Citizenship by investment is a high-stakes legal and financial process. The firm you choose can affect not only your timeline and outcome, but also your compliance risk, data security, and the quality of the investment you’re making (especially in real-estate-linked programs)
Citizenship by investment is a high-stakes legal and financial process. The firm you choose can affect not only your timeline and outcome, but also your compliance risk, data security, and the quality of the investment you’re making (especially in real-estate-linked programs).
This guide is intentionally neutral: it doesn’t rank or name firms. Instead, it gives you a practical framework to evaluate any CBI advisory firm—plus a copy/paste consultation question list and a red-flag checklist you can use immediately.
Key takeaways (scan this first)
- Treat advisor selection like hiring counsel for a complex transaction, not buying a travel product.
- Ask for proof of authorization/registration where programs require filings through approved agents.
- Demand fee transparency: itemized quotes, clear refund terms, and disclosure of commissions/referrals.
- Evaluate the firm’s due diligence and source-of-funds process—a serious firm screens issues early.
- Check data handling: secure upload, access control, and retention/deletion policies.
- If real estate is involved, scrutinize escrow, conflicts of interest, and exit rules.
- Use the scoring table in this article to compare firms side by side.
What a CBI advisory firm does (and what it should not do)
A reputable CBI advisory firm typically helps with:
- Program fit and strategy: matching your goals (mobility, security, family planning, education, business access) to the right jurisdictions and pathways.
- Eligibility screening: identifying risk factors early (prior visa refusals, complex source of funds, multi-citizenship scenarios).
- Document planning and assembly: civil documents, police certificates, corporate records, translations/notarization coordination.
- Submission workflow: many programs require applications to be submitted via authorized agents or through approved channels.
- Process management: handling requests for additional information, keeping timelines moving, coordinating appointments where needed.
- Post-approval steps: passport issuance, renewals, adding dependents later (where permitted), compliance reminders.
What a CBI advisory firm should not do:
- Guarantee approval (no one can honestly guarantee a government decision).
- Promise a “passport in X days” without explaining due diligence and variables.
- Ask you to hide, omit, or “work around” source-of-funds questions.
- Handle your money in unclear ways (e.g., vague payment instructions or non-escrow arrangements for investments).
Step-by-step: how to evaluate a CBI advisory firm
Step 1: Confirm they can legally represent you for the program you want
Many CBI and residency-by-investment pathways are structured so that applications must be submitted through authorized agents (terminology varies by country and program).
What to ask for:
- Proof they are authorized/registered for the specific program you’re considering.
- The legal entity name that holds authorization (not just a brand name).
- If they use partners: who exactly is authorized, and who is accountable to you.
Why it matters:
If a firm can’t clearly explain its filing authority and accountability chain, you may end up with hand-offs, confusion, or gaps in responsibility when issues arise.
Step 2: Make sure accountability is written (engagement letter + scope)
Before you share sensitive documents or pay fees, insist on a written engagement letter that answers:
- What services are included (and excluded)?
- Who does what (sales, case manager, legal lead)?
- What happens if your circumstances change mid-process?
- How disputes, cancellations, and refunds are handled.
Practical tip:
A serious firm can explain the process without “mystery.” If you’re told the details are confidential or “too complex to put in writing,” that’s a warning sign.
Step 3: Demand fee transparency and understand the total cost
CBI costs are usually a combination of:
- Government fees and contributions (program-dependent)
- Due diligence fees (often per applicant)
- Professional fees (legal/advisory services)
- Third-party costs (translations, notarizations, courier, medicals, document retrieval)
- If real estate is involved: taxes, legal conveyancing, maintenance, and exit costs
What “good” looks like:
- An itemized quote separating government vs professional vs third-party costs
- Clear payment schedule (what is due when, and why)
- Written explanation of what triggers extra charges (e.g., added dependents, complex corporate records, urgent timelines)
Don’t skip this:
Many unpleasant surprises come from unclear add-ons—especially for document-heavy families, multi-jurisdictional assets, or applicants with complex income histories.
Step 4: Ask how they manage risk and due diligence (before filing)
CBI programs typically conduct thorough background and compliance checks. A reputable firm does not wait for the government to uncover issues—it performs a serious pre-assessment.
