The 26-person initiative announced in November 2019 targeted recipients from Russia, Cambodia, China, Kenya, Malaysia and Iran. Still, procedural gaps stalled the campaign before the Cyprus Papers transformed a limited review into a national reckoning.
WASHINGTON, DC, September 9, 2026 — Cyprus’s first major attempt to withdraw citizenship granted through its investment program began in November 2019, when the Cabinet authorized proceedings against 26 foreign recipients whose approvals had come under renewed scrutiny.
The decision was politically significant because it acknowledged that earlier passport approvals could no longer be treated as irreversible. Yet, it did not instantly cancel every citizenship or complete the legally required deprivation process.
Government officials presented the review as evidence that Cyprus could correct questionable decisions within its own legal system. However, events over the following months revealed that the state had not established the procedures needed to finish the job.
The initiative covered nine Russians, eight Cambodians, five Chinese nationals, two Kenyans, one Malaysian and one Iranian, a composition that showed how widely the program had marketed European Union citizenship across several high-risk political and commercial environments.
Those 26 people were connected to nine investment projects, according to reporting at the time, meaning the Cabinet was examining clusters of investors and related recipients rather than 26 entirely separate transactions.
The announcement arrived before Al Jazeera published the Cyprus Papers in August 2020. Still, it followed years of investigative reporting, European pressure and growing concern that citizenship approvals had sometimes outrun effective background screening.
A Warning Before the Leak
By early 2019, Cyprus was already facing sustained questions about a program that converted large investments, usually involving real estate, into citizenship carrying the right to live and travel across the European Union.
The European Commission’s January 2019 assessment of investor-citizenship and investor-residence schemes warned that weak transparency and inconsistent cooperation could create risks involving security, money laundering, tax evasion and corruption throughout the bloc.
Those concerns mattered beyond Cyprus because a passport issued by one member state did not merely confer local nationality; it also created European citizenship rights with consequences for every other member country.
Cypriot authorities had tightened parts of the program, including background-check requirements and eligibility rules. Still, critics argued that repeated reforms could not undo approvals made under earlier, substantially looser standards.
The November 2019 decision therefore represented an initial test of whether the government could look backward, identify recipients who no longer met the public-interest standard, and legally unwind naturalizations already granted.
Describing that decision as a completed purge, however, overstates what occurred, because the Cabinet had initiated a process whose outcome depended upon notice, evidence, administrative procedure and potential judicial challenge.
That distinction later became central to the entire Cypriot cleanup, as official announcements frequently counted decisions to begin or approve deprivation while actual cancellation required additional legal and administrative steps.
Who Was Included in the 26-Person Review?
The nationality breakdown was unusually specific for a process in which the government generally withheld individual names, citing privacy rules and the legal sensitivity surrounding pending deprivation proceedings.
Nine of the recipients were Russian nationals, reflecting the program’s strong appeal among wealthy post-Soviet business figures seeking European mobility, asset diversification and an alternative jurisdiction for family or commercial planning.
Eight were Cambodian nationals, a group that attracted particular attention after reporting connected Cypriot citizenship approvals to senior Cambodian officials and politically influential figures within an authoritarian political system.
Five recipients were Chinese nationals, while the remaining four were two Kenyans, one Malaysian and one Iranian, bringing the total to 26, as government sources said at the time.
The arithmetic is important because later summaries sometimes reduced the initiative to Russians, Cambodians and Chinese investors, inadvertently omitting the four recipients from Kenya, Malaysia and Iran and obscuring the review’s broader reach.
It is also inaccurate to state that every person on the list had been publicly proven to have concealed a criminal background, violated investment conditions or committed another identifiable act of fraud.
Authorities did not publish a complete individualized statement of grounds for all 26 recipients, and inclusion in an administrative review was not equivalent to a judicial finding of criminal or civil liability.
Some cases reportedly involved criminal allegations, sanctions exposure, inaccurate disclosures, or developments occurring after naturalization. In contrast, others raised questions about whether the approval criteria used at the time had been sufficiently rigorous.
That evidentiary uncertainty did not make the review meaningless, but it required careful language because citizenship deprivation directly affects legal status, family rights, reputation, and access to European territory.
Political Exposure Was a Risk Indicator, Not Proof of Misconduct
Several accounts described members of the 26-person group as politically exposed persons, commonly known as PEPs, but that classification should not be confused with proof of corruption or automatic ineligibility.
A politically exposed person is generally someone entrusted with a prominent public function, or a close relative or associate of such a person, whose position can create an elevated risk of bribery, influence trading or misuse of public funds.
Financial institutions, immigration authorities, and professional intermediaries are expected to apply enhanced scrutiny to those applicants, including deeper source-of-wealth analysis, adverse-media checks, and ongoing monitoring after approval.
