Argentina’s CBI Ambitions Outpace Its Institutions

May 14, 2026 | Noticias del Estudio

Paula Carello, former Technical Advisor to Argentina’s National Directorate of Migration, argues that the cancelled procurement exposed structural flaws that no new tender can resolve, warning that Argentina currently lacks the institutional safeguards necessary for a citizenship-by-investment program. She maintains that Buenos Aires should instead prioritize exploring residence-by-investment (RBI) mechanisms, emphasizing that citizenship should reflect a genuine bond with the Republic rather than the mere purchase of a passport.

On April 14, 2026, Argentina’s Ministry of Economy quietly annulled International Public Tender No. 34-0001-CPU25, the procurement process that would have awarded a four-year contract (or until 5,000 positive citizenship recommendations were issued by the Citizenship by Investment Agency, whichever came first) to a consulting firm or consortium for the design, implementation, launch, and promotion of the country’s citizenship by investment (CBI) program.

Resolution RESOL-2026-522-APN-MEC was not published in the Official Gazette, and its language was, to put it charitably, cryptic.

Article 1 approved “the proceedings conducted” for the tender. Article 2 annulled the tender itself. The reasoning, buried in the recitals, cited a Technical Report warning that continuing “under current conditions might not ensure the degree of coherence, comprehensiveness, and strategic coordination required for the adequate implementation of the program.” That is bureaucratic language for “we need to rethink this.”

The decision was prudent. What the tender process exposed, however, deserves public scrutiny it has not received.

The tender nobody covered

The procurement launched on December 5, 2025. No Argentine media outlet reported it. Eleven foreign companies (none of them Argentine) expressed interest; six submitted formal bids before the January 20, 2026, deadline.

The bid evaluation report, published March 5, recommended a consortium for the award. Two losing bidders filed formal challenges. One month later, the Ministry pulled the plug.

Part of the procurement file remains inaccessible through the COMPR.AR official tender’s portal, contrary to transparency and accountability principles. Key documents are missing, including the bids (certain portions of which should be public, while others may legitimately remain confidential), the Technical Report that led to the cancellation (IF-2026-28784861-APN-SLYA#MEC), the text of the challenges, and the observations on the offers.

My team has submitted both a formal request to review the case file and a public access-to-information request. One has received an evasive response referring us back to COMPR.AR, while the other remains unanswered.

The silence extends well beyond the procurement portal. The government has not discussed it in political speeches, press conferences, or specialized forums. It consulted no local experts, no academics, and (I would venture to say) no international organizations such as the IMF, the FATF, the IOM, or OECD, all of which have flagged CBI programs as vehicles for money laundering, terrorist financing, corruption, evasion of financial sanctions, evasion of justice, or the misuse of citizenship to hide assets offshore by escaping international tax reporting mechanisms and standards (for example, the OECD/G20 CRS), whether through tax avoidance or evasion.

The only (or main) actors paying close attention to the topic have been the international CBI firms themselves. Several are already capturing leads on their websites.

In this context, it cannot be ruled out that actors linked to this sector have engaged in lobbying activities oriented towards the regulatory amendment by the executive branch and the eventual launch of the program.

Both sides of the counter

The core problem with the annulled tender was not procedural. It was structural.

The Specific Terms and Conditions required (among other things) the winning firm to “assist the Agency in establishing an information system designed to receive applications online and evaluate them.” The awarded company would have designed the intake and evaluation system, advised the government on what qualifies as a “relevant investment” under the new Article 2 of Citizenship Law 346, and simultaneously maintained its own global client pipeline of applicants who would use that very system.

This is not a theoretical conflict of interest. Every firm that bid operates in the B2C space, sourcing and shepherding individual applicants through CBI programs worldwide.

The winner would have been positioned on both sides of the counter: designing the rules, building the infrastructure, and then feeding its own clients into it. This overlap demands institutional safeguards guaranteeing impartiality and transparency. The tender contained none.

