Due diligence for Vanuatu citizenship: how the applicant and source of funds are checked

Who checks an applicant for Vanuatu citizenship

In brief: the check is run by the Vanuatu Financial Intelligence Unit. It screens every adult participant against international databases and examines where the contribution money comes from. Refusals follow sanctions status, a wanted notice, serious convictions and an unproven source of funds.

This article is about how the check works. The programme’s basic terms are in the overview of Vanuatu citizenship by investment, and the steps in the article how to get a Vanuatu passport. The contribution is a necessary but not sufficient condition: the decision is made on the documents.

The check is built into processing from day one. First the agent runs a pre-screening, then a short package goes to the FIU, and only after its positive findings does the family assemble the full package for the Citizenship Commission. Vanuatu has been an Interpol member since 20 November 2018, so screening against wanted-person databases is part of the standard check for every applicant. The programme’s terms, timelines and amounts are collected in one document in the guide to terms and cost.

Why checks were tightened

In brief: after the EU reviewed visa-free travel in 2022-2025, Vanuatu tightened applicant checks. For the applicant this means a full package of source of funds documents before filing.

The EU reviewed visa-free travel for Vanuatu in three steps: a partial suspension from 3 March 2022 for passports issued from 25 May 2015, a full one from 4 February 2023, and EU Regulation 2025/11 of 19 December 2024 moved Vanuatu to the visa list. The Council of the EU cited the risks of citizenship by investment programmes, including concerns about the quality of applicant checks.

Vanuatu then tightened its check requirements, and on 6 February 2026 the Council of Ministers considered the report of a commission of inquiry into citizenship programmes and ordered its recommendations to be implemented. For an applicant with a clean background and documents, strict control is an advantage: banks and visa services accept a passport issued after a full check more readily. To live in Europe, Vanuatu citizens obtain Greek residence, and they enter the Schengen area with a visa. How the route to Europe works is described on the page Greek residence for Vanuatu citizens.

The FIU fee: $5,000 under DSP and $8,000 under the CIIP fund

In brief: the due diligence fee is paid once for the whole application, not per participant: $5,000 under DSP and $8,000 under the CIIP fund. It is the only payment to the government before the Commission’s decision; the contribution is paid only after approval.

This order protects the family: while the FIU and the Commission review the application, the main sum stays with the applicant. The DSP contribution from $130,000 or the CIIP fund share of $157,000 is paid only after approval, once the decision has been made. The check fee is not refunded on refusal, so background and source of funds are reviewed before it is paid.

On top of the contribution, this fee is the only government charge; the programme has no other mandatory payments. The all-in total under DSP is $135,000 for a single applicant, $155,000 for a couple, $170,000 for a family of three and $185,000 for a family of four. Under the CIIP fund the total is $165,000 for a family of up to four, of which $50,000 is returned after 5 years. DSP is usually better value for a single applicant or a couple, the fund for a family of three or more.

Translations, notarisation and bank charges are paid on actual invoices, and their volume depends on the number of participants and documents. The calculation by family composition is covered in the article the all-in total by family composition.

How the check works: the FIU, international databases and source of funds

In brief: the check runs on three levels: pre-screening by a licensed agent, FIU screening against international databases and examination of source of funds and wealth. The FIU findings form the basis of preliminary approval.

Level 1. Pre-screening by the agent

The licensed agent establishes the applicant’s identity and reviews background, origin of funds and the absence of convictions before the application goes to the government. The agent is accountable for whom it files, so a weak document package serves neither the agent nor the client.

Level 2. The government FIU check

Once the check fee is paid, the application goes to the FIU. Every adult participant is checked against:

• Interpol wanted-person databases, including Red Notices;
• UN, EU, OFAC and other sanctions lists;
• politically exposed person status, including relatives and close associates;
• convictions, from certificates and law enforcement databases;
• document authenticity, with the issuing authorities.

Level 3. Source of funds and source of wealth

Two concepts are distinguished here. Source of funds shows where the contribution money came from: an asset sale, dividends, savings, the sale of a business. Source of wealth shows how the applicant’s capital was built up over the years. The reviewer needs a documentary chain: not a balance on an account but the history of how it got there and the taxes paid.

