Latest / IMI Podcasts / Argentina Publishes Tender to Appoint Master Agent for New CBI Program
Transcript
- 0:00SPEAKER_00: Argentina's Ministry of Economy has issued an official tender for a four-year consulting contract that will design, implement, and operate the country's first citizenship by investment or CBI program.
- 0:14SPEAKER_00: The tender number 34-001-CPU 25 closes January 20, 2026, with the formal bid opening taking place immediately as the submission period ends.
- 0:32SPEAKER_00: The Agencia de Programmas de Ciudadania Pur Invasion, referred to as APCI, a decentralized agency created under Decree 366 of 2025 and regulated by Decree 524 of 2025, will oversee the program.
- 0:52SPEAKER_00: Government officials project the initiative will process up to 5,000 favorable recommendation reports during the initial contract period.
- 1:01SPEAKER_00: Argentina will compensate the winning consultancy only for applications that independent agents or third parties submit.
- 1:09SPEAKER_00: The tender explicitly excludes payment for cases that the contractor sources directly.
- 1:15SPEAKER_00: The documents state that the co-contractor will receive the fixed amount solely for applications submitted by local agents or managers or third parties unrelated to the awardee itself.
- 1:28SPEAKER_00: This clause forces the master operator to build a certified agent ecosystem rather than control the entire market.
- 1:36SPEAKER_00: Bidders will receive US dollar payments at a fixed fee per approved application, structured across five tranches of 1,000 applications each.
- 1:46SPEAKER_00: For bid evaluation purposes, the tender applies declining weighted coefficients 2.00, 1.75, 1.50, 1.25, 1.00 to successive tranches when comparing competing proposals.
- 2:05SPEAKER_00: The contractor receives compensation only after APCI issues an informi circunstanciado recommendando la approbacion, detailed report recommending approval for each application.
- 2:19SPEAKER_00: Rejected applications generate no payment.
- 2:23SPEAKER_00: Invoices carry forty-five-day payment terms.
- 2:26SPEAKER_00: The tender permits the consultancy to charge investors directly for processing and due diligence services.
- 2:34SPEAKER_00: Government payments cover applications from certified agents while investor fees compensate for self-sourced cases and operational costs.
- 2:44SPEAKER_00: 4.
- 2:44SPEAKER_00: Implementation milestones over forty eight months.
- 2:49SPEAKER_00: Milestone one, design.
- 2:52SPEAKER_00: Completion required within two months of contract start.
- 2:56SPEAKER_00: Program rules, processes, manuals, staffing profiles and cost estimates.
- 3:02SPEAKER_00: Implementation timeline deliverable requires APCI director approval.
- 3:08SPEAKER_00: Milestone two implementation plus launch planning.
- 3:12SPEAKER_00: Completion required within six months of contract start.
- 3:20SPEAKER_00: APCI certification as ready to receive applications.
- 3:24SPEAKER_00: Approved launch plan.
- 3:26SPEAKER_00: Milestone three launch execution.
- 3:29SPEAKER_00: Completion required within twelve months of contract start.
- 3:38SPEAKER_00: APCI Director Approval of Execution.
- 3:41SPEAKER_00: Milestone four Annual Promotion Plus Technical Assistance.
- 3:47SPEAKER_00: Ongoing promotion and technical support through month forty eight.
- 4:05SPEAKER_00: Bidder qualification requirements exceed standard procurement.
- 4:10SPEAKER_00: Firms must demonstrate proven expertise in residence and citizenship by investment programs.
- 4:17SPEAKER_00: At least one governmental mandate within the past ten years constitutes a mandatory requirement.
- 4:24SPEAKER_00: Legislative drafting experience carries particular weight.
- 4:28SPEAKER_00: Contractors must have written CBI legislation or regulations for other jurisdictions.
- 4:44SPEAKER_00: Detailed CVS with project specifics must accompany all bids.
- 4:49SPEAKER_00: International networks factor heavily into evaluation.
- 4:53SPEAKER_00: The tender requires relationships with CBI agents, financial institutions, due diligence firms, legal advisors, and wealth management companies.
- 5:04SPEAKER_00: Evaluation assigns 60% weight to technical criteria and 40% to economic competitiveness.
- 5:11SPEAKER_00: Technical scoring allocates 20 points each across five categories.
- 5:19SPEAKER_00: Innovation and economic impact, alignment with national development goals, Global Competitiveness Strategy, Expertise 20 points.
- 5:31SPEAKER_00: Human capital, technology, infrastructure, Legal Experience and Operational Support, Digital Solutions and International Communications Deployment, Track Record 20 points, Demonstrated Program Design and Launch Experience, Case Studies and Governmental Stakeholder Engagement, Regulatory and Supranational Environment Navigation, Business Plan 20 Points Strategic Vision for Development, Launch, Execution, Promotion, Long Term Sustainability, Economic Benefit to Argentina, International Network 20 points, Global Reach and Promotional Alliances, Relationships with agents, financial institutions, audit firms, legal advisers, and wealth managers.
- 6:23SPEAKER_00: Contractors must submit certified fiscal year reports demonstrating debt to equity ratio less than or equal to zero point five zero.