Consider the launch-day scenario: the awarded firm, having helped build and configure the application system, submits 5,000 client files within the first hour of operations. Which applications are evaluated first, and under what priority framework? Who would have designed that framework? The same firm, or the government, acting with its close support and advice.

Buenos Aires, Argentina

The source code issue compounds this problem. Had the contract proceeded, the winning consortium could (or would) have retained ownership of the system’s codebase. Every future update or upgrade would then have generated recurring costs for the Argentine state, replicating the dependency dynamic seen in outsourced electronic visa systems (as well as other digital systems such as entry-exit controls or electronic case files) across multiple jurisdictions.

Argentina’s National Migration Directorate (DNM, the authority currently responsible for granting citizenship by naturalization) developed its own RADEX system for immigration procedures using internal technical staff. There was no operational reason to hand CBI application infrastructure to an external party with commercial interests in its output.

The contrast with international practice is instructive. In EU-funded migration cooperation programs (border management, for instance), the European Commission contracts external experts through pre-existing framework agreements with firms and/or consortiums of firms that have been previously evaluated and selected.

No comparable institutional framework existed between the Argentine government and the firms competing for this tender. These were companies with no prior formal cooperation with Buenos Aires, bidding to design and implement a program of extraordinary sensitivity.

Institutional challenges

The legal architecture for Argentina’s CBI program exists on paper. DNU 366/2025 amended the Citizenship Law. Decree 524/2025 created the CBI Programs Agency.

The amended Article 2 of Law 346 establishes that foreigners who make a “relevant investment” may naturalize “regardless of the length of their residence.” In practice, almost nothing behind this framework is operational.

The CBI Programs Agency had no director, until recently. Last week, through Decree 285/2026, a public official from the national tax authority was appointed to the position on a pro bono basis, an unusual arrangement for a role of this nature.

It is also worth noting that President Milei has stated that “no hay plata” (“there is no money”) in his initial presidential speech and has subsequently dismantled various public structures since the beginning of his mandate. Against this backdrop, the creation of new positions for this initiative, or the potential engagement of an international company, appears difficult to reconcile with the government’s stated fiscal constraints.

The term “relevant investment” has no regulatory definition. Article 2 bis of the amended law delegates that definition to the Ministry of Economy, which has not issued it yet. The threshold of US$500,000 announced by the presidential spokesman in 2025 remains a press statement, not a regulation.

The Tender’s Specific Terms and Conditions further reveal that the types of investments to be considered “relevant” would ultimately have been established following the advice of the awarded foreign company, which, per Section CI of Annex I, was expected to provide “consulting services, analyzing the legislation.” In what universe is a foreign firm, without prior experience in Argentina and unfamiliar with its legal, social, economic, and cultural reality, in a position to determine which investments are genuinely useful or strategic for the country?

Mendoza Province, Argentina

The division of responsibilities between the Agency and the DNM remains undefined. The DNM, a decentralized body now under the Ministry of Security (having previously been under the Ministry of the Interior), already handles residence permits and, following the DNU’s transfer of jurisdiction from the federal courts, naturalization by residence.

Adding CBI processing to its workload raises an immediate practical question: What happens to the existing backlog?

Residence permits are currently taking four to 12 months. Naturalization applications filed in 2025 under the two-year residence track have not moved, reportedly because the Citizenship Law’s implementing regulations have not been issued.

When CBI cases begin to arrive (the DNM is expected to approve or reject them within 30 days, as per Decree 524/2025), how will priorities for case supervision be set? The institutional architecture is not yet in place. Additional human resources will need to be recruited and trained to meet this demand. Unless, of course, the intention was to outsource part of this processing to a foreign firm (an unthinkable scenario in institutional terms).

The dual e-system problem compounds this issue. The DNM operates the “RADEX” information system for immigration and citizenship procedures, while the Ministry of Foreign Affairs relies on GDE, a separate electronic system.

