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06. Choosing a host country

Chapter scope: which cooperating state should host the chartered floating village, judged on political economy as well as engineering, and how to negotiate with the winner. Shared assumptions are in 00-design-basis.md; the legal pathway is in 01 §7.3; the engineering site scores are in 03 §1.10. Governance indices are the World Bank's 2026 WGI release (2025 data, 0 to 100 scores) and Transparency International's CPI 2025. All URLs accessed November 2026.

Summary

  • Panama survives the test, narrowly, and not for the reasons the synthesis gave. On a weighted matrix of nine political-economy criteria plus the chapter 03 engineering score (30% weight), Panama scores 72, the UAE 71, Malaysia (Johor, a candidate added in this chapter) 70, Indonesia (Riau) 59 and the Maldives 57. The top three are within the error of the method; the gap to the rest is not.
  • The Riau Islands lose their engineering lead on politics. Riau is 5 points ahead of Panama on engineering and 21 points behind on political economy. Indonesia has no legal route to devolved civil law, its sea-space permit (KKPRL) cannot be transferred or mortgaged, its Constitutional Court has already struck down private coastal-water concessions, and the 2023 Rempang riots happened in the same free-trade zone. Indonesia only beats Panama if engineering carries more than about 80% of the weight.
  • Panama's real weakness is the instrument the study recommends. Panama's Supreme Court annulled two legislatively ratified concession "contract-laws" in 26 months: First Quantum's copper mine (November 2023) and CK Hutchison's canal ports (January 2026). Both fell on procedure (direct award without tender, missing Comptroller countersignature, inadequate public interest and consultation). A bespoke Host State Agreement passed as a contract-law would walk into the same trap.
  • The key instrument in Panama is therefore a framework statute, not a contract-law: a special marine economic area law modelled on Law 41 of 2004 (Panamá-Pacífico), creating an autonomous agency, a 75 to 99 year tenure that overrides the 20-year port-law cap, and a competitive award, with Comptroller countersignature, Escazú-standard consultation, Law 54 stability registration and treaty-protected structuring.
  • Timing matters. Panama plans a constituent assembly in 2027 and a new constitution from 1 January 2029. The recommended sequence is a pilot module under ordinary law (vessel registration plus a 20-year seabed concession) while the framework law waits for the new constitutional settlement.
  • Verdict: Amber. A credible host exists, but no candidate offers a durable, self-governing concession off the shelf.

1. Method

What is scored. Nine political-economy criteria (A to I, below) were scored 1 (poor) to 5 (good) from the evidence in Sections 3 to 9, then combined with chapter 03's engineering score. The scores are the author's judgement on cited evidence, not measurements. Weights reflect the study's own finding that "what kills seasteads is politics, insurance and money" (08 synthesis): durability of the deal carries the most weight.

Code Criterion Weight within political economy What a 5 looks like
A Legal hooks and tenure 15% Existing special-zone statute, sea-space tenure ≥ 75 years, floating structures recognised
B Durability of the deal 20% Record of honouring ratified concessions through changes of government; no annulments
C Governance quality 10% WGI rule of law and regulatory quality > 70; CPI > 60
D Political stability and security 10% WGI political stability > 75; no recent constitutional shocks or armed conflict
E Treaty and arbitration cover 10% ICSID member; investment treaty with ISDS covering US or UK investors
F Practicalities 10% Residence route for families, low tax, hard currency, banking, hospital, airport, labour
G Social licence 10% No customary or indigenous marine tenure at likely sites; low fishing conflict
H Geopolitics 5% Aligned with residents' home states; low sanctions and conflict exposure
I Civil-liberties fit 10% Residents can worship, speak, assemble and govern their own affairs freely

Engineering. Chapter 03 scores are used unchanged where they exist (Riau 85, Panama 80, North Malé 79, Tarawa 67, São Tomé 58). For candidates chapter 03 did not score, this chapter estimates a score on the same eight met-ocean criteria and weights; these are marked "est." and are judgements without an IBTrACS count. Base case: 70% political economy, 30% engineering. Section 10 tests other weights.

Governance data caveat. The 2026 WGI release reports absolute 0 to 100 scores rather than percentile ranks, and warns against using them as definitive investment criteria.1 Small states rest on few sources: Kiribati's rule-of-law score uses 7, the Maldives' 8, Panama's 13.2

2. The field

Candidate Status One-line reason
Panama (Bay of Panama, Pacific) Assessed in depth Dollarised maritime hub; cyclone-free Pacific coast
Indonesia (Riau Islands) Assessed in depth Best engineering site (chapter 03)
Maldives (North Malé Atoll) Assessed in depth Floating City precedent; SEZ Act
El Salvador Assessed Investor-friendly legislature, dollarised, Freedom Visa
Kiribati (Tarawa) Assessed briefly Best weather, weakest institutions
São Tomé and Príncipe Assessed briefly Cyclone-free, but no lagoon and piracy (chapter 03)
Malaysia (Johor) Added Same waters as Riau; new Johor-Singapore SEZ (2025) and a residency category tied to it
United Arab Emirates Added Only candidate with a statute on floating houses and an English common-law zone
Honduras Dropped Supreme Court declared the ZEDE framework unconstitutional in 2024 (01 §4.8)
Seychelles Dropped Parliament refused a 20-year Indian facility on Assumption Island in 2018 as a loss of sovereignty;3 a foreign self-governing enclave would meet the same objection
Sri Lanka Dropped Its Supreme Court held that even reclaimed Port City land is national territory under Parliament's full power;4 the Port City model gives economic, not governmental, autonomy
Palau Dropped On the EU list of non-cooperative tax jurisdictions (October 2026)5 and in the typhoon belt
French Polynesia, Tuvalu, Fiji, Vanuatu, Philippines Dropped Cyclone exposure fails the chapter 03 rule; Polynesia also has the 2018 precedent (02 §5.2)
Cabo Verde Dropped No sheltered lagoon on an exposed trade-wind coast (judgement)

3. Governance snapshot

Rule of law Political stability Regulatory quality Control of corruption Voice and accountability CPI 2025 ICSID member
Panama 53.6 69.9 53.4 36.8 66.5 33 Yes (1996)
Indonesia 54.4 52.7 57.3 37.7 54.7 34 Yes (1968)
Maldives 58.5 67.0 48.7 41.3 49.3 39 No
El Salvador 47.0 67.6 53.1 37.0 44.0 32 Yes (1984)
Kiribati 73.0 (7 sources) 87.5 48.3 54.0 76.7 not ranked No
São Tomé and Príncipe 51.2 75.2 39.3 50.6 61.3 45 Yes (2013)
Malaysia 65.4 71.6 67.3 59.4 55.8 52 Yes (1966)
UAE 67.6 80.1 75.7 71.3 38.1 69 Yes (1982)
Singapore (benchmark) 83.2 89.0 91.9 87.8 54.6 84 Yes

Sources: WGI 2026 update via the World Bank API;2 CPI 2025;6 ICSID/3 list of 16 August 2026.7 The UAE stability score is for 2025 and predates the 2026 Gulf shipping attacks (Section 9.2).

None of the three original front-runners is a governance standout. Panama, Indonesia and El Salvador sit within two CPI points of each other, below the global average of 42.6

4. Panama (Pacific side)

  • Constitutional limits. National territory, including the territorial sea, "may never be ceded, transferred or alienated, either temporarily or partially, to other States" (Art. 3). The territorial sea, its bed and subsoil belong to the State for public use and "may not be the object of private appropriation" (Art. 258). Concessions over waters must be "inspired by social welfare and public interest" (Art. 259). Retail trade is reserved for Panamanians (Art. 293).8 Consequences: sea-space can only ever be held by concession, never owned; the village shop and café need a Panamanian operator; and nothing may be framed as a cession to any state.
  • Special-zone precedent. Law 41 of 2004 created the Panamá-Pacífico Special Economic Area with its own "legal, fiscal, customs, labour, immigration and business" regime applying to residents and visitors, run by an autonomous state agency that must select developers by an international selection process (Arts 1, 2 and 41).9 It was amended by Law 66 of 2018.10 This is the closest existing template for a zone statute.
  • City of Knowledge. Decree-Law 6 of 1998 approved a contract between the State and a private foundation, transferring former Canal Zone property and granting tax exemptions for 25 years, renewable for further 25-year periods.11 It shows that Panama will contract with a foundation for a special-purpose enclave.
  • SEM regime. Law 41 of 2007 (Multinational Headquarters) grants five-year renewable staff visas that need no work permit.12 It is useful for staff and residents' companies, not for tenure.
  • Tenure caps. Maritime Authority (AMP) concessions run for at most 20 years, extendable once for up to the original term, and the AMP is not obliged to renew on the same terms (Law 56 of 2008, Art. 38).13 Public-private partnerships are capped at 30 years plus 10 and may only originate from the public sector (Law 93 of 2019, Arts 7 and 65); a 2026 reform bill would allow private initiatives and 40 plus 10 years, but is not law.14 Neither reaches the 75 to 99 years the study needs; only a special statute can.
  • Stability. Law 54 of 1998 freezes the legal, national tax, customs and labour regime for 10 years for registered investments of at least US$2m, "save for reasons of public utility or social interest".15 Useful as a layer, too short and too qualified to carry the project alone.
  • Floating homes as vessels. Any person, without nationality or domicile requirements, may register a vessel in Panama (Law 57 of 2008, Art. 3).16 Ocean Builders reports that its SeaPod gained "full legal approval as a houseboat vessel" (company claim, not independently verified); its pods are on the Caribbean coast near Puerto Lindo, not the Pacific.17 Vessel status is a practical route for a pilot module, but it brings flag-state safety rules and offers no self-government.

