Due Diligence for Argentina Citizenship by Investment

For an investor committing USD 350,000 or USD 800,000, due diligence is the stage of greatest institutional scrutiny. It protects the integrity of the program, of Argentine citizenship and of the international mobility it carries.

Citizenship by investment programs worldwide have been reviewed by international bodies for security and anti-money-laundering risk. A robust review process is therefore expected to be a central feature of the Argentine program — and the stage where most avoidable problems arise.

This platform is directed by Juan Pablo Rojas Pascual and Rojas Pascual Abogados, an Argentine law firm specialized in citizenship by investment. Its attorneys are dedicated to analyzing each applicant's profile, documentation and risk factors before anything is submitted to the authorities.

Legal reports. Senior attorneys prepare a legal report assessing the applicant's eligibility, the evidentiary validity of the apostilled and translated documents, and the absence of grounds of inadmissibility under Argentine immigration law.

Accounting reports. A dedicated team of certified public accountants prepares financial reports that document the lawful origin of the applicant's wealth and trace the funds to be invested — tax returns, corporate statements, sale agreements, inheritance records and banking flows — organized to be presented together with the application.

This independent preparation does not replace or predict the government's review. Its purpose is to identify and resolve inconsistencies in advance, so the file reaches the authorities complete, coherent and well documented.

Verification of identity, nationality, marital status and family relationships through passports, birth and marriage certificates and, where applicable, records of name changes.

Documents generally need to be apostilled or legalized and translated by a certified translator. Inconsistencies in names, dates or spellings across documents are a frequent cause of information requests.

Source of wealth explains how the applicant's overall net worth was built over time — business activity, employment, investments, sale of assets or inheritance.

Source of funds traces the specific money used for the investment, from its origin to the transfer, through bank statements and transaction records.

Both must be documented and consistent. Undocumented wealth, unexplained transfers or funds routed through opaque structures are among the most significant risk factors.

Criminal record certificates are generally required from the countries of citizenship and from countries of recent residence. Checks may be cross-referenced with international databases.

The exact look-back period and certificate validity will depend on the program's implementing regulations.

Applicants can expect screening against international sanctions lists (such as those of the United Nations, the United States, the European Union and the United Kingdom), politically exposed person (PEP) databases and adverse media.

PEP status is not automatically disqualifying in most programs, but it typically triggers enhanced review of wealth origin.

Evidence of tax compliance in the home jurisdiction, and the absence of fraudulent insolvency or enforced tax debts, supports the coherence of the financial profile presented.

Prior visa refusals, deportations or overstays in any country may be reviewed. A prior refusal is not necessarily disqualifying, but it should be disclosed and explained accurately.

• Agency for Citizenship by Investment Programs (Decree 524/2025): technical evaluation and coordination of the review.
• National Directorate of Migrations (DNM): the authority that decides on the application under Law 346 and Decree 366/2025.
• Ministry of Economy: defines eligible investments and the mechanisms for receiving funds.

Other Argentine bodies with anti-money-laundering competence may be involved; the precise inter-agency procedure is subject to the program's implementing regulations.

Applicants or funds connected to jurisdictions identified as higher-risk by international standard-setters (such as FATF lists) may face enhanced review and additional documentation requirements.

Authorities may request additional documents or clarifications during review — for example, to explain a specific transaction. Responses should be complete, consistent with the original file and submitted promptly.

Our legal and accounting team prepares and reviews responses so they align with the reports already submitted.

• Undocumented or inconsistently documented wealth
• Inclusion on sanctions lists or sanctions exposure through business partners
• Criminal convictions or pending criminal proceedings
• Inconsistent identity or civil records
• Funds from high-risk jurisdictions without adequate explanation
• False or incomplete statements in the application

• Gather records of wealth origin covering the relevant years (tax returns, corporate documents, sale or inheritance records).
• Obtain criminal record certificates and verify their validity periods.
• Align names and dates across all identity and civil documents.
• Keep the investment funds in traceable, documented accounts.
• Disclose prior visa refusals and any relevant legal matters to your advisers from the start.

A private consultation with a senior specialized attorney is the recommended first step to review these points before any submission.