WHAT EFFECT WILL THE NEW FALL 2026 EU ETIAS PROGRAM HAVE ON SUPPRESSING MONEY LAUNDERING AND FINANCIAL CRIME BY CBI PASSPORT HOLDERS, OR IS THERE ANOTHER TARGET?

The new EUROPEAN TRAVEL INFORMATION AND AUTHORISATION SYSTEM, or ETIAS for short, comes into being in late 2026. Its impact upon travelers from outside the EU who have previously been enjoying visa-free entry depends upon whether they are ordinary leisure visitors, holders of Citizenship by Investment (CBI or CIP) passports., or financial criminals.

(1) Most leisure travelers will not be affected, unless they have something in their background that warrants exclusion, like a major criminal record.

(2) CBI passport holders, who generally purchased their economic citizenship expressly to avoid the expense and delays of securing a visa from their high-risk or even sanctioned countries of login, may now find they will be directed to secure a difficult to obtain visa. For many, although they will not admit it, visa-free entry into the EU was the primary reason they invested in a CBI passport in the first place. They now may have invested six figures with nothing to show for it. Will they now sue the company that sold them the citizenship?

(3) The money launderers, transnational financial criminals, and terrorist financiers may be identified during the ETIAS qualification process, and blocked as well, even under aliases, due to the employment of facial recognition software, but they have other, covert, means of gaining access, and the financial means to achieve it, so the effectiveness of ETIAS against them may be limited. I believe they will find adequate workarounds to gain entry.

So which group is the real target of ETIAS? Is it a thinly-disguised means for the European Commission to block those CBI passport holders it deems potentially high-risk? Or will denial of admission be limited to convicted felons who are serious criminals, and the most high-risk CBI passports only? We cannot say, but if there is widespread denial of CBI passport holders, the investment migration industry may face an existential moment; Stay tuned.