Design Is Not Distribution: Who Gets a Seat When a Country Sells Citizenship

When a government announces a citizenship by investment programme, smaller firms in the trade tend to hear the same verdict within a week: the big consultancies wrote the rules, so the big consultancies will take the business. The programmes those consultancies designed say something more precise. Under the 2023 regulations of St Kitts and Nevis, each contribution file pays US$20,000 to the international marketing agent and US$5,000 to the local agent who files it (SRO 26 of 2023). Both seats exist. One pays four times the other.

That ratio is the subject of this dossier. Design and operation were usually captured by one firm. Filing almost never was. What separated the firms that earned well from the firms that merely held a licence was who owned the client.

Only one programme closed the list

Montenegro is the case people have in mind. Its government designed the programme itself and named three intermediaries as the only firms allowed to submit applications, and those three filed all 711 applications counted by May 2022 (Government of Montenegro, 2019; Ministry of Interior of Montenegro, 2022). Twenty-two firms had applied for the role, local firms and a lawyer from Tivat among them (IMI Daily, 2019). Montenegro also wrote the one rule we found that shuts out a purely local firm by design: a licence only for a firm with at least three years of work in at least three countries, one of them a member of the EU, at EUR 50,000 a year (Government of Montenegro, 2022).

Almost everywhere else, the list was long and largely local.

Malta shows the pattern most clearly. Its 2014 regulations made one firm the concessionaire, “to design, implement, administer, operate and promote” the programme, and still let applications come “either through Approved Agents or the concessionaire” (Legal Notice 47 of 2014). The regulator later wrote that the concessionaire’s role had been “consensually toned down” from the start (Office of the Regulator, 2017). The design went to one firm. The filing went to more than a hundred.

The seat that pays is set above the seat that files

A licence is not a share of the money. Where regulations fix commissions, they favor whoever brings the client. St Kitts pays US$20,000 to the marketer and US$5,000 to the filer. Moldova paid EUR 25,000 to its service provider against EUR 10,000 to the accredited agent (Moldova CBI Unit, 2018).

The designer also earned on files it never touched. Malta’s regulator recorded EUR 19.054 million distributed to the concessionaire by June 2017 (Office of the Regulator, 2017), on a reported 4% of every contribution (IMI Daily, 2020), whoever had filed the case.

Volume concentrated as well. Between July 2019 and December 2020, “over half of the applications were submitted by only four agents” in Malta, and 27 of 62 agents filed a single application each (MaltaToday, 2022, citing the regulator). For most licence holders, the licence was a cost.

The share can move

None of this is fixed. Saint Lucia’s two exclusive marketers took 56% of the commissions paid in FY2017/18 and 18% in FY2024/25, with the authorised agents and promoters taking the other 82% (CIP Saint Lucia annual reports, 2018 and 2025). Exclusivity expired and the money followed the firms with clients.

In Cyprus, an unofficial ranking puts a local law firm first with 272 investors and the best-known global consultancy sixth with 33 (Dom). A local firm with a reputation in the right markets can out-file a global brand. The same programme carries the warning that goes with it: after it closed, the Cyprus Bar audited 26 law firms and fined five (Financial Mirror, 2023). Volume is an asset only while every file holds.

Three seats a smaller firm can hold

The first is often protected by statute. St Kitts admits as an Authorised Agent only a locally incorporated consultant, a local chartered accountant, or “an attorney-at-law who is a holder of a valid practising certificate”, and foreign marketing agents must contract with one and file through it (SRO 26 of 2023). Antigua licenses only citizens with seven years of residence (Antigua and Barbuda, 2016). Dominica licenses only citizens with an office on the island (SRO 8 of 2024).

The second is real and rarely written down. Malta’s 2021 code let agents appoint “Referral Sub-Agents” with the Agency’s approval and made the agent “fully responsible” for them (Malta Community Agency, 2021). The global firms advertise the tier openly; one pays introducers “a portion of our fee as a commission” (Henley & Partners, 2026). None of them publishes the terms. Kristin Surak described the arrangement a decade ago: “Local service providers may conclude agreements with the dominant consultancies that pledge to channel clients through their offices”, and these “smaller outfits do not shape the industry in the same way as the dominant consultancies” (Surak, 2016).

The third is the least visible and the most durable. São Tomé and Príncipe recorded 350 approvals in its first year and 29 passports issued (CIU São Tomé and Príncipe, 2026). Every case in that gap needs someone in the country who can move a document.

What a designer’s contract can say about the rest of the market

Argentina has left the clearest written statement of how a state might pay its designer. The tender for a single operator, 34-0001-CPU25, would have paid the winner a fixed price per favorable file “únicamente por las solicitudes que sean ingresadas por agentes locales o gestores o terceros ajenos al propio adjudicatario”, and nothing for files brought in by the operator or anyone linked to it (Ministerio de Economía, 2025). The ministry added that signing a services contract with a local agent was enough to make that agent “linked” (Ministerio de Economía, Circular 5, 2026). The tender was voided by Resolution 522/2026 on April 14, 2026, so none of it is law.

Two things in it still matter to a small firm. The design pointed the operator’s fee at independent agents, so the designer would have earned most where it did not compete. And it defined no “local agent” and created no accreditation; the reading that it “forces the master operator to build a certified agent ecosystem” is an interpretation, not tender text (IMI Daily, 2025). No official text had set rules for agents under Argentina’s programme as of October 7, 2026.

The European Commission’s 2019 review named the tension in this model: in none of the member states it studied “is there a mechanism to deal with the risk of conflict of interest” where the same firms advise governments and applicants (European Commission, 2019). Regulators who read that sentence tend to write rules that make room for independent filers. The seat a small firm wants is usually written in the agent rules, not in the announcement.