency, not money laundering. Malta's scheme was ruled unlawful in April 2025; later changes to Maltese law were not independently verified for this page. Other EU programmes and non-EU programmes vary by country and change frequently.
What are golden visas and citizenship by investment?
A golden visa lets a foreigner gain residence in a country by investing there. A “golden passport” goes further and grants citizenship. Experts call them residence by investment (RBI) and citizenship by investment (CBI) programmes. The first modern scheme was launched by St. Kitts and Nevis in 1984, according to the joint report from the FATF (the global anti-money laundering standard-setter) and the OECD. Since then the sector has grown into a multi-billion-dollar business, and the European Parliament estimated that between 2011 and 2019 more than 132,000 people gained residence or citizenship in EU states this way, with at least EUR 21.4 billion invested.
Many applicants are legitimate. They may want stability, easier travel, schooling for their children, or a base for a new business, and the OECD’s own web page says the schemes can serve “perfectly legitimate reasons.” The problem is narrower: a programme that sells status for money has to decide how closely to examine the money. Where it does not, the programme can become a laundering and sanctions-evasion route. For that reason authorities group this topic with professional enablers and real estate, the two things that most programmes rely on.
How does the risk arise?
The FATF/OECD report of November 2023 sets out the threat in three groups. Criminals may seek to launder illicit funds through the programme itself, or use the status to commit further crimes. Intermediaries in the investment migration business, such as agents, wealth managers and property developers, may commit fraud, bribe officials or launder money. And corrupt officials may profit from bribes in programmes with weak governance.
The report lists what a new status can give a person who wants to hide wealth or avoid law enforcement:
- A new identity on paper. A new nationality, with new documents, can change a person’s birth or nationality records and make it harder for banks to carry out accurate due diligence at onboarding.
- Freedom to move. A new passport can provide visa-free travel and a way to leave a country where an investigation is under way.
- Access to banks and companies. Status can make it easier to open accounts and set up companies in jurisdictions with weaker transparency, and a domestic customer may face less scrutiny than a foreign one.
- A cover story for large transfers. The report says residence programmes can justify large cross-border capital flows that would otherwise raise red flags.
- A place to put family and assets. Moving relatives and assets overseas can hinder asset recovery.
The investment itself can also be misused. The report describes fraudulent investment schemes run by intermediaries, and property purchases at inflated prices. In one case study from Cyprus, investors paid prices well above estimated market value and part of the money was then returned to the investor’s foreign account, so the investor had in fact invested less than the programme required. This is the kind of pattern examiners are trained to spot.
Why does it work?
The report points to governance more than to cleverness. Programmes are vulnerable when vetting by government or private providers is weak, when there is little monitoring after approval, when there is no way to revoke a passport if a holder’s risk profile changes, and when public and private sectors do not share information. It adds that illicit actors may “forum shop” between programmes, picking those with lighter checks or lower cost.
Many parties play a part too. Programmes involve government agencies and private marketing, property and concierge firms, and the report warns that malign interests can infiltrate programmes where roles of public and private actors are unclear and conflicts of interest are poorly managed. Criminal, negligent or complicit property agents, wealth managers, immigration agents and concierge firms can fail to do their own due diligence, or create misleading evidence for applications.
Timing matters as well. The report notes that illicit actors may obtain status as an insurance policy before committing crimes, or before their offences are discovered. That makes checks at the time of application important, and also ongoing monitoring afterwards.
Tax transparency is a separate risk
The OECD list that people often call the “high-risk list” is about tax, not money laundering. The OECD says it has analysed over 100 schemes and flags those that offer a low personal income tax rate on offshore assets and do not require a significant stay, since documents from those schemes could be used to misstate tax residence and weaken reporting under the Common Reporting Standard, the OECD system for automatic exchange of bank account information. The November 2023 report said 22 schemes were identified at that time. When this page was checked in October 2026 the OECD list showed three residence permits issued by Panama. The two ideas overlap, but a scheme can be on the tax list without being a laundering risk and vice versa.
Real cases: the UK review and the Malta ruling
The UK’s Tier 1 (Investor) visa. The UK launched the route in 2008, requiring applicants to show access to 1 million pounds to invest. The government closed it to new applicants on February 17, 2022, saying some cases gave rise to security concerns, including people who had acquired wealth illegitimately and were associated with corruption.
In a January 2023 statement, the Home Secretary summarized a review of the 6,312 migrants and adult dependants who obtained leave between June 2008 and April 2015. The review identified a small minority potentially at high risk of having obtained wealth through corruption or other illicit finance or of involvement in serious and organised crime. The statement stressed this did not prove guilt. It reported that the route had attracted a disproportionate number of applicants from countries the UK’s 2020 national risk assessment flagged as relevant to money laundering risk, and that there was evidence of high-risk applicants seeking out financial institutions with the weakest due diligence. The government said it had already sanctioned ten oligarchs who had used the route. It also concluded that the immigration system was not well equipped to detect financial crime, which calls for specialist skill.
