Turkish CBI Plus US E-2 Combo: An Alternative to EB-5 for Vietnamese Investors

The Türkiye CBI plus US E-2 combo path is one of the two most popular routes helping Vietnamese investors access the US market at a lower budget than the Visa EB-5 programme. Because Vietnam is not on the United States’ Treaty Country list, the investor must hold the nationality of a country with an E-2 treaty — and Türkiye is one of the most competitively priced options in terms of investment size.

Türkiye citizenship by investment allows the investor to receive a Turkish passport within 3 to 6 months with a minimum investment of $400,000 USD in real estate. The Turkish citizen may then apply for United States E-2 Visa — a temporary residence visa allowing the holder to run a business in the United States, with a flexible investment starting from $100,000 USD. Notably, the Turkish property can be resold after 3 years, offering the possibility of recovering most of the invested capital.

This article examines in detail the two steps of the Türkiye CBI plus US E-2 combo path, compares it with the Grenada combo, and highlights one important legal point to note: how the 3-year domicile requirement under the Amigos Act 2022 affects Türkiye differently from Grenada.

Why Türkiye is an E-2 gateway for Vietnamese nationals

Türkiye signed the Treaty of Commerce and Navigation with the United States on 18/05/1990 and remains one of the countries with a current E-2 treaty, as confirmed by the US Department of State’s list of Treaty Countries. This is the legal basis allowing Turkish citizens to apply for an E-2 visa with the same benefits as citizens of traditional treaty countries.

Compared with Grenada, Türkiye has three important differences:

Point 1 — Investment size: Türkiye requires a $400,000 USD real-estate investment, higher than Grenada’s NTF at $235,000 USD, but with the possibility of recovering the capital (resale after 3 years). Grenada’s NTF, by contrast, is a non-refundable donation.

Point 2 — Type of asset: Türkiye accepts only income-generating investments (real estate, bank deposits, government bonds, funds, companies) — there is no donation option. The consequence: every Turkish CBI application falls under “financial investment” as defined by the Amigos Act, triggering the 3-year domicile requirement.

Point 3 — E-1 treaty status: Türkiye holds both E-1 (Treaty Trader) and E-2 (Treaty Investor) status, whereas Grenada has only E-2. This is an advantage for investors with import-export activity between the United States and Türkiye.

In addition, a Turkish passport grants visa-free or visa-on-arrival access to more than 110 countries, including Japan, Singapore, South Korea and Hong Kong, and improves the odds of a 5-year Schengen visa and a 10-year US visa with a simpler application than with a Vietnamese passport.

Step 1 — Investing for Turkish citizenship

The first step in the Türkiye CBI plus US E-2 combo is obtaining Turkish citizenship through the Citizenship by Investment programme, launched by the Turkish government in January 2017. The programme is administered by the Provincial Directorate of Civil Registration and Nationality and has been adjusted several times, with the current minimum, in effect since 06/2022, at $400,000 USD for the real-estate option.

The five current investment options:

Option 1 — Real estate: buy one or more properties with a combined value of at least $400,000 USD, held for a minimum of 3 years. The property must have a title deed (TAPU) in the investor’s name and be valued by an appraiser licensed by the SPK. This is the most popular option, accounting for around 95% of all applications.

Option 2 — Bank deposit: deposit at least $500,000 USD in a Turkish bank, maintained for 3 years.

Option 3 — Government bonds: buy at least $500,000 USD in Turkish government bonds, held for 3 years.

Option 4 — Investment fund: invest at least $500,000 USD in a licensed real-estate investment fund or venture capital fund, held for 3 years.

Option 5 — Job creation: create at least 50 full-time jobs for Turkish citizens, confirmed by the Ministry of Labour.

Standard processing takes 3 to 6 months. The applicant does not need to reside in Türkiye during processing — the entire application can be filed remotely through an authorised representative. Only one visit to Türkiye is required, to provide biometric data.

In addition to the main investment, investors must pay additional taxes and fees of around 5% of the property value: transfer tax (4%), notary fees, valuation fees, and legal and representation fees. Eligible family members include the spouse, children under 18, and children with disabilities regardless of age.

The Türkiye passport is valid for 10 years, and Türkiye allows dual citizenship — investors do not need to renounce Vietnamese citizenship when acquiring Turkish citizenship.

Step 2 — Applying for the US E-2 Visa

Once they hold Turkish citizenship, investors can apply for a US E-2 visa at the US Embassy in Ankara or the Consulate General in Istanbul. The E-2 process is managed by United States Department of State (DOS) directly, without going through USCIS for applications filed from abroad.

