An article for IMGW News authored by Dr Sirous Motevassel, PhD in International Law.
Takeaways from this article:
- The United States has issued a 60-day compliance notice to several Caribbean CBI countries. This is not a visa ban but a request for cooperation on documentation and data-sharing.
- The European Union is preparing new rules under its visa suspension mechanism. These will not take effect before late 2025.
- Caribbean governments have introduced stronger due diligence procedures, including in-person interviews and enhanced background checks.
- A regional regulator for Citizenship-by-Investment is being established to harmonise standards and improve oversight.
- No Caribbean country has lost visa-free access to the EU. With continued reform, the programmes remain credible and viable.
The Caribbean Citizenship-by-Investment (CBI) sector is once again in the international spotlight. This follows recent policy signals from the United States and the European Union, both of which have advanced new frameworks with implications for mobility, identity governance and cross-border security. As someone with over two decades of experience in international law and the investment migration field, I believe it is important to present a clear and reasoned analysis of what these developments mean in practice.
The United States: Emphasis on Compliance, Not Punishment
In June 2025, the US State Department issued a policy memorandum identifying 36 countries, including Antigua and Barbuda, Dominica, Saint Kitts and Nevis, and Saint Lucia. The document linked these states’ CBI programmes to perceived risks involving document integrity, visa overstays and lack of deportation cooperation¹².
The directive does not constitute a ban. It provides a 60-day window for remediation. Many Caribbean governments have already implemented improvements, working with US partners to strengthen identity vetting and limit access from high-risk jurisdictions.
Key Points:
- Scope of Action: The 60-day window seeks improvements in document security, data exchange and migration control¹.
- Targeted Concerns: The US has criticised the sale of citizenship without residency, weak document safeguards and low enforcement capacity on removals¹².
- Ongoing Reforms: Caribbean states now require in-person interviews, conduct enhanced background checks and have restricted applications from select countries¹².
The precise implications for visa categories are yet to be detailed, but the overall direction of US policy is clear. Governments must continue to demonstrate regulatory maturity and operational transparency.
The European Union: Legislative Reform in Motion
The EU, meanwhile, is nearing the final stages of revising its visa suspension mechanism. These amendments, expected to take effect in late 2025, would expand the criteria for suspending visa-free access. Among the triggers are increased asylum applications, a low recognition rate and programmes that grant nationality without substantial ties to the host state³⁴.
Key Provisions:
- Lowered Thresholds: A 30 percent increase in asylum claims, or fewer than 20 per cent approvals, may now trigger review³.
- Targeted Suspensions: Measures may apply to specific groups, such as public officials or high-net-worth individuals³.
- Focus on CBI: The EU is paying close attention to states that grant passports without a meaningful connection between the applicant and the country³⁴.
No Caribbean country has lost Schengen access. However, the EU Parliament and Council have provisionally agreed to the changes, which will enter into force 20 days after publication in the Official Journal³. Regional actors must remain alert and aligned with evolving European standards.
Regional Response: Strengthening Oversight
In a significant policy step, the five Eastern Caribbean Currency Union (ECCU) countries have reviewed legislation to establish a regional CBI regulator⁵. This body will standardise practices, improve public accountability and reduce reputational risk.
Regulatory Functions:
- Issuing regional policy and licensing frameworks
- Approving due diligence protocols and auditing national units
- Maintaining a public register and deterring malpractice⁵⁶
This collaborative initiative reflects a deepening commitment to governance and institutional integrity.
Despite renewed external scrutiny, Caribbean Citizenship-by-Investment remains a lawful, strategic and carefully managed channel for attracting capital and strengthening small economies. The region’s reforms, regulatory cooperation and international engagement speak to a sector willing to adapt to international expectations. Investors should retain confidence in the credibility and continuity of the Caribbean CBI.
References
¹ https://www.imidaily.com/north-america/us-includes-seven-cbi-countries-in-travel-ban-memorandum/
² https://www.travelandtourworld.com/news/article/us-set-to-expand-additional-travel-restrictions-on-seven-countries-including-antigua-barbuda-dominica-saint-kitts-and-nevis-saint-lucia-and-other-nations-with-citizenship-by-investment-programs/
³ https://www.imidaily.com/europe/eu-set-to-finalize-visa-free-suspension-mechanism-for-cbi-countries/
⁴ https://unitedpacstlucia.com/eu-visa-free-travel-suspension-caribbean-cbi/
⁵ https://www.sknis.gov.kn/2025/05/14/bill-to-establish-regional-citizenship-by-investment-regulator-reviewed-at-eccu-legal-meeting-in-anguilla/
⁶ https://www.migrateworld.com/en/blog/post/caribbean-countries-establish-interim-regulatory-commission-for-cbi/
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