Five Percent, Flat: What a 21 CBI Engagement Actually Includes, and Why the Industry Charges 15 to 25

You will audit a hardware wallet’s firmware before trusting it with a fraction of your stack. You will read an exchange’s fee schedule down to the maker-taker basis points before placing a single order. You verify, because verification is the discipline. And then the citizenship industry asks you to do something you would never do anywhere else in your financial life: commit six figures to a process whose full price you have not actually been told. Not the government’s price; that one is published in an official gazette. The firm’s price. The advisory fee, the processing charge, the service cost, the administrative line items that materialize only after the engagement letter is signed. The industry has trained clients to treat that opacity as normal. It is not normal. It is a design, and it points away from you.

A fee you cannot see before you commit is not a fee. It is a position taken against you.

The Number, Stated Plainly

For its two productized programs, 21 CBI charges 5% of the government contribution. Flat, published, and calculated on a number you can verify against the program’s own schedule. Not 5% of the total cost. Not 5% plus processing. Bespoke work is different: scope and professional fees are set after the paid Sovereignty Strategy Session, with no standing percentage or fixed jurisdiction fee.

Run it across the productized slate. Vanuatu’s Development Support Program (DSP) starts at a $130,000 contribution; the advisory is $6,500. El Salvador’s Freedom Passport carries a $1,000,000 contribution; the advisory is $50,000. São Tomé and Türkiye remain useful market comparisons, but 21 CBI covers them only through bespoke advisory and publishes no standing fee for either.

Argentina reinforces the distinction. It is not a CBI program; it is a residency-to-citizenship pathway, and there is no government contribution on which to base a percentage. Any Argentina work is bespoke, scoped and priced after the Session. Argentine government filing fees remain separate and are paid in pesos at filing.

That is the pricing model: published 5% math for the two productized programs, bespoke scope everywhere else. The rest of this post explains what the productized fee buys and why the broader industry can bill three to five times more for the same passport.

What The Five Percent Buys

A productized engagement runs in phases, and the advisory fee covers all of them.

It starts with the applicable paid entry step. We assess your profile and run a preliminary compliance review against the program’s approval and denial criteria, because a flag should surface at our desk, not at the government diligence unit. You get a family composition review, a complete documents checklist, and a cost estimate. If the review turns up a problem we cannot solve, or a program that does not fit, we say so before program money moves.

Then comes the part where Bitcoiners actually get stuck: source of funds. A decade in cold storage, three exchanges, two of them dead, a mining history from 2016. We structure that history into a file a government compliance officer can read, because we have presented on-chain wealth to these desks before and know what they accept. The full anatomy of that process is on our source-of-funds page.

Then preparation, filing, and liaison. Both productized programs require the application to move through a licensed channel; direct application is not a thing. We prepare the file, handle the defined government correspondence, and send status updates as it moves. For El Salvador, that channel is direct: 21 CBI is a licensed agent of The Bitcoin Office of El Salvador. Vanuatu’s file settles in BTC, Lightning, or USDT after compliance clearance through BitSettle; El Salvador’s government contribution settles directly in BTC or USDT by program rule. Any bespoke filing or conversion role must be stated separately in the engagement scope.

And the engagement model itself is part of what you are paying for. One advisor, with a direct line, over Signal or PGP, end-to-end encrypted, with minimal data retention and compartmentalized case handling. No chatbot. No junior associate. No platform dashboard. The person who assessed your file is the person who files it.

What It Does Not Include

Honesty requires the other half of the ledger. The government contribution is the government’s, not ours: $130,000 for Vanuatu and $1,000,000 for El Salvador. Third-party costs also exist on every file. Vanuatu’s $5,000 due-diligence line, passport issuance, and enrollment costs are separate from the advisory. Bespoke jurisdictions have their own legal, notary, valuation, filing, and settlement costs; those are scoped for the engagement rather than published as a 21 CBI product ladder.

What you will not find is a markup hiding inside any of those lines. The due diligence fee is the due diligence fee. That sounds like a low bar. In this industry, it is not.

Where 15 To 25 Actually Comes From

The 15 to 25% figure is not rhetoric. It is the industry’s documented fee architecture, and it has three layers.

Layer one: client-side professional fees. Typical firms charge $15,000 to $20,000 in professional fees per file, and agent-plus-legal stacks commonly run $25,000–$80,000. These are rarely itemized before commitment; they surface as processing fees, service charges, and administrative costs once the file is open and walking away feels expensive. On a Vanuatu application, 15 to 25% of the government fee alone is $19,500 to $32,500. On a Türkiye file measured against the total investment, the same percentages produce $60,000 to $100,000.

Layer two: what governments themselves pay agents per approved file. The investment-migration trade press tracks these commissions program by program: $50,000 per approved client in Saint Kitts & Nevis, roughly $40,000 in Vanuatu, $20,000 in São Tomé & Príncipe, and 10% of the investment amount in Dominica. Commissions are not illegitimate; they fund the distribution networks these governments rely on. But invisible money bends advice. Our answer is a client-side fee you see first, the same 5% formula on both productized programs, bespoke pricing stated in the engagement letter, and a recommendation framework you can check on the methodology page.

Layer three: real estate. Türkiye’s route runs through property, and property runs through commissions: agents earn 4 to 15% of a unit’s value on citizenship-eligible sales, with some networks demanding 15 to 20, and units marketed to foreign buyers are routinely priced above market precisely because the buyer’s real goal is the passport, a pattern Ankara has repeatedly tightened mandatory-valuation rules to police. The commission never appears on an invoice. It appears in the price of the building, and the client holds that markup for the entire three-year holding period.

Stack the three layers and the arithmetic stops being mysterious. A client can pay an extra $20,000 to $60,000 on a single file without one line item ever saying advisory fee. That is how 15 to 25% of total cost became the industry norm, and why no rate card was ever going to show it to you.

The Math, Side By Side

Take Vanuatu, the program we are asked about most. The published single-applicant ladder: $130,000 government contribution, $5,000 due diligence and FIU screening, $2,500 birth registration and national ID, $1,000 passport enrollment, and our $6,500 advisory. All-in, $145,000, every line visible before you engage, government processing in 30–60 days once the file is submitted.

The industry model on the same file: 15 to 25% of the government fee is $19,500 to $32,500, before the charges that appear later. The difference is $13,000 to $26,000. At this writing (June 12, 2026; CoinGecko close of $63,456 per BTC), that spread is roughly 0.20 to 0.41 BTC. The entire 21 CBI advisory on the same file is about 0.102 BTC; call it ten million sats. You have run harder numbers for smaller stakes, and you have walked away from exchanges over basis points. This is the same audit, one decimal place to the left.

Why The Model Holds

The obvious question: if 5% covers a real engagement, why does the rest of the industry charge triple? Structure, not arithmetic. A commission-funded firm carries a sales floor, offices in two or three financial capitals, referral chains where every intermediary takes a cut, and a marketing budget built to win search auctions. Every layer eats, and the client feeds all of them. The fee is not high because the work is expensive. The fee is high because the structure pays for everything except the work.

21 CBI carries none of it, on purpose. One advisor: a US Air Force veteran with an LL.M. in European and comparative law, over a decade at the US Department of Homeland Security on immigration policy, residency paperwork filed in his own name, keys held in his own custody. No sales team, no lobby, no account managers. The trade-off is honest, and you should weigh it: you do not get a concierge army or a marble office. You get the person who knows your file, on an encrypted line, with the math published before the engagement letter. If you want the lobby, we are the wrong firm. If you want the work, the work is what the 5% buys.

Payment follows the same posture. BTC, Lightning, and USDT are our payment rails. Credit cards and bank transfers also accepted as needed. The El Salvador contribution itself settles in BTC or USDT only; that is the program’s rule, not our framing, and this firm was built to handle it natively.

The Decision Test

Strip it down to a test you can run on any firm, including this one. Ask for the complete fee schedule, in writing, before you sign anything. If the answer is a number and a formula, you are talking to an advisor. If the answer is a discovery call, you have found the 15 to 25%.

Then choose by your priorities, not by anyone’s commission. Choose Vanuatu if speed leads: $6,500 advisory. Choose El Salvador if Bitcoin-native sovereignty is the point: $50,000 advisory. If São Tomé’s Non-CRS posture, Türkiye’s E-2 eligibility, Argentina, or another jurisdiction belongs in the analysis, the answer is bespoke advisory after the Session, not a retired rate card.

Think in sats. Pay in Bitcoin. Five percent on the two productized programs; bespoke scope everywhere else. If you are undecided or need a jurisdiction outside El Salvador and Vanuatu, start with the paid Sovereignty Strategy Session. No obligation to proceed beyond the session.

Program figures and commission data are as of June 2026 and change as governments amend their schedules. This is general information, not legal, tax, or investment advice for your situation. Consult a qualified advisor regarding your specific circumstances.