Citizenship by Investment Authorized Agents

Why programmes use licensed intermediaries — government fees and agent fees are separate

A CBI file can contain civil records, police certificates, company ownership documents, source-of-wealth evidence and large financial transfers. Governments use licensed agents as a controlled submission channel so applications arrive in a prescribed format and there is an accountable professional between the applicant and the citizenship unit. The government still makes the decision; the agent does not confer citizenship. Dominica states that all CBI applications must be submitted through an Authorised Agent and that application forms are available only through those agents. Antigua and Barbuda likewise works through authorised representatives and a licensed local agent who submits the file to the Citizenship by Investment Unit. Other programmes have their own regulated intermediary structures, so the first check is always the current official application procedure.

An international immigration consultancy may market a programme without being the local license holder that can lodge the application. Some firms work with a domestic authorised agent; others may be licensed themselves. Ask for the exact legal entity that will submit the file, then match it against the government list rather than relying on a logo, referral arrangement or sales brochure. The useful work happens before the government sees the application. An agent should identify eligibility problems, explain dependant rules, reconcile names and dates across documents, review source-of-funds evidence, obtain required forms and tell the applicant which statements need further proof. A rushed submission that merely packages documents can create avoidable delays or credibility questions.

A programme may publish contribution, processing, due-diligence, interview and passport fees, while the authorised agent charges professional fees separately. Applicants should receive a written cost schedule showing which amounts go to the government, which go to a developer or fund, which are professional charges and which are refundable if the application stops at a particular stage.

The practical reason for the agent model is accountability. Governments do not want every overseas promoter sending incomplete files directly to a citizenship unit. A licensed local intermediary can be held to filing standards, document requirements and anti-money-laundering obligations. That does not make the agent a government official, but it creates a defined channel through which the application is assembled and lodged.

Verify authority before sending sensitive documents

CBI applications contain unusually valuable personal data: passport copies, home addresses, tax records, bank statements and family documents. Use the programme's official website to confirm the authorised agent, verify contact details independently, and be cautious if payment instructions arrive from a different company or bank account without a documented explanation.

A sales consultant may be the person you speak with every day while a different licensed company is legally responsible for submission. Ask for that submitting entity before signing and verify it on the programme's current official list. The engagement letter should also explain whether money passes through the consultant, the authorised agent, an escrow account, a developer or the government. That payment chain matters because a licence held by one company does not automatically validate instructions sent by another. If the legal names on the invoice, bank account and authorised-agent register do not line up, obtain a written explanation and verify it independently before transferring funds.

Authorisation should be checked on the program authority's current list, not on a screenshot sent by the adviser. Licences can expire, be suspended or apply only to a particular legal entity. If the brand name on the website differs from the company named on the licence, ask for the corporate relationship in writing. That small check can prevent an applicant from sending passports and funds to an unregulated intermediary trading under a familiar marketing name.

An authorised agent cannot promise approval

Licensing means the intermediary is permitted to act in the programme; it does not mean every client will pass government due diligence. Be wary of claims that an agent has a special channel, can bypass an interview, can hide a visa refusal or can guarantee a passport by a fixed date. Those statements conflict with the basic logic of independent government screening.

Treat the agent relationship as part of compliance

Keep the engagement letter, fee schedule, versions of forms, written explanations and payment receipts. If a fact changes before approval—new employment, litigation, a marriage, a passport renewal or a sanction issue—tell the agent promptly and ask whether the government must be updated. A well-documented relationship makes the application easier to audit and reduces misunderstandings about who submitted what.

Applicants should know the chain of responsibility. If an international adviser, property broker and local authorised agent are all involved, ask who holds client money, who signs the government forms, who performs the initial compliance review and who is liable for mistakes. A polished sales relationship is not a substitute for knowing which regulated entity is actually responsible for the file.