By Leah Hashagen, Staff Editor Volume 40
President Trump’s controversial September 2025 executive order created a new “Gold Card” visa program, offering expedited permanent residency (and ultimately, citizenship) in exchange for payments of $1 million USD for individuals and $2 million USD for corporations. The administration claimed that, as of December 2025, revenue from the Gold Card program had already reached $1.3 billion USD. Yet the Gold Card is already facing challenges in federal court over its constitutionality amidst national protests and general anxiety over the administration’s handling of immigration policy.
The United States is not alone in offering residency with a price tag. Citizenship-by-investment (CBI, or “golden passport”) and residency-by-investment (RBI, or “golden visa”) programs can be found across the globe. Such programs, long mired in controversy, now form a $25 billion USD industry.
Immigration by Investment: EU Legal Challenge & Established US Practice
In April 2025, the European Court of Justice (ECJ) ruled Malta’s golden passport program illegal. Previously one of the world’s most sought-after investor citizenship schemes, Malta’s program allowed an investor who contributed €750,000 EUR and maintained a one-year residency to obtain a Maltese passport—and by extension, EU citizenship. The ECJ ruled that although EU member states generally have the discretion to determine their own citizenship, Malta had violated Article 4(3) of the Treaty on European Union by jeopardizing EU solidarity and mutual trust by treating citizenship as a financial transaction.
Simmering animosity towards Malta’s program intensified after the 2017 car-bombing assassination of journalist Daphne Caruana Galizia, who was investigating illicit connections between the golden passport program and Maltese politicians. Public opposition reached a new high after Russia invaded Ukraine in 2022, spurring fears that Russian nationals would use the program to circumvent EU travel bans.
As of February 2026, approximately 60 countries have some sort of CBI or RBI scheme, with around 35 of those countries attracting the bulk of investment. Although these programs have recently drawn heightened scrutiny, many have existed for decades.
For instance, the United States’s current Gold Card program is merely a new iteration of the EB-5 Immigrant Investor Program, which was established in the 1990s. The EB-5 visa allows an investor to become a permanent resident (Green Card holder) provided they invest a minimum of $800,000-$1,050,000 USD in a new commercial enterprise and create 10 permanent full-time jobs for US workers. The Gold Card does not create a new visa itself but instead creates a donation-based pathway to access existing visa categories (EB-1A and EB-2 NIW). Unlike the statutorily sanctioned EB-5, the Gold Card was created by executive order and thus can be altered or rescinded with a change in administration.
Pay-to-Passport: Conduits for Crime, Corruption & Inequity?
Critics of these kinds of programs raise concerns over national security, economic distortion, and human rights. Governments hungry for capital have been accused of forgoing due diligence in exchange for legal bribes, effectively allowing criminals and corrupt officials to evade arrest and sanctions. For example, Cyprus ended its program in 2020 after Al Jazeera published an investigation in which a fictitious Chinese businessman with a criminal record was offered citizenship without proper authorization.
Domestic security agencies and the Organized Crime and Corruption Reporting Project (OCCRP) have warned that such schemes could be used by organized crime and terrorists to escape watchlists. Much concern is also centered on the risk such programs pose of serving as a conduit for financial crimes, such as fraud, money laundering, and tax evasion. The Financial Action Task Force (FATF) and the Organization for Economic Cooperation and Development (OECD), in their joint 2023 report, illustrated how criminals could hide their identities and illicit activities behind shell corporations across multiple jurisdictions, making it easier to evade law enforcement detection.
Popular resistance against the unintended economic consequences of these programs has also led several countries to scale back or eliminate investor visa schemes. Popular and profitable RBI programs in Portugal and Spain have been curtailed in response to the resulting pressure exerted on the local housing market. Foreign investors purchased property solely to secure residency, leaving units vacant and driving up housing prices for locals. In 2025, Spain significantly reduced its previous golden visa program and imposed a new tax on foreign-owned property. Portugal, a favorite among Americans seeking residency in Europe, amended its program in 2023 to eliminate direct property-owning mandates.
