Authorised Agents vs. Sub-Agents: What’s the Difference?

Authorised Agents vs. Sub-Agents: What's the Difference?

The Citizenship by Investment (CBI) process has evolved in recent years, with exponential growth in the regulations for implementing these programs. CBI has long required the expertise and experience of Authorised Agents and supporting professionals to facilitate and guide investors through the process of obtaining citizenship. The tightening of the service provider regulatory requirements led to a decrease in the number of professionals with permission to carry out this service. In 2021, the global number of Authorised Agents shrank by 70%.

While the global pandemic no doubt contributed to a general fall in demand for CBI worldwide, the picture isn’t that clear-cut. More and more governments are scrutinising how these programmes are conducted, making it more complicated for firms to become accredited to help investors acquire citizenship. In this article, we explore just who exactly is involved in securing CBI, what their specific roles are, and why it is important to know the difference.

How Does CBI Work?

CBI programmes have been operating for decades internationally, most notably in (but not limited to) developing countries to obtain increased foreign direct investment (FDI). These programmes offer second citizenship status to individuals or families in exchange for a fixed investment in the country. The new capital then goes towards infrastructure, industry or other public spending projects.

Following the issuing of a Certificate of Naturalisation, new citizens can then apply for passport and the right to travel freely and settle in their chosen country. As of 2021, there are 14 registered CBI programs globally, but more than one hundred countries around the world have a scheme that at least resembles this brand of FDI.

What are Authorised Agents?

Investors do not simply approach the government in question with a financial offer. Authorised Agents (also known as licenced, accredited or international marketing agents) are intermediaries between a country’s citizenship unit and a prospective investor. Professionally, they may be financial consultants, lawyers or legal representatives.

The Agent’s primary role is to liaise with government departments regarding every CBI application. In addition, they offer advice to applicants when completing all forms and requirements, offering translation and certification.

In many cases, these agents must renew their authorisation every year, demonstrate that they have carried out know-your-client (KYC) checks and other due diligence, and clearly identify the location of the demographic they are marketing to.

What are Sub-Agents?

While the Authorised Agent serves in an international advisory capacity, other important roles are carried out by sub-agents. These professionals serve as a bridge between the Authorised Agent and the client investors, especially in instances where the Authorised Agent is not present in a target investment country but can collaborate with a sub-agent who is. In nearly all cases, these agents are immigration agencies.

As noted by the Dominica CBIU, the role of a sub-agent includes identifying and communicating with prospective applicants, onboarding prospective applicants as clients, and creating and disseminating promotions, advertisements, or publications on the CBI program.

Professionals carrying out this role need to be registered by an Authorised Agent, as the latter is deemed responsible for all promotions, advertisements, or publications disseminated by them or any sub-agents in relation to CBI.


In short, both Authorised Agents and sub-agents are important facilitators of CBI programmes and must abide by the same rules. Both local promotion and citizenship assistance require proper licensing, and similarly often employ the expertise of professionals with legal experience.

Although both serve on behalf of the client investor, Authorised Agents facilitate CBI closely with the citizenship units of the government in question, often communicating the specific rules and requirements to the sub-agent so that they can assist the client with the formalities of the application. Sub-agents will assist Authorised Agents in identifying clients and helping them into the application process.

Authorised Agents are therefore responsible for sub-agents. Unlike the latter, only they can submit CBI applications to the government unit of the country in question. It is also the responsibility of these entities to conduct background checks for any issues related to an applicant’s reputation.

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