PEP status alone does not establish criminality, however, because many ministers, judges, senior military officers, state-enterprise executives and their relatives hold legitimate assets and conduct entirely lawful international business.
The compliance failure arises when an applicant’s political exposure is hidden, inadequately investigated or treated as irrelevant despite warning signs involving unexplained wealth, government contracts, sanctions or credible corruption allegations.
In Cyprus, the controversy concerned whether decision-makers and private service providers consistently identified those risks, documented their assessments and rejected cases in which the origin of wealth or public-interest implications remained unresolved.
Commercial guidance on lawful citizenship planning similarly emphasizes that durable status depends upon complete disclosure and regulatory compliance, an approach reflected in Amicus International Consulting’s discussion of why legally structured citizenship is more resilient than shortcut programs.
That broader principle does not determine the merits of any Cypriot case. Still, it illustrates why a passport obtained through accurate documentation and genuine eligibility is less vulnerable to later administrative challenge.
What the Original List Proved and What It Did Not
The government’s willingness to revisit 26 approvals demonstrated that citizenship acquired through investment could be examined after naturalization, particularly when new evidence or previously missed information raised statutory concerns.
It did not demonstrate that the state had already proved each allegation, completed each hearing, or exhausted each recipient’s right to challenge deprivation before an administrative tribunal or court.
Nor did the nationality breakdown establish that applicants from any particular country were inherently suspect, because meaningful due diligence must evaluate the individual, the transaction, the source of wealth and the surrounding evidence.
Nationality can influence the availability and reliability of public records, especially when an applicant comes from a country with limited transparency, political interference or inaccessible criminal databases. Still, it cannot substitute for individualized assessment.
The concentration of recipients within nine investment projects also suggested that authorities were examining relationships among applicants, intermediaries and transactions. However, the public record did not establish collective wrongdoing within every project.
For investigators, related applications can expose common service providers, shared property investments, overlapping corporate structures and repeated documentary weaknesses that would be harder to recognize when each file is reviewed in isolation.
For affected citizens, however, association with another applicant cannot lawfully replace proof concerning their own disclosures and eligibility, particularly when relatives or business partners may possess different knowledge of the disputed facts.
The original initiative therefore served two purposes: it communicated political willingness to act while creating a practical test of whether Cyprus could translate reputational concerns into legally sustainable deprivation decisions.
The answer during the first months was sobering, because the government had identified targets and announced action before completing the procedural framework that would allow evidence to be tested and final decisions to survive review.
The Cabinet’s Announcement Met a Legal Vacuum
Within three months of the November announcement, the government’s position became public when lawmakers were told the deprivation process had stalled because the necessary procedural regulations were missing.
Reuters reported in February 2020 that a legal technicality had temporarily halted the effort, leaving authorities unable to move cleanly from a Cabinet decision into completed citizenship withdrawal.
The problem was not simply bureaucratic delay, because deprivation requires a lawful procedure identifying who examines the evidence, how the affected person receives notice, what response is permitted and which authority reaches the final decision.
Without supplementary regulations and an operational review mechanism, Cyprus risked issuing orders that could be overturned for procedural unfairness, even when the underlying concerns about an applicant were serious and well documented.
Officials consequently needed to establish a committee and define the rules governing its work, transforming what had initially appeared to be a swift enforcement announcement into a slower exercise in administrative-law construction.
The episode revealed a striking contradiction at the center of the investment program: Cyprus had developed detailed machinery to approve and process lucrative citizenship applications without building equally robust machinery to reverse defective approvals.
That imbalance benefited the program during its expansion, when it celebrated speed and investment inflows. Still, it became a liability once investigators, journalists and European institutions began testing the reliability of past decisions.
Why Revocation Could Not Be Automatic
Citizenship is a legal status, not a commercial license that can be canceled immediately when public controversy develops, even when the original grant followed a major financial investment.
A defensible deprivation action normally requires the state to identify a statutory ground, assemble admissible evidence, notify the citizen, consider any response, and preserve access to judicial review under national and European legal principles.
Cases involving alleged misrepresentation can be especially fact-intensive because authorities must carefully distinguish an applicant’s false statement from information that was unavailable, immaterial, or discovered only after naturalization.
The timing of adverse information also matters, since a later prosecution or sanction does not necessarily prove that an applicant lied during the original process. However, it can trigger a fresh public-interest or security assessment.
Family members create another complication because spouses, children, and parents may have received citizenship through the principal investor while having different levels of knowledge, independence, and responsibility for the underlying application.
These safeguards can make deprivation appear frustratingly slow, but abandoning them would weaken the government’s cases and increase the likelihood that courts would restore citizenship because officials had denied fundamental procedural rights.
