BRIDGES Insights

The Strictness Index of Citizenship Programme Checks

Sergey Evdokimov, Managing Partner, BRIDGESSergey EvdokimovManaging Partner, BRIDGES

Updated: August 202613 min readExpert reviewed

Terms and costs verified: August 2026

The Strictness Index of Citizenship Programme Checks
Contents

Clients almost always ask about money and timelines and almost never about the checks. Yet it is the checks that filter people out. A contribution can be borrowed and a timeline can be waited out, but nothing can fix a background that will not pass.

Due diligence feefrom USD 5,000 to 10,000
Most expensive checkSaint Kitts and Nevis
Single fee per applicationSão Tomé and Príncipe
Interview mandatoryDominica, Saint Lucia, Saint Kitts
Main cause of refusalsthe source of funds
Data verified29 August 2026

Here is how the checks work in the active programmes: who does the checking, what exactly they look at, where refusals are more frequent and what an applicant can close in advance.

What the comparison shows

  • The check is carried out by a different body from the one that decides — in every programme they are separate.
  • The cost of the check varies more than twofold: from USD 5,000 to USD 10,000 for the principal applicant.
  • An interview is mandatory in a minority of programmes; in the rest it is held selectively.
  • The main reason for rejection is the same everywhere: an unevidenced origin of funds.
  • A refusal is recorded and asked about on the next programme's application form.
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What the check costs in each programme

The due diligence fee is a mandatory state payment. It is non-refundable: it is paid on filing and not returned whatever the decision. It is the first thing an applicant loses if rejected.

ProgrammePrincipal applicantDependantInterview
São Tomé and PríncipeUSD 5,000 per applicationincluded in the application feeno data
VanuatuUSD 5,000at the body's tariffnot provided for
GrenadaUSD 6,000USD 6,000provided for in the regulations
NauruUSD 6,000USD 3,000 from age 16no data
Saint LuciaUSD 8,000USD 5,000 from age 16mandatory for the principal applicant
Antigua and BarbudaUSD 8,500USD 5,000provided for in the regulations
DominicaUSD 7,500USD 4,000mandatory from age 16
Saint Kitts and NevisUSD 10,000USD 7,500 from age 16mandatory for the principal applicant

The amounts are from the relevant bodies' published tariffs as at 29 August 2026. Note the difference in approach: São Tomé charges per application regardless of the number of people, while the others charge for each person checked. For a family of four that creates a gap of tens of thousands of dollars.

DUE DILIGENCE FEE, PRINCIPAL APPLICANT, USD THOUSAND04812Official dataBRIDGES estimate5São Tomé5Vanuatu6Grenada6Nauru8St Lucia7.5Dominica8.5Antigua10St Kitts

The published due diligence fee for the principal applicant. The data are official, taken from the relevant bodies' tariff pages as at 29 August 2026. The fee is non-refundable: it is paid on filing and not returned if the application is rejected.

Who exactly checks the applicant

The structure is the same in every programme and is more sensible than people assume. The check is run by a separate body — a financial intelligence unit or an authorised service — while the decision is taken by the citizenship commission. The separation is deliberate: whoever grants the status should not check the applicant themselves.

StageWho carries it outWhat is assessed
Preliminary assessmentthe licensed agentobvious obstacles, completeness of the pack
Background checkthe financial intelligence unit or an authorised serviceconvictions, wanted lists, sanctions lists
Source-of-funds checkthe same servicethe origin of the money along the whole chain
Interviewthe relevant bodyconfirmation of the information in person
Decisionthe citizenship commissionthe outcome based on the check

The practical consequence: a weak case stalls at the second and third stages, before the commission decides. Such cases often do not appear in the official refusal statistics, so real strictness is higher than the published figures show. What that looks like over time is analysed in refusals of Vanuatu citizenship.

Expert comment

People prepare for the wrong thing. They bring a statement of the account balance and consider the matter closed, but the reviewer is interested not in the balance but in the path of the money: where the income came from, which contract evidences it, which taxes were paid. At the first meeting I ask people to describe in their own words where the money came from, and along the way I note two or three points where a request will come. Almost always those points are closed by documents the person already has. They simply did not think they needed to show them.

Sergey Evdokimov

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What is examined in the source of funds

The requirement is the same in every programme, but the emphasis shifts for different categories of applicant.

Where the money comes fromWhat will be requestedWhere the gap usually is
An operating businessownership structure, accounts, taxes, origin of profitsno evidence for the years when the business was growing
Sale of a stake or an assetthe contract, the valuation, receipt of the money, taxes paida sale between related parties without an independent valuation
Inheritance or a giftthe testator's documents, proof of relationship, tax statusno documents on the origin of the testator's funds
Investment incomebrokerage reports, transaction history, initial capitalthe source of the first deposit to the brokerage account is not evidenced
Employmentemployment contracts, income statements, savings over the periodsavings noticeably larger than total declared income

The general rule: what is checked is not the existence of the sum but the path by which it appeared. A break in the chain at any point produces a request, and an unanswered request produces a rejection.

What an additional request looks like

Between "approved" and "refused" there is an intermediate state that is almost never written about: the additional request. Formally it is not a refusal, but most rejections and almost all delays grow out of it.

The request goes to the agent, the applicant has limited time to reply, and while the reply is being prepared the case stands still. Typical wording looks like this.

What is askedWhat lies behind itHow to reply
Confirm the origin of the receipt on such-and-such a datemoney appeared in the account without a document on its originthe contract, the certificate of completion, the payment order and tax confirmation
Provide documents on the company whose stake was soldchecking that the asset existed and was sold at market pricearticles, accounts, the sale contract, an independent valuation
Explain the discrepancy in the spelling of the namedifferent transliterations in the passport and the certificatea certificate of identity or a notarised declaration
Clarify your employment over the periodan unexplained gap in the employment historydocuments for the period, or an explanation with evidence
Provide tax confirmation for the incomechecking that tax was paid in its jurisdictionreturns and certificates from the tax authority

None of the typical requests concerns the applicant as a person — they are all about documents. Hence the practical conclusion: a fully assembled case goes through without requests, while a partly assembled one receives them in batches.