When a case touches both systems (as border rejections under DNU 366/2025 do, since appeals go through consulates using GDE while the underlying file sits in RADEX), coordination between the two platforms creates delays that are sometimes insurmountable. A CBI applicant whose file involves both the Agency and the DNM would probably face the same friction, unless a new inter-institutional mechanism is established. This points to the need for strong cross-agency arrangements.

Finally, no supervisory or evaluation mechanism has been established to oversee the work of the Ministry of Economy (through the Agency, which receives applications, conducts the initial assessment, and carries out due diligence) and the Ministry of Security (through the DNM, which makes the final evaluation and decision).

Nor has any inter-institutional approval mechanism been put in place, as exists in other highly sensitive matters such as the recognition of asylum status within CONARE.

The only form of oversight would be judicial review, once the DNM, exercising its discretionary authority, has rejected an application and the case is brought before the courts, an outcome that is not ideal for investors seeking fast and efficient procedures.

Santa Fe Province, Argentina

What does “relevant investment” actually mean?

The historic Citizenship Law, dating to 1869, recognized people who established a new industry in the country, introduced a useful invention, or any other moral or material advancement to the Republic, the right to nationality. The spirit of the law was to recognize the value of those who chose to build, contribute, and innovate in this country.

The inventor, the entrepreneur, the person who introduced a mode of production that did not previously exist locally. Those were individuals who lived in Argentina and left a mark. In today’s terms, “citizenship by merit.”

DNU 366/2025 replaced all of this with “relevant investment.” Two words, undefined, carrying the full weight of who gets to become Argentine.

Under the previous framework, a “new industry” meant one that did not exist locally, promoting employment and innovation. A “useful invention” meant an idea, patented or not, that someone wished to introduce. The focus was on utility from the standpoint of production, not commerce.

The new law narrows this further. The monetary amount invested threatens to become the sole criterion.

I believe this is a mistake. Certain industries or inventions of high community, social, cultural, or economic impact may require minimal or even zero capital investment: data processing mechanisms, innovations in social sciences, or technological solutions are some examples.

The results they produce could be profoundly beneficial for the country. Under the new letter of the law, someone with a transformative idea but no capital will find it far harder to justify access to citizenship. I hope I am wrong.

In addition, I believe that other forms of “merit” in the national interest (scientists, artists, athletes, and others) should also be recognized, and that mechanisms allowing access to citizenship for such individuals should be further explored rather than excluded from the letter of the law, as this would run counter to both the spirit and the letter of the Constitution itself. Revisiting the experiences of other countries in this regard is essential for sound normative and policy development.

Finally, the acquisition of citizenship based on family ties (including parents and partners) is also fundamental, yet it was omitted from the new text of the law. This omission directly affects the right to family unity and the protection of the family as recognized under international law.

Buenos Aires, Argentina

Are donations investments?

This is not an abstract question. Even before DNU 366/2025, members of certain communities attempted to channel citizenship applications through “donations” to public hospitals or educational institutions, presenting these contributions to federal courts (which then held jurisdiction) as a basis for naturalization, based on the existing provisions. Very few succeeded.

Under the emerging regulatory framework, this mechanism could acquire a new dimension. Article 6 quater, subsection f) of the amended Law 346 grants the CBI Programs Agency the authority to accept “inheritances, bequests, and donations” as part of the investment scheme. It is, however, important to note that there is no program yet and apparently there eventually may be “programs” (not only one).

To which projects would these funds be allocated? Would they reach vulnerable populations or be used to reduce external debt? Would they finance NGO initiatives, and if so, which projects and which organizations? Who would define priorities, and through what mechanisms? None of this has been established and should further be studied.

A “whole-of-government” (WoG) and “whole-of-society” (WoS) approach (in line with the Global Compact on Safe, Orderly and Regular Migration) should be applied in any CBI (and RBI) program, and even more so in matters related to donations and engagement with civil society. In this regard, lessons from other countries should be considered, such as the creation of a dedicated fund to channel resources in a transparent manner, with multiple layers of oversight to prevent corruption and diversion of funds.

