Real Estate Option Program (REO)

Legislative Provisions

The pathway to Vanuatu citizenship under the Real Estate Option Program was created by the Citizenship (Amendment) Act No. 1 of 2021. (A copy of the Amending Act is Document 1.)

This Amending Act modified the Citizenship Act [CAP 112] (“the Act”) to allow a person to acquire Vanuatu citizenship pursuant to Section 13B(2)(c) of the Act as an investor under the Real Estate Option Program (REO) who complies with the requirements set out in Section 13F of the Act.

Pursuant to Section 13F of the Act, the Prime Minister signed the Citizenship (Real Estate Option Program) Regulation Order No. 93 of 2021, which allowed the REO Program to commence. (A copy of Regulation Order No. 93 is Document 2.)

The REO Program Regulations were later amended by a regulation signed by the Prime Minister on 27 September 2021. (A copy of the amendment is Document 3.)

This amendment inserted Section 4A into the regulation, allowing applicants to invest in a lot as tenants in common in equal shares, with each applicant investing USD $100,000.

The REO Program Regulations were further amended by another regulation signed by the Prime Minister on 3 October 2021. (A copy of the amendment is Document 4.)

This amendment, among other changes, modified Section 4A to allow applicants to invest in a lot as tenants in common in quarter shares, with each applicant investing USD $50,000.

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Investment Structure

Applicants are required to invest in a lot within a Vanuatu Government Approved Project (VGAP) designed to foster the growth of tourism infrastructure in Vanuatu.

There are two options available for applicants.

Option 1 – Buyback Option

Some applicants prefer not to bear the ongoing costs associated with maintaining a property.

For these applicants, the developer of the VGAP project will buy back the investment, ensuring that the applicant is not burdened with ongoing property ownership expenses.

Applicants selecting the buyback option will pay a net investment amount of USD $50,000, which includes all transfer costs back to the developer.

Under this option, the applicant does not retain ownership of the property and is not responsible for ongoing maintenance costs.

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Option 2 – Retain the Investment

Applicants who wish to retain their investment after citizenship approval must invest the full USD $100,000 in the property.

In addition to the investment amount, applicants must also pay the FIU due diligence fee and applicable government processing fees.

Government fees are typically:

• Applicant + Spouse + 1 Child: USD $45,000
• Applicant + Spouse + 2 Children: USD $55,000

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Payment Structure

The REO Program investment amount is payable in stages.

1. Initial Stage
   • Financial Intelligence Unit (FIU) Due Diligence Check: USD $5,000
2. After FIU Clearance
   • Application must be completed
   • Investment agreement must be signed
   • Supporting documents must be submitted
   • Payment of:
     • 25% of Citizenship & Processing Fees
     • 25% of the Investment Amount
   These payments are made to the Escrow Agent bank account.
3. After Approval by the Commission
   • Citizenship Certificate and passports will be issued once:
     • Remaining 75% of Citizenship & Processing Fees
     • Remaining 75% of Investment Amount
   are paid to the Escrow Agent bank account.

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Processing Steps

Applicants must complete the official application forms and provide all required supporting documentation.

Key requirements include:

• Signing the Investment Agreement documents
• Documents must be witnessed by a Notary Public
• If documents are not in English, an official notarized translation must be provided

The first step in the process is the Financial Intelligence Unit (FIU) due diligence check, which costs USD $5,000.