Contact +971 58 805 2476
Citizenship

Citizenship by Investment Restricted Nationalities: Who Can and Cannot Apply in 2026?

Saad Ahsan Saad Ahsan ·
Overview of citizenship by investment restricted nationalities and due diligence rules in 2026

Citizenship by investment programs are largely gaining the attention of individuals from several countries, even large economies such as the United States, Russia, and China. Still some nationalities affect an individual’s eligibility for a certain citizenship by investment program. 

The governments of several countries offering citizenship by investment programs have maintained a formal list of nationalities restricted for their programs. While some countries do not only restrict based on nationality rather they also focus on factors such as criminal records, sanctions, residence history, security issues and others when evaluating an individual’s citizenship by investment eligibility.   

This article explains individuals the main citizenship by investment restricted nationalities in 2026, how the rules differ for all programs and when exceptions may be available. 

Can Anyone Apply for Citizenship by Investment?

No, anyone can not apply for citizenship by investment programs. Meeting the required investment does not fulfill the complete requirements for eligibility of an individual. Most programs also focus on extensive background checks before approving an applicant for citizenship.

Although requirements vary but the common factors governments focus on for an individual profile’s examination include:

  • Nationality and country of residence

  • Identity and family history 

  • Criminal records

  • Show proof of source of funds

  • Business activities

  • Immigration history

  • Previous visa records

  • Security issues

  • Accuracy of information in the application documents

For example, Antigua and Barbuda citizenship by investment program states that applicants may be considered ineligible where they provide false information, have been involved in criminal activities, present a national security risk or have visa refusals history with countries to which Antigua and Barbuda has visa-free access. 

Similarly, Dominica applies broad eligibility criteria alongside its nationality restrictions. Its rules also focus on issues like visa refusals, security risks, and false information. Hence, citizenship by investment eligibility should always be reviewed rather than just assessing an individual’s profile based on nationality. 

Why Do CBI Programs Restrict Certain Nationalities?

Governments introduce citizenship by investment restrictions for multiple reasons. They put more focus on protecting the integrity and reputation of their programs while also protecting their nations. 

Security Concerns

The most significant reason why all countries put focus on citizenship by investment  restrictions or introduce new rules and regulations is the security concerns. They want to protect their nations from individuals which might harm their countries in any way. 

For instance, St Kitts and Nevis legally excludes citizens and ordinary residents of some specific countries for national security, defence, and public safety. 

Due Diligence

The citizenship authorities verify the applicant’s profile, residence history, criminal records, financial background, and business activities for citizenship application. 

If an individual’s records are not reliable or the independent investigators could not carry out enough checks then the government may restrict that individual from the relevant country or condition applications. 

Sanctions and International Compliance

International sanctions is the other reason why an individual can be restricted from a certain  country. Even if an individual’s nationality is not prohibited, the sanction exposure can affect the citizenship application. Governments may examine the applicant’s profile, business, family members and financial transactions separately. 

Program Reputation and Integrity

Citizenship creates a long-term legal relationship with an individual and the country granting nationality. A country’s reputation is very important so it must be protected at all cost. CBI countries therefore make sure that they protect the reputation and international standing of their country and passports. 

Dominica citizenship by investment programs hence focuses on a strict due diligence framework. The system includes a mult-layered process which involves authorised agents, the CBI unit, and independent due diligence agencies. 

Caribbean Programs Enhancing Due Diligence Amid EU Pressure

Due to increasing EU pressure in 2026, the Caribbean citizenship by investment programs have been focusing more on due diligence to protect the global reputation of their countries and maintain international trust. 

Citizenship by Investment Programs With Published Restricted Nationality Lists

The CBI programs rules and regulations are not the same. Nationality restrictions vary from country to country. Different programs impose different restrictions based on multiple factors. 

Each program applies its own policies and assesses an individual's profile based on different factors, so the following section should be read independently and reviewed by an individual before applying for citizenship. 

Antigua and Barbuda Restricted Nationalities

Antigua and Barbuda’s official citizenship by investment unit publishes six countries in its restricted countries list. These countries include:

Restricted Nationality

Can An Exception Apply?

Russia

Yes, subject to conditions

Belarus

Yes, subject to conditions

Afghanistan 

Yes, subject to conditions

Iran

Yes, subject to conditions

North Korea

Yes, subject to conditions

Somalia

Yes, subject to conditions

Sudan

Yes, subject to conditions

Yemen

Yes, subject to conditions

It is not necessary that this list remains the same throughout. Changes may occur with time based on different factors. 