Malta and the EU Court of Justice. In March 2022 the European Commission said that selling EU citizenship through “golden passports” was illegal under EU law and posed serious risks, including opening the door to corruption, money laundering and tax avoidance. It also urged member states to withdraw residence permits from sanctioned Russian and Belarusian nationals and to assess withdrawing citizenship. On April 29, 2025 the Court of Justice, in a case the Commission brought against Malta, held that Malta’s 2020 investor citizenship scheme infringed EU law because it amounted to the commercialisation of nationality and, by extension, of Union citizenship. The Court said a member state cannot grant its nationality in exchange for predetermined payments or investments.
How does it get caught?
The FATF/OECD report’s mitigation chapter, together with the UK and EU actions above, point to a layered response.
- Multi-layered due diligence. The report calls for checks by both private and public actors, with specific attention to the source of funds and wider wealth, the way funds are transferred, and the finances of accompanying family members.
- Ongoing monitoring and revocation. Because status may be obtained before crimes are committed or found out, the report stresses monitoring after approval and the power to suspend or revoke.
- Financial intelligence. In a case study from Malta, the financial intelligence unit received a report about a company brokering a transaction involving two foreign politically exposed persons, one of whom was also applying for citizenship by investment and was under corruption investigation abroad. The application was denied, and the people involved in the transaction were prosecuted for money laundering and corruption.
- Coordination. The report says domestic coordination among law enforcement, immigration authorities and financial intelligence units, plus international information sharing, is needed because the risks extend beyond the country that runs the programme.
- Sanctions and political decisions. The UK’s sanctions on oligarchs who had used its route, and the EU’s call to withdraw permits from sanctioned Russians and Belarusians, show how programme records become sanctions leads. The closure of the UK route and the court ruling against Malta show the most blunt response: ending the programme.
For how banks and regulators spot higher-risk customers more generally, see the detection overview.
Frequently asked questions
Are golden visas illegal?
No. Governments run them lawfully, and the FATF and OECD report acknowledges that many applicants earned their wealth legitimately and have benign reasons, such as stability, mobility or education for their children. The concern is that weak vetting makes the programmes attractive to people seeking to launder money or evade sanctions. In the EU, the Court of Justice has ruled that granting citizenship in exchange for predetermined payments, without a genuine link to the country, breaches EU law.
Why did the UK end its golden visa?
The government said the Tier 1 (Investor) route gave rise to security concerns, including people who had acquired their wealth illegitimately and were associated with corruption. A later Home Office review found that the route attracted a disproportionate number of applicants from countries the UK's national risk assessment flagged for money laundering risk, and that the immigration system lacked the specialist skill to detect financial crime. It said investment-based migration based on passive wealth carries inherent difficulties.
What is the OECD's list of high-risk schemes?
It is a tax transparency tool, not an AML blacklist. The OECD flags residence and citizenship schemes that offer a low personal income tax rate on offshore assets and need little physical presence, because their documents can be used to misstate tax residence under the Common Reporting Standard. A November 2023 report said 22 schemes were identified at that time. The OECD page checked in October 2026 lists three Panama residence permits, and the OECD says the list is updated on an ongoing basis.
What happened to Malta's scheme?
On April 29, 2025 the EU Court of Justice ruled that Malta's investor citizenship scheme, which granted nationality in return for predetermined payments or investments, infringed EU law. The Court said the acquisition of Union citizenship cannot result from a commercial transaction. Reports indicate Malta has since discontinued the programme, but this page has not independently confirmed the current legal status.
Related techniques
- Real estate · Parking illicit funds in property through shell companies, trusts, and all-cash purchases, then drawing the money back out as clean-looking rent or resale proceeds.
- Professional enablers · Lawyers, accountants, company formation agents, and real estate professionals whose ordinary services, knowingly or not, give illicit money a respectable paper trail.
- Shell companies and nominees · Companies with no real operations hold accounts and assets while nominee directors and stacked ownership across jurisdictions hide the true beneficial owner.
- Sanctions evasion · Hiding who really owns or benefits from assets and payments so sanctions do not bite, using many of the same tools as money laundering but often with lawfully earned money.
Glossary
Sources
- Misuse of Citizenship and Residency by Investment Programmes (joint FATF/OECD report) (FATF and OECD, November 2023).
- Residence/Citizenship by investment schemes (OECD, accessed October 2026).
- Commission urges Member States to act on golden passports and golden residence permits schemes, and to take immediate steps in the context of the Russian invasion of Ukraine (European Commission, March 28, 2022).
- Judgment of the Court in Case C-181/23, Commission v Malta (Citizenship by investment), press release No 52/25 (Court of Justice of the European Union, April 29, 2025).
- Tier 1 Investor Visa route closes over security concerns (UK Government (Home Office), February 17, 2022).
- The Tier 1 (Investor) route: Review of operation between 30 June 2008 and 6 April 2015 (written statement HCWS492) (UK Parliament (Home Office), January 12, 2023).