Core E-2 requirements for Turkish citizens:
– Turkish citizenship at the time of application (met through the CBI passport)
– Invest a substantial amount in a US business
– The business must be real, operating, and not “marginal” (not merely sufficient to support the family)
– The investor must hold at least 50% of the shares or have operational control
– The investor must come to the United States to develop and run the business

There is no fixed threshold for E-2 investment. In practice, E-2 applications from Turkish citizens typically fall in the range of US$100,000 to US$300,000, with some cases reaching up to US$500,000 depending on the industry. Service businesses (restaurants, salons, convenience stores, consulting firms) generally require lower investment; large franchise or manufacturing businesses may require higher investment.

The E-2 application must include: a detailed business plan with a 5-year projection; evidence of capital transfer into the US business; proof of the lawful source of funds (including the original funds used for the Turkish CBI investment); a lease agreement or proof of premises ownership; business registration in the state of intended operation; an EIN (Employer Identification Number) from the IRS; and a US business bank account.

According to lawyers specialising in E-2 visas for Turkish citizens, processing time at the US Embassy in Ankara or Istanbul is typically 2 to 4 months from DS-160 submission to interview. The E-2 visa for Turkish citizens is usually issued for a 5-year term (based on reciprocity), with a maximum stay of 2 years per entry. The visa can be renewed indefinitely as long as the business remains operational and meets the criteria.

The Amigos Act 2022 — the 3-year domicile requirement as it applies to Türkiye

This is the most important legal point that investors considering the Turkish CBI plus US E-2 combo must fully understand.

In December 2022, the US Congress passed the National Defense Authorization Act for Fiscal Year 2023, which contained a provision informally known as the “Amigos Act”. The new rule amended 8 U.S.C. § 1101(a)(15)(E) by adding a requirement: if an E-1 or E-2 applicant acquired the treaty country’s nationality through a “financial investment” and has never previously been issued an E-visa, the applicant must have been domiciled in that treaty country continuously for at least 3 years at any time before applying for the E-visa.

Because the Turkish CBI programme only accepts income-generating investment options (real estate, deposits, bonds, funds, business) — with no donation route — every Turkish CBI application falls under “financial investment” as commonly understood under the new regulation. As a result, Turkish CBI investors typically face a 3-year domicile requirement before applying for the E-2.

Unlike Grenada, Türkiye has NO “spousal registration” mechanism allowing a spouse to obtain citizenship quickly through marriage without residency. Under Turkish citizenship law, a foreign spouse must legally reside in Türkiye for at least 3 years before becoming eligible to apply for citizenship by marriage. The strategy of “avoiding the Amigos Act via spousal registration” — a key strength of Grenada — is not feasible with Türkiye.

Domicile is not the same as residence: According to lawyers specialising in E-visas, “domicile” under US law is not the same as day-to-day physical residence. Domicile is determined by a combination of factors: place of habitual residence, intent to stay long term, and assets and economic activity in that country. However, to demonstrate 3 continuous years of domicile in Türkiye, investors need to build objective evidence: a lease or property purchase agreement in Türkiye, a local bank account, a Turkish tax number, a residence permit, and business or investment activity in Türkiye.

Making the most of the mandatory 3-year period: Because the Turkish real-estate CBI programme already requires holding the property for 3 years before selling, many investors choose to spend these 3 years actually residing in Türkiye — enrolling children in international schools, running a local business, building a life — meeting the CBI programme’s requirement while also satisfying the Amigos Act’s domicile requirement. After 3 years, investors can sell the property (if they wish) and apply for the E-2 with a solid case.

Disclaimer: Establishing and proving domicile for E-2 purposes requires consultation with a US-licensed immigration lawyer specialising in E-visas. The information in this article is for reference only.

Comparing the Türkiye combo with the Grenada combo

This is a practical comparison for investors weighing two alternative routes to EB-5:

Criteria	Türkiye combo	Combo Grenada
CBI investment amount	US$400,000 real estate	US$235,000 NTF donation or US$270,000 real estate
CBI capital recovery	Yes (property can be sold after 3 years)	No for NTF, yes for real estate (after 5 years)
CBI processing time	3-6 months	3-6 months
Visa-free passport	110+ countries (including Japan, Singapore)	140+ countries (including the UK, Schengen, China)
E-1 treaty with the United States	Yes	No
Spousal registration cho Amigos Act	None	Yes
3-year domicile requirement applies	Applies to every route	Can be avoided via the NTF donation or spousal route
E-2 investment amount (US business)	$100,000 — $300,000 USD	$100,000 — $300,000 USD
Total combo budget	US$550,000 — US$750,000 (high recovery potential)	$400,000 — $600,000 USD

In summary, the Türkiye combo has a higher total budget but better CBI capital recovery (property can be sold after 3 years), plus a passport with an E-1 treaty. The Grenada combo has a lower budget and more flexibility around the Amigos Act, but the NTF route does not allow capital recovery.