4.2 Governance and the court problem

Two Supreme Court rulings define the risk.

  1. Cobre Panamá (27 November 2023). The full court unanimously declared Law 406 of 2023, which approved First Quantum's 20-year mining concession, unconstitutional.18 The court held that "contract-laws" are administrative acts subject to the Constitution and to procurement, environmental and fiscal law; that the concession was directly awarded without the required public tender; and that it breached some 25 articles, including Arts 258, 259 and 266.19 It noted that a 2017 ruling had already found the same defects.20 The mine has been shut for nearly three years; claims against Panama total at least US$27bn, and a government commission recommended in September 2026 negotiating a self-financed closure conditional on all arbitrations being dropped.21
  2. Panama Ports Company (29 January 2026). The court declared Law 5 of 1997, its addenda and the 2021 extension of CK Hutchison's Balboa and Cristóbal concession unconstitutional.22 The extension had never been countersigned by the Comptroller General nor approved by the National Assembly, and the court held that "no concession exists".23 Within a month the ruling was gazetted, PPC's workers were removed and interim operation passed to other operators, including Maersk.24

The lesson is specific. Panama's courts do not strike concessions at random; they strike those that skipped competitive award, Comptroller countersignature, legislative approval or genuine public-interest justification. A seastead agreement that is directly negotiated, ratified as a contract-law and generous to foreigners would be exposed on all four counts.

Stability. The 2023 mining protests, the 2025 pension-reform protests (with a state of urgency, suspended guarantees and at least 376 arrests in Bocas del Toro)25 and a planned constituent assembly in 2027, with a new constitution intended to take effect on 1 January 2029,26 mean the constitutional ground will move during the concession's first years.

Treaty cover is strong. Panama is an ICSID member;7 the US-Panama Trade Promotion Agreement gives US investors ISDS under ICSID or UNCITRAL rules;27 and the 1983 UK-Panama BIT is in force with UNCITRAL arbitration.28 The Cobre Panamá claims show that treaty arbitration gives real leverage, and also, as with Próspera (01 §4.8), that it converts a lost concession into a damages claim rather than restoring it.

4.3 Practicalities

  • Money and tax. The US dollar circulates at par with the balboa. Income tax is territorial: foreign-source income is exempt for individuals and companies;29 from 2027 only foreign-source passive income of multinational-group entities without local substance is taxed at 15% (Law 526 of 2026).30
  • Banking reputation. Panama left the FATF grey list in October 2023 after a 2019 to 2023 listing (and an earlier 2014 to 2016 one).31 The EU removed it from its list of non-cooperative tax jurisdictions on 9 October 2026, but it stays on the monitored Annex II pending a 2027 review.5
  • Residence. The Friendly Nations route (51 countries) requires a local job, property of at least US$200,000, or a US$200,000 three-year deposit.32 The Qualified Investor route gives permanent residence for US$300,000 of first-sale property or US$500,000 of resale property (Executive Decree 17 of 2026).33 Judgement: a floating home registered as a vessel is unlikely to count as real property, so the deposit or employment routes are the safe ones; a legal opinion is needed.
  • Labour. The 2026 minimum wage for construction in the Panama City region is US$3.51 an hour, about US$730 a month for a 48-hour week.34
  • Logistics are scored 5/5 in chapter 03 (Panama City port, yards, Tocumen airport), with the penalties a high tsunami rating and a 6.7 m spring tide.

4.4 Social licence

  • Indigenous waters are mostly on the other coast. Guna Yala's Fundamental Law includes its islands, reefs and coastal sea on the Caribbean side and reserves all tourism there to Guna;35 foreign hotels on Guna islands in the 1960s were eventually burnt out or attacked.36 A Pacific site avoids comarca waters, which is a real point in Panama's favour over the Caribbean coast where Ocean Builders sits.
  • Fishers and conservation on the Pacific side. The Pearl Islands form a 168,771 ha Special Marine-Coastal Management Zone under Law 18 of 2007, created to protect the livelihoods of communities that depend on its resources.37 The Gulf of Panama is the country's most important fishing ground (per the zone's management plan).37 Siting should avoid the zone and its satellite areas.
  • Mobilisation capacity. The anti-mining movement brought down a ratified contract and the 2025 protests were partly about "the lack of free, prior and informed consultation" on extractive projects.25 Panama incorporated the Escazú Agreement on environmental participation by Law 125 of 2020, and the Cobre Panamá challengers relied on it.20
  • Likely framing. Panama's history with the Canal Zone makes "a foreign-run enclave on Panamanian water" a potent line, all the more after 2025's US pressure on the canal. Chapter 02's French Polynesia lesson applies directly: no site is named until consultation has begun.

4.5 Geopolitics

Panama let its Belt and Road agreement lapse in February 2025 after US Secretary of State Rubio warned of "measures" over Chinese influence near the canal.38 It is firmly in the US orbit, which suits American residents but also makes sovereignty a live domestic issue.

4.6 What Panama gets

Panama completed its first climate relocation in 2024, moving about 300 Guna families from Gardi Sugdub, and officials expect 63 coastal communities to need relocation in coming decades.39 A floating-housing demonstrator with open designs, a research partnership with the Smithsonian Tropical Research Institute (already surveying the Pearl Islands),40 AMP concession fees, Panamanian construction and operating jobs, and diversification after the mine closure is a coherent offer. The risk is the optics of wealthy foreigners afloat while Guna families move inland; the offer must lead with the public benefit.

Panama: Political economy 69/100; engineering 80; combined 72.

5. Indonesia (Riau Islands)

  • Special zones exist, but are economic only. Law 39 of 2009 lets a private company propose a Special Economic Zone (KEK) and run it, with tax, customs, land, licensing and immigration facilities; foreigners in a KEK can hold stay permits of up to 5 years at a time, 15 years in total.41 The Riau Islands already have three KEKs (Nongsa Digital Park, Batam Aero Technic, Galang Batang).42 Batam, Rempang and Galang form a free-trade zone for 70 years from 2007, run by BP Batam.43 None of these devolves civil or commercial law.
  • Sea-space permit. Any activity occupying sea space for 30 days or more needs a KKPRL (marine spatial-use conformity approval), issued via the OSS system and assessed against zoning plans.44 KKP's own technical guidance states that a KKPRL "cannot be transferred, cannot be assigned and cannot be used as security for debt", and that its validity follows the underlying business licence.45 Consequence: the tenure under the platform cannot be mortgaged or sold with the homes, which is a serious problem for residents' leaseholds and for any lender.
  • Constitutional limit. In 2010 the Constitutional Court struck down the HP-3 coastal-water concession rights of Law 27 of 2007, holding that handing coastal waters to private capital would displace traditional fishers and customary communities and breach Article 33's "economic democracy".46 A long-term exclusive sea-space right for foreigners is exactly what that ruling forbade.
  • Foreign tenure on land. Foreigners can hold hak pakai (right of use) for a house for 30 + 20 + 30 = 80 years over state land, and strata units only inside special and free-trade zones (Government Regulation 18 of 2021, Arts 49, 52, 71).47 At least 30% of any small island must stay under state control.48
  • Floating structures fall under "buildings and installations at sea" in the KKPRL process,45 not under a residential regime.

5.2 Governance, precedents and sovereignty sensitivity

  • Rempang (2023). In September 2023 about 1,000 people clashed with police outside BP Batam over the planned eviction of Rempang's 7,500 residents (Malay, Orang Laut and Orang Darat communities present since the 17th century) for a Chinese-backed glass and solar plant; 43 were arrested.49 The project dropped off the 2025 national strategic project list,50 and BP Batam still describes it as Batam's only national strategic project in September 2026.51 This is the free-trade-zone authority a Riau seastead would deal with.
  • Islands are a sovereignty issue. When four Anambas islands appeared on a foreign sales website in June 2025, ministers insisted islands cannot be sold, and the land minister said he suspected geopolitical motives.4852
  • Unrest. The August 2025 protests over lawmakers' perks spread to at least 32 of 38 provinces and were the worst violence in decades.53
  • Treaties. Indonesia began terminating its 60-plus BITs in 2014 (including those with the Netherlands, Singapore and China) after the Churchill Mining claim;545558 it has no BIT with the US.56 The EU-Indonesia Investment Protection Agreement, concluded in 2025, contains no ISDS.57 The ASEAN Comprehensive Investment Agreement still offers ISDS to ASEAN investors,58 so a Singapore holding company is the natural structure.