The rule for replying is simple: reply with a document, not an explanatory note; close the whole episode, not only the literal question; and keep within the time allowed.

How long the check itself takes

The check is the least predictable part of the process. The regulations set the upper limit, and the actual time depends on how completely the case has been assembled.

ProgrammeIndicative duration of the checkWhat stretches it
Vanuatu2-4 weeksa request on the source of funds
Nauru3-5 weeksthe bank check on the payment
Dominica6-10 weeksthe interview and agreeing a date
Grenada8-12 weeksrequests on corporate documents
Antigua and Barbuda8-12 weekschecks on dependants over 16
Saint Lucia8-12 weeksthe principal applicant's interview
Saint Kitts and Nevis10-14 weeksthe extended check and the interview

The durations are based on actual Bridges Global cases and are our estimate, not the official regulations. The overall comparison by programme is in the speed index.

Where refusals are more frequent

Fact: according to the official statistics of the Vanuatu Citizenship Commission, the refusal rate rose from 0.37 per cent in 2021 to almost two per cent in 2023. There are no comparable public statistics for the Caribbean programmes.

Bridges Global estimate: the check is strictest where its fee is higher and the interview is mandatory. In our practice that means Saint Kitts and Nevis, Dominica and Saint Lucia. Softer are the programmes with a single fee per application and no mandatory interview.

An important caveat: strictness does not mean inaccessibility. It means the case must be assembled completely before filing, not completed in response to requests.

What an applicant can close in advance

  • The money chain. Contracts, statements and tax confirmations for the whole path of the funds, not a final certificate.
  • Gaps in employment. Any break is explained with a document, not orally.
  • The spelling of the name. Different transliterations in the passport, the certificate and bank documents are reconciled in advance.
  • Previous refusals. If there was a refusal, it is disclosed at once: concealment turns a solvable situation into an unsolvable one.
  • Family composition. Everyone you plan to include goes into the first application.

In our practice a correctly assembled case goes through without a single additional request. Each request adds two weeks to a month and a half to the timeline.

Check the calculation for your own family. For the active programmes we have open full-cost calculators: the main investment, state fees, due diligence and mandatory costs are calculated for your composition. Free and without registration.

What to do if you are refused

A refusal does not always close the road, but what to do next depends on the ground.

  • Incomplete documents. The most common and most solvable case: the case is rebuilt and filed again.
  • Questions about the source of funds. Solvable if the origin of the money can in principle be evidenced with documents. The full chain is needed, not another certificate.
  • A criminal record. Depends on the offence, how long ago it was and whether it is spent. Such situations are analysed in the article on citizenship with a criminal record.
  • Sanctions restrictions. There are no prospects, and it is better to hear that before paying than after.

What not to do: apply straight away to another programme without mentioning the previous refusal. The application form will ask about it, and concealment once discovered closes the road everywhere.

What to do with this

Choosing a programme for the softness of its checks is a poor strategy. First, the difference is smaller than it seems: the requirement to evidence the origin of funds is the same everywhere. Second, a document's reputation is directly linked to the strictness of the programme, and a passport with a weak check raises questions wherever it is used.

The sensible order is the reverse: first assemble the case so that it would pass in the strictest programme of the segment, then choose by timeline and budget. That way the choice stays with you, not with the reviewer.

Frequently asked

Questions people ask before deciding

01What does due diligence cost in citizenship-by-investment programmes?

From USD 5,000 to USD 10,000 for the principal applicant. The most expensive check is in Saint Kitts and Nevis at USD 10,000; the most affordable is São Tomé and Príncipe, where USD 5,000 is charged per application regardless of the number of people. The fee is non-refundable.

02Who checks the applicant?

A separate body — a financial intelligence unit or an authorised service. The decision is taken by the citizenship commission. The separation is deliberate: whoever grants the status does not check the applicant themselves.

03What exactly is examined in the source of funds?

Not the account balance but the path of the money: where the income came from, which contract evidences it, which taxes were paid and how the funds moved between accounts. A break in the chain produces an additional request.

04In which programme is the check stricter?

On our estimate, where the check fee is higher and the interview mandatory: Saint Kitts and Nevis, Dominica and Saint Lucia. There are no public refusal statistics for the Caribbean programmes, so this is a Bridges Global estimate, not official data.

05Does a refusal affect applying to another programme?

Yes. A refusal is recorded and asked about on the next programme's application form. Concealment turns a solvable situation into an unsolvable one, so a previous refusal should be disclosed at once.

06Should I choose a programme with a soft check?

No. The requirement to evidence the origin of funds is the same everywhere, and a document's reputation is linked to the programme's strictness. It is wiser to assemble the case so that it would pass in the strictest programme of the segment and then choose by timeline and budget.

About the author

Sergey Evdokimov, Managing Partner, BRIDGES

Author: Sergey Evdokimov

Managing Partner, BRIDGES

As Founder and Managing Partner of BRIDGES, I am responsible for the firm's strategy and personally lead its most complex client matters, including cases in which citizenship or residence decisions require a strategic view and consideration of capital.

Personal programme selection is conducted by Anna Kovalevskaya, Head of Legal, BRIDGES.

Material

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Budget, family, timelines and relocation plans - which answers lead to which programme.

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Anna KovalevskayaHead of Legal, BRIDGES
Anna Kovalevskaya, Head of Legal, BRIDGES