Official · 02.10.2026Argentina announces South America's first Citizenship by Investment Programme→
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Global Wealth

How the OECD and FATF see citizenship by investment

Two international bodies shape how banks, border agencies and governments treat investment passports. Their tests are public, specific and largely technical. Argentina has said it will meet them. Here is what that involves.

Updated 8 min readSourced from official announcements

Key facts

  • The OECD treats a scheme as potentially high-risk for CRS if it offers tax below 10% on offshore financial assets and needs less than 90 days' presence.
  • The five Eastern Caribbean CBI programmes are on the OECD's list.
  • The joint FATF/OECD report of November 2023 sets out good practice: multi-layered vetting, source of wealth, ongoing monitoring, transparency.
  • Argentina says its due diligence is aligned with OECD and FATF standards.
  • Since December 2025 the EU can suspend visa-free travel for countries with investor-citizenship schemes.

Every investment passport is judged twice. First by the government that issues it. Then, every time it is used, by banks, border officers and foreign governments. The second judgement depends heavily on two international bodies: the OECD and the Financial Action Task Force (FATF).

Argentina has said its programme meets their standards. This article explains what those standards are and how Argentina’s announced design compares.

The OECD and the Common Reporting Standard

The Common Reporting Standard (CRS) is the OECD’s system for the automatic exchange of financial account information between tax authorities. Banks collect information on their customers’ tax residence and report accounts to the countries where those customers are tax resident. By 2023, more than 110 jurisdictions were exchanging data every year.

The weak point is self-certification. A customer tells the bank where he or she is tax resident. If the customer shows a passport or residence card from a low-tax country, and does not mention the country where he or she actually lives, the bank reports to the wrong place, or nowhere useful.

The high-risk list

To close that gap, the OECD analysed more than 100 residence and citizenship schemes offered by CRS-committed jurisdictions. It treats a scheme as potentially high-risk when both conditions apply:

  1. it gives access to a personal income tax rate below 10% on offshore financial assets; and
  2. it does not require significant physical presence, meaning at least 90 days, in the jurisdiction.

The list, in the version last archived in May 2024, includes the citizenship-by-investment programmes of Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis and St Lucia. It also includes schemes in Malta, Cyprus and Vanuatu, some since closed or replaced, and several residence schemes, among them those of the UAE, the Bahamas and Barbados. The 2023 FATF/OECD report counted 22 schemes on the list.

What banks must do

Inclusion on the list does not ban anyone. It changes how banks treat the documents. Under Section VII of the CRS, a bank cannot rely on a self-certification if it has reason to know it is incorrect. The OECD expects banks to take the list into account and, where in doubt, ask further questions, such as:

  • Did you obtain residence rights through an investment scheme?
  • Do you hold residence rights anywhere else?
  • Did you spend more than 90 days in another jurisdiction last year?
  • Where did you file personal income tax returns last year?

For honest applicants the practical lesson is simple: declare every tax residence and expect the questions.

The 2023 FATF/OECD report

In November 2023 the FATF and the OECD published a joint report, Misuse of Citizenship and Residency by Investment Programmes. The FATF Plenary approved it in October 2023.

The report accepts that most applicants have legitimate wealth and benign intentions. It also documents how criminals have used these programmes to launder proceeds of crime and corruption, to move assets beyond the reach of recovery, and to obtain identity documents that disguise where they owe tax. It found citizenship programmes particularly vulnerable, because they offer mobility and new identity documents.

Its recommended safeguards fall under four headings: responsibility and oversight, adequate vetting, continued monitoring and corrective measures. Among the specific practices:

  • multi-layered due diligence, with each layer (agent, agency, receiving bank) screening independently rather than relying on the others;
  • checks on source of wealth, not only source of funds, to stop criminals using a clean payment to bring in wider illicit wealth;
  • disclosure of all current and previous nationalities and identities;
  • interviews, biometrics and checks against international law-enforcement databases;
  • firewalls between decision-makers and the agents and marketers who profit from applications;
  • public reporting of the number of approvals and the revenue earned, with audits of how funds are used; and
  • clear roles for public and private actors, to prevent private interests capturing the programme.