5.3 Practicalities, social licence, geopolitics and offer

The second-home visa needs Rp2bn (about US$120,000) of funds and allows 5 or 10 years;59 the investor golden visa needs US$350,000 (5 years) or US$700,000 (10 years) in bonds, listed shares or funds.60 In practice the hospital and airport would be Singapore's (chapter 03 puts Batam's shipyard zone about 20 km away), which is an engineering strength and a political weakness: a foreign enclave on the Singapore side of Indonesian waters invites the "Singapore's annex" frame. Indonesia joined BRICS as a full member in January 2025.61 The offer to Indonesia is real (Batam's yards would build the caissons; a demonstrator for an archipelago facing sea-level rise), but it does not answer the tenure, the court or the sovereignty problem.

Indonesia: Political economy 48/100; engineering 85; combined 59.

6. Maldives (North Malé Atoll)

The Special Economic Zones Act 2014 was not repealed; it was amended in November 2025.62 It overrides the Tourism, Land and Uninhabited Islands Acts for zone matters (s. 79), allows international arbitration clauses, grants "SEZ Residency" for the duration of a residential lease (s. 80), and lists, among incentives a developer may obtain by negotiation, land leases to foreign companies of 66 years plus a further 33 by supplementary agreement.63 The 2025 amendment created "sustainable townships" with a minimum investment of US$500m, 60% renewable energy and reduced income tax,64 three times this project's central cost. The Constitution, as amended in 2019, forbids foreign ownership of any territory and caps foreign leases at 99 years; the 2019 amendment reversed a 2015 change that had allowed foreign freehold for US$1bn reclamation projects, amid fears of Chinese military use.65 The Floating City developer describes a "legal framework and title deeds for the owners".66

6.2 Governance and precedents

  • Contracts cancelled by the next government. The Maldives cancelled GMR's 25-year Malé airport concession in 2012 after a change of government; a Singapore-seated UNCITRAL tribunal awarded about US$270m, paid in 2016.67 The award was honoured, but the concession was not.
  • Courts. In May 2025 Parliament removed two Supreme Court justices who had been hearing a challenge to anti-defection amendments protecting the President's supermajority; the UN raised "serious concerns" about judicial independence.68
  • Money. Fitch rated the sovereign CCC- in June 2026 after it repaid a US$500m sukuk using most of its reserves;69 Moody's upgraded it to Caa1 in October 2026 but expects debt above 100% of GDP.70
  • Treaties. The Maldives is not an ICSID member.7
  • Delivery. The Floating City's prototypes are afloat, but its architect said in 2026 the project had "slowed down" (01 §4.12; 03 §1.11).66

6.3 Practicalities, social licence and fit

There is no residence-by-investment law yet: the "Pearl Residence" scheme had no bill or published terms by October 2026, and Parliament rejected a motion to suspend it in August 2026.71 The existing corporate resident visa needs a US$250,000 five-year deposit or investment.72 Civil-liberties fit is the worst in the field: the Constitution makes Islam the state religion, citizens must be Muslim, non-Muslims may not worship publicly, and alcohol is sold to foreigners only on resort islands.73 India and China compete openly for influence: Indian troops were withdrawn in 2024,74 and India extended a US$565m credit line in 2025.75 The Maldives' motive (sea-level rise, housing) is the strongest in the field, but the Floating City already fills that niche.

Maldives: Political economy 48/100; engineering 79; combined 57.

7. El Salvador

  • Legal hooks. A dollarised economy with a free-trade-zones law (reformed December 2025), a Special Regime for High-Value Investments (August 2025) and a Digital Assets Law (2023).76 No charter-city or sea-space concession law was found (unverified). "Bitcoin City", announced in 2021 near the Conchagua volcano, has had no groundbreaking.77
  • Durability. The governing party passed the IMF-required Bitcoin Law reform "minutes" after receiving it in January 2025, ending mandatory acceptance and tax payment in bitcoin, as a condition of a US$1.4bn IMF programme.7879 In July 2025 it approved indefinite presidential re-election and six-year terms in a single day.80 A legislature that can grant a charter overnight can revoke one overnight. The US State Department also reports a case in which criminal proceedings were used to revisit an arbitration already affirmed by a US court.76
  • Treaties. ICSID member and party to CAFTA-DR.76 In Pac Rim v El Salvador the CAFTA claims were dismissed under the denial-of-benefits clause because the claimant's US entity lacked substance, and the investor paid US$8m in costs.81 Treaty structuring must have real substance.
  • Residence. The Freedom Visa costs US$1m in bitcoin or USDT (not US$5m) for a fast-track passport, capped at 1,000 a year.82
  • Engineering (est. 53). The obvious sheltered water, the Gulf of Fonseca, had 15 tropical storms within 300 km in chapter 03's IBTrACS count and is shared with Honduras and Nicaragua.
  • Fit. Libertarian-friendly rhetoric, but a state of exception in force since March 2022;76 the "libertarians in a police state" frame is easy to write.

El Salvador: Political economy 54/100; engineering 53 (est.); combined 54.

8. Kiribati and São Tomé and Príncipe

  • Kiribati. Native land "shall not be alienated, whether by sale, gift, lease or otherwise" to non-natives, and non-native leases need ministerial approval and island-court confirmation, with further approval needed beyond 99 years or 10 acres.83 In 2022 the government suspended every superior-court judge after rulings against it.84 It switched recognition from Taiwan to China in 2019 and reopened the Phoenix Islands Protected Area to commercial fishing despite UNESCO's concern.8586 It is not an ICSID member.7 Best weather in chapter 03, weakest legal base here. Political economy 40; engineering 67; combined 48.
  • São Tomé and Príncipe. The president dismissed the prime minister and government by decree in January 2025, two years after a failed coup attempt.87 Reasonable CPI (45) and ICSID membership, but no lagoon and Gulf of Guinea piracy (chapter 03). Political economy 49; engineering 58; combined 52.

9. Candidates added during research

9.1 Malaysia (Johor)

Malaysia and Singapore signed the Johor-Singapore SEZ agreement on 7 January 2025, with 5% corporate tax for up to 15 years for qualifying activities and a 15% rate for knowledge workers;88 Forest City is a special financial zone inside it.89 MM2H residence has a dedicated SEZ/SFZ category with a 10-year renewable pass for a US$65,000 deposit (US$32,000 if aged 50 or over).90 Governance indices are better than Panama's (Section 3). Two warnings: in 2018 the then prime minister declared that foreigners would get no visas to live in Forest City because it was "built for foreigners, not built for Malaysians",91 and Forest City's 2014 reclamation began without the required environmental assessment and destroyed about 10 ha of seagrass, forcing a RM104m fishers' compensation fund.9293 Engineering is taken as equal to Riau (est. 85) because the Johor Strait shares its met-ocean setting. Malaysia's sea-space tenure law and capacity to devolve rules were not researched here and are the first Stage 0 gap. Political economy 64; engineering 85 (est.); combined 70.

9.2 United Arab Emirates

Dubai Law 3 of 2023 expressly empowers the Maritime Authority to "regulate the construction and use of floating houses, hotels, and structures" and register them as vessels;94 floating villas already sit off Dubai's World islands.95 Abu Dhabi Global Market applies English common law directly,96 which is the very model chapter 01 recommends. The 10-year golden residence needs AED 2m (about US$545,000) of property.97 Against that, the UAE scores lowest on voice and accountability (38), and in 2026 Gulf shipping, including ADNOC-operated vessels, has come under repeated attack, with the Joint Maritime Information Centre rating the threat "severe".9899 Engineering is estimated at 75 (very sheltered, but extreme water temperatures and the security criterion). Political economy 69; engineering 75 (est.); combined 71. If the Gulf conflict ends, the UAE moves to first place (Section 10); it fails the brief's libertarian purpose more than its engineering.