- 6:34SPEAKER_00: Current ratio greater than or equal to one point zero zero.
- 6:40SPEAKER_00: Solvency assets, liabilities greater than or equal to two point zero zero.
- 6:49SPEAKER_00: Profit margin greater than or equal to zero point one zero.
- 6:54SPEAKER_00: A certified public accountant must verify all financial statements.
- 7:00SPEAKER_00: Mandatory declarations span eight.
- 7:03SPEAKER_00: Compliance areas.
- 7:04SPEAKER_00: Bidders must submit sworn statements covering eligibility to contract no tax slash social security debts, criminal convictions, or government employment, anti-competitive conduct absence, sustainable procurement compliance, disability workforce requirements, decree three hundred and twelve slash two thousand tenformation security policy compliance integrity programs law twenty seven point four zero one on corporate criminal liability Conflict of Interest Disclosures Decree 2021 Relationships with the President, Vice President, Cabinet Chief, Ministers, or Decision Making Authorities.
- 7:56SPEAKER_00: Three officials hold decision authority over the tender Minister of Economy Luis Andres Caputo, Legal and Administrative Secretary Jose Ignacio Garcia Hamilton, and Under Secretary of Administration Gabriel Martin Krugeras.
- 8:14SPEAKER_00: The contract permits government termination if application volumes fall short of specific targets, fewer than 200 approvals by month 24, fewer than 300 approvals by month 36, or fewer than 100 between months 25 to 36, fewer than 400 approvals by month 48, or fewer than 100 between months 37 to 48.
- 8:40SPEAKER_00: Early termination compensation equals payment for 100 approvals, recognizing sunk costs for completed milestones.
- 8:48SPEAKER_00: The government will not pay lucro cesante or lost profits.
- 8:53SPEAKER_00: Contract duration extends to four years or 5,000 approved applications, whichever occurs first.
- 8:59SPEAKER_00: A single one year extension remains possible.
- 9:02SPEAKER_00: Missing milestone one, two, or three deadlines costs 1% of the total contract value.
- 9:09SPEAKER_00: Each missed annual control deliverable at months 24, 36, or 48, and potentially month 60 if extended, incurs a 0.5% penalty.
- 9:22SPEAKER_00: Five total violations or two or more violations of the same type permit contract rescision.
- 9:28SPEAKER_00: The tender provides no preset investment minimums.
- 9:32SPEAKER_00: The winning consultancy will design investment categories, establish criteria, advise APCI on suitability, and help establish evaluation standards.
- 9:42SPEAKER_00: Neither Decree 366-2025 nor Decree 524-2025 specifies investment amounts.
- 9:54SPEAKER_00: Media reports and industry speculation have cited figures such as$500,000, but no such threshold appears in any official government document or legal text.
- 10:05SPEAKER_00: The winning consultancy gains influence over threshold recommendations while final authority remains with APCI and the Ministry of Economy.
- 10:14SPEAKER_00: The winning consultancy's business plan must demonstrate alignment with national development goals, indicating investments supporting Argentina's economic priorities will receive favorable consideration.
- 10:28SPEAKER_00: Emphasis on real economy investment suggests preferences for productive sectors over passive holdings.
- 10:35SPEAKER_00: Based on the tender's emphasis on economic development and productive investment, eligible areas could include agribusiness, renewable energy, mining, technology, tourism infrastructure, industrial capacity, job creation pathways with employment requirements, and knowledge economy investments.
- 10:56SPEAKER_00: Real estate may qualify only as part of productive investment projects, though the tender does not explicitly enumerate eligible sectors.
- 11:05SPEAKER_00: The tender mandates a range of services including legislative consulting and comparative advantage analysis, functional program development, structure, mechanisms, processes, optimized application forms, service standards, policies, procedures, workflows, timelines, implementation agendas with action plans and schedules, initial launch planning, international outreach, applicant pipeline, positioning at the highest international standards, annual international promotion strategies requiring APCI director approval, foreign direct investment attraction strategies, implementation programs, guidance, and APCI training, online application and evaluation system with multi-level due diligence, government facilities and resources utilization plans, financial projections, revenue, costs, application volumes, ad hoc support tasks throughout contract execution.
- 12:07SPEAKER_00: APCI starts without existing infrastructure.
- 12:11SPEAKER_00: The Ministry of Economy resolution establishing the procurement notes that APCI is not yet constituted and does not have a formal structure or appointed head.
- 12:23SPEAKER_00: The winning consultancy will define early processes, build operational capacity, and transfer institutional competence over time.
- 12:33SPEAKER_00: This positions the contractor as an institutional architect rather than a mere operational vendor.
- 12:40SPEAKER_00: Bidders must provide cover letters, executive summaries, less than or equal to 3,000 words, addressing firm history, key personnel biographies, service descriptions, program outline, regulatory compliance, international networks, organizational profiles with corporate structure, and key personnel, CVS, certified experience documentation, financial solvency reports, management plans with timelines, proposed services descriptions, financial impact assessments with investment projections and applicant fee proposals, guarantee structure protects government interests, and bid bond five percent of total offer waived for contracts below 1,000 modulos, approximately forty million Argentine pesos.