Investment modalities in CBI programs worldwide typically cluster around four pillars: i) direct donations to government funds (non-refundable contributions); ii) business investments (capital injections into local businesses); iii) real estate acquisitions; and iv) placements in financial instruments (government bonds or approved funds).

Each carries distinct risks (for the country and the community offering CBI, and for the investors themselves). Real estate, for instance, is among the most widely used modalities globally because it is relatively easy to execute (and attractive to applicants), but its social and economic disadvantages are well documented.

Concerns about housing affordability and market distortions have featured prominently in policy debates in countries such as Spain or Portugal, including decisions affecting the real estate pathways of their golden visa programs.

In addition, real estate-based programs can be vulnerable to mispricing and weak oversight. In some cases, properties may be deliberately overvalued; applicants are recorded as investing, for example, US$1 million in an asset that is in fact worth a fraction of that amount, allowing intermediaries or developers to capture the difference.

These structures can also facilitate money laundering, not only from foreign applicants but also from domestic actors, if due diligence, valuation standards, and source-of-funds controls are insufficient. With respect to real estate, it is essential to channel investment initiatives across different regions of the country (as other jurisdictions offering CBI have done), rather than concentrating them primarily or exclusively in Buenos Aires.

Santa Cruz Province, Argentina

A format that is strategic for the investor is not always aligned with the needs of the receiving community. For any of these modalities, Argentine authorities would benefit greatly from direct peer-to-peer exchanges with counterparts in other countries, sharing practical experience rather than relying solely on international private intermediaries, whose interests may not align with the national interest and whose understanding of the local context is limited or nonexistent.

With regard to donations, I would personally welcome contributions to local clubs, which operate as NGOs in the form of associations, many of which have closed or are at risk of closing due to lack of funding. Their infrastructure is often in poor condition, despite their community impact.

The Villa Malcolm Club in Argentina, photo by Paula Carello

Other NGOs focused on support to vulnerable populations, science, the arts, or animal welfare could also benefit from such a program. The challenge lies in ensuring that funds are properly channeled and allocated fairly.

Closing the alignment gap

In practice, there was often a lack of alignment between individuals with ideas or investments they wished to contribute, whether in health, industry, or social sciences, and the institutions or companies capable of developing them locally. CONICET (the national research council), NGOs, local entrepreneurs, and even government bodies all played a role, but there was no public policy focused on effectively matching one with the other.

A future CBI program could facilitate that kind of partnership: a system of foreign investor “sponsorship” of local entrepreneurs, NGOs, or even public institutions (in particular, local authorities from less advantaged or developed areas of the country). However, given the well-known challenges related to transparency and administrative capacity in parts of the Argentine public sector, that more ambitious path may be difficult to realize in practice. There’s no harm in dreaming (“soñar no cuesta nada”).

Who gets a passport? The family question

CBI marketing literature speaks of citizenship as “legacy.” Where previous generations bequeathed real estate or money to their children, today’s “high-net-worth” families think in terms of passports.

This raises a design question Argentina has not yet addressed. Does the investment benefit only the person making it, or does it extend to family members?

If the latter, to whom? Children? Grandchildren? Parents of the investor only, or also those of the spouse? How many spouses?

Some market participants have been blunt: if the program benefits only the applicant, it will fail commercially. I am not entirely convinced, based on my experience and recent consultations on the subject.

Article 2 of Law 346 was not modified on the minimum age for naturalization: over 18 years of age. Legally, the program cannot include minor children of investing parents.

Even if some legal device were found to permit it, the resulting discrimination would invite litigation. Children of parents who naturalized through the two-year residence track receive no such extension; why should children of investors with no link or rootedness to the country?

In terms of comparative law, approaches vary. Some jurisdictions accept only minor children; others extend to adult children up to age 30; a few include the applicant’s parents. A comparative analysis between CBI family extension and the established concept of “family reunification” in Argentina’s immigration law would be timely and illuminating, but it has not been conducted.

Another issue that warrants further exploration is the level of investment required from family members, as most jurisdictions establish a lower threshold for dependents than for the main applicant.