According to the official Citizenship by Investment Unit (CIU), a citizen born in of the above countries may potentially apply if they meet the following conditions:

  • Migrated from the country before reaching the age of majority or have maintained permanent residence in another country for at least ten years.

  • Maintain no economic ties to any restricted country.

All applicants must still pass the complete due diligence process. The passport itself is not always the only concern. Long-term residence and economic connections also matter a lot sometimes.

Dominica Restricted Nationalities

Dominica has a dedicated official government page that deals with banned and restricted countries. Its requirements and rules differentiate between stronger bans and applicants who may qualify if they meet some additional requirements. 

Dominica’s Published Restrictions

Nationality/Jurisdiction

Published Treatment

Belarus

Banned

Russia

Banned

Yemen

Banned

Northern Iraq

Specified applicants banned

Iran

Conditional eligibility

North Korea

Conditional eligibility

Sudan

Conditional eligibility

Northern Iraq

All nationals of Northern Iraq remain banned from applying for the citizenship by investment program of Dominica. This includes citizens from the Kurdistan region of Iraq named as:

  • Erbil

  • Amedi

  • Dahuk

  • Kirkuk

  • Lalish

  • Raniya

  • Soran

  • Sulaymaniyah

  • Zakho

North Korea, Sudan, and Iran

North Koreans, Sudanese, and Iranians citizenship applications are treated differently under the citizenship by investment unit’s published page. 

The nationals of North Korea, Sudan, and Iran can be refused for Dominica citizenship by investment application unless the individual satisfies the following conditions:

  • The individual did not live in the relevant country for at least 10 years. 

  • The individual holds no substantial assets in the relevant country.

  • The individual conducts no business or similar activity in or with that country. 

However, the enhanced due diligence also applies at the expense of the applicant. 

Hence, this shows that Dominica provides a clear example of how a restricted nationality differs from a banned country. The restrictions can range from a direct ban to conditional eligibility based on an applicant’s circumstances. 

Grenada Restricted Nationalities

The Grenada citizenship by investment unit also publishes a list of restricted countries. The countries include:

Restricted Nationality

Can An Exception Apply?

Afghanistan

Yes, subject to conditions

Iran

Yes, subject to conditions

Somalia

Yes, subject to conditions

North Korea

Yes, subject to conditions

Yemen

Yes, subject to conditions

Sudan

Yes, subject to conditions

The above all six countries are restricted for Grenada citizenship by investment program. The nationals of these countries can apply for the program if they meet the following criteria.

  • They migrated from the country before reaching the age of majority.

  • They have no economic activity or ties with any restricted country. 

  • They have held permanent residency or legal residence in an approved country for at least 10 years. 

These approved countries include:

  • United States

  • United Kingdom

  • Canada

  • Schengen Member States

  • New Zealand

  • Australia

  • Saudi Arabia

  • United Arab Emirates

The government of Grenada warns individuals that enhanced investigation involves significantly higher costs. 

Saint Kitts and Nevis Restricted Nationalities

Among Caribbean CBI programs, St Kitts and Nevis applies one of the very clear nationality restrictions.  The country restricts nationals of six countries and the reason is national security and public safety. The restricted countries are stated below in the list. 

Restricted Nationality

Can An Exception Apply?

Afghanistan

No

Belarus

No

Iran

No

Iraq

No

North Korea

No

Russia

No

Unlike other countries such as Antigua and Barbuda, Grenada, the St Kitts and Nevis published list does not provide any type of exception including residence-based route or others that allow applicants to overcome the exclusion. 

The country is very clear in restricting these countries and does not accept applications from nationals of these countries. Saint Kitts and Nevis states that the restriction is applied due to national security, defence, and safety reasons. 

Another difference is that it applies restrictions on Iraq as a whole rather than on some cities like Dominica’s published restriction is limited to only some specified areas of Northern Iraq. 

The above facts are enough for individuals to understand that the assumption that Caribbean citizenship programs apply same nationality policies or restrictions is not correct. 

El Salvador Freedom Passport Restrictions

El Salvador publishes a list of prohibited jurisdictions that can not apply for El Salvador Freedom Passport citizenship by investment program. 

