«Can they refuse me at the last moment, after I have already transferred the money?» This question comes up on almost every call, and it is asked in a different tone from questions about timelines or visa-free travel. Here the person is not worried about inconvenience. They are worried about loss.
The short answer: yes, you can be refused. But the sum you are actually risking is, in most programmes, nowhere near the price of the programme — and the gap between those two figures is usually about tenfold. Below: where exactly in the procedure the money sits, how much is lost on a refusal at each stage, and the six clauses of the contract that answer this question in advance.
1. The payment order is not a detail — it is the structure
Citizenship and residency-by-investment programmes split into two types on a single criterion: the moment at which the money becomes irreversible.
Type 1. The main contribution is paid after the decision. The state first vets the applicant and issues an approval in principle, and only then accepts the main sum. That is how São Tomé and Príncipe, Vanuatu and the Caribbean programmes are built. Before the decision, only the entry into the procedure is paid: the registration fee and the cost of the background check.
Type 2. The investment is made before you apply for the status. That is how Turkish citizenship by investment and the Greek golden visa work: first you buy the property or place the funds, then you file for the status on the basis of a transaction already done. The risk here is shaped differently — the money does not burn, but it is tied up in an asset you did not buy in order to own it, and on a refusal that asset has to be sold on its own schedule, not yours.
This distinction is the most important thing in the whole subject. Someone who has heard the words «non-refundable contribution» usually reads them as «I pay and I lose it if anything goes wrong». In fact «non-refundable» means something else: it is a contribution to a state fund rather than the purchase of an asset you could resell. By the time it is paid, the decision on you has already been made.
2. How much leaves your account before the decision
São Tomé and Príncipe. The registration fee on filing is $5,000 — a state charge, non-refundable. It leaves before the decision. The $90,000 contribution to the National Transformation Fund is paid after approval in principle. The certificate, passport and national ID come to $750, at the final stage. So a refusal at the vetting stage costs $5,000 of the state part plus whatever portion of the professional fee has been worked through by then — against a full state part of $95,750. The full costing is in our breakdown of the São Tomé programme.
Vanuatu. The file goes through a Financial Intelligence Unit check, and the main investment is paid after it clears. Before that, the fee for the check itself is paid. The payment order, and the share due before the file is considered, are set out in the current edition of the programme regulations — that is the clause to read before signing a contract with any agency. The contribution scale: $130,000 for a single applicant, $150,000 for a couple, $165,000 for three, $180,000 for four, plus $15,000 for each additional person. Details are in our breakdown of the Vanuatu programme.
The Caribbean programmes. Built the same way: due diligence first, charged separately and non-refundable, then the decision, then the contribution. In Grenada the deadline for a decision is written into the statute — CBI Act No. 15 of 2013, s. 8(2): 60 days from a complete set of documents. That is a rare case of a state binding itself to a deadline; we wrote about it in our piece on realistic timelines.
In practice. The real loss on a refusal at the vetting stage is roughly $10,000–$30,000, depending on the programme and the number of people in the file. The lower bound is a single applicant on the most accessible programme; the upper bound is a family on a Caribbean one. That is real money. It is not $90,000 and not $130,000.
3. How likely is a refusal
Sellers in this industry usually answer «we do not get refusals». Verifiable statistics exist in exactly one place — where a government has published the results of a closed programme.
Montenegro reported the results of its «golden passport» scheme: 1,113 applications, 869 approvals, 239 refusals — 21.5%. Five more files are still in the procedure three and a half years after intake closed. This is not a point about Montenegro — it is the order of magnitude for the industry: roughly one in five is refused.
Programmes that are currently open do not publish this kind of statistics, and anyone quoting you an approval rate for Turkey or Greece is quoting it from themselves.
4. What people are actually refused for
In our practice a refusal arrives for one of three reasons, and all three are visible in advance.
- EU and US sanctions lists. It is not only the applicant who is screened, but connected persons and sources of income. This surfaces on a pre-check within a day, not six months later.
- Inability to evidence the source of funds. Not «grey» money — specifically the inability to document where it came from. Cash from the nineties, the sale of a stake without paperwork, a gift inside the family with nothing in writing.
- Errors and omissions in the file. An undeclared previous visa refusal, a spelling mismatch between documents, an undeclared family member. The state reads that as concealment.
There is a fourth reason, but that one is our refusal rather than the state’s: we do not take files where it is clear the person expects a document to solve a criminal problem.
None of those three surfaces at the moment the money is transferred. All three surface before it — provided the check is done before, not after.
5. Six clauses of the contract that answer this in advance
This applies to a contract with any agency, not only with us. Read them before signing.
- The payment order, stage by stage. What leaves on filing, what leaves after approval. If the contract shows a single sum in a single payment before filing, that is the principal red flag of this whole subject.
- What happens if the state refuses. Which sums are returned, which are not, within what period and to which account.
- What happens if you withdraw yourself. The terms are usually harsher than on a state refusal, and that is normal — but you should know it.
- Who pays for a re-filing. On several programmes a refusal can be followed by filing in another jurisdiction with the same document pack. The question is at whose cost the new file is assembled.
- Where the money goes. The state portion goes to the programme or fund account named in the statute — not to the agent’s account and not to a «segregated lawyer’s account». We were burned on exactly this ourselves, and wrote it up separately.
- What the professional fee covers and what is billed separately. Notarisation, translations, apostille and legalisation are normally costed against a checklist for your specific family composition and are not part of the main quotation.
6. What to do before transferring anything
There is only one correct order: the check first, the money second. A pre-check takes 24 to 48 hours, runs on documents, and answers the single question worth asking first — does your case go through or not. If it does not, you find out before the expense rather than after.
We say so immediately if a case does not go through. That is not a figure of speech but a working rule: a file that falls apart at vetting costs us more than it costs you.
Send us the basics through the form — family composition, citizenship, what you need to solve. We will tell you which programmes are open to you and what your real risk is at the entry point.
A related read: where these passports actually work — the same honesty applied to visa-free access.
This material is general information and is not legal or tax advice. Programme terms and payment orders change; we confirm the current edition against the primary source before filing.