Comparing the Türkiye combo with EB-5

The table below compares the total budget of the Turkish CBI plus US E-2 combo route against the EB-5 programme for a typical family (spouse and 2 children):

Item	Türkiye → E-2 combo	EB-5
Main investment	US$400,000 real estate	$800.000 USD (TEA)
US business investment	$100,000 — $300,000 USD	Included in the EB-5 capital
CBI programme fees and taxes	~$30,000 — $50,000 USD	Not applicable
E-2/EB-5 legal fees	$15,000 — $30,000 USD	$50,000 — $100,000 USD
USCIS / DOS fees	~$5,000 — $10,000 USD	~$30,000 — $50,000 USD
Total budget	$550,000 — $790,000 USD	$900,000 — $1,000,000 USD
Ability to recover capital	Turkish property + US business	EB-5 capital (after the project cycle)
Outcome in the United States	Time-limited residence (E-2)	Permanent green card

The Türkiye combo saves around US$200,000 to US$450,000 compared with EB-5, in exchange for time-limited residence rather than a green card. However, once the 3-year domicile requirement before the E-2 is factored in, the actual total timeline of the Türkiye combo can be longer than EB-5 for Vietnamese applicants.

Benefits and limitations of the Türkiye CBI plus US E-2 combo

When entering the United States on an E-2 visa via Turkish citizenship, investors and their families receive the following benefits:
– Live and work in the United States for the visa term (5 years), renewable indefinitely
– The spouse is granted work authorization and can work for any business
– Children under 21 accompany the investor as E-2 dependants and attend public schools free of charge
– Freedom to enter and leave the United States during the visa’s validity
– Permanent Turkish passport — visa-free access to 110+ countries, easier to obtain a 5-year Schengen visa and a 10-year US visa
– Ownership of Turkish real estate (can be sold after 3 years to recover capital)

Important limitations:
– The E-2 does not lead to a green card and does not count towards US naturalisation requirements
– Children cannot maintain E-2 dependent status once they turn 21
– 3-year domicile requirement in Türkiye before applying for the E-2 (Amigos Act)
– E-2 status becomes invalid if the US business closes
– The US business must be maintained for the entire visa period
– Turkish real estate is exposed to lira-USD exchange rate risk and Turkish economic volatility

A combined route from E-2 to EB-5 or a green card

Similar to the Grenada combo, many investors use the Turkish CBI plus US E-2 combo as an intermediate stage, later transitioning to the United States permanent resident card once financial conditions allow.

Common transition options:

Switching to EB-5: after successfully running the E-2 business and accumulating capital, invest an additional US$800,000 in an EB-5 project to obtain a green card. This route suits investors who already have a solid foothold in the United States and want to move to resident status.

Switching to EB-1C: for investors already running a substantial E-2 business who meet the “multinational manager or executive” criteria of Visa EB-1. EB-1C does not require PERM (labour certification), so it processes faster than other employment-based categories.

Switching to EB-2 NIW: for investors with extraordinary ability or significant contributions to the national interest.

With the Türkiye combo, the combined route generally takes longer than the Grenada combo because of the mandatory 3-year domicile requirement.

Detailed article on the Comparing EB-5 and the US E-2 visa.

Which option suits Vietnamese investors

The Turkish CBI plus US E-2 combo suits Vietnamese investors with the following characteristics:
– Budget of US$550,000 — US$790,000, prioritising CBI capital recovery over donation
– Willing to actually reside in Türkiye for 3 years (meeting both the property-holding requirement and the Amigos Act domicile requirement)
– Have import-export activity between the United States and Türkiye (able to make use of the E-1 visa)
– Want to own property in Türkiye — a strategic geographic location between Europe and Asia
– Accept lira-USD exchange rate risk and Turkish economic volatility

The Grenada combo is generally better suited to investors with a lower budget, who are not willing to reside abroad for 3 years, and who prioritise a passport that is strong for travel (140+ visa-free countries including the UK, Schengen, China).

EB-5 remains the optimal choice for investors with a budget of US$850,000 or more, aiming for a green card and permanent US citizenship for the whole family, with no plan to run a business in the United States.

Summary

The Turkish CBI plus US E-2 combo is an alternative to EB-5 suited to Vietnamese investors with a medium budget who prioritise CBI capital recovery and are willing to actually reside in Türkiye. With a total cost of US$550,000 — US$790,000 and a CBI process of 3-6 months, this route delivers three outcomes at once: a permanent Turkish passport, property ownership in Türkiye, and time-limited residence rights in the United States.

However, the 3-year domicile requirement under the 2022 Amigos Act is a significant legal hurdle for the Türkiye combo — unlike Grenada, there is no spousal registration mechanism to get around it. Planning the 3 years of residence in Türkiye to coincide with the property-holding requirement is the most practical strategy.

PLI’s immigration specialists recommend that investors fully weigh three factors before deciding: their ability to actually reside in Türkiye for 3 years, their capacity to run a business in the United States after entering on the E-2, and their long-term goal of a green card via transition to EB-5 or EB-1C. Consulting a US immigration lawyer specialising in E-visas together with a licensed CBI representative in Türkiye is an essential step before committing a large sum to this combo route.