Politically exposed persons

Politically exposed persons, their relatives and close associates undergo enhanced checks. The status itself does not mean refusal: the reviewer looks at how income relates to the position, whether there is a conflict of interest and where the contribution money comes from. The application includes details of positions and periods of service, income declarations and documents on the origin of capital earned outside public service.

Why money is checked most closely

Sanctions status and wanted notices are rare, but even honest applicants stumble over the origin of capital. The money came from selling a business stake many years ago, was then reinvested, part went into property and part into a fund. The required sum is on the account, but tracing the path of every dollar is not possible straight away. So the source of wealth is assembled in advance: it is the foundation of the whole check. How income from digital assets is proven is shown in the case of crypto capital.

Documents by type of income

• Sale of a business or stake: the agreement, proof of receipt of the money, ownership documents before the deal, company accounts.
• Dividends: the profit distribution resolution, a statement of receipt, tax documents.
• Salary and bonuses: the employment contract, income certificates for several years, bank statements.
• Sale of property: the sale agreement, proof of previous ownership, confirmation of settlement.
• Inheritance or gift: the certificate of entitlement, the gift agreement, documents on the donor’s or testator’s source of funds.
• Digital assets: transaction history on exchanges and wallets, statements of withdrawal to a bank, tax returns.

How long the check takes

Without additional queries the FIU check takes up to 7 business days in BRIDGES practice, and the whole path to the passport roughly 2-3 months: after the FIU findings, the full package is assembled for the Citizenship Commission, which meets twice a month. The check timeline is not guaranteed: capital from several jurisdictions, a complex business structure or contentious episodes in the background add queries. Each missing document means a new query and a new review of the answer, so a complete package at the outset directly shortens the timeline.

Which family members are checked and what documents are needed

In brief: only the main applicant goes through the FIU check and proves the source of funds. All participants aged 18 and over provide a police clearance certificate, and a medical certificate is needed for everyone, including young children.

Age determines the document set. A spouse, children aged 18 to 25 and parents over 50 gather the adult set with a police clearance certificate, and children aged 18-25 also prove full-time study. A child under 18 needs no police clearance: a passport, birth certificate, medical certificate and photos are prepared.

The document standard per participant: the main applicant gathers 11 documents, an adult participant 7 and a child 3. At the first stage the FIU needs a certified copy of the passport for each person, and for everyone aged 18 and over a police clearance certificate, a second identity document and a CV in English. The spelling of names in all documents is checked against the passport data page.

• Police clearance certificate. From the country of residence, no older than 3 months on the filing date, translated and certified.
• Second document. A national ID card, driving licence or residence permit.
• CV. Written in English to a template, with only verified facts of the person’s background.
• Medical certificate. Needed for every participant, including children; signed by a doctor.

Who can join the application and how its composition changes after citizenship is granted is covered in the article who can be included in the application.

The check on the application calendar

In brief: pre-screening takes 1-2 business days, the FIU check up to 7 business days without queries and a query response 1-3 business days. Then the full package goes to the Commission, which meets twice a month.

The order of work is strict, and each stage opens the next. Personal documents, diplomas, medical certificates and source of funds documents are gathered after positive FIU findings, so the family does not spend time and money on translations before the check is passed. The completed forms are handed to the agent in advance of the next Commission meeting.

After approval the applicant has 3 months to pay the contribution and take the oath. Biometrics are given in person in Dubai, Hong Kong, Port Vila, Moscow or St Petersburg, the only trip required. The passport is issued in 1-3 weeks, and the whole path takes roughly 2-3 months without relocation.

The calendar is built backwards from the Commission meeting date: by then the FIU findings, translations and signed forms must be ready. If the passport is needed by a specific date, a margin of one extra meeting is built in.

Grounds for refusal

In brief: refusals follow sanctions status, an active wanted notice, serious or unspent convictions, an unproven source of funds and concealed circumstances. If information raises questions, the government requests documents, approves the application with conditions or rejects it.

1. Sanctions. An applicant on UN, EU or OFAC sanctions lists is almost always refused.
2. Wanted notice. An active Interpol notice closes access to the programme.
3. Convictions. Serious and unspent convictions are grounds for refusal, while old minor episodes are considered separately.
4. Source of funds. If the origin of money cannot be proven with documents, the amount does not matter.
5. A concealed refusal. A previous refusal under another programme needs explaining, and an attempt to hide it becomes grounds for rejection in itself.
6. High-risk jurisdictions. Citizens of certain countries undergo enhanced checks or are not admitted; the current list is checked on the filing date.