Following is the list of prohibited jurisdictions and regions:

Jurisdiction/Region

Restriction

Cuba

Prohibited

North Korea

Prohibited

Iran

Prohibited

Syria

Prohibited

Crimea (region of Ukraine)

Prohibited

Some other self-proclaimed jurisdictions that are prohibited include:

Jurisdiction

Restriction

Donetsk

Prohibited

Luhansk

Prohibited

Kherson

Prohibited

Zaporizhzhia

Prohibited

El Salvador uses the term ‘Prohibited Jurisdictions’ rather than ‘Banned nationalities’ which is more accurate. 

The September 2026 review also shows that the individuals appearing on the applicable Office of Foreign Assets Control (OFAC) sanctions list are also excluded from applying no matter what their nationality is. 

Can Restricted Nationals Still Qualify?

The restricted nationals can qualify sometimes but the policies and rules differ depending on the programs. There is no universal or same exception that applies across all CBI programs. 

So, it depends entirely on the country. 

Programs with Published Conditional Rules

Antigua and Barbuda: Certain restricted nationals may qualify for the Antigua and Barbuda citizenship by investment program based on the individual’s long-term residence outside the restricted nationalities and no economic ties to the restricted country.  

Dominica: Certain Iranian, North Korean, and Sudanese applicants can qualify if they meet the published ten-year permanent residence in another country criteria and have no assets and economic ties with the restricted country. 

Grenada: Certain Iranian, Sudanese, Yemeni, and Afghan applicants may become eligible for the Grenada CBI program after meeting the residence requirements, have no economic ties with restricted countries, and pass enhanced due diligence checks. 

Program With No Published Exceptions

Saint Kitts and Nevis is one of those countries that provides no nationality-based exceptions in its published restricted nationalities list. The country includes nations such as Afghanistan, Belarus, Iran, Iraq, North Korea, and Russia in the restricted countries list. 

This demonstrates that it is very important for applicants to assess legal eligibility criteria of countries before applying. Rather than just focusing on investment amounts comparisons or passport benefits, individuals should also consider reviewing the restrictions clearly. 

CBI Programs Without a Published Restricted-Nationality List

All citizenship by investment programs do not publish a complete list of nationalities. A September 2026 review found that only five of the 13 Caribbean CBI programs explicitly published the nationality or jurisdiction lists. 

The programs that do not publish lists may rely on other factors when considering such as:

  • Sanctions requirements

  • National security approval

  • Government discretion

  • Property-ownership restrictions

  • International compliance rules

  • Source of funds concerns

  • Due Diligence checks

A very important fact to consider is that a published restricted nationality list does not mean all other countries’ nationals will be accepted. An applicant should meet the eligibility criteria and fulfill the requirements defined by the relevant program to qualify. 

Does Residence Matter as Much as Nationality?

For some citizenship programs, there are other very important factors to consider an applicant’s eligibility for a program. For instance, if there are two applicants who belong to the same nationality but differ based on other factors.

One may have lived in the restricted country continuously and maintained significant economic and business ties there. While the other may have left as a child, lived in another country for more than 10 years and has economic ties with the restricted nationality. 

Then the above two applicant’s eligibility outcome can not be the same. Residence can matter where a program asks about applicant the following:

  • The applicant left the restricted country before adulthood.

  • The applicant has held permanent residence in another country for a minimum 10 years.

  • Holds a valid long-term residence permit.

  • Maintains assets in the restricted country.

  • Conducts business activity in the restricted country.

  • Can undergo enhanced background checks.

Antigua and Barbuda, Dominica, and Grenada all provide examples which show that there are other factors than nationality that should be reviewed to check eligibility. 

However, residence alone can not decide the eligibility as the person who has lived abroad for many years may still not be eligible for the program due to other factors. 

So certain factors are assessed together for different conditions to check whether an individual qualifies for a citizenship program. 

What Happens If Your Nationality Is Restricted?

Applicants should always review the eligibility criteria, residence requirements, restricted nationality lists before making any major financial decisions. Other than evaluating program benefits and investment routes they should check whether their application will proceed based on all other factors too. 

A smart investor must focus on the below steps during the process. 

1- Check the Official CBI Authority

The individual must check the rules and requirements on the government program website or current legislation. Individuals can read the third-party articles, they can also be useful, but the official authority remains the primary source of information for updated and accurate policies. 

2- Determine Whether the Restrictions Is Absolute

Individuals must understand about the program and along with that also check whether there are some restrictions for it.  They should verify whether a program applies the following:

  • A complete nationality ban.

  • A residence-based restriction.

  • A conditional exception.

  • Enhanced due diligence. 

