Caribbean citizenship by investment programs have come under increasing scrutiny from both the United States and the European Union, amid rising global efforts to strengthen border security and improve identity and passport governance. However, despite these recent developments from two global powers, Caribbean CBI programs continue to prove their legitimacy and stability, backed by internal reforms and regional efforts to enhance transparency and accountability.
The U.S.: Encouraging Compliance, Not Imposing Sanctions
In June 2025, the U.S. Department of State issued a policy memo addressing 36 countries, including four Caribbean nations known for their CBI programs: Antigua and Barbuda, Dominica, Saint Kitts and Nevis, and Saint Lucia.
The memo raised concerns regarding document credibility, visa overstay rates, and limited deportation cooperation.
What Does the U.S. Memo Actually State?
- Not a ban: The memo does not impose sanctions. Instead, it grants a 60-day window for countries to enhance their procedures.
- Specific requirements: These include improving data sharing, updating identity verification protocols, and restricting access for high-risk nationalities.
- Proactive reforms underway: Several Caribbean governments have introduced in-person interviews, strengthened security checks, and restricted applications from certain nationalities.
The European Union: Legislative Amendments Pending – Not Yet Enforced
The EU is nearing finalization of amendments to its visa waiver suspension mechanism, which could affect some countries in the future if compliance standards are not met.
Key Elements of the EU Revisions:
- Expanded assessment criteria: These include monitoring countries with a 30% increase in asylum applications or an approval rate below 20%.
- Focus on CBI programs: Particularly those that do not require residency or a genuine connection to the issuing country.
- No restrictions imposed yet: To date, no Caribbean country has lost visa-free access to the Schengen Area.
The revised mechanism is expected to be enacted by late 2025, following its publication in the EU’s official journal.
Regional Coordination: Establishing a Unified CBI Oversight Authority
In a landmark regional step, five Eastern Caribbean Currency Union (ECCU) countries are revising their legislation to establish a regional regulatory body for citizenship by investment programs. This initiative aims to unify standards and strengthen institutional governance.
Proposed Responsibilities of the New Authority:
- Develop a shared regulatory framework and unified policies.
- Review and accredit due diligence and security vetting protocols.
- Create a public application registry and prevent abuse or manipulation of the programs.
Caribbean CBI Programs: A Legal and Stable Investment Option
Despite international scrutiny, Caribbean CBI programs remain among the most flexible, legal, and effective tools for acquiring second citizenship.
Ongoing reforms by participating countries and their cooperation with international stakeholders are reinforcing these programs’ credibility and long-term viability.