Buenos Aires, Argentina

Money, merit, and services

Beyond the family scope, there is the question of whether Argentina should consider a form of “citizenship by merit” (as it has historically done), either instead of or alongside pure CBI. Countries such as Austria and Malta have moved in this direction, framing their approaches around “exceptional services” rather than investment alone, although some argue that, in practical terms, the distinction is largely one of labeling rather than substance (when it comes to financial contributions).

This is broadly consistent with the Argentine constitutional framework, which provides that foreigners may “obtain naturalization after two continuous years of residence in the Nation; however, the authorities may shorten this period in favor of the applicant, provided they demonstrate and prove services rendered to the Republic” (Article 20).

Whether this model could be applied in the new Argentine context, given the evolving institutional framework (notably the creation of a new Agency and the shift of decision-making authority to the Federal Immigration Department rather than Federal judges), and how it might be implemented, is worth exploring. At a minimum, it would preserve the spirit of the Constitution’s recognition of contributions beyond purely financial ones.

The DNM’s discretionary power to grant or reject applications may raise concerns for some in this regard, as is also the case in other countries where the process is not governed by a simple formula-based program. In this context, the role and expertise of local lawyers is essential.

Constitutional questions: nationality law amendments and investor residency requirements

Decree of Necessity and Urgency No. 366/2025 did not go through Congress. It amended the Citizenship Law (along with the Migration Law, the National Education Law, and the Higher Education Law) by a presidential intervention.

As highlighted, Article 20 of the Argentine Constitution provides that foreigners shall obtain naturalization by residing two continuous years in the Nation; but the authority may shorten this term in favor of those who request it, alleging and proving services to the Republic. The original Citizenship Law 346 interpreted “services to the Republic” expansively but always in the context of people who lived in Argentina.

The new framework explicitly permits naturalization “regardless of the length of residence,” which means a person could spend a few days in Argentina, write a check, and leave with a passport. Whether this is constitutionally compatible with Article 20 is a question that multiple pending cases are already testing.

Federal courts have received challenges seeking declarations of unconstitutionality of DNU 366, many centered on the DNU’s requirement that naturalization-by-residence applicants must not have left the country for a single day during the qualifying period of two years.

The CBI residency mechanics remain undefined.

Would a CBI applicant need to obtain a residence permit, as all other naturalization applicants must? Could they process citizenship on a “transitory” residence granted for “special reasons” under Article 24, subsection H) of the Migration Law? Could they naturalize without having spent a single day in the country, that is, eliminating (instead of “reducing”) the residence requirement, and applying, for example, at the consulates?

Santa Fe Province, Argentina

There is also a deeper question about the DNU mechanism itself. Citizenship is a matter that, under the Constitution, should be subject to congressional debate. Amending the Citizenship Law by an emergency decree, bypassing the legislature on a question of this magnitude, raises questions about the legitimacy of the entire framework, which I strongly agree with.

And beneath the legal architecture sits an uncomfortable moral and human question. Certain persons with no connection to Argentina, but with substantial financial resources, can access citizenship, while others who have lived in the country for years on modest incomes cannot even get their permanent residence permits processed.

The injustice of this asymmetry cannot go unmentioned.

What the EU trajectory should tell Buenos Aires

Argentina seems to be entering a “market” that the world’s most developed legal systems are actively exiting. The CJEU ruled Malta’s program illegal under EU law on April 29, 2025, finding that selling citizenship without a genuine link to the country violates principles of loyal cooperation.

The European Commission has required accession candidates (Moldova, Montenegro) to shut down their CBI or RBI programs as a precondition for membership talks (North Macedonia and Serbia did not have full CBI programs but were warned). Brussels has also pressured other third countries enjoying Schengen visa waivers to reconsider CBI offerings or risk losing that access.

The passport devaluation risk is not abstract. Argentina’s visa-free access profile, built over decades on the basis of its nationals’ compliance with immigration rules abroad and the credibility of its identification and security systems, could be undermined if a poorly managed CBI program results in passport holders whose backgrounds, documentation, or travel patterns prompt increased scrutiny from receiving countries.

