CBI regulatory disclosure.
Current travel, visa-waiver, pricing and regulatory issues affecting Caribbean citizenship-by-investment programmes.
Citizenship-by-investment advice must be current. The value of a second citizenship depends not only on the statute that grants it, but also on the diplomatic, immigration and regulatory environment surrounding the issuing country.
This note records the principal regulatory issues Moore Law considers when advising on Caribbean citizenship-by-investment programmes, particularly Dominica and St Kitts and Nevis.
Last reviewed:
This page is a general regulatory note only. Programme rules, visa-waiver arrangements, government fees and eligibility requirements can change without notice.
Why this page matters.
Most CBI marketing presents the passport as a finished product: a number of visa-free destinations, a price and a timeline. That is incomplete. The ongoing value of a citizenship depends on