Ask how the firm handles:
- Source of funds and source of wealth review (what documents they expect and why)
- Sanctions and adverse media screening (at a high level)
- Prior visa refusals, name variations, or complex family structures
- “What would make you decline a case?” (This is a strong question. Good firms can answer it.)
Why this matters:
If a firm is willing to take any case with minimal review, you may face avoidable rejections, delays, or compliance exposure.
Step 5: Evaluate their data protection and document handling
You’ll likely share passports, bank statements, corporate documents, and family records. Your advisor should have clear information security practices.
Minimum standards to look for:
- Secure upload portal (or equivalent controlled method)
- Limited internal access (need-to-know basis)
- Clear retention/deletion policy
- Clear rules for sending sensitive documents (avoid open email where possible)
Red flag:
If the default workflow is “email everything to a generic inbox,” ask what protections are in place.
Step 6: Check program breadth—and whether advice is biased toward one solution
Some firms focus on a small number of jurisdictions. That isn’t automatically bad, but it increases the risk of single-program bias, where the “recommended” program is simply the one they sell most often.
A good consultation should include:
- Your goal and constraints first (timeline, family, budget, travel, risk tolerance)
- Alternatives and trade-offs (not just benefits)
- A clear explanation of why one route fits you better than another
A quick test:
Ask: “If this program changes next month, what would you recommend instead?”
A credible firm can outline backup options.
Step 7: If real estate is involved, treat it like an investment transaction—not a checkbox
Real-estate-linked CBI/RBI routes can be attractive, but they add layers of risk and complexity.
Key topics your advisor should address clearly:
- Who holds funds and how: escrow mechanics and release conditions
- Conflicts of interest: commissions, referral fees, developer relationships (and how they’re disclosed)
- Exit rules: holding periods, resale restrictions, market liquidity, transaction costs
- Project risk: what happens if construction is delayed or the offering changes materially
What to request in writing (where applicable):
- Reservation and purchase agreements
- Escrow documentation
- Developer disclosures and timelines
- A plain-English summary of your exit pathway and restrictions
Copy/paste consultation questions (use this checklist)
Bring this into your first call and insist on clear answers.
Authorization & legal accountability
- Are you an authorized agent/registered representative for the specific program I’m considering? What is the registered legal entity name?
- Who signs the engagement letter, and which jurisdiction governs it?
- If you use partners or subcontractors, who is responsible if there is an error or delay?
- What professional standards or internal controls do you follow for compliance work?
Case strategy & eligibility
- What are the top reasons cases like mine get delayed or refused?
- Which documents are usually hardest to obtain for applicants from my country of residence?
- How do you assess source of funds and source of wealth before filing?
- If you see a risk factor, how do you handle it (alternative program, additional documents, or advising me not to proceed)?
Fees, payments & refunds
- Can you provide an itemized quote separating government fees, due diligence fees, your fees, and estimated third-party costs?
- What payments go to the government vs your firm vs third parties?
- What is refundable, and under what conditions?
- Do you receive commissions or referral fees from developers, banks, or other partners? If yes, how is that disclosed?
Process, timelines & communication
- What is the realistic timeline range right now, and what typically drives delays?
- Who will manage my case day to day (name/role), and what response time should I expect?
- How do you handle urgent travel needs while an application is processing?
- What is your escalation path if I’m not getting updates?
Data protection & document handling
- How do you store passports, bank records, and sensitive documents?
- Do you provide a secure portal for uploads?
- Who can access my file internally, and how is access controlled?
- What is your document retention and deletion policy?
Investment & exit planning (if applicable)
- Who reviews the purchase contract and escrow arrangement?
- What are the resale rules, holding period, and typical transaction costs at exit?
- What happens if a project is delayed or changes materially?
- If I choose not to proceed after reserving a unit, what is refundable and what is not?
Post-approval support
- What support do you provide after approval (passport issuance, renewals, adding dependents later where permitted)?
- If my goals change, can you help with a multi-step, multi-jurisdiction plan?
Red flags checklist (quick due diligence)
Use this as your “walk-away” list.