10. Scoring matrix

10.1 Scores

Criterion (weight in political economy) Panama UAE Malaysia Indonesia Maldives El Salvador São Tomé Kiribati
A Legal hooks and tenure (15%) 4 4 3 2 4 3 2 2
B Durability of the deal (20%) 2 4 2 2 2 2 2 1
C Governance quality (10%) 3 4 4 3 3 2 2 3
D Stability and security (10%) 3 2 4 2 2 3 3 3
E Treaty cover (10%) 5 4 4 3 2 4 3 1
F Practicalities (10%) 5 5 4 3 2 3 1 1
G Social licence (10%) 3 4 3 2 3 3 3 2
H Geopolitics (5%) 3 1 3 2 2 3 3 2
I Civil-liberties fit (10%) 4 1 3 3 1 2 4 4
Political economy (/100) 69 69 64 48 48 54 49 40
Engineering (/100, chapter 03 or est.) 80 75 est. 85 est. 85 79 53 est. 58 67
Combined, 70:30 (/100) 72.3 70.8 70.3 59.1 57.3 53.7 51.7 48.1

10.2 Sensitivity

Weighting scenario 1st 2nd 3rd Riau's rank
Base (30% engineering) Panama 72.3 UAE 70.8 Malaysia 70.3 4th
Politics only (0% engineering) Panama 69.0 (tie) UAE 69.0 Malaysia 64.0 6th (tie)
Engineering 50% Panama 74.5 (tie) Malaysia 74.5 UAE 72.0 4th
Engineering 70% Malaysia 78.7 Panama 76.7 Indonesia 73.9 3rd
Durability doubled (B = 40%) UAE 72.1 Panama 68.9 Malaysia 67.5 4th
Civil liberties tripled (I = 30%) Panama 73.6 Malaysia 69.8 UAE 65.1 4th
Practicalities tripled (F = 30%) Panama 75.9 UAE 74.4 Malaysia 72.2 4th
Equal political-economy weights Panama 73.8 Malaysia 72.2 UAE 67.6 4th
Ignore civil liberties and geopolitics UAE 76.9 Panama 71.8 Malaysia 70.8 5th
Gulf conflict ends (UAE D = 4, H = 3, engineering 81) UAE 76.8 Panama 72.3 Malaysia 70.3 4th
Another Panama annulment (Panama B = 1) UAE 70.8 Malaysia 70.3 Panama 69.5 4th

What the sensitivity shows.

  1. The winner does change under plausible weights: Malaysia if engineering carries more than 50% (it ties Panama at exactly 50%), the UAE if durability dominates or civil liberties are ignored. Panama wins outright in four of eleven scenarios, ties in two more, and is never below third.
  2. Indonesia never wins. Its 5-point engineering lead over Panama is outweighed by a 21-point political-economy deficit; the crossover is at roughly 81% engineering weight, by which point Malaysia, in the same waters, is ahead anyway.
  3. A one-point change on any 20%-weighted criterion moves a candidate by about 3 points. The top three should be treated as a tier, not a ranking.

11. Recommendation

Rank Host Combined score Role
1 Panama (Bay of Panama, Pacific side) 72 Lead negotiation
2 UAE (Abu Dhabi or Dubai) 71 Watch list: revisit if the Gulf conflict ends and founders accept limited civil liberties
3 Malaysia (Johor, JS-SEZ) 70 Parallel fallback: commission a Stage 0 legal opinion on sea-space tenure
4 Indonesia (Riau Islands) 59 Supplier, not host: build the caissons in Batam
5 Maldives (North Malé Atoll) 57 Not recommended for a libertarian community; possible partner for Floating City technology
6 El Salvador 54 Not recommended: cyclone-exposed and reversible-by-decree
7 São Tomé and Príncipe 52 Not recommended
8 Kiribati 48 Not recommended

Does Panama hold up? Yes, as first among near-equals, and on different grounds from the synthesis. The synthesis cited vessel approval, the ship registry, the dollar and cyclone-free water. Of these, the dollar and the weather stand; vessel approval is a company claim about a Caribbean site; and the registry is irrelevant to tenure. Panama's real advantages are territorial taxation, the strongest treaty cover in the field, an existing special-area statute to copy, a civil-liberties culture that suits the residents, and a Pacific coast largely free of indigenous marine tenure. Its real weakness, which the synthesis did not mention, is that its Supreme Court has twice voided ratified concessions of exactly the type chapter 01 recommends.

12. Negotiating strategy (Panama)

Step Months Action Purpose and evidence
0. Groundwork 0 to 3 Opinions from Panamanian constitutional and procurement counsel on Arts 3, 258, 259, 266 and 293 and on Escazú duties; structure a US holding entity with real substance (TPA access) and a UK fallback Avoid the Cobre Panamá defects;19 avoid Pac Rim's denial-of-benefits loss81
1. Quiet approach 3 to 6 Brief the Ministry of Commerce and Industry (which runs the Law 54, SEM and Qualified Investor regimes), the Ministry of Economy and the AMP. Present a "floating climate-adaptation neighbourhood and marine research station", never a "country" Chapter 01: sovereignty language triggers enforcement
2. Partner institution 4 to 9 Seek a research partnership with the Smithsonian Tropical Research Institute and an operating relationship with the City of Knowledge Foundation, the precedent for a state contract with a foundation1140 Gives ministers a public-interest reason to defend the project (Art. 259)
3. Pilot under ordinary law 6 to 30 One module registered as a vessel (Law 57) on a 20-year AMP seabed concession;1316 Panamanian-operated shop and café (Art. 293) Proves insurability and comfort (Stage 1 of the synthesis) without needing new legislation before the 2027 to 2029 constitutional process26
4. Consultation 9 to 18 Escazú-standard process with Gulf of Panama fishers, Taboga and Pearl Islands communities and environmental NGOs; publish three candidate polygons outside the Las Perlas zone37 and choose only afterwards The French Polynesia lesson; the 2025 FPIC complaints25
5. Term sheet 15 to 20 Publish a non-binding term sheet (Section 13) Transparency is the Cobre Panamá court's central theme
6. Legislation 24 to 42 A framework law for a Special Marine Economic Area, modelled on Law 41 of 2004, passed with cross-party support, ideally after the new constitution is settled A statute of general application survives review better than a contract-law
7. Competitive award after 6 Agency runs an international selection (as Law 41 Art. 41 requires); the founders bid with their own pilot data; contract countersigned by the Comptroller; register under Law 54 Addresses the three procedural grounds of the 2023 and 2026 annulments

Judgement: Step 7 means the founders could lose the tender. That is the price of durability in Panama; the pilot's performance data and the founders' sunk design work are the best protection.

13. Draft term sheet (Panama, non-binding)

Clause Proposed term
Parties Republic of Panama, acting through the Special Marine Economic Area Agency created by the framework law, with AMP and the Ministry of Economy; and the concessionaire, a Panamanian company wholly owned by the project foundation through a US holding entity with real substance
Area About 10 ha of water (150 × 150 m platform, ~500 m attenuator, 12 moorings and a safety buffer, per 03 §3) in the Bay of Panama outside the Las Perlas management zone, plus a 1 ha shore-base lease; final polygon fixed after consultation
Term 75 years from first occupation, renewable once for 24 years (99 in total), overriding the Law 56 cap by express provision of the framework law; tenure assignable and mortgageable with Agency consent not unreasonably withheld
Jurisdiction split Panama retains: sovereignty, criminal law and policing, defence, foreign affairs, immigration and border control, AML/CFT supervision, tax on Panama-source income, environmental baseline, labour minimums. Agency and community: building and safety code (classification-society rules by reference), internal governance through the foundation, leases and residents' covenant (01 §7.3), utilities, marina and helideck operation, commercial arbitration of private disputes. No sovereignty claim of any kind (Art. 3)
Fees Annual sea-space fee at no less than the AMP seabed tariff for the area; a community benefit fund of 1% of construction cost plus 0.5% of annual operating cost; ordinary taxes on Panama-source commercial income; a golden share for the Agency with veto only over transfer of control
Local employment and procurement At least 70% of permanent staff Panamanian within 5 years, with a published training plan; Panamanian operators for retail; local procurement targets reported annually
Residence Fast-track residence category for owner-residents and dependants under the framework law; until then the Friendly Nations deposit route32
Environmental obligations Full environmental impact study and seabed survey before siting; no siting over coral or seagrass; treated wastewater to agreed standards with monitoring data published; decommissioning plan and bond
Public access Park, marina and café open to the public at agreed hours; research berths for Panamanian institutions
Stabilisation Fiscal regime, tenure and devolved rule-making frozen for the term; carve-outs for non-discriminatory health, safety, environmental and human-rights measures (01 §7.3); registration under Law 54 as an additional layer15
Dispute resolution 90 days' negotiation, then mediation, then ICSID arbitration (or UNCITRAL seated outside Panama); express preservation of US-Panama TPA and UK BIT rights2728
Exit and tow-away On termination for any cause other than the concessionaire's uncured default: right to disconnect and tow the platform away within 12 months, with Panama's right of first refusal to buy at independent valuation
Termination For cause (uncured safety, environmental or AML breach after notice); for public interest at any time with compensation at fair market value plus relocation cost; if any court invalidates the framework law or contract, this is treated as a public-interest termination with compensation; severability

Verdict

Overall: AMBER. A suitable host exists, but none offers a durable, self-governing sea-space concession off the shelf. Panama is the recommended lead (72/100), with Malaysia (Johor) as the parallel fallback and the UAE on a watch list; Riau's engineering lead does not survive the political-economy test.