Over time, this could lead not only to individual questioning at borders, but also to broader diplomatic friction, stricter visa requirements, or enhanced vetting for all Argentine citizens, regardless of how they obtained nationality.

The UK’s recent decision to strip Saint Lucia of visa-free access illustrates how quickly this can happen and how difficult it is to reverse.

Conversations with the EU Delegation in Buenos Aires could perhaps bear fruit and help avoid various of the mentioned risks.

Buenos Aires, Argentina

The RBI alternative

Argentina already has a legal basis for residence by investment under Migration Law 25,871 (article 23, d), in force for over 20 years. In practice, however, the pathway functions only very limitedly, due to institutional, economic, and operational barriers. In our experience handling a small number of cases, implementation has been sporadic, but not particularly difficult to navigate.

The DNM has granted investor residence to a handful of individuals, but no structured program exists. This is worth more attention than it has received.

Argentina is not a passport-of-convenience destination in the mold of a Caribbean island; it is a place where many foreigners actually choose to live nowadays (although I would personally also love to live in the Caribbean or the Pacific). An RBI program would therefore be more likely to attract applicants with genuine residential intent, generate capital inflows (potentially at lower individual thresholds but higher aggregate volumes) and avoid the constitutional, political, ethical, and reputational risks associated with CBI.

It would also build institutional capacity. The DNM would continue developing its internal expertise, due diligence infrastructure, and inter-agency coordination needed to evaluate investment-linked applications before the stakes escalate to the level of irrevocable citizenship grants.

Lessons learned from an RBI program could directly inform any future CBI design. The government’s own Resolution (which I comment on in the opening lines of this article) hints at this logic: the language referring to “reassessing the operational relevance of the ongoing process” reads like an implicit acknowledgment that the institutional foundations are not yet in place. An RBI program could help build them.

In a 2024 Access to Public Information request, I obtained the following information from the DNM regarding RBI:

Investor Residency Applications Initiated (2010–2024, as of September)

PeriodTotal
20107
20114
20129
20132
20143
20152
20162
20173
20182
20191
20200
20214
20224
20230
20240
TOTAL43

Favorable Investor Residency Decisions (2010–2024, as of September)

PeriodTotal
201018
20115
20123
20132
20143
20157
20166
20175
20183
20190
20200
20210
2,0220
20230
20241
TOTAL53

Closed Cases

YearTotal
20121
20151
20161
20171
20186
20192
20212
20221
20232

In one of the responses received, I was informed as follows: “Finally, it is hereby informed that, with regard to point 3, no regulatory administrative act has been issued, and a possible regulatory update is currently under review.”

While recent press releases have addressed the government’s current intentions regarding RBI, the draft regulation has in fact been under development for almost three years (or even more).

Three (or four?) paths forward, and recommendations

With the tender annulled, Argentina has three options, although a fourth may already be emerging or already taking place.

The first is to launch a new procurement process with revised terms. If the government goes this route, the terms must address the conflict-of-interest problem head-on, as well as the many others raised above.

A B2B model, in which the consulting firm operates through registered local intermediaries rather than maintaining its own client pipeline, would partially mitigate the “both sides of the counter” dynamic. Local experts, academics, and regional or international organizations of which Argentina is a member, such as the OAS, UN, or MERCOSUR (or others such as the OECD, which the country intends to join), should be included in the design process, rather than relying exclusively on foreign firms competing for a contract.

Their insights and experience are valuable and should be taken into account, albeit with appropriate caution.

A call for expressions of interest from prospective promotional agents would allow the state to know its partners, diversify its channels, and enforce unified messaging. Every company in this market will promote the Argentine program regardless; the state might as well know who they are.

The second option is to design the program internally. Argentina has highly qualified personnel within the federal immigration authority, which would be responsible for approving citizenship applications, who have successfully implemented a well-established immigration architecture, including digital case management systems and innovative policies and practices, as well as due diligence procedures. This strong institutional capacity extends beyond migration to other ministries as well. As I have noted before, “this is not rocket science, after all.”