- Guarantees of approval or “risk-free” promises
- Pressure to pay immediately, especially before written scope and fee breakdown
- Requests to pay into personal accounts or unclear payment channels
- Refusal to provide an itemized quote and written refund terms
- No engagement letter, or a vague scope with no accountability
- No clear proof of authorization/registration for the program (where applicable)
- A one-program pitch with no discussion of alternatives and trade-offs
- Timeline claims that ignore due diligence realities
- Discouraging you from independent legal/tax advice
- No clarity on escrow/custody of investment funds
- Poor document security (asking you to email sensitive files without controls)
- “Special government connections” language
- Asking you to omit, hide, or reshape source-of-funds facts
A simple scoring framework to compare firms side by side
Score each firm 1–5 (5 = strongest). This keeps the decision objective.
| Criteria | What “5/5” looks like | Score (1–5) |
| Authorization/registration clarity | Provides proof for the exact program; clear legal entity | |
| Written scope & accountability | Detailed engagement letter; clear roles; clear liability boundaries | |
| Fee transparency | Itemized quote; clear payment schedule; clear refunds | |
| Due diligence rigor | Strong pre-assessment; realistic risk discussion; won’t take every case | |
| Data protection | Secure portal; access controls; retention policy | |
| Program breadth & fit process | Offers multiple options with trade-offs; avoids single-solution bias | |
| Conflict disclosure (investment/referrals) | Transparent commission/referral disclosure; client-first structure | |
| Process management | Named case manager; service levels; escalation path | |
| Post-approval support | Clear deliverables for issuance/renewals/dependents | |
| Multi-jurisdiction planning | Can build plan B/C pathways if programs change |
Where FTB Mobility fits (factual overview)
FTB Mobility supports clients with residency and citizenship by investment planning with a focus on transparent process management and multi-jurisdiction optionality. Key facts clients often look for when comparing firms include:
- Active in investment immigration since 2013
- Coverage across 25+ government-approved programs spanning multiple regions (including Caribbean citizenship pathways and residency options in Europe and Asia-Pacific)
- Offices in China, Hong Kong, Singapore, Vietnam, Thailand, France, UAE, and the United States, supporting cross-border clients and time zones
- Ability to support beyond filing where relevant—such as investment coordination, property acquisition support, and relocation-adjacent planning (often important for real-estate-linked pathways)
- Support for both individual and corporate mobility needs
- A dedicated immigration practice for clients prioritizing RCBI programs
If you’re comparing firms, you can bring the checklists above into a consultation and evaluate the answers side by side.
FAQ
Do I need to use an authorized agent for CBI?
Many programs require applications to be submitted through approved/authorized channels rather than directly by applicants. Requirements vary by country and program—ask your advisor to show how they are authorized for the specific route you want.
Can a CBI advisory firm guarantee approval?
No reputable firm should guarantee a government outcome. What they can do is reduce risk by screening eligibility, preparing documentation properly, and managing the process carefully.
What documents are usually required for CBI due diligence?
While requirements vary, expect civil status documents, identification, police certificates, financial evidence for source of funds/wealth, and supporting records for business ownership or employment. A strong firm will give you a tailored document plan early.
How do I know if fees are reasonable?
Compare at least two itemized quotes with the same scope. Make sure you’re comparing like-for-like: government fees, due diligence fees, professional fees, and third-party costs. Also ask about refund terms and what triggers additional charges.
What are the biggest red flags when choosing a CBI firm?
Approval guarantees, unclear payment channels, vague scopes, refusal to itemize fees, weak data handling, and pressure tactics are among the most common warning signs.
Can a CBI firm help with taxes or relocation planning?
Some firms coordinate with tax advisors and support relocation needs (banking coordination, education planning, housing support), especially when a move is part of the strategy. Always clarify what is included in writing and which specialists are involved.
Do you support Asia-based applicants?
FTB Mobility has offices in China, Hong Kong, and Thailand, and routinely supports cross-border clients who need time-zone coverage and multi-jurisdiction planning.
Do you also support corporate immigration and employee mobility?
Yes—some clients need individual CBI/RBI planning alongside corporate mobility solutions. If corporate needs are in scope, confirm deliverables, jurisdictions covered, and who will lead the work.
Final note (important)
CBI and RBI rules can change, and each case depends on personal facts and documentation. Use this guide to structure your evaluation, then confirm requirements through official program guidance and qualified professional advice before committing funds.Want a second opinion? Bring the copy/paste checklist above to a consultation and ask for written, itemized answers—then compare firms using the scoring table.