Host Rating One-line reason
Panama (Pacific) Amber Best all-round, but its Supreme Court voids ratified concessions that skip tender, countersignature or consultation
Malaysia (Johor) Amber Excellent water and governance; tenure law unresearched; Forest City shows how quickly policy can turn
UAE Amber/Red Floating-house statute and common-law zone, but an active Gulf conflict and poor civil-liberties fit
Indonesia (Riau) Red as host, Green as builder Non-mortgageable sea permit, 2010 court ruling against private coastal rights, Rempang
Maldives Red for this brief Islamic constitution, judicial purge, not ICSID, CCC- sovereign
El Salvador, Kiribati, São Tomé Red Cyclones, institutions or logistics

Top five host-specific risks 1. Constitutional annulment in Panama (Cobre Panamá 2023, Panama Ports 2026). Mitigation: framework statute, competitive award, Comptroller countersignature, Escazú consultation, compensation-on-invalidation clause. 2. Constitutional change in Panama, 2027 to 2029. Mitigation: pilot under ordinary law; legislate after the new constitution settles. 3. Social-licence failure (Gulf of Panama fishers, environmental movement, "new Canal Zone" framing). Mitigation: consult before naming the site; benefit fund; public access; Panamanian operators. 4. Tenure shorter than the hull. Panama's AMP cap is 20 plus 20 years; Indonesia's KKPRL cannot be mortgaged. Mitigation: only a statute can deliver 75 to 99 years; do not commit Phase 1 capital before it exists. 5. Weak treaty structuring. Mitigation: a US entity with real substance (Pac Rim's lesson) and political-risk insurance; remember that arbitration compensates but does not restore.

References

  1. World Bank, "Worldwide Governance Indicators" (2026 update; methodology and usage advisory). https://www.worldbank.org/en/publication/worldwide-governance-indicators (accessed Nov 2026) ↩

  2. World Bank Data API, WGI source 3, indicators GOV_WGI_RL.SC, PV.SC, RQ.SC, CC.SC, VA.SC and RL.SR (number of sources), latest year 2025. Index: https://api.worldbank.org/v2/sources/3/indicators?format=json ; example query: https://api.worldbank.org/v2/country/PAN;IDN;MDV/indicator/GOV_WGI_RL.SC?source=3&format=json&mrv=1 (accessed Nov 2026) ↩↩

  3. The Indian Express (Reuters), "Seychelles parliament blocks planned Indian naval base on remote island", June 2018. https://indianexpress.com/article/world/seychelles-parliament-blocks-planned-indian-naval-base-on-remote-island-5228694/ (accessed Nov 2026) ↩

  4. Supreme Court of Sri Lanka, Determination on the Colombo Port City Economic Commission Bill, S.C.S.D. Nos. 04/2021 et al. https://www.parliament.lk/uploads/bills/gbills/scdet/6218.pdf (accessed Nov 2026) ↩

  5. Council of the EU, Economic and Financial Affairs Council, 9 October 2026 (Panama and Viet Nam removed from Annex I). https://www.consilium.europa.eu/en/meetings/ecofin/2026/10/09/ ; EY Global Tax News, "EU issues revised list of non-cooperative jurisdictions for tax purposes", October 2026. https://globaltaxnews.ey.com/news/2026-2170-eu-issues-revised-list-of-non-cooperative-jurisdictions-for-tax-purposes (accessed Nov 2026) ↩↩

  6. Transparency International, Corruption Perceptions Index 2025. https://www.transparency.org/en/cpi/2025 ; full report and scores: https://transparency.org.my/filemanager/files/shares/cpi%202025/CPI%202025%20full%20Report.pdf (accessed Nov 2026) ↩↩

  7. ICSID, List of Contracting States and Other Signatories of the Convention (ICSID/3), as of 16 August 2026. https://icsid.worldbank.org/sites/default/files/2026-08/2026_Aug16_ICSID3_ENG.pdf (accessed Nov 2026) ↩↩↩↩

  8. Constitute Project, Panama's Constitution of 1972 with Amendments through 2004, Arts 3, 258, 259, 266, 290, 291, 293. https://www.constituteproject.org/constitution/Panama_2004 ; Spanish text: https://constitucion.te.gob.pa/constitucion-vigente/ (accessed Nov 2026) ↩

  9. Ley 41 de 20 de julio de 2004, Área Económica Especial Panamá-Pacífico (MICI copy). https://www.mici.gob.pa/wp-content/uploads/2021/11/03-LEY-PP-L412004.pdf (accessed Nov 2026) ↩

  10. Agencia Panamá Pacífico, "Sobre nosotros" (Law 41 of 2004 and Law 66 of 2018). https://app.gob.pa/about-us (accessed Nov 2026) ↩

  11. Decreto Ley No. 6 de 10 de febrero de 1998, contract between the State and the Fundación Ciudad del Saber, clause five (25-year renewable fiscal benefits). https://logistics.gatech.pa/wp-content/uploads/2023/04/ley6_de1998_cds.pdf (accessed Nov 2026) ↩↩

  12. MICI, "SEM: ¿Qué es?". https://mici.gob.pa/sem-que-es/ ; Comisión SEM, Guía ejecutiva para las empresas SEM (visas without work permits). https://sem.gob.pa/wp-content/uploads/2022/05/GUIA-PARA-LAS-EMPRESAS-SEM-2021.pdf (accessed Nov 2026) ↩

  13. Ley 56 de 6 de agosto de 2008, General de Puertos, Art. 38 (AMP). https://www.amp.gob.pa/wp-content/uploads/2023/12/Ley-56-de-6-de-agosto-de2008-Ley-General-de-Puertos.pdf ; see also Procuraduría de la Administración, opinion C-172-22 on a 20-year seabed concession. https://vocc.procuraduria-admon.gob.pa/sites/default/files/C-172-22%20AMP_0.pdf (accessed Nov 2026) ↩↩

  14. Ley 93 de 19 de septiembre de 2019 (APP), Arts 7 and 65, Gaceta Oficial 28864-B. https://www.gacetaoficial.gob.pa/storage/gacetas/2019/09/28864_B/GacetaNo_28864b_20190919.pdf ; Financiero News, "Reforma APP abre la puerta a proyectos privados, amplía contratos hasta 50 años", 2026. https://www.financieronews.com/post/reforma-app-abre-la-puerta-a-proyectos-privados-ampl%C3%ADa-contratos-hasta-50-a%C3%B1os-e-incorpora-a-idaan (accessed Nov 2026) ↩

  15. Ley 54 de 22 de julio de 1998, Estabilidad Jurídica de las Inversiones, Arts 10 and 16. https://mici.gob.pa/wp-content/uploads/2021/09/01-ley-54-espanol.pdf (accessed Nov 2026) ↩↩

  16. Ley 57 de 6 de agosto de 2008, General de Marina Mercante, Arts 1 to 4 (bilingual text, AMP). https://www.amp.gob.pa/wp-content/uploads/2025/06/Ley-57-de-6-de-agosto-de-2008-Espanol-e-Ingles.pdf (accessed Nov 2026) ↩↩

  17. Ocean Builders, "Why are we moving Alpha Blue from the marina?" (company claim). https://oceanbuilders.com/blog/why-are-we-moving-alpha-blue-from-the-marina/ ; Ocean Builders, "Panama's Caribbean Coast: The SeaPod Advantage", 2 September 2025. https://oceanbuilders.com/blog/panamas-caribbean-coast-the-seapod-advantage/ (accessed Nov 2026) ↩

  18. Órgano Judicial, "CSJ declara inconstitucional la Ley 406 de 20 de octubre de 2023", 28 November 2023. https://www.organojudicial.gob.pa/noticias/judiciales/CSJ-declara-inconstitucional-la-Ley-406-de-20-de-octubre-de-2023 ; Reuters, "Panama president directs First Quantum to shut copper mine after court ruling", 28 November 2023. https://www.reuters.com/markets/commodities/top-panama-court-rules-first-quantum-mining-contract-unconstitutional-2023-11-28/ (accessed Nov 2026) ↩

  19. BDO Panamá, "Se declara inconstitucional el contrato de concesión de Minera Panamá, S.A." (summary of the judgment, including the articles held breached). https://www.bdo.com.pa/getattachment/276a18e4-c525-4ede-9b34-ba9ea13d62a1/Se-declara-Inconstitucional-el-Contrato-de-Concesion-de-Minera-Panama,-S-A-(1).pdf?lang=es-PA (accessed Nov 2026) ↩↩