Lawful second-citizenship planning therefore requires more than possession of an authentic passport booklet, because the durability of the status depends upon the legality of the naturalization, the accuracy of the record and continuing compliance obligations.
Amicus International’s overview of obtaining a second passport with a New Legal Identity likewise cautions that noncompliance can produce legal consequences, including revocation. However, each jurisdiction applies its own statutory standards and procedures.
The Cyprus Papers Changed the Scale of the Crisis
The 26-person initiative might have remained a contained review of legacy approvals if the Cyprus Papers had not exposed the breadth of weaknesses surrounding the investment program during the following year.
Beginning in August 2020, Al Jazeera reported on leaked application files involving thousands of recipients, intensifying scrutiny of approvals granted to politically connected figures, people facing allegations abroad and applicants whose eligibility appeared questionable.
An undercover report released in October then showed senior Cypriot figures appearing willing to help a fictitious Chinese businessperson with a criminal conviction pursue citizenship, producing a political shock that incremental reforms could no longer contain.
Cyprus announced the program’s termination in October 2020 and stopped accepting new applications from November 1, ending the scheme prospectively while leaving the government responsible for examining thousands of citizenships already granted.
The closure changed the political meaning of the 2019 list, which no longer looked like an isolated enforcement action and instead appeared as an early warning that structural defects extended across the approval system.
It also widened the central question from whether 26 named or identifiable recipients should retain citizenship to whether the legal architecture used for thousands of naturalizations had complied with Cypriot law.
The Nicolatos Inquiry Turned Suspicion into a Systemic Finding
The independent commission chaired by former Supreme Court president Myron Nicolatos examined the program’s operation. It delivered a final report in 2021 that sharply criticized both its legal foundation and administrative oversight.
The inquiry concluded that more than half of the citizenships examined had been granted unlawfully, including large numbers of relatives who received nationality even though the governing law did not authorize their naturalization through the mechanism used.
That finding transformed the cleanup from a narrow exercise centered on notorious individuals into a systemic review involving statutory interpretation, Cabinet practice, service-provider conduct and the responsibilities of multiple government departments.
The commission’s conclusions also demonstrated why nationality totals must be interpreted carefully, because official figures could include principal investors alongside spouses, children and parents whose citizenship depended upon the investor’s application.
By identifying defects in the approval process itself, the inquiry supplied a broader legal and evidentiary foundation for subsequent deprivation decisions. However, every affected citizen still retained the right to challenge the government’s action.
The 2021 Expansion Went Far Beyond the Original List
In October 2021, the Cabinet decided to withdraw citizenship from 45 people, including 39 principal investors and six dependents, following recommendations connected to the Nicolatos Commission’s work.
The government also ordered investigations into six additional cases and further scrutiny of 47 others, signaling that the enforcement pipeline had become a multi-tiered process rather than a single list awaiting execution.
Those figures did not necessarily replace the 2019 group on a one-for-one basis, because successive reviews were assembled under different recommendations, procedural stages and distinct categories of alleged defect.
Nevertheless, the 2021 action showed that the initial 26-person initiative had become the opening phase of a much wider campaign to reassess approvals issued throughout the program’s history.
The shift was institutional as well as numerical, since Cyprus now possessed an independent inquiry’s findings, revised deprivation procedures, and much stronger political incentives to demonstrate credible enforcement to European partners.
A First Reaction That Revealed the Larger Problem
The November 2019 announcement was important because it broke with the assumption that investment citizenship, once approved, would remain secure regardless of later discoveries or changes in the government’s assessment.
Yet the stalled proceedings also exposed how unprepared Cyprus was to conduct the review it had announced, showing that enforcement credibility depends as much on procedural capacity as on political resolve.
The group’s composition—nine Russians, eight Cambodians, five Chinese nationals, two Kenyans, one Malaysian and one Iranian—remains the most accurate public breakdown of that original 26-person initiative.
Calling the group a collection of proven offenders would go beyond the public record, while describing the Cabinet decision as 26 completed revocations would erase the legal obstacles that immediately followed.
The more defensible conclusion is that Cyprus began a targeted deprivation process against 26 recipients whose cases had raised serious concerns, only to discover that its legal framework was not ready to carry that decision through.
By the end of 2021, the Cyprus Papers, the program’s termination, and the Nicolatos inquiry had turned that early enforcement experiment into a far broader reckoning over how citizenship had been sold, supervised, and sometimes unlawfully granted.
The initial list therefore matters less as a completed victory than as the moment Cyprus publicly acknowledged that past passport decisions required reversal and, at the same time, revealed how difficult lawful reversal would become.