Citizenship by Investment (CBI) programs have increasingly emerged as pivotal economic instruments for countries seeking to diversify their revenue streams and attract foreign capital. While Caribbean nations such as Antigua and Barbuda, Dominica, Grenada, Saint Kitts & Nevis and Saint Lucia have long been recognized as most popular and the highest number of application in this field, a growing number of countries, including Egypt, Jordan, Cambodia, and Pacific island states of Vanuatu and Nauru, are now actively leveraging similar models. Even Montenegro, a former player in the investment migration market, is rumoured to be considering reopening its CBI.
Yet, amid rising geopolitical tensions, heightened security imperatives and intensifying scrutiny from Western governments, the global future of CBI programs faces considerable uncertainty. Recent diplomatic pressures, legal challenges and policy realignments suggest that the landscape of investor citizenship is undergoing a profound transformation. The continued viability of these programs will depend on their ability to evolve, convincingly, transparently, and in alignment with the expectations of key global actors, the United States, the United Kingdom, and the European Union.
The US perspective
From the United States’ vantage point, concerns over Caribbean CBI programs heightened sharply in June 2025, though early warning signs had already emerged earlier in the year. A leaked memorandum, attributed to Secretary of State Marco Rubio, identified four Caribbean CBI jurisdictions—Antigua & Barbuda, Dominica, Saint Kitts & Nevis, and Saint Lucia—among 36 countries potentially facing US travel restrictions.
Grenada’s exclusion from the list is particularly noteworthy. As the only Caribbean nation with an active E-2 investor treaty with the US, its omission may reflect strategic differentiation by American policymakers, possibly acknowledging special US interests in Grenada or closer diplomatic alignment!
The memo grants affected governments a 60-day window to meet newly established benchmarks, including the submission of initial action plans outlining how they intend to comply. Chief among the concerns raised is the sale of citizenship without a residency requirement, a feature that has long been criticized as a security vulnerability. The document also alludes to alleged instances of anti-American activity involving nationals from some of the listed countries.
Moreover, the memo implies that countries willing to adopt cooperative migration measures, such as accepting third-country nationals deported from the US or entering into a “safe third country” agreement, could mitigate some of Washington’s reservations.
The scope of the list extends beyond the Caribbean, including 25 African countries and several states in Central Asia and the Pacific, many of which, such as Vanuatu, Egypt and Cambodia, also operate investor citizenship programs.
While no formal demands have been publicly articulated, other plausible concerns include misuse of CBI passports for identity fraud (such as name changes), weak due diligence that enables money laundering or terrorist financing and the potential for fraudulent or irregular migration.
In response, Caribbean leaders have reiterated their commitment to reform. Prime minister Terrance Drew of St Kitts & Nevis confirmed that key changes will include a mandatory residency requirement and upgraded biometric verification. The reforms aim to align the program with international best practices, address global concerns about applicant ties to the country, and strengthen the program’s credibility. Drew emphasized that these changes are part of a long-term strategic roadmap, not a reactive measure, and reaffirmed his commitment to transparency, security and the national interest.
Meanwhile, Dominica’s prime minister Roosevelt Skerrit pledged swift legislative action and full diplomatic cooperation, stating, “We take the matter seriously… we are prepared to address the concerns raised by international partners through appropriate diplomatic and cooperative means”.
These island economies rely heavily on US access, not only for travel and commerce, but also for remittances, tourism, and financial services infrastructure. A formal addition to the US travel ban list could prove deeply destabilizing. Even the threat of visa restrictions has sparked public concern and an actual ban could have long-lasting socio-economic consequences, particularly in nations where CBI revenue represents a significant portion of GDP.
Furthermore, it’s essential to acknowledge that these issues did not emerge in isolation. Since early 2023, the five Eastern Caribbean nations with CBI schemes have engaged in a series of US–Caribbean roundtable discussions. These meetings led to the adoption of six principles covering collective denials, applicant interviews, financial intelligence checks, auditing, passport retrieval, and restrictions on certain nationalities.
Despite the gravity of Washington’s concerns, the response from Caribbean governments suggests that a path to resolution remains open. With pledged reforms, particularly around biometric screening, residency requirements and enhanced due diligence, it appears likely that these nations will succeed in appeasing immediate US demands and avoid formal placement on a travel ban list.
However, while these measures may provide short-term relief, they largely amount to stopgap solutions. Without deeper, structural reforms to address the systemic vulnerabilities inherent in fast-track CBI models, these efforts risk being viewed as reactive rather than transformative. For now, the issue may be temporarily defused, but Western expectations, particularly those of the US, are moving toward a more rigorous, transparent, and integrity-based framework for investment migration.
