Choosing an adviser before the rules exist

The adviser you choose will see your bank statements, your family history and your tax returns. They will shape how your wealth is presented to the Argentine state. For most families, this is the most important decision before the application itself.

The difficulty is timing. Argentina announced its citizenship by investment programme on 2 October 2026, but it has not published how agents will be licensed or supervised. In most established programmes, only licensed agents may file, and the government publishes their names. Until Argentina decides its own model, you have to do the vetting yourself.

This guide does not name or recommend firms. It sets out the tests any good adviser should pass.

What other programmes require of agents

It helps to know what a regulated system looks like.

In St Kitts and Nevis, the 2024 regulations say applications may be submitted “only by an Authorised Agent”. Agents are authorised by the Citizenship Unit’s Board of Governors, must be based in the federation and renew their authorisation each year. The Unit publishes the list of authorised agents and a separate blacklist of firms it says have no association with it.

The same regulations ban certain marketing practices. Agents may not suggest that they can affect the government’s decision or the processing time. They may not offer “special discounts”, misstate the official fees or minimum amounts, or claim success numbers by country.

Dominica and Antigua and Barbuda also require applicants to apply through an authorised or licensed agent. Antigua’s Citizenship by Investment Unit publishes its list of licensed agents and a caution notice that tells applicants to rely only on licensed agents and approved providers.

None of these rules applies to Argentina. They show the standard a careful adviser should already meet.

Test 1: Licensing and professional standing

Ask what each person on your file is licensed to do, and where.

• Argentine law. Advice on Argentine nationality law should come from an Argentine lawyer. In the City of Buenos Aires, lawyers must be registered with the Colegio Público de la Abogacía de la Capital Federal under Ley 23.187. The Colegio publishes a lawyer guide on its website. Ask for the registration number and check it.
• Home-country regulation. If the firm is a law firm, wealth manager or accountant at home, ask which body regulates it. A complaint route matters if something goes wrong.
• Licences elsewhere. Many firms are licensed agents in Caribbean programmes. Check the claim on the government’s own list, not on the firm’s website.
• Blacklists and sanctions. Search official blacklists and court records for the firm and its principals.

A licence in another programme proves that a firm has passed someone’s checks. It does not prove that it understands Argentine law.

Test 2: Conflicts of interest

An adviser can be paid by more than one party. Ask for written answers to these points:

• Did the firm bid in the cancelled tender, sign any agreement with the Agency, or take part in government workshops? Is that relationship paid?
• Will the firm receive any commission, rebate or referral fee from anyone else connected to your application, such as a bank, a translator, a property developer or a bond placement agent?
• Does the firm sell other programmes that it may steer you towards?

Paid relationships are not wrong in themselves. Undisclosed ones are. Our briefing on the tender, consortium and advisers sets out what is publicly known about the firms around the programme.

Test 3: Fee structure

Professional fees in this market vary widely. The structure matters as much as the amount.

Ask what is included: document review, translations, apostilles, source-of-funds reports, government fees and due-diligence fees. Ask too what happens to fees already paid if the programme is suspended or the Supreme Court rules against the decree. A good engagement letter answers this before you sign.

Test 4: Client money and escrow

The government says all funds must move through the formal financial system. In practice, that means you should expect to pay the contribution or the bond subscription directly to an official account.

If an adviser asks to hold any of your money, ask:

• Is the account a regulated client or escrow account, in the name of a law firm or licensed escrow agent?
• Is there a written escrow agreement that states when the money is released and when it comes back?
• Which court or regulator would you turn to if it is not returned?

In St Kitts, for example, real-estate funds for incomplete projects are held on trust by the Unit or the applicant’s attorney until citizenship is granted, then moved to an irrevocable escrow account under a dedicated law. Argentina has no comparable rule yet. Our guide to refunds and escrow covers this in detail.

Red flags

Walk away, or at least slow down, if an adviser:

1. guarantees approval, or a fixed processing time;
2. claims influence with officials, or an “official” or “exclusive” status it cannot document;
3. offers a discount on the government price, or a cheaper “special route”;
4. asks you to pay the investment, or any large sum, before the rules are published;
5. asks for payment to a personal account, a third country unrelated to the firm, or in crypto-assets without a clear reason;
6. suggests you leave out a past visa refusal, a political role or an old business dispute;
7. proposes moving money through several accounts to make its origin look “cleaner”;
8. will not put its scope, fees and refund terms in a signed engagement letter.

Points 6 and 7 are not only red flags about the adviser. They can lead to refusal or, later, revocation. See application mistakes to avoid and our source of funds guide.

Questions to ask at the first meeting

• Who in your firm will work on my file, and what are their qualifications?
• Which Argentine lawyer will advise on the legal basis and the court case?
• What can you do now, before the portal opens, and what must wait?
• How will you document my source of wealth for the Agency, the UIF and SIDE?
• How will you keep my data secure, and where will it be stored?
• What is your plan if the Supreme Court confirms the June 2026 ruling?

An adviser who explains the legal status of the programme without being asked is a good sign. One who dismisses it is not.

The engagement letter

Before you pay anything, the engagement letter should state:

• the parties, including the legal entity that is responsible to you;
• the scope of work and what is excluded;
• every fee, with milestones and currency;
• the refund terms if the programme is suspended, changed or ruled invalid;
• the conflicts disclosed, and a promise to disclose new ones;
• confidentiality and data-protection terms;
• the governing law and the forum for disputes.

Sources

• Government of Argentina, programme announcement (2 October 2026): https://www.argentina.gob.ar/noticias/luis-caputo-anuncio-la-puesta-en-marcha-del-programa-de-ciudadania-por-inversion-de
• St Kitts and Nevis, Citizenship by Substantial Investment Regulations 2024 (SRO 20 of 2024), regulations 13 and 20 and Schedule 2: https://ciu.gov.kn/wp-content/uploads/2025/01/sro-20-of-2024.pdf
• St Kitts and Nevis Citizenship Unit, Authorised Agents: https://ciu.gov.kn/authorised-agents/
• St Kitts and Nevis Citizenship Unit, Blacklisted Agents: https://ciu.gov.kn/blacklisted-agents/
• Dominica CBIU, Economic Diversification Fund (application steps): https://www.cbiu.gov.dm/investment-options/economic-diversification-fund/
• Antigua and Barbuda CIU, caution notice: https://cip.gov.ag/how-to-apply/caution/
• Colegio Público de la Abogacía de la Capital Federal: https://www.cpacf.org.ar/
• BowTiedMara, on the tender cancellation: https://www.bowtiedmara.io/p/argentina-just-killed-the-cbi-tender