  20. La Estrella de Panamá, "Las razones por las que el contrato Ley 406 es inconstitucional". https://www.laestrella.com.pa/panama/nacional/razones-contrato-ley-406-inconstitucional-GMLE502712 ; judgment text (Callejas claim, Escazú/Ley 125 arguments): https://revistas.usma.ac.pa/ojs/index.php/IEP/article/download/382/594/1084 (accessed Nov 2026) ↩↩

  21. Interministerial Commission (Panama), Final Report on Cobre Panamá, September 2026 (English translation hosted by First Quantum). https://www.first-quantum.com/wp-content/uploads/2026/10/Interministerial_Commission_Final_Report_Eng.pdf ; France 24 (AFP), "Panama ministers push for reopening of huge open-pit copper mine", 30 September 2026. https://www.france24.com/en/live-news/20260930-panama-ministers-push-for-reopening-of-huge-open-pit-copper-mine (accessed Nov 2026) ↩

  22. Corte Suprema de Justicia, "Comunicado Pleno de la CSJ 29 de enero de 2026". https://www.organojudicial.gob.pa/uploads/blogs.dir/1/2026/01/426/comunicado-pleno-de-la-csj-29-de-enero-de-2026-1.pdf ; Reuters, "Panama court quashes CK Hutchison port contracts, clouding sales plan", 30 January 2026. https://www.reuters.com/world/asia-pacific/panama-court-voids-ck-hutchison-port-contracts-2026-01-30/ (accessed Nov 2026) ↩

  23. La Prensa (Panamá), "'No existe concesión', sentencia la Corte en el fallo que declaró inconstitucional el contrato de PPC", 2026. https://www.prensa.com/judiciales/no-existe-concesion-sentencia-la-corte-en-el-fallo-que-declaro-inconstitucional-el-contrato-de-ppc/ (accessed Nov 2026) ↩

  24. Reuters, "CK Hutchison says Panama Canal port workers removed after court-ordered takeover", 23 February 2026. https://www.reuters.com/business/autos-transportation/panama-officially-scraps-ck-hutchison-contracts-handing-canal-ports-maersk-2026-02-23/ (accessed Nov 2026) ↩

  25. Inter-American Commission on Human Rights, press release 138/25 on Law 462 protests and the Bocas del Toro state of emergency, 2025. https://www.oas.org/en/iachr/jsForm/?File=%2Fen%2Fiachr%2Fmedia_center%2Fpreleases%2F2025%2F138.asp ; Reuters, "Panama temporarily suspends some constitutional guarantees in protest-rocked province", 20 June 2025. https://www.reuters.com/world/americas/panama-temporarily-suspends-some-constitutional-guarantees-protest-rocked-2025-06-20/ (accessed Nov 2026) ↩↩↩

  26. Destino Panamá, "Propuesta de nueva Constitución deberá estar lista en 2028", September 2026. https://destinopanama.com.pa/2026/09/propuesta-de-nueva-constitucion-debera-estar-lista-en-2028/ (accessed Nov 2026) ↩↩

  27. USTR, United States-Panama Trade Promotion Agreement, Chapter Ten (Investment). https://www.ustr.gov/archive/assets/Trade_Agreements/Bilateral/Panama_FTA/Final_Text/asset_upload_file684_10351.pdf ; US Department of State, "U.S.-Panama TPA Investor-State Arbitrations". https://2021-2025.state.gov/u-s-panama-tpa-investor-state-arbitrations/ (accessed Nov 2026) ↩↩

  28. UNCTAD Investment Policy Hub, "Panama - United Kingdom BIT (1983)" (in force; ISDS under UNCITRAL). https://investmentpolicy.unctad.org/international-investment-agreements/treaties/bilateral-investment-treaties/2738/panama---united-kingdom-bit-1983- (accessed Nov 2026) ↩↩

  29. PwC Worldwide Tax Summaries, "Panama: Corporate - Income determination". https://taxsummaries.pwc.com/panama/corporate/income-determination (accessed Nov 2026) ↩

  30. BDO, "Panama: Exception to the territoriality regime: new economic substance rules for foreign-source passive income" (Law 526 of 28 May 2026). https://www.bdo.global/en-gb/insights/tax/world-wide-tax/panama-exception-to-the-territoriality-regime-new-economic-substance-rules-for-foreign-source-pas (accessed Nov 2026) ↩

  31. FATF, "Jurisdictions under Increased Monitoring - 27 October 2023". https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Increased-monitoring-october-2023.html ; Reuters, "Panama exits financial crime watchdog FATF's gray list", 27 October 2023. https://www.reuters.com/world/americas/panama-says-exits-financial-crime-watchdog-fatfs-gray-list-2023-10-27/ (accessed Nov 2026) ↩

  32. Friendly Nations Panama, "Friendly Nations Visa Laws: The Official Texts" (Executive Decrees 226 of 2021 and 16 of 2026; secondary source summarising the Servicio Nacional de Migración requirements). https://friendlynationspanama.com/laws/ (accessed Nov 2026) ↩↩

  33. Decreto Ejecutivo No. 17 de 8 de septiembre de 2026 (Inversionista Calificado), Gaceta Oficial 30613. https://www.migracion.gob.pa/wp-content/uploads/2026/09/Decreto-Ejecutivo-No.-17-de-8-9-2026.pdf ; MICI, "Inversionista Calificado". https://mici.gob.pa/inversionista-calificado/ (accessed Nov 2026) ↩

  34. La Prensa (Panamá), "Salario mínimo 2026 en Panamá: estas son las nuevas tarifas por actividad y región". https://www.prensa.com/economia/salario-minimo-2026-en-panama-estas-son-las-nuevas-tarifas-por-actividad-y-region/ (accessed Nov 2026) ↩

  35. Congreso General Guna, Gunayar Igardummadwala (Fundamental Law of Gunayala), 2013, Arts 4 and 52 to 56. https://www.gunayala.org.pa/Ley%20Fundamenta.Gunayala..pdf (accessed Nov 2026) ↩

  36. M. Martínez Mauri, "Navegantes, autoridades indígenas y turistas en Panamá", Letras Verdes 18 (2015). https://doi.org/10.17141/letrasverdes.18.2015.1655 (accessed Nov 2026) ↩

  37. Ley 18 de 31 de mayo de 2007, Zona Especial de Manejo Marino-Costera del Archipiélago de Las Perlas, Gaceta Oficial 25805. https://www.gacetaoficial.gob.pa/storage/gacetas/2007/06/25805/4735.pdf ; Louis Berger and ANCON, Informe Final del Plan de Manejo Marino Costero Integrado del Archipiélago de Las Perlas. http://hdl.handle.net/1834/8063 (accessed Nov 2026) ↩↩↩

  38. Reuters, "Rubio hails Panama's move to exit Chinese infrastructure plan", 3 February 2025. https://www.reuters.com/world/rubio-hails-panamas-move-exit-chinese-infrastructure-plan-2025-02-03/ ; PBS (AP), "Rubio presses Panama to reduce Chinese influence over its canal or face U.S. 'measures'". https://www.pbs.org/newshour/politics/rubio-presses-panama-to-reduce-chinese-influence-over-its-canal-or-face-u-s-measures (accessed Nov 2026) ↩

  39. AP, "Panama prepares to evacuate first island in face of rising sea levels", June 2024. https://apnews.com/article/panama-island-guna-climate-change-f368711649ff6986ea25a79534405a84 ; Human Rights Watch, "Panama Completes First Climate-Related Relocation", 29 May 2024. https://www.hrw.org/news/2024/05/29/panama-completes-first-climate-related-relocation (accessed Nov 2026) ↩

  40. Smithsonian Institution, "Smithsonian Coral Biodiversity Survey of Panama's Pearl Islands". https://www.si.edu/newsdesk/releases/smithsonian-coral-biodiversity-survey-panama-s-pearl-islands (accessed Nov 2026) ↩↩

  41. Undang-Undang No. 39 Tahun 2009 tentang Kawasan Ekonomi Khusus, Arts 26 and 36 to 40. https://peraturan.bpk.go.id/Download/43905/UU%20Nomor%2039%20Tahun%202009.pdf ; KEK National Council, "Incentives" (immigration and land facilities). https://kek.go.id/id/investment/incentive (accessed Nov 2026) ↩

  42. KEK National Council, "Pemerintah Tetapkan Dua KEK Baru di Batam", June 2021. https://kek.go.id/media/press/Pemerintah-Tetapkan-Dua-KEK-Baru-di-Batam-298 (accessed Nov 2026) ↩

  43. Peraturan Pemerintah No. 46 Tahun 2007 tentang Kawasan Perdagangan Bebas dan Pelabuhan Bebas Batam, Art. 1. https://peraturan.bpk.go.id/Download/37875/PP%2046%20Tahun%202007.pdf?embed=True ; PP No. 41 Tahun 2021 (KPBPB administration). https://peraturan.bpk.go.id/Details/161958/pp-no-41-tahun-2021 (accessed Nov 2026) ↩