The UK perspective
The United Kingdom’s stance is emblematic of a broader trend toward stricter scrutiny of CBI programs. All Caribbean nations with CBI offerings are members of the Commonwealth and enjoy generous, visa-free access to the UK, a symbol of enduring trust. However, all that changed in July 2023, when the UK Home Office announced that Dominican passport holders would require visas due to “clear and evident abuse” of the country’s CBI scheme. The home secretary explicitly pointed to weak due diligence, name change provisions and a lack of residency conditions as key concerns. The remarkable fact is that Dominica was named alongside Vanuatu, which undeniably deserved much of the international critique due to its lax CBI regulations.
The backlash was swift and wide-ranging. According to updated figures, Dominica has revoked at least 68 citizenships tied to cases where individuals failed to disclose prior UK visa refusals. This effort is part of a broader diplomatic and regulatory push to restore trust with London. Dominican officials have also indicated that new reforms are expected in the coming weeks to address lingering concerns and enhance compliance with international standards. These actions and official statements demonstrate that the Dominican leadership is determined to regain visa-free access to the UK.
The Dominica case serves as a cautionary lesson for the region: visa-free access to the UK can no longer be presumed. Caribbean nations now face renewed pressure to ensure that their CBI programs adhere to global norms of transparency and integrity or risk exclusion from British travel privileges.
While the loss of UK visa-free access is not as economically or diplomatically devastating as a US travel ban, it still carries significant reputational and mobility costs. For British authorities, maintaining secure borders increasingly includes ensuring that Commonwealth partners uphold the integrity of their passport and immigration systems. In Dominica’s case, ongoing reforms and diplomatic engagement may yet reverse the UK’s 2023 decision. But the message is clear: former colonial ties and Commonwealth membership offer no immunity from enforcement if standards fall short.
The EU perspective
Unlike the somewhat opaque signals from Washington, the European Union has issued clear and sustained warnings regarding CBI programs, both within its borders and among partner nations.
The European Parliament has long criticized CBI and residency by investment (RBI) schemes. As early as 2014, MEPs condemned the “commodification of EU citizenship,” arguing that these schemes undermine core values such as sincere cooperation, fairness, and non-discrimination.
In March 2022, parliament advanced a resolution calling for a union-wide phase-out of CBI schemes by 2025, controlled through annual limits. Simultaneously, it urged the EU Commission to regulate RBI programs, including minimum stay requirements, transparent investment routes and enhanced vetting.
However, the most significant blow to Caribbean CBI programs came with the EU’s adoption of a revised Visa-Free Travel Suspension Mechanism, which explicitly lists “investor citizenship schemes” as grounds for suspending visa-free entry to the Schengen Area. Under this framework, the EU is empowered to unilaterally revoke Schengen access from any country whose CBI program is deemed to pose a threat to the Union’s security, migration management, or institutional integrity.
The case of Vanuatu illustrates the EU’s willingness to act on these powers. After years of warnings, the EU suspended Vanuatu’s visa-free travel in February 2023, citing inadequate due diligence and identity change provisions. A year later, in early 2024, the EU permanently removed Vanuatu from its visa-free list, the first such case on record. It established a precedent: CBI programs that fail to meet EU standards will face real and lasting consequences.
Another milestone was the Court of Justice of the European Union’s (CJEU) April 2025 ruling, targeting Malta’s CBI program. The court declared that offering citizenship in exchange for payment represents a “commercialization of the grant of nationality,” violating the principle of sincere cooperation and fundamentally undermining the EU legal order.
The ruling, which contradicted the Court’s Advocate General’s opinion, emphasized that citizenship must reflect a “genuine link” between the individual and the state, not be reduced to a transactional commodity.
Though Caribbean states are not EU members, the ruling casts a long shadow. The message is clear: CBI schemes that lack substantive residency, integration and robust vetting are incompatible with the values underpinning European visa policy. Investors attracted by visa-free access to Europe may find that benefit suspended if the EU deems a CBI program non-compliant. Furthermore, repeated EU critiques highlight concerns that CBI/RBI schemes pose money laundering, corruption and national security risks.
The message is clear: unless Caribbean CBI programs can demonstrate real residency, vetted integration and robust due diligence, they may face being penalized under EU visa rules.
Additionally, the EU’s historical hostility to CBI stems in part from past failures within its own borders. Both Cyprus and Malta—former proponents of European CBI schemes, have faced high-profile scandals tied to corruption and abuse. The Cyprus program became infamous after it granted citizenship to Malaysian financier Jho Low, accused of embezzling billions from the MDB fund,and later, after Al Jazeera broadcast its journalistic investigation “The Cyprus Papers”, exposing wrongdoings and abuse on behalf of high-ranking officials related to the Cyprus Investment Program. In Malta, journalist Daphne Caruana Galizia was assassinated while investigating corruption, including links to the country’s CBI program. Malta’s program itself was launched in 2014 under controversial circumstances, when the contract was awarded to Henley & Partners amid complaints from competing bidders. These cases have not only damaged the credibility of CBI within the EU but have also shaped Brussels’ increasingly rigid stance toward all such schemes.
The EU’s message to Caribbean nations is unequivocal: unless their CBI programs are overhauled to reflect the principles of transparency, genuine residency, and robust security, the threat of Schengen visa-free access being revoked remains very real. Europe has made clear that it will no longer accept ‘passport vending’, and recent legal and policy developments demonstrate that it now has both the tools and the resolve to act.
Looking ahead
In light of mounting international pressure, Caribbean nations can no longer rely on rhetorical commitments or cosmetic adjustments. Meaningful structural reform is urgently needed to preserve the livability of their CBI programs and protect their access to global mobility frameworks. One of the most credible models gaining traction among policy experts could be a three-stage citizenship process designed to align investment migration with the expectations of Western governments.
Stage A would begin with the granting of a residency permit, subject to rigorous due diligence, a visit, biometric screening and some degree of establishment in the territory. This phase ensures that only high-integrity applicants enter the system.
Stage B would introduce a substantive residency period, lasting up to one year or even more, during which applicants would be required to demonstrate genuine ties to the host country. These ties could take the form of physical presence, participation in economic or community initiatives and adherence to local norms and legal obligations. It is this middle stage that serves as the actual litmus test of the applicant’s commitment, offering both governments and international observers measurable indicators of integration and good faith.
Stage C, the final phase, would permit eligible residents to apply for full citizenship, provided all previous requirements have been met without exception. Current citizenship law could be modified to allow economic residents to apply for citizenship sooner than the currently mandated waiting period.
In summary, Caribbean CBI programs are emblematic of a broader global CBI landscape that now includes states as diverse as Egypt, Jordan, Cambodia and Pacific island nations of Vanuatu and Nauru. Although Jordan has issued over 500 CBI passports since 2018, it was notably not included in the June 2025 US travel ban memo. That absence suggests that Western scrutiny is not arbitrary, but rather focused on specific program weaknesses, chiefly a lack of residency, weak due diligence or inadequate cooperation on migration controls.
This reality reinforces a fundamental principle: the grant of citizenship remains a sovereign decision of nation-states. When there’s sufficient alignment between national interests and international trust, legal and legitimate pathways for visas, investment, or residency will always exist. But in realms as sensitive as national identity and mobility, perception and credibility are paramount.
Caribbean and other nations with CBI programs now face a pivotal choice. They can cling to fast-track, zero-residency models that may soon be out of step with international expectations, or they can embrace a phased, credibility-first model. A compelling three-stage process, requiring residency, integration, and finally citizenship, may strike the essential balance: preserving economic benefits while forging legitimacy through transparency, cooperatio and measurable public engagement.
If these programs evolve in line with international expectations, they may not only survive but also establish new global benchmarks for investment migration. However, failure to adapt could lead to consequences that go beyond economic setbacks, potentially resulting in reputational damage and diplomatic friction, as Western authorities intensify pressure through visa restrictions, financial regulations, and legal frameworks.
The future of CBI—whether in the Caribbean or elsewhere will be shaped not by the revenue it generates, but by the responsibility with which it is administered and the extent to which it aligns with global standards of integrity, national interest and collective security. Even a structured, phased model such as the proposed A, B, and C stages involving residency, integration, and eventual citizenship may not fully satisfy the expectations of Western policymakers. More ambitious and verifiable reforms will likely be necessary to restore long-term confidence.
Ultimately, transparency must become the cornerstone of any credible CBI framework. Programs must be designed and implemented not in the service of short-term private interests, but to reflect national priorities and long-term development goals. If this realignment is achieved, CBI can continue to serve as a legitimate and respected tool of sovereign economic strategy. If not, it risks becoming a casualty of growing geopolitical scrutiny and regulatory backlash.