- 13:32SPEAKER_00: Challenge bond is three percent of challenge line item under the general regime for open purchase order contracts, ordin de compra bieta.
- 13:42SPEAKER_00: This procurement does not require a separate performance guarantee beyond the bid and challenge guarantees.
- 13:49SPEAKER_00: All guarantees must carry US dollar denomination.
- 13:54SPEAKER_00: The tender explicitly allows confirmation of offers up to the moment of opening, explaining why both timestamps match.
- 14:02SPEAKER_00: The payment exclusion clause creates a hybrid ecosystem by design rather than accident.
- 14:08SPEAKER_00: Argentina structures the contract to prevent gatekeeping while ensuring professional operation.
- 14:14SPEAKER_00: The winning consultancy becomes the program's technical and operational backbone.
- 14:19SPEAKER_00: Processing all applications, whether from certified agents or self-sourced, the contractor operates the evaluation system and issues recommendation reports to APCI.
- 14:32SPEAKER_00: This positions the master operator as an infrastructure provider rather than a market monopolist.
- 14:38SPEAKER_00: The government pays the contractor only for applications that independent agents submit.
- 14:44SPEAKER_00: This payment structure forces ecosystem development.
- 14:48SPEAKER_00: The tender presumes a future certification system governing agent registration, though specific requirements remain undefined.
- 14:56SPEAKER_00: Investment migration consultancies will likely need certification to submit applications through the official channel.
- 15:04SPEAKER_00: Certification frameworks may establish due diligence requirements for agents, code of conduct standards, marketing compliance rules, application submission protocols, annual recertification processes, and early mover advantages.
- 15:19SPEAKER_00: A PCI starts without existing infrastructure or appointed leadership.
- 15:24SPEAKER_00: The winning consultancy will define initial processes, establish operational standards, and shape agent relationships during the critical first two years.
- 15:34SPEAKER_00: The tender permits the consultancy to charge investors directly for processing and due diligence.
- 15:42SPEAKER_00: This creates pricing flexibility independent of government fee structures.
- 15:47SPEAKER_00: Master operators can design tiered service levels, expedited processing options, or premium advisory packages while maintaining baseline compliance with APCI requirements.
- 16:00SPEAKER_00: Business plan evaluation emphasizes alignment with national development goals and real economy impact.
- 16:07SPEAKER_00: Based on tender language emphasizing economic development, likely eligible areas could include agribusiness, renewable energy, mining, technology, tourism infrastructure, industrial capacity, job creation pathways, and knowledge economy investments.
- 16:24SPEAKER_00: Real estate may qualify only as part of productive investment projects, though the tender does not explicitly enumerate sectors.
- 16:32SPEAKER_00: The 6040 technical economic weighting prioritizes expertise over cost minimization.
- 16:39SPEAKER_00: This evaluation structure appears to favor established firms with proven governmental relationships and legislative drafting experience, volume-based termination rights and milestone deadline penalties introduce enforcement mechanisms absent from most citizenship programs.
- 16:57SPEAKER_00: Investment migration consultancies must deliver applications, not just design programs.
- 17:03SPEAKER_00: The 200 approval threshold by month 24 suggests government expectations of roughly 100 applications annually during the initial years.
- 17:13SPEAKER_00: The absence of legally established thresholds creates strategic flexibility but also uncertainty.
- 17:20SPEAKER_00: Investment migration consultancies cannot market specific figures until the winning contractor finalizes program design with APCI approval.
- 17:30SPEAKER_00: Industry speculation has centered on figures around$500,000, but these remain unconfirmed projections rather than binding policy.
- 17:39SPEAKER_00: The winning consultancy could propose lower thresholds$300,000 to$400,000, higher amounts$600,000 to$750,000, or multi-tier structures with varying minimums across investment categories.
- 17:55SPEAKER_00: Contractors face competing incentives between government paid applications from certified agents and higher margin self-sourced cases.
- 18:05SPEAKER_00: The payment structure mitigates this tension by prohibiting government compensation for consultant sourced applications.
- 18:13SPEAKER_00: This alignment encourages ecosystem development while protecting direct investor relationships.
- 18:19SPEAKER_00: The tender contains no explicit geographic or nationality restrictions, which suggests potential universal program eligibility, subject to due diligence.
- 18:31SPEAKER_00: Anti-money laundering compliance, source of funds verification, and reputational screening could determine individual eligibility rather than categorical exclusions.
- 18:43SPEAKER_00: The ninety-day offer validity period, auto renewable unless providers object ten days before expiration, allows extended evaluation.
- 18:53SPEAKER_00: Contract awards may not occur until April or May 2026.
- 18:59SPEAKER_00: Full operational capacity within six months of contract start could place program launch in late 2026 or early 2027.
- 19:12SPEAKER_00: This episode first appeared as an article by Ahmad Abbas on IMIDAily.com.
- 19:18SPEAKER_00: Subscribe for free to the IMI newsletter for breaking news and updates from the investment migration industry, and upgrade your membership to IMI Pro to get access to our exclusive professional community, citizenship catalogue, investment migration company Rollodex, private briefings, and more members only content.