  44. Ministry of Marine Affairs and Fisheries (KKP), "E-Sea Perizinan: Pelaksanaan KKPRL" (Permen KP 28/2021). https://e-sea.kkp.go.id/perizinan (accessed Nov 2026) ↩

  45. KKP, Keputusan Dirjen Pengelolaan Kelautan dan Ruang Laut No. 50 Tahun 2023, Pedoman Teknis Penyelenggaraan KKPRL, sections B, D and application requirements. https://ppid.kkp.go.id/media/uploads/document_regulation/Kepdirjen_PKRL_50_Tahun_2023_Pedoman_Teknis_Penyelenggaraan_KKPRL_1.pdf (accessed Nov 2026) ↩↩

  46. Mahkamah Konstitusi, Ikhtisar Putusan No. 3/PUU-VIII/2010 (HP-3). https://www.mkri.id/public/content/persidangan/sinopsis/ikhtisar_161_1450_Ikhtisar%20Putusan%20No.%203_PUU-VIII_2010_Jefri%20%283%29.pdf ; Antara, "MK: Hak Pengusahaan Perairan Pesisir Inkonstitusional". https://www.antaranews.com/berita/263376/mk-hak-pengusahaan-perairan-pesisir-inkonstitusional (accessed Nov 2026) ↩

  47. Peraturan Pemerintah No. 18 Tahun 2021, Arts 49, 52, 69 to 72. https://peraturan.bpk.go.id/Download/154522/PP%20Nomor%2018%20Tahun%202021.pdf (accessed Nov 2026) ↩

  48. KKP, "KKP Tegaskan Pulau Tidak Bisa Diperjualbelikan", 20 June 2025. https://kkp.go.id/djpk/kkp-tegaskan-pulau-tidak-bisa-diperjualbelikan-08P5/detail.html (accessed Nov 2026) ↩↩

  49. The Jakarta Post, "Police arrest 43 after riot over Rempang industrial park", 13 September 2023. https://www.thejakartapost.com/indonesia/2023/09/13/police-arrest-43-after-riot-over-rempang-industrial-park ; BenarNews, "Indonesian police arrest dozens protesting China-backed project near Singapore", 12 September 2023. https://www.benarnews.org/english/news/indonesian/police-arrest-dozens-protesting-china-project-09122023131541.html (accessed Nov 2026) ↩

  50. Tempo, "DPR Buktikan Proyek Rempang Eco City Tak Masuk Daftar 77 PSN Prabowo", April 2025. https://www.tempo.co/ekonomi/dpr-buktikan-proyek-rempang-eco-city-tak-masuk-daftar-77-psn-prabowo-1284270 (accessed Nov 2026) ↩

  51. Bisnis.com, "BP Batam: Rempang Eco City Satu-satunya Proyek Strategis Nasional di Batam", 7 September 2026. https://sumatra.bisnis.com/read/20260907/534/2002018/bp-batam-rempang-eco-city-satu-satunya-proyek-strategis-nasional-di-batam (accessed Nov 2026) ↩

  52. Antara, "No foreigners granted land ownership in islands: govt", June 2025. https://en.antaranews.com/news/363333/no-foreigners-granted-land-ownership-in-islands-govt (accessed Nov 2026) ↩

  53. Reuters, "Explainer: What's fuelling the rage in Indonesia?", 2 September 2025. https://www.reuters.com/world/asia-pacific/whats-fuelling-rage-indonesia-2025-09-02/ ; Reuters, "Deadly Indonesia protests force U-turn on lawmakers' perks", 31 August 2025. https://www.reuters.com/world/asia-pacific/deadly-indonesia-protests-force-u-turn-lawmakers-perks-2025-08-31/ (accessed Nov 2026) ↩

  54. Norton Rose Fulbright, "BIT by BIT in Indonesia". https://www.nortonrosefulbright.com/en/knowledge/publications/3214a3d6/bit-by-bit-in-indonesia (accessed Nov 2026) ↩

  55. ISDS Platform (IAReporter), "Indonesia ramps up termination of BITs". https://isds.bilaterals.org/indonesia-ramps-up-termination-of (accessed Nov 2026) ↩

  56. US Department of State, 2018 Investment Climate Statements: Indonesia. https://2021-2025.state.gov/reports/2018-investment-climate-statements/indonesia/ (accessed Nov 2026) ↩

  57. European Parliament, Legislative Train, "EU-Indonesia FTA" (IPA without ISDS). https://www.europarl.europa.eu/legislative-train/theme-a-global-europe-leveraging-our-power-and-partnerships/file-eu-indonesia-fta ; European Commission, "Key elements of the EU-Indonesia Trade Agreement and Investment Protection Agreement". https://policy.trade.ec.europa.eu/eu-trade-relationships-country-and-region/countries-and-regions/indonesia/eu-indonesia-agreements/key-elements-eu-indonesia-trade-agreement-and-investment-protection-agreement_en (accessed Nov 2026) ↩

  58. Clifford Chance, Reflections from the International Arbitration Group 2016 (Indonesia BIT terminations and the ASEAN Comprehensive Investment Agreement). https://www.cliffordchance.com/content/dam/cliffordchance/briefings/2016/04/reflections-from-the-international-arbitration-group.pdf (accessed Nov 2026) ↩↩

  59. Directorate General of Immigration, "Siaran Pers: Ditjen Imigrasi Resmi Luncurkan Aturan Second Home Visa", 25 October 2022. https://www.imigrasi.go.id/siaran_pers/2022/10/25/siaran-pers-ditjen-imigrasi-resmi-luncurkan-aturan-second-home-visa (accessed Nov 2026) ↩

  60. Directorate General of Immigration, Visa E28C (individual investor). https://www.imigrasi.go.id/wna/daftar-visa-indonesia/E28C (accessed Nov 2026) ↩

  61. Reuters, "Indonesia joins BRICS bloc as full member, Brazil says", 6 January 2025. https://www.reuters.com/world/indonesia-join-brics-bloc-full-member-brazil-says-2025-01-06/ (accessed Nov 2026) ↩

  62. Maldives Ministry of Economic Development and Trade, "Laws & Regulations" (SEZ Act 24/2014 and First Amendment 18/2025). https://trade.gov.mv/en/laws-and-regulations/ (accessed Nov 2026) ↩

  63. Special Economic Zones Act, Act 24/2014 (unofficial translation), ss. 79, 80 and Schedule of incentives. https://sez.gov.mv/wp-content/uploads/2024/08/SEZ-Act-en.pdf (accessed Nov 2026) ↩

  64. Invest Maldives, "President Dr. Mohamed Muizzu Ratifies Amendment to Special Economic Zone Act Enabling Sustainable Township Development", December 2025. https://investmaldives.gov.mv/president-dr-mohamed-muizzu-ratifies-amendment-to-special-economic-zone-act-enabling-sustainable-township-development/ (accessed Nov 2026) ↩

  65. The President's Office (Maldives), "President ratifies Fourth Amendment to the Constitution", 23 April 2019. https://presidency.gov.mv/Press/Article/21028 ; Reuters, "Maldives parliament repeals law allowing foreign land ownership", April 2019. https://www.reuters.com/article/world/asia-pacific/maldives-parliament-repeals-law-allowing-foreign-land-ownership-idUSKCN1RU0MW/ (accessed Nov 2026) ↩

  66. Newsweek, "A Mile-Long Ship for 80,000 People? Why Floating Cities Never Get Built", 2026 (interview with Koen Olthuis). https://www.newsweek.com/freedom-ship-why-floating-cities-never-get-built-12022797 (accessed Nov 2026) ↩↩

  67. Global Arbitration Review, "Maldives airport panel lands on quantum figure". https://globalarbitrationreview.com/article/maldives-airport-panel-lands-quantum-figure ; Observer Research Foundation, "Maldives: Govt pays up GMR". https://www.orfonline.org/expert-speak/maldives-govt-pays-up-gmr (accessed Nov 2026) ↩

  68. Al Jazeera, "Maldives parliament removes two Supreme Court judges", 14 May 2025. https://www.aljazeera.com/news/2025/5/14/maldives-parliament-removes-two-supreme-court-judges ; OHCHR, "Maldives: UN raises concerns over judicial independence", May 2025. https://www.ohchr.org/en/press-releases/2025/05/maldives-un-raises-concerns-over-judicial-independence (accessed Nov 2026) ↩

  69. Fitch Ratings, "Fitch Upgrades Maldives to 'CCC-'", 3 June 2026. http://www-origin.fitchratings.com/research/sovereigns/fitch-upgrades-maldives-to-ccc-03-06-2026 (accessed Nov 2026) ↩

