Vanuatu stops Russian and Sudanese applications under its Citizenship-by-Investment (CBI) scheme

The Vanuatu Citizenship Office has sent an official communication to all authorized intermediaries, stating that citizens of Russia and Sudan will no longer be eligible to submit applications for citizenship through investment (CBI). The measure, according to the notice, follows an internal memo dated March 9 and signed by Jack Canas, Compliance and Due Diligence Manager.

The revised eligibility limitations, published under reference 02COC/26, list eight affected countries: Iraq, Iran, North Korea, Yemen, Syria, Afghanistan, Russia, and Sudan. Notably, Russia and Sudan are the only newly added jurisdictions, while the remaining six had already been subject to restrictions earlier.

At the same time, Russian applicants are still able to explore other investment migration routes, including programs in Turkey, Jordan, and Egypt, along with other alternative jurisdictions. Still, Vanuatu’s decision effectively shuts down an additional option for a group whose choices have been shrinking since 2022.

Earlier, in early 2023, several Caribbean CBI programs tightened their policies for Russian and Belarusian nationals amid scrutiny and pressure linked to the U.S. Treasury. Around the same period, five Eastern Caribbean jurisdictions endorsed a framework commonly referred to as “six CBI principles.” Vanuatu did not formally align with that approach and, until now, continued accepting Russian applicants—an advantage that authorized agents had previously highlighted.

Timelines and why the ban may have been introduced

In recent years, Vanuatu’s CBI offering has repeatedly faced criticism and additional restrictions from Western partners. For instance, the United Kingdom removed its visa-free arrangement in July 2023, pointing to “clear and verifiable abuses.” Later, in late 2024, the European Union took further action by deciding to permanently end the Schengen exemption for holders of the relevant passports.

Separate reporting has also suggested that Port Vila’s travel-related status may have appeared on U.S. restriction lists. Against this backdrop, the Russian-focused limitation in Vanuatu can be seen as part of a broader pattern of policy adjustments intended to rebuild confidence across multiple destinations.

One World Migration head Anastasia Barna believes the move may be strategic and tied to negotiations: “I see only one reason: Vanuatu wants to discuss with the UK or the EU the return of visa-free travel. A prohibition affecting Russians would likely be the first requirement London and Brussels would ask for. I previously told clients: ‘hurry up,’ because it looked inevitable.”

CEO of Savory & Partners Jeremy Savory reaches a similar conclusion, emphasizing timing. “Other countries introduced similar changes two years ago. Vanuatu kept processing applications. They may have assumed alignment with UK and EU expectations wouldn’t be necessary—but a trigger likely occurred. It’s also possible that application volumes rose and that certain passport holders’ documentation and behavior drew attention. Those factors could easily have influenced the government’s decision.”

At the same time, Savory & Partners noted that the firm had not recommended Vanuatu to clients for several years. In its view, even early in the review stage it became apparent that the program did not align with the due diligence standards applied by other players in the market. “Time confirmed that the conclusion was correct,” Savory added.

Reshaping the program: a broader compliance “reset”

Alpha Immigration Associates managing director Manpirit Kataria interprets the decision as part of a wider effort to raise compliance levels under the administration of Prime Minister Jotham Napat. “Vanuatu is focusing on long-term reputation, not just short-term application numbers. Between probes involving diplomatic passports, stricter banking controls, and related actions, the new leadership deserves credit for trying to change the overall direction.”

Other steps support this interpretation. In March 2025, the government fully suspended the Capital Investment Immigration Plan (CIIP) as part of a regulatory “reset.” In late 2025, officials investigated four authorized agents suspected of falsifying payment receipts. Prime Minister Napat also ordered the revocation of the Vanuatu passport of IPL founder Lalit Modi, citing concerns connected to extradition proceedings.

“In this industry, the central value isn’t the passport alone—it’s the trust that comes with it,” Kataria stressed.

Economic consequences and budget impacts

The restriction is also expected to have financial implications. Vanuatu’s CBI income reached its high point in 2020, at USD 132.6 million, representing 42% of total budget inflows. After the Schengen exemptions were withdrawn, revenues declined: in 2023 they dropped to USD 68 million, and in 2024 they were approximately USD 60 million.

How much of the remaining demand came specifically from Russian nationals remains unclear, as Port Vila does not provide a detailed breakdown by country of applicants.

Grenada is often cited as a comparison case. Before Grenada’s own Russian restriction took effect, around 90% of applicants in 2023 were Russian. Vanuatu likely depended less on that source of demand, yet the willingness to give up part of revenue suggests the government concluded that diplomatic risks now outweigh potential fiscal benefits.

“Ultimately, the winner isn’t always the ‘largest’ program—it’s the cleanest one. The credibility of a passport matters more than chasing application volume,” Kataria said.

Administrative confusion or clarification of wording?

A source connected to the Civil Commission told IMI (on the condition of anonymity) that the memorandum may have stemmed from an internal misinterpretation. The source suggested the original plan might not have been an absolute stop to applications, but rather strengthened due diligence specifically for applicants from Russia and Sudan. The source also added that the authorities intend to clarify the situation soon.

IMI will update the article as soon as new details are confirmed.

If you are considering citizenship by investment (CBI) and want to avoid surprises from changing eligibility rules, it’s important to work with reliable information and perform rigorous due diligence. At Digital Nomad, we assist in evaluating available pathways, preparing the required documentation, and understanding how compliance updates can influence your schedule and approval prospects—so you don’t invest time in routes that are becoming restricted.

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