The report also notes a direct consequence: programmes that look open to abuse can lead other countries to suspend visa-free travel.

The consequences are now formal

Recent decisions show that the warnings have teeth.

  • The EU. Regulation (EU) 2025/2441, in force since 30 December 2025, added investor-citizenship schemes without a genuine link as a ground to suspend visa-free travel to the Schengen area. The EU had already fully suspended Vanuatu’s waiver, with the latest act in force from 3 February 2025. In 2025 the EU Court of Justice ruled that Malta’s citizenship programme breached EU law.
  • The United States. A proclamation of 16 December 2025 restricted visitor and student visas for nationals of Antigua and Barbuda and Dominica from 1 January 2026, citing citizenship by investment without residence.
  • The United Kingdom. Dominica (2023) and St Lucia (2026) lost visa-free access.

How Argentina’s design compares

Argentina’s official announcement of 2 October 2026 maps onto several of the FATF/OECD recommendations.

FATF/OECD good practice Argentina’s announced design
Multi-agency vetting Agency evaluation, with SIDE, the UIF, the Ministry of Security and the Ministry of the Interior taking part
Final decision by a public authority The National Directorate of Migration gives final approval
Source of funds and wealth Checks on traceability and legality of funds, plus financial and asset analysis
Criminal and reputational background Included, with migration history and jurisdictional risk
Funds through regulated channels All funds must move through the formal financial system
Stated standard Aligned with OECD and FATF (GAFI)

On tax, Argentina’s position differs from the OECD’s high-risk profile. Argentina taxes residents on worldwide income at progressive rates from 5% to 35%, and naturalisation by investment does not by itself make a person an Argentine tax resident. A new citizen does not gain access to a low tax rate simply by acquiring the passport. That said, the OECD makes its own assessments, and we found none for Argentina as of 2 October 2026.

Open questions

Several points that the FATF/OECD report treats as important are not yet public:

  • whether Argentina will publish approval numbers and revenue;
  • any physical-presence or residence requirement after the grant;
  • the role of private intermediaries. A four-firm consortium tender was cancelled in April 2026, and a group of firms later signed a non-onerous technical collaboration agreement with the Agency, according to industry reports. The report’s emphasis on clear public and private roles applies here; and
  • the legal basis itself. The Cámara Nacional Electoral declared DNU 366/2025 unconstitutional on 30 June 2026, and the government has appealed to the Supreme Court. See the legal status briefing.

What this means for applicants

Expect thorough questions, and treat them as protection. A programme that vets carefully keeps its passport’s access, and that access is what you are paying for. Prepare a full account of your source of wealth, declare every nationality and tax residence, and keep the paper trail. See the requirements, how to apply, and proving crypto-derived wealth. For a comparison with other programmes, see Argentina vs Caribbean passports.

Sources

Frequently asked questions

What is the OECD's high-risk CBI/RBI list?

It is a list of residence and citizenship-by-investment schemes that the OECD considers potentially high-risk for avoiding Common Reporting Standard (CRS) tax reporting. Banks must take it into account when they check a customer's tax residence.

What makes a scheme high-risk for the OECD?

Two features together: access to a personal income tax rate below 10% on offshore financial assets, and no requirement to spend significant time, at least 90 days, in the jurisdiction.

Is Argentina on the OECD high-risk list?

We found no OECD assessment of Argentina's programme as of 2 October 2026; the programme was only announced that day. Argentina taxes residents on worldwide income at up to 35%, and citizenship alone does not create tax residence.

What did the 2023 FATF/OECD report conclude?

That CBI and RBI programmes can benefit host countries and legitimate applicants, but carry significant risks of money laundering, fraud and corruption, and should be designed with multi-layered due diligence, source-of-wealth checks and ongoing monitoring.

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