A working group or committee composed of local specialists (lawyers, economists, NGO representatives, specialists in health, education, science, and environment), government officials (including the Federal Investment Council), international experts invited in a consultative capacity, and public officials and academics from countries with CBI and RBI experience could help produce a viable design. It would suffice to hold a series of expert meetings and conduct study trips or virtual exchanges with countries that already operate such programs. It would also be worthwhile to talk to countries that discontinued or modified theirs, to learn from their experience.

A baseline assessment using Logical Framework methodology (or an equivalent) should precede any action: feasibility, stakeholder analysis, risk analysis, IT system evaluation, and so on.

The design should balance productive, economic, and social development in the terms of the RIGI (Decree 749/2024) with human development at its center, in the terms of the United Nations Development Program (UNDP) and the Sustainable Development Goals (SDGs).

The design should include a monitoring system (for example, a mid-term review or an evaluation after the first 200 or 500 citizenships, allowing for appropriate adjustments before completion) as well as an impact evaluation framework.

The third option is to shelve CBI entirely. The legal authority and CBI framework exist in the amended law, but provisions in legislation without implementing regulations or concrete operational measures are not uncommon in Argentina (for example, the creation of a special migration jurisdiction).

The political cost of launching a program that draws EU criticism, risks passport devaluation, and generates domestic litigation over constitutional questions may exceed the fiscal benefit. At US$500,000 per applicant and an optimistic 5,000 grants, total initial revenue would be US$2.5 billion: roughly 0.5% of Argentina’s gross public debt, which exceeded US$460 billion in early 2026.

Buenos Aires, Argentina

But the issue goes beyond numbers. The core question, in my view, is who would benefit from one of the most significant honors the country can confer, why they would do so, and what risks, costs, and potential benefits this would entail, and, in the case of the latter, who the real beneficiaries would be.

A fourth option has recently been mentioned in an academic setting: that the government may work closely with all (or some) of the companies that participated in the tender process in the design of the program.

There has been no official information in this regard, and the scenario appears largely informal and uncertain. The concrete role of the “agencies” remains unclear, giving rise to several questions.

If the government decides to move forward with this “new” CBI program, my recommendation is the second option, paired with a serious RBI pilot.

Conclusions

The granting of nationality generates irreversible consequences for individuals (investors) and systemic consequences for the country. It should not be designed by firms whose primary interest is generating billable client applications.

A large-scale public tender is not indispensable. Nor is management of the program by companies with direct or indirect interests in its implementation. If CBI is to proceed, it should be built by Argentina, for Argentina, under the highest standards of transparency and institutional integrity. Only in that manner can the country build a reputable, non-controversial, and non-challenged CBI system.

There are other mechanisms for attracting capital that do not carry the same risks as CBI.

RBI is one of them, and it has barely been explored locally. The existing migration regulations are 20 years old and functionally useless in their current form, but the legal basis is there. The DNM has made tentative efforts, granting residence to a small number of investors who proposed to invest in and reside in the country. This pathway deserves to be developed for its potential (including for small investors) for social and economic advancement.

Finally, I express my deep concern about the inequalities and long-term harm that public policies[PC1.1] lacking a holistic, participatory, and strategic vision can generate at the community level – especially when they are designed without meaningful consultation with local actors and implemented in ways that privilege external interests over national wellbeing and development. Such approaches risk weakening local capacities, deepening dependency, and excluding the very communities they are supposed to benefit.

This runs contrary to the spirit of the Sustainable Development Goals, particularly the commitment to “leave no one behind,” as well as the principles enshrined in the Universal Declaration of Human Rights. Sustainable progress cannot be built by sidelining local knowledge, institutions, and talent, nor by prioritizing short-term gains over the long-term wellbeing of society.

What we dismantle, neglect, or compromise today in the name of urgency or convenience may return tomorrow as greater inequality, social fragmentation, and lost opportunities for future generations. Let us think together -responsibly, inclusively, and strategically- about building a better Argentina and a better world for all.