  70. Moody's Ratings, "Moody's Ratings upgrades Maldives' ratings to Caa1 from Caa2", 8 October 2026. https://ratings.moodys.com/ratings-news/474658 (accessed Nov 2026) ↩

  71. Atoll Times, "Parliament votes down call to halt investor residency scheme", 18 August 2026. https://atolltimes.mv/post/news/16873 (accessed Nov 2026) ↩

  72. Maldives Immigration, "Resident Visa" (Corporate Resident Visa). https://www.immigration.gov.mv/visa/resident (accessed Nov 2026) ↩

  73. US Department of State, Maldives 2023 International Religious Freedom Report. https://www.state.gov/wp-content/uploads/2024/04/547499-MALDIVES-2023-INTERNATIONAL-RELIGIOUS-FREEDOM-REPORT.pdf (accessed Nov 2026) ↩

  74. BBC News, "Maldives: Indian troops to exit country as China gains foothold", March 2024. https://www.bbc.com/news/world-asia-india-68498232 (accessed Nov 2026) ↩

  75. Reuters, "Modi announces $565-million credit line for debt-plagued Maldives", 25 July 2025. https://www.reuters.com/world/china/modi-announces-565-million-credit-line-debt-plagued-maldives-2025-07-25/ (accessed Nov 2026) ↩

  76. US Department of State, 2026 Investment Climate Statements: El Salvador. https://www.state.gov/reports/2026-investment-climate-statements/el-salvador (accessed Nov 2026) ↩↩↩↩

  77. El Diario de Hoy, "¿Es una broma?: Aquí no hay rastros de Bitcoin City", 2025. https://www.eldiariodehoy.com/noticias/nacionales/es-una-broma-aqui-no-hay-rastros-de-bitcoin-city/31556/2025/ (accessed Nov 2026) ↩

  78. Reuters, "Lawmakers in El Salvador rush new bitcoin reform after IMF deal", 30 January 2025. https://www.reuters.com/world/americas/lawmakers-el-salvador-rush-new-bitcoin-reform-after-imf-deal-2025-01-30/ ; Decreto Legislativo No. 199 (Reformas a la Ley Bitcoin), 29 January 2025. https://www.jurisprudencia.gob.sv/DocumentosBoveda/R/2/2020-2029/2021/06/1080B6.HTML (accessed Nov 2026) ↩

  79. IMF, "IMF Executive Board Approves New 40-month US$1.4 billion Extended Fund Facility Arrangement for El Salvador", Press Release 25/043, 26 February 2025. https://www.imf.org/en/news/articles/2025/02/26/pr25043-el-salvador-imf-approves-new-40-month-us1-bn-eff-arr (accessed Nov 2026) ↩

  80. Reuters, "El Salvador scraps presidential term limits, opening door for another Bukele term", 31 July 2025. https://www.reuters.com/world/americas/el-salvador-scraps-presidential-term-limits-opening-door-another-bukele-term-2025-07-31/ ; IACHR, press release 156/25. https://www.oas.org/en/IACHR/jsForm/?File=%2Fen%2Fiachr%2Fmedia_center%2FPReleases%2F2025%2F156.asp (accessed Nov 2026) ↩

  81. IISD Investment Treaty News, "Pac Rim v. El Salvador: all claims dismissed; OceanaGold to pay US$8 million in costs", 13 March 2017. https://www.iisd.org/itn/2017/03/13/all-claims-dismissed-oceanagold-to-pay-usd-8-million-in-costs-pac-rim-cayman-llc-v-el-salvador-icsid-case-no-arb-09-12/ (accessed Nov 2026) ↩↩

  82. Government of El Salvador, "Adopting El Salvador: Freedom Passport" programme page. https://world.adoptingelsalvador.gob.sv/welcome (accessed Nov 2026) ↩

  83. Kiribati, Native Lands Ordinance (Cap. 61), ss. 5, 9, 10 and 12. https://www.melad.gov.ki/images/lmd/Legislation/CAP61_NATIVE_LANDS_.pdf ; FAOLEX copy: https://faolex.fao.org/docs/pdf/kir35345.pdf (accessed Nov 2026) ↩

  84. Lowy Institute, "The president vs the judge: How Kiribati came to a constitutional standoff". https://www.lowyinstitute.org/the-interpreter/president-vs-judge-how-kiribati-came-constitutional-standoff ; Reuters, "Kiribati suspends appeals court judges as constitutional crisis worsens", 6 September 2022. https://www.reuters.com/world/asia-pacific/kiribati-suspends-appeals-court-judges-constitutional-crisis-worsens-2022-09-06/ (accessed Nov 2026) ↩

  85. UNESCO World Heritage Centre, "UNESCO expresses concern over the lifting of fishing no-take zones in Kiribati's Phoenix Islands Protected Area". https://whc.unesco.org/en/news/2370 (accessed Nov 2026) ↩

  86. Reuters, "Kiribati says China-backed Pacific airstrip project for civilian use", 13 May 2021. https://www.reuters.com/world/asia-pacific/kiribati-says-china-backed-pacific-airstrip-project-civilian-use-2021-05-13/ (accessed Nov 2026) ↩

  87. Euronews, "São Tomé and Príncipe government dismissed by president", 7 January 2025. https://www.euronews.com/2025/01/07/sao-tome-and-principe-government-dismissed-by-president (accessed Nov 2026) ↩

  88. Ministry of Finance Malaysia, "JS-SEZ Incentive Package To Drive High-Value Investments Into Johor", 8 January 2025. https://www.mof.gov.my/portal/en/news/press-release/js-sez-incentive-package-to-drive-high-value-investments-into-johor ; Singapore EDB, "Agreement between Singapore and Malaysia and the Johor-Singapore Special Economic Zone". https://www.edb.gov.sg/en/corporate-news/agreement-between-singapore-and-malaysia-and-the-johor-singapore-special-economic-zone (accessed Nov 2026) ↩

  89. MIDA, Guidelines for Forest City Special Financial Zone (FCSFZ) Tax Incentive Package, 2025. https://www.mida.gov.my/wp-content/uploads/2025/04/Guideline-FCSFZ.pdf (accessed Nov 2026) ↩

  90. Ministry of Tourism, Arts and Culture Malaysia, "MM2H Category Overview". https://www.mm2h.gov.my/category/overview (accessed Nov 2026) ↩

  91. Reuters, "Malaysia says no to foreign homeowners in Forest City project", 27 August 2018. https://www.reuters.com/article/world/malaysia-says-no-to-foreign-homeowners-in-forest-city-project-idUSKCN1LC0WH/ ; The Star, "Dr M: Chinese nationals can buy Forest City units, but no residential visas", 4 September 2018. https://www.thestar.com.my/news/nation/2018/09/04/dr-m-chinese-nationals-can-buy-forest-city-units-but-no-residential-visas/ (accessed Nov 2026) ↩

  92. Mongabay, "Seagrass restoration in Malaysia finds multi-species approach boosts recovery", February 2026. https://news.mongabay.com/2026/02/seagrass-restoration-in-malaysia-finds-multi-species-approach-boosts-recovery/ (accessed Nov 2026) ↩

  93. MIT thesis on Forest City (fishers' compensation fund and stop-work order). https://dspace.mit.edu/bitstream/handle/1721.1/105036/959623436-MIT.pdf (accessed Nov 2026) ↩

  94. Government of Dubai, Law No. (3) of 2023 Concerning the Dubai Maritime Authority. https://dlp.dubai.gov.ae/Legislation%20Reference/2023/Law%20No.%20(3)%20of%202023%20Concerning%20the%20Dubai%20Maritime%20Authority.html (accessed Nov 2026) ↩

  95. The National, "Floating villas with coral gardens coming to Ras Al Khaimah", 14 June 2024. https://www.thenationalnews.com/lifestyle/home-garden/2024/06/14/ras-al-khaimah-property-floating-villas-kleindienst-group/ (accessed Nov 2026) ↩

  96. Abu Dhabi Global Market Courts, "English Common Law". https://www.adgm.com/adgm-courts/english-common-law (accessed Nov 2026) ↩

  97. Federal Authority for Identity, Citizenship, Customs and Port Security, "Golden Residency Guide". https://icp.gov.ae/en/services/uae-golden-residency/ (accessed Nov 2026) ↩

  98. Reuters, "Shipping slows through Strait of Hormuz after tanker attacks, data shows", 17 August 2026. https://www.reuters.com/world/middle-east/shipping-via-hormuz-strait-slows-after-tanker-attacks-data-shows-2026-08-16/ (accessed Nov 2026) ↩

  99. gCaptain, "New Wave of Attacks Hits Tankers and LNG Carrier in Strait of Hormuz and Persian Gulf", November 2026. https://gcaptain.com/new-wave-of-attacks-hits-tankers-and-lng-carrier-in-strait-of-hormuz-and-persian-gulf/ (accessed Nov 2026) ↩