The above conditions are not the same for every program. 

3- Review Your Residence History

If a program applies residence-based exceptions then individuals must provide proof of legal evidence showing where they have resided during the qualifying period. 

4- Check Your Economic Connections

Some programs specifically consider whether applicants maintain:

  • Business activity

  • Significant investments

  • Property

  • Financial interests

  • Other economic ties

With the restricted country. 

5- Review Sanctions Exposure

There are other factors to consider rather than nationality. Sanction status is one of those factors. An individual from another accepted country could still not qualify if they or relevant businesses appear on the applicable sanctions list. 

6- Compare Alternative Programs

Different CBI programs apply different policies. If an applicant is not eligible for one program, another country might apply different nationality rules. 

Hence, eligibility should be the first stage of program comparison before evaluating investment amounts, program benefits, family inclusion, travel benefits, and processing time. 

Why Due Diligence Matters Even When Nationality Is Allowed?

Due diligence is a significant step in the whole application process of some CBI programs. Applicants should not assume that if you live outside the restricted nationality list, it means approval will be very straightforward. 

Citizenship applications can still fail due to the following reasons such as:

  • Criminal history

  • Ongoing investigation

  • Sanctions concerns

  • Unexplained source of funds

  • Inability to verify financial information

  • False statements

  • Security concerns

  • Unresolved immigration issues

  • Adverse background findings

Dominica citizenship by investment program puts major focus on the due diligence process. It includes several layers rather than a single background check. 

Antigua and Barbuda provides published lists but also provides several factors that can make an applicant ineligible regardless of an individual’s nationality. 

Hence, an individual from a non-restricted nationality means an applicant may potentially enter the process but it does not guarantee approval for the citizenship application. 

Can Restricted-Nationality Lists Change?

Yes, CBI restricted nationality lists and eligibility policies can change with time due to national security, public safety, increasing international pressure, or due diligence process changes. 

Due to these concerns the list may change and exceptions may apply so the applicant must review updates list before making any financial commitment. 

Conclusion

Most countries offer citizenship by investment programs and accept applications from a wide range of countries but some citizenship by investment program’s eligibility criteria differ in terms of nationality, residence history, and individual circumstances.

Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis and El Salvador apply different nationality or jurisdiction restrictions. Some countries apply direct exclusions while some also provide conditional routes for applicants like the ones who have lived abroad for a qualifying period, have no economic ties with a restricted country or meet due diligence requirements. 

Hence, applicants should review their eligibility before comparing investment thresholds, processing times, or passport benefits. Saad Ahsan Residency and Citizenship can help individuals and families assess citizenship options based on their goals and profile. They help individuals evaluate the best program possible based on their nationality, residence history, or long-term goals. 

Frequently Asked Questions

Does citizenship by investment eligibility guarantee approval?

No. Eligibility means that an applicant may be able to submit or proceed with an application but it does not guarantee approval. An individual not belonging to restricted nationality in any way may apply for the program but approval will be granted is not guaranteed. 

Can sanctions affect citizenship by investment application?

Yes. Sanctions screening is separate from nationality eligibility. An individual may not be from restricted nationality but can not be eligible due to sanctions exposure, business relationships, or economic activities.

Does living outside a restricted country make someone eligible?

Not always, eligibility is reviewed based on multiple factors so an individual who has lived outside the restricted country does not guarantee eligibility. Eligibility requirements may also include economic ties, assets, business activities and enhanced due diligence.

Can Afghan citizens apply for citizenship by investment?

It depends on the jurisdiction. Antigua and Barbuda lists Afghanistan as a restricted nationality but provides an exception if they meet a certain condition. Similarly, Grenada also provides a conditional route. Saint Kitts and Nevis excludes Afghan citizens and ordinary restrictions.

Can Iranian citizens apply for citizenship by investment?

Some programs apply exceptions. Antigua and Barbuda, Grenada, and Dominica publish routes under which some Iranian nationals can apply for their citizenship by investment program.

Can Russians apply for Caribbean citizenship by investment? 

Eligibility depends on the program. Dominica includes Russia as a banned nationality.  St Kitts and Nevis excludes Russian citizens and residents. While Antigua and Barbuda’s official six country list does not include Russia.

Which nationalities cannot apply for citizenship by investment?

There is no single restricted nationality list for each citizenship program. Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis, and El Salvador apply different nationality of jurisdiction restrictions. Some restrictions are absolute, while others provide exceptions.