Citizenship by Investment: Dedicated Crypto-Friendly Compliance Process

Is it possible to use crypto gains as proof of source of funds for Citizenship by Investment in the Caribbean, Vanuatu and Turkey? This is a question we are asked a lot these days, and the answer is definitely YES!


With the unprecedented level of interest from the crypto community recently, NTL Trust launched a new compliance route specially to handle crypto citizenship applications more efficiently - reducing risk for all stakeholders by using reputable crypto-friendly escrow agents, banks and trust companies.


The Caribbean and Turkey in particular have seen a wave of applications from individuals who have been successful at growing their wealth in crypto. Crypto being a volatile investment, the smart thing to do is to lock in some profits for the long term.


How? By investing in the ultimate hedging strategy: a new citizenship, possibly backed up by a hard asset in the form of real estate. A new citizenship is an investment that will literally provide benefits for the rest of your life… and beyond for your children and their children.


Are all Citizenship by Investment Countries Crypto-Friendly?


The Federation of St Kitts and Nevis, alongside Antigua and Barbuda, are the CBI countries in the Caribbean have so far proven to be the most crypto-friendly citizenship by investment jurisdictions. They have specifically passed legislation supporting virtual or digital assets and digital currency exchanges in recent years.


However, NTL Trust has successfully submitted many cases with crypto source of funds citizenship applications in St Lucia, Dominica, Grenada, Vanuatu and Turkey as well. Some clients prefer these jurisdictions because of the many other benefits they offer. The governments don’t need to be crypto-friendly per se – all that is needed is that their due diligence committee is crypto literate enough to understand source of funds documentation, and that a reliable intermediary such as an escrow agent can facilitate the exchange to fiat funds if necessary.


Is it difficult to prove source of wealth?


Due to the nature of crypto, where all transactions appear on the public blockchain, it is easy for most crypto investors to prove source of funds and wealth. It is important, however, to have a crypto-literate compliance officer, a clear policy on crypto source of funds, and also bank escrow agents who understand crypto transactions in the case of real estate transactions.


Of course, governments are keen to avoid being duped into granting citizenship to bad actors. The most important thing they can do is uphold the integrity and reputation of their programs for the long term benefit of all their existing citizens.


What is the opinion of regulators on the matter?


It is important to understand that Citizenship by investment is not your typical crypto transaction. The main compliance issues with crypto involve the on and off ramps into fiat, and the need for high velocity transactions.


With citizenship by investment, there is a significant manual element to the due diligence process, which can take some weeks. From our point of view (and our regulators agree), this reduces risks and allows us to review every case on its merits. If necessary, a specialist forensic investigator of crypto transactions will check the data provided.


If I have crypto assets, how do I prove my source of funds is legitimate?


For most crypto investors interested in obtaining a new citizenship, brokerage account statements from companies like Binance will be the key documentation. Where assets are held on physical devices like Trezors, or in software wallets, the transactions and current valuations can usually be verified using screenshots and blockchains. A personal financial statement prepared by a crypto-friendly CPA may also be useful, or a legal opinion from a law firm that understands blockchain. We can make the necessary introductions.


If your source of funds is slightly more complex (for example, your own ICO) we also have solutions and – importantly – experience.


What if I do not have sufficient bank balance?


Most crypto investors do not keep large amounts of money in the banking system. Yet copies of bank statements are invariably required when applying for citizenship by investment. The solution is generally to provide bank statements with weak balances, but demonstrate with alternative documentation the solvency of the crypto balances. We can help you with this. It may be necessary for you to open a crypto-friendly offshore bank account.



Can I buy qualifying real estate with crypto?


Yes. Some real estate developers are happy accept crypto funds directly. In other cases, they may prefer to receive fiat but our exchange and escrow partners can facilitate the deal in the background, fixing the contract price in the coins you have.



The key takeaway is that NTL Trust understands crypto investments as a source of funds – how to do our own AML/CFT due diligence, and how to present your application to your chosen government in such a way that everything is clear to them so they can process your application for a new citizenship in the fastest possible time.


Please contact NTL Trust today to discuss your requirements!

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