More broadly, critics fault CBI and RBI programs with “commercializing” citizenship, encouraging discrimination, and creating a two-tiered immigration system in which the wealthy can bypass traditional due diligence procedures. In such a system, high-net-worth individuals with visa restrictions (typically, Chinese, Russians, Iranians, and Americans) can bypass traditional law enforcement mechanisms by investing a relatively small amount.
A “Golden Ticket” for Small Nations?
Supporters point to the revenue these programs generate. In particular, small island nations disproportionately suffering from the effects of climate change have framed their CBI/RBI programs as a means by which they can quickly raise revenue with few strings attached. Saint Kitts and Nevis’s CBI program accounted for 60 percent of the country’s GDP from 2017 to 2021. Vanuatu’s CBI program accounts for approximately 30 percent of GDP. Proponents suggest that such programs, which target high-net-worth individuals, attract foreign talent and entrepreneurial investment. However, countries that have invested in such schemes have reconsidered; Australia recently abandoned its previous RBI program due to the influx of corrupt actors and lack of evidence that the program spurred any domestic economic benefit. Supporters also suggest that rather than being discriminatory, such programs are actually an equalizing measure, allowing for increased mobility, better access to healthcare, and higher standards of living for those from the Global South or politically out-of-favor regimes.
Some advocates urge a reconceptualization of legal citizenship for a more modern, globalized world. Henley & Partners, a firm specializing in “citizenship and residency planning,” has argued that traditional citizenship frameworks based on jus sanguinis (citizenship by blood/descent) or jus soli (citizenship by birthplace) are outdated, and that citizenship should be reconceptualized as a membership in a “country club”—a flexible status reflecting mobility and economic participation rather than ancestry or territory.
Supporters of CBI schemes generally articulate citizenship based on what I will call jus valoris—citizenship by economic value. It differs from other forms of legal citizenship or naturalization in that naturalization does not necessarily have an economic component. Though the process differs in every country, economic components (i.e., demonstrating financial stability) are rarely the primary criteria in a typical naturalization process. Citizenship-by-investment, though it may have other requirements (such as residency), is primarily driven by economic contribution—whether that be by direct investment or being a high-worth individual.
Citizenship in an Age of Mass Migration & Globalization
Indeed, modern global migration is causing tensions in traditional conceptions of state-based citizenship and Westphalian singularity. Dual and multinational citizenship is on the rise. In 1960, fewer than 5 percent of countries recognized dual citizenship; in 2023, roughly half did. Many states now extend significant political and social benefits to non-citizen residents (“denizenship”). Thus, some scholars have argued for a citizenship model based on primary residency rather than bloodline or birthplace. Such a model would maintain the territorial sovereignty of the nation-state, prioritizing physical status within the territorial bounds of the state. Others support moving to supranational models, such as EU citizenship. Alternatively, nativist factions across the world seek to narrow rather than broaden access to political membership—such as Trump’s 2025 executive order bidding to end birthright citizenship and recent campaign to denaturalize foreign-born US citizens.
The debate over investor immigration is therefore part of a larger reckoning over how political communities define belonging in an age of globalization and mass migration. Are golden passports merely a pragmatic adaptation to a world where capital and talent are highly mobile? Or does the commodification of citizenship risk eroding national solidarity by transforming civic obligation into a financial transaction? Moreover, if citizenship becomes purely transactional, what happens to equality before the law? Yet if states refuse to adapt ideas of citizenship to structural global change, do they risk clinging to outdated and exclusionary models of nationality rooted in racial superiority and ethnic homogeneity?
Ultimately, the future of golden passport and visa programs will depend on whether governments can articulate a conception of citizenship that balances economic necessity, security, and civic integrity in a globalized age. Though Trump’s Gold Card may dominate headlines today, the deeper question is whether citizenship is a commodity, a sovereign prerogative, a political bond, or if it should become something else altogether.