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John Maniatis is Managing Director Private Clients at Henley & Partners USA Inc.
High-net-worth Americans increasingly recognize the value of a ‘sovereign portfolio’ — a strategic combination of residence permits and alternative citizenships that provides unparalleled flexibility and security. Unlike previous generations who might have sought access rights to a single alternative country, sophisticated investors now pursue a range of complementary options that work together to deliver comprehensive benefits.
At Henley & Partners, we’ve observed a significant trend: American clients aren’t looking to permanently relocate but instead want contingency plans and expanded opportunities. The approach has evolved from seeking a singular backup ‘Plan B’ option to building a carefully calibrated collection of mobility assets that provide them and their families with personal access rights to a wide range of jurisdictions worldwide.
The European Court of Justice’s April 2025 ruling against Malta’s citizenship investor program has fundamentally altered the investment migration landscape. This landmark decision, which challenged the legality of direct citizenship by investment within the European Union, reinforces the importance of diversified mobility strategies rather than reliance on any single program option.
The most sophisticated strategy now emerging involves pairing residence rights in an EU member state with citizenship rights in select third-country jurisdictions. We anticipate this continued shift towards portfolio-based strategies as clients increasingly combine one of the golden visa programs in Europe with non-EU citizenship options to diversify access and mitigate both regulatory and reputational risk. This combination creates unmatched geographic and domicile diversification while minimizing exposure to changing legal frameworks — particularly important for Americans navigating complex international business environments.
For Americans specifically, this approach addresses unique challenges including Foreign Account Tax Compliance Act (FATCA) reporting requirements, complex international taxation issues, and the growing scrutiny that US citizens sometimes face in certain markets. By holding complementary residence permits and passports, Americans can optimize their global access and presence while maintaining their US citizenship.
European residence permits form the foundation of most sovereign portfolios due to the exceptional quality of life and business opportunities they offer, along with access rights to the whole of Europe’s Schengen Area. Portugal’s Golden Residence Permit Program remains a cornerstone investment despite recent modifications, requiring a EUR 500,000 (approximately USD 575,000) capital transfer into Portuguese venture capital or investment funds. With minimal physical presence requirements — just seven days annually — and a potential citizenship pathway after five years, Portugal offers an exceptional European base without disrupting American residence.
The Malta Permanent Residence Programme remains open to investors, creating a clear path to residence in one of Europe’s leading investment locations, driven by its reputation for stability, predictability, and security through a minimum EUR 182,000 (approximately USD 205,000) mixed capital contribution and real estate purchase or lease. The island nation’s spectacular natural beauty and Mediterranean lifestyle make it a desirable place of residence for wealthy individuals and families.
Greece provides one of the most cost-effective European options, requiring real estate investments starting at EUR 250,000 (approximately USD 280,000), with no mandatory stay requirements. For Americans concerned about property market exposure in the USA, Greek real estate offers attractive diversification with strong rental yields in the tourism sector.
Italy’s Investor Visa Program delivers access to Europe’s third-largest economy alongside unparalleled cultural amenities through a EUR 500,000 investment in Italian companies or EUR 250,000 in innovative start-ups. For American entrepreneurs with transatlantic business interests, Italian residence creates seamless operations within Europe’s regulatory framework.
For those seeking prestige combined with substantial tax advantages, the Monaco Residence offering stands unmatched. While investment thresholds exceed EUR 1 million for property acquisition, the Principality’s tax environment and security infrastructure justify the premium for certain investors. Monaco’s banking privacy and asset protection frameworks offer particular advantages to American investors concerned about litigation exposure.
The EU member state of Latvia also now offers a compelling alternative through a EUR 250,000 real estate investment plus a modest government fee, with five-year residence permits not requiring any physical presence for renewal. For Americans with Eastern European heritage or business interests, Latvia provides a cost-effective EU foothold in a promising investment destination with strategic geographic positioning.
The ideal sovereign portfolio balances European residence with strategic citizenship options that provide different benefits. Caribbean citizenship programs in Antigua and Barbuda, Grenada, St. Kitts and Nevis, and Dominica all provide visa-free access to 140+ countries with processing times of under six months. With investment requirements starting around USD 200,000, these programs create immediate travel flexibility while European residence applications proceed.
For American investors, Caribbean citizenship offers particular advantages in business contexts where presenting as a US citizen may create complications. Additionally, certain Caribbean passports offer visa-free access to territories sometimes restricted for Americans, creating valuable alternatives for frequent travelers.
Türkiye’s Citizenship by Investment Program requires a USD 400,000 real estate investment, delivering visa-free access to 110+ destinations and a strategic position between Europe, Asia, and the Middle East. The Turkish passport particularly complements European residence by providing business access across Middle Eastern markets, sometimes challenging for Western passport holders. For Americans involved in international trade or investment, Turkish citizenship facilitates operations in regions where US interests face complex geopolitical headwinds.
The island nation of Nauru launched its Economic and Climate Resilience Citizenship Program in late 2024, requiring just USD 130,000 for a single applicant or USD 137,500 for a family of two to four members. Nauru’s program provides visa-free access to strategic destinations including Hong Kong (SAR China), Singapore, the UAE, and the UK. For Americans concerned about global conflicts, Nauru’s far-off central Pacific location and politically neutral stance offer strategic diversification beyond traditional citizenship options.
A comprehensive sovereign portfolio often includes options with strategic geographic positioning relative to the USA. Costa Rica requires just USD 150,000 in qualifying investments with no mandatory stay requirements for renewal, offering exceptional stability in Latin America with substantial tax advantages for foreign-source income. For Americans seeking a nearby retreat with familiar cultural touchpoints, Costa Rica combines accessibility with high-quality healthcare and environmental sustainability.
Panama’s Friendly Nations Visa requires just a USD 200,000 real estate investment or bank deposit, providing lifetime residence status without physical presence and a convenient Central American footprint. The program’s connection to the region’s banking hub provides additional financial advantages when paired with European options. For Americans concerned about currency risk and banking stability, Panama’s dollarized economy and strong financial sector provide valuable fallback options.
For those seeking maximum geographic diversification, New Zealand’s Active Investor Plus Program accepts applications with investments starting at NZD 5 million (approximately USD 3 million). The country’s unparalleled political stability, self-sufficiency, and geographic isolation make it the ultimate ‘peace of mind’ option within a sovereign portfolio. For high-profile Americans concerned about privacy and security, New Zealand’s remote location and cultural respect for discretion offer unique advantages.
As regulatory landscapes evolve — particularly within Europe following recent court decisions — flexible portfolio approaches prove increasingly valuable. By diversifying across multiple programs rather than relying on a single solution, investors insulate themselves from policy changes in any single jurisdiction.
For forward-thinking Americans, alternative residence and citizenship options represent concrete assets with tangible benefits beyond peace of mind. They create inheritance planning tools, expand business capabilities, and ensure family members can access global opportunities and mitigate risks regardless of geopolitical developments.
In tomorrow’s world, mobility and jurisdictional access rights will increasingly determine personal and financial freedom. The sovereign portfolio strategy ensures these rights remain secure, diversified, and optimized for maximum benefit across generations.
Henley & Partners assists international clients in obtaining residence and citizenship under the respective programs. Contact us to arrange an initial private consultation.
