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CBI Legal Analysis

Argentina Citizenship by Investment: Legal Due Diligence

What legal due diligence covers in an Argentine citizenship by investment case, why it should precede the investment, and how it differs from the authorities' review.

Juan Pablo Rojas Pascual, Argentine attorney and legal counsel for international investors

Written by Juan Pablo Rojas Pascual

Reviewed by Juan Pablo Rojas Pascual

Published:

Last updated:

2 min read

Direct answer

Direct answer

Legal due diligence in an Argentina CBI case is the review, by the applicant's own Argentine counsel, of everything the authorities are likely to examine: identity and civil status documents, background, the investment route, the origin of funds and wealth, and any corporate structures. Done before funds are committed, it identifies inconsistencies and risks while they can still be corrected or explained.

Key facts

  • 01Decree 524/2025 gives the Agency for Citizenship by Investment Programs an evaluation role before the DNM decides.
  • 02The announced program contemplates identity, background, financial transparency and national-security checks.
  • 03Applicant-side due diligence is legal analysis, not an audit or AML certification.
  • 04Its output should be a written list of findings and remedial steps.

Areas reviewed

  • Identity and nationality documents, including name variations
  • Civil status records for the applicant and each family member
  • Criminal record certificates and any relevant proceedings
  • Prior migration history
  • Investment route and channel of funds
  • Source of funds and source of wealth
  • Companies, trusts and beneficial ownership
  • Consistency of dates, amounts and descriptions across the file

Why timing matters

If a problem is found after the investment has been made — for example, that a portion of the funds cannot be documented — the investor may face a choice between a weaker application and an unrecoverable contribution. Performing due diligence first keeps that decision in the investor's hands.

What the client receives

A written summary of findings, ranked by significance, with recommended steps: documents to obtain, explanations to prepare, structures to clarify. Where a risk cannot be mitigated, the summary says so. See our legal due diligence service.

Frequently asked questions

How long does due diligence take?

It depends on the complexity of the applicant's profile and how quickly documents are available. A defined scope and timetable are agreed at the start.

Does due diligence include family members?

Yes, when they are expected to apply. Each person's documents and background are reviewed.

Sources & legal references

  1. [1]Decreto 524/2025 — procedimiento de ciudadanía por inversión — InfoLEG — Ministerio de Justicia · Regulation · 30 July 2025
  2. [2]Argentina announces Citizenship by Investment Program investment thresholds — KPMG GMS Flash Alert 2026-258 · Professional analysis · 8 October 2026
  3. [3]Ley 25.246 — Encubrimiento y lavado de activos de origen delictivo — InfoLEG — Ministerio de Justicia · Legislation
  4. [4]Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents — HCCH — Hague Conference on Private International Law · Legislation

Information on this site is general and does not constitute legal advice. Citizenship and residence decisions are made by the competent Argentine authorities, subject to applicable law and administrative requirements.

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