There are roughly 60 registered agents for Vanuatu’s citizenship programme and several hundred more worldwide selling Caribbean, European and other programmes. Most are competent. Some are excellent. A small number will take your money, lodge nothing, or lodge something that gets your citizenship revoked two years later.
The difference is rarely obvious from a website. This guide explains how the agent system actually works, what “government-approved” does and does not mean, the warning signs that matter, and the seven questions that separate the good from the dangerous. We are Vanuatu’s government-appointed Master Agent, so we have an interest, but everything below applies equally to any programme in any country.
How the agent system works
Every citizenship by investment programme is run by a government unit: a Citizenship Commission, a Citizenship by Investment Unit, a Program Office. That unit does not deal with applicants directly. It deals with agents it has authorised.
In most programmes there are two tiers.
Master agents (sometimes called authorised, licensed or approved agents) hold a direct authorisation from the government and lodge applications directly with the unit. They carry the compliance obligation. They are the party the government holds responsible if something goes wrong.
Sub-agents (marketing agents, promoters, introducers) do not hold a government authorisation. They find clients and pass them to a master agent, who lodges the application. Sub-agents range from serious law firms and wealth managers to a person with a website and a WhatsApp number.
What “government-approved” actually means
Almost every agent website says “government-approved”, “licensed” or “authorised”. The phrase means different things.
At its strongest, it means the firm holds a current authorisation from the citizenship unit, with a number you can check. At its weakest, it means the firm once had a conversation with a master agent, or is a registered company in its own country, or nothing at all.
The only way to know is to ask for the authorisation number and verify it with the government unit directly. For Vanuatu, that is the Citizenship Commission in Port Vila. Stanford Knight’s number is 307812 and you can see our credentials here. A firm that cannot give you a number, or discourages you from checking it, has answered your question.
The pricing trap
This is where people lose their citizenship, not just their money.
Government contributions are set in law. In Vanuatu, the Development Support Programme contribution is $130,000 plus $5,000 due diligence for a single applicant. That figure is not negotiable and no agent can lawfully reduce it.
Yet applicants regularly receive quotes below the legislated minimum. There are three ways that happens. The agent lodges the application with the correct fee and absorbs the loss to win the client, which is unsustainable and usually signals a firm in trouble. The agent lodges through a channel that underpays the government, which the Commission treats as a non-compliant application and can lead to revocation of citizenship after the fact. Or the agent never intends to lodge anything.
The rule is simple. If a quote is below the published government cost, something is being left out, and it is your citizenship that is at risk, not the agent’s.
The opposite problem exists too. Most agents add 10–20% on top of government costs as their own fee. That is legitimate, but it should be disclosed as a separate line, not folded into a single “programme price” that makes comparison impossible. Stanford Knight is paid directly by the Government of Vanuatu, so the price on our site is the complete cost; but if you are comparing agents, insist on seeing the government fee and the agent fee separately.
Red flags
Some of these are disqualifying on their own. Several together should end the conversation.
No physical office in the programme country. An agent for a Vanuatu programme with no presence in Vanuatu is relying on someone else to do the work that matters. Ask for the address and check it.
Guaranteed approval. No agent controls the government’s decision. What a good agent can offer is pre-screening so that unsuitable applications are never lodged, which is how every application Stanford Knight has lodged has been approved. “Guaranteed” is a different claim and a false one.
Pressure to pay quickly. Limited-time offers exist in this industry; Nauru is running one now. But an agent who pushes you to wire the full contribution before due diligence has begun does not understand the process or does not intend to follow it. Payments should be phased: a deposit at engagement, the balance before lodgement.
Money to a personal or unrelated account. Client funds should sit in segregated client trust accounts, separate from the agent’s operating money. Ask where your money will be held. Many agents in this sector cannot answer.
Promises about visa-free access that don’t match reality. Any agent still telling you a Vanuatu passport gives you Schengen or UK access is either out of date or lying. Both are disqualifying.
No written engagement letter. Scope, timeline, costs and responsibilities should be in writing before you pay anything.
Reluctance to be verified. If checking their authorisation with the government is treated as an insult, walk away.
What good looks like
A good agent does the opposite of all of the above, and a few things more.
They assess your eligibility candidly before you spend anything, and they tell you if you don’t qualify or if another programme suits you better. They prepare the application to the standard the government expects, rather than lodging and hoping. They have a direct, working relationship with the government unit; our Port Vila office is adjacent to the Citizenship Commission, and initial queries are handled the same day. They hold your money in trust. They have a secure document portal rather than asking you to email passport scans. And they have a track record you can check: years operating, applications lodged, outcomes.
Reputation in this industry is earned slowly and lost fast. An agent who has been operating in the same programme for a decade or more has survived every regulatory change, every audit and every downturn. That is worth something.
Seven questions to ask before you pay
1. What is your government authorisation number, and which government unit issued it
Then check it.
2. Are you the master agent, or will my application be lodged by someone else?
If someone else, who?
3. What is the government fee, and what is your fee, as two separate figures?
4. Where is your office in the programme country, and who works there?
5. Where will my money be held, and in whose name?
6. What is your pre-screening process, and what happens if you find a problem?
7. How many applications have you lodged, and how many have been approved?
A note on Vanuatu specifically
Vanuatu has around 60 registered agents. The Citizenship Commission has become considerably more active in policing them, particularly on sub-agents advertising below the legislated fee. If you are considering Vanuatu, verify your agent with the Commission, and be especially wary of pricing that looks too good.
Stanford Knight’s position is unusual: our senior team helped draft the legislation that created the programme in 2012, we are paid by the government rather than by clients, and our head office sits next to the Commission. We say that not because it makes us the only option, but because it is the standard of verification you should apply to whoever you choose. Ask us the seven questions. Then ask everyone else.
Frequently asked questions
How do I verify a citizenship agent?
Ask for their authorisation number and confirm it with the government citizenship unit directly. Do not rely on the agent’s website.
Is it safer to use a master agent than a sub-agent?
A master agent is directly accountable to the government and lodges the application itself. A sub-agent works through one. Either can be a good adviser, but you should always know which master agent will actually lodge your application.
Why do some agents quote below the government fee?
Either they are absorbing a loss to win business, using a non-compliant channel that risks revocation, or not intending to lodge. None is acceptable.
What are agent fees normally?
Typically 10–20% on top of government costs. Stanford Knight charges none because we are paid by the Government of Vanuatu.
Can my citizenship be revoked because of my agent?
Yes, if the application was lodged with false information or through a channel that underpaid the government. Choosing a compliant agent is the single most important decision in the process.
Next step
If you want to test us against the seven questions, book a consultation. No commitment, no fee, and straight answers. If you are a professional adviser looking for a compliant Vanuatu partner, see our Partner and Agent Programme