States exchange information, so it is better to disclose previous refusals and convictions yourself, with documents. In contentious cases the reviewer is more likely to request additional documents than to approve an applicant with an unclear background. How applications with a conviction or after a refusal are prepared is described in the article Vanuatu citizenship with a criminal record, and the grounds for and consequences of refusal in refusal of Vanuatu citizenship.

How to answer FIU queries

In brief: a query is answered with documents rather than an explanatory letter, on time and in one package. Each answer is checked against what has already been filed so the data does not diverge.

An FIU query does not mean refusal: it is a normal part of the check when the reviewer is missing a link in the chain. The most common requests are for proof of receipt of money from an asset sale, documents on ownership of a company before a deal, an explanation of large transfers between accounts and income certificates for earlier years.

1. Understand the question behind the query. The reviewer does not want a document for its own sake but a closed link in the chain.
2. Answer with a document. A statement, agreement or payout resolution carries more weight than an explanatory letter.
3. Check the data. Amounts, dates and names in the answer must match the documents filed earlier.
4. Send the answer in one package. Partial answers trigger new rounds of queries and move the timeline.

If a document cannot be obtained, for example because the company has been liquidated, indirect evidence is gathered: tax returns for those years, bank statements, public registry records. BRIDGES works through such situations before filing so they do not come up during the check.

Typical reviewer questions in citizenship by investment programmes are collected in the article what due diligence asks about, and the circumstances that drag the check out in seven reasons the check is delayed.

How BRIDGES prepares documents for the check

In brief: BRIDGES checks the client using the same logic as the government, before the FIU fee is paid: sanctions and wanted-person databases, PEP status, source of funds and document completeness.

The pre-screening happens before the contract and before any payments. A lawyer reviews the applicant and family members across five areas and in 1-2 business days prepares a risk assessment and a document preparation plan. Letters and CVs are written after the check: they include only what is backed by documents.

• Pre-screening. Before any payments we check the applicant against sanctions and wanted-person databases, PEP status and open sources. A stop factor is named at once, before the fee is paid.
• Source of funds and wealth. We build the documentary chain of the money’s origin so the reviewer has no questions left.
• Document review. Police clearances, translations, apostilles and tax documents are checked for completeness before filing.
• Complex backgrounds. A public position, capital from several jurisdictions or a previous refusal require a careful package and an explanation of context.
• Current rules. Restrictions by applicant citizenship are checked on the filing date.

All documents are cross-checked: names, dates, addresses, companies, employment periods and amounts must match everywhere. Common filing slips are collected in the article five filing mistakes, and how we work with a family from pre-screening to passport is described on the page support under the Vanuatu programme.

The full document list and formatting requirements are in the article documents for Vanuatu citizenship. If you are comparing programmes by timeline and requirements, see Vanuatu or Dominica and the fastest second citizenship.

Pre-filing checklist

In brief: before filing, check sanctions status, wanted notices, convictions, source of funds documents, the tax side and disclosure of previous refusals. If any point raises doubt, start with a pre-screening.

Doubt about one of the points is not a reason to give up on the programme but a reason to start with a pre-screening: it is better to learn about a risk before paying the non-refundable fee than after.

What the passport gives after the check

In brief: the applicant receives permanent citizenship, a 10-year passport and a source of funds package that will be useful for banks and for residence in Europe.

• Citizenship and family. A 10-year passport, dual citizenship allowed, citizenship passes to children.
• Travel. 42 countries without a visa and another 30 with a visa on arrival, the Schengen area with a visa.
• Europe. The Vanuatu passport is a first step to Greek residence, where the source of funds is checked on the same documents.
• Banks. Documents that passed the FIU check answer compliance questions when opening accounts.
• Taxes. Vanuatu has no personal income tax, capital gains tax or inheritance tax; these terms apply to tax residents.

The document package that passed the check is kept with the citizen’s documents: the certificate, the passport and the fund agreement if CIIP was chosen. It will be needed for passport renewal, adding relatives and residence applications, where the source of funds is checked again.

How to use these documents when opening an account is covered in the article Vanuatu banks and an account abroad.

BRIDGES research on this topic: programme refusals in 2021-2026, who obtains a Vanuatu passport.