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A second passport bought for safety can become the flag

By Immimaps4 min read
A second passport bought for safety can become the flag

Since 2025, citizenship by investment has been named in US screening rules, in EU visa law and in an EU court ruling. What the texts say, and who they reach.

Why people buy a second passport

A citizenship bought through an investment programme is often sold as a safety net: a second passport for travel, for family, or for a time when the first one stops opening doors. Since 2025, several official texts have started to treat that same purchase as a reason for a closer look.

What the texts say

United States, the December 2025 proclamation. Proclamation 10998, in force since 1 January 2026, explains in its preamble that "some of these countries have offered Citizenship by Investment (CBI) without residency", which "poses challenges for screening and vetting purposes". It gives an example: "a foreign national from a country that is subject to travel restrictions could purchase CBI from a second country that is not subject to travel restrictions" and so evade the restrictions on the first. For two countries placed under partial restrictions, Antigua and Barbuda and Dominica, the one reason the proclamation gives is that each "has historically had CBI without residency".

United States, the January 2026 hold. The USCIS memo PM-602-0194, dated 1 January 2026, held pending applications filed from inside the US by people from the countries in that proclamation. Its footnote defines who is covered as people with a nationality or country of birth in a listed country, or people "who have acquired Citizenship by Investment (CBI)" listed in the proclamation, and repeats the proclamation's example. Law firms report that US courts set this memo aside in June 2026 and blocked it in August 2026.

European Union, visa-free travel. Regulation (EU) 2025/2441 changes the EU's rules for suspending visa-free travel. Its final text, dated 5 November 2025, adds a new ground: a visa-free country that runs an investor citizenship scheme, granting citizenship for predetermined payments or investments without a genuine link to the country. Its recitals point to serious security risks from weak vetting, such as money laundering and corruption. It does not suspend anyone by itself. It gives the EU a ground to act against the selling country, and the people who would lose visa-free travel would be that country's citizens, including those who bought in.

Malta, after the EU Court of Justice. On 29 April 2025 the EU Court of Justice ruled that Malta's 2020 citizenship-by-investment scheme broke EU law: granting nationality, and with it EU citizenship, for predetermined payments made it a commercial transaction. Malta replaced the route with naturalisation on merit. Its regulations, published on 29 July 2025, say that direct-investment applications "which had not been approved for naturalisation by the Minister … prior to 29 April 2025, shall cease to have effect". People already naturalised keep their citizenship.

Residence by investment: closed, with filers protected

Two EU countries closed investor residence routes in the same period, and both protected people who had already filed. Spain's law, in force on 3 April 2025, lets investors who filed before that date be decided under the rules in force when they filed; the law itself gives no reason for the change. The Netherlands ended its investor scheme on 17 April 2024, still assessing applications filed before that date under the old policy; its explanatory note cites EU concern about criminal risks such as money laundering. Malta's lapse of unapproved citizenship applications is the exception, not the pattern.

Who it reaches

Holders of a citizenship bought through an investment programme, especially where their birth nationality is on a restricted list. People with a citizenship application under an investment programme still in progress. And citizens of countries that sell citizenship, whose visa-free access to the EU now has a stated condition attached.

What it tells you

This is analysis of a record, not a forecast. A second passport bought for safety has been named, in these texts, as a way to get around screening. Holding one can bring its holder into a screening group they would not be in by birth alone. In the US texts, the purchase itself is part of the definition. In the EU, the scheme can cost the selling country its visa-free travel. In Malta, applicants without ministerial approval by the court's date lost their application.

What would show this wrong

A destination exempting people who hold an investment citizenship from nationality screening, or the EU leaving the new ground unused against countries that keep selling citizenship.

Sources

General information, not legal advice.

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