The Author: Paula Carello is a former technical advisor to Argentina’s National Migration Directorate (the authority currently responsible for granting citizenship by naturalization) and to the Santa Fe Provincial Chamber of Deputies. She is a university professor and an international consultant on migration, asylum, development, and human rights (including for the UN and the EU), and practices law at Lux Brumalis Law Firm & Consultancy in Argentina.

This article reflects the views of the author alone and should not be taken to represent the views of IMI Daily or of any organization with which the author is affiliated.

FUENTE: https://www.imidaily.com/opinion/argentinas-cbi-ambitions-outpace-its-institutions/

Otras Noticias

Los abogados que intervienen en cada caso mantienen un registro detallado de las gestiones realizadas, lo que permite, en cualquier momento, proporcionar una descripción precisa de las tareas llevadas a cabo.

Salvo en supuestos particulares que, por su naturaleza, justifiquen una modalidad distinta, los honorarios del estudio Lux Brumalis no se determinan estrictamente en función de una tarifa horaria. Por el contrario, se establece una estimación inicial de honorarios basada en el análisis del caso, su complejidad y las gestiones previsibles al inicio de la relación profesional.

Dicha estimación tiene carácter orientativo, en tanto puede verse ajustada en función de la evolución del caso, la aparición de circunstancias imprevistas o la necesidad de realizar tareas adicionales no contempladas inicialmente.

Las condiciones económicas aplicables a cada asunto son acordadas con el cliente al inicio de la relación profesional, teniendo en cuenta su situación particular. En este sentido, se presta especial atención a personas físicas y a organizaciones del sector sin fines de lucro.

What to Expect from Your First Immigration, Asylum or Citizenship Consultation with our law firmAt Lux Brumalis, the initial immigration consultation is a key step to understanding your options and planning your path forward in Argentina.During this session, we offer a comprehensive review of your situation and provide strategic legal guidance tailored to your needs (or those of your company, family or employee).Our firm specializes on migration, asylum and citizenship law and we cover also issues related to family law, civil law, commercial and tax law, criminal law, among others.Our first consultation includes:
  • Case Assessment
We review your background, and personal, company or family situation to determine the most appropriate immigration pathways under Argentine law-such as temporary or permanent residence, family reunification, student residence permit, asylum or humanitarian residence permits, work visa, retired or the “rentista” category, among others.Should you be interested in acquiring Argentinean nationality by option or naturalization, we shall also assess all issues regarding this scenario.Before the interview, you shall prepare a short description of your case. This will help us maximize the time of the consultation.
  • Eligibility Evaluation
We assess your eligibility for different scenarios (for asylum recognition, residence categories or citizenship) and identify any potential risks or legal barriers -such as expired visas, overstays, lack of required residence periods, criminal records, or missing documentation.
  • Legal Guidance
You will receive a clear explanation of the applicable procedures, estimated timelines, required documentation, and the outcomes associated with each option.
  • Document analysis
We will review any documents you have available at the time of your consultation to assess their validity, completeness, and relevance to your immigration case. This helps us determine what can be used, what needs to be corrected, and what may still be required.
  • Personalized Document Checklist
We provide an initial checklist of the documents you will need for your case. Detailed instructions regarding translations, apostilles, legalizations, and other formalities, as well as specific document analysis (of documents that you may not have processed by the time of the interview) shall come at a later stage.
  • Strategy Planning
Together, we shall outline a case strategy tailored to your specific goals -whether you’re beginning a new application, requesting regularization, or dealing with a pending issue before the Dirección Nacional de Migraciones (DNM) or the federal courts.
  • Q&A
We will make time to answer all your questions to navigate the Argentine legal system with confidence.
  • Proposal for Legal Representation
If you wish to move forward, we’ll provide a clear service proposal, including fees, scope of work, and next steps for full legal representation
Paula CARELLO Attorney at Law +54 9 341 7 440184 pcarello@luxbrumalis.com.ar