Agent Obligations

Agent obligations in the Vanuatu citizenship procedure are the duties a licensed designated agent carries because it is the only party allowed to lodge an application: to identify the client properly, to submit an honest and complete file, to handle official payments only as instructed, and to stay within the limits of what it can promise. Those duties come from the licensing framework under the Citizenship Act [CAP 112] and its regulations, and from Vanuatu's anti-money laundering law — not from the brochure an agent hands out.

This page is for applicants who are comparing agents, or who are already working with one and want to know what they are entitled to expect. It separates the obligations that follow from the agent's role in the procedure from the "services" that are marketing. The licensing of agents as such is a different topic, covered on the page about how designated agents are licensed.

Where Do an Agent's Duties Come From?

A Vanuatu designated agent's obligations have three sources, and it helps to keep them apart:

• The citizenship framework. The Citizenship Act and the regulations made under it create the designated agent role and set the conditions of a licence. The agent acts as the channel between the applicant and the Citizenship Office, which means the authorities hold the agent responsible for what it submits.
• Financial-crime law. Vanuatu's anti-money laundering and counter-terrorism financing regime applies to businesses that handle client funds and verify client identity. The Financial Intelligence Unit is the institution at the centre of that regime.
• Your contract. Whatever the agent agrees to do in its engagement letter — timelines for responses, translation, courier handling, refund terms for its own fees — is a private commitment. It is enforceable as a contract, but it is not a regulatory duty, and it cannot add anything to the procedure itself.

We do not quote section numbers or paraphrase specific clauses here, because the regulations are amended from time to time. Ask your agent to identify, in writing, which current instrument it relies on for any requirement it imposes on you.

What Must an Agent Do Before Lodging a File?

Before a Vanuatu application reaches the Citizenship Office, the agent is expected to do work that a purely commercial intermediary might prefer to skip.

Know who the client is

The Vanuatu agent verifies your identity and that of every dependant, and builds a picture of where your money comes from. This is the start of customer due diligence. It is separate from, and comes before, the formal due diligence check paid for through the programme fee of US$5,000.

Screen out files that should not be lodged

An agent that knows an applicant has concealed a conviction, or cannot explain the origin of the funds, is not meant to lodge the file and hope. The Citizenship Commission decides, but the agent's licence depends on not feeding it applications built on false information.

Assemble a truthful dossier

Every certified copy, translation and declaration in the Vanuatu file passes through the agent's hands. The agent is responsible for presenting documents as they are — not "tidying" dates, names or employment histories to make the story smoother.

Obligations Compared With Common Sales Claims

The gap between what an agent must do and what some agents advertise is where most applicant disappointment begins. The comparison below is a practical way to read a proposal.

Area	What the role requires	Sales claim to treat with caution
Outcome	Submit a complete, accurate file and pass on the Commission's decision	"Guaranteed approval" or "pre-approved" status
Timing	Respond to requests from the Citizenship Office without delay	"Passport in 30 days"; realistic processing is usually two to four months
Payments	Pass on official payment instructions; contribution paid in US dollars only after approval	"Pay in crypto" or "pay us the full amount upfront"
Price	Disclose the official amounts separately from the agent's own fee	A single bundled figure with no breakdown
Travel access	Describe access accurately — about 88 destinations without a prior visa	"Visa-free Europe", which ended for Vanuatu nationals on 4 February 2023

How Should an Agent Handle Your Money?

Payment handling is the area where a Vanuatu agent's obligations are most concrete. Under the Development Support Program the official contribution is US$130,000 for a single applicant, US$150,000 for a couple, US$165,000 for a family of three and US$180,000 for a family of four. Those sums are due after approval, not before, and they are paid in US dollars only. Cryptocurrency is not accepted.

An agent meeting its obligations will therefore:

1. Give you the official payment instructions as issued, without substituting its own account unless the official instructions provide for payment through a designated client account.
2. Keep its own professional fee visibly separate from government amounts.
3. Provide receipts for every amount it collects, including the due diligence fee and any small administrative fees set by regulation.
4. Refuse to accept funds that it cannot connect to the source-of-funds evidence in your file.

If an agent cannot explain where a particular payment goes, treat that as a reason to pause, not as a detail to sort out later.

What Must an Agent Keep, Report and Disclose?

Because it handles identity documents and client money, a designated agent holds a considerable amount of personal data about you and your family. Its obligations here are partly about confidentiality and partly about record retention for regulatory purposes; the record-keeping page sets out what is held about an applicant and by whom.

Two points often surprise applicants. First, confidentiality towards you does not override reporting duties: where anti-money laundering law requires an agent to report a suspicion, it must do so and is generally not allowed to tell the client. Second, material facts that arise after lodging — a new criminal charge, a change in a dependant's status — should be passed to the Citizenship Office through the agent, rather than leaving the Commission to decide on outdated information. A responsible agent will insist on this.

What an Agent Is Not Obliged — or Allowed — to Do

Understanding the limits is as useful as understanding the duties. A Vanuatu designated agent:

• cannot decide your application; the decision belongs to the Citizenship Commission;
• cannot fix your visa position in the Schengen area, which since 3 February 2025 has been governed permanently by Regulation (EU) 2025/11, or in the United Kingdom, which has required visas from Vanuatu nationals since 19 July 2023;
• is not responsible for advising on your tax or nationality position in your current country unless it has expressly agreed to do so and is qualified there;
• should not describe itself or any partner website as an official or government body.

When the Citizenship Commission suspended new applications under the Capital Investment Immigration Plan in March 2025, the obligation on agents was straightforward: stop presenting that route as open. The Development Support Program was not affected. An agent that still sells a suspended route is failing the most basic duty in this list — to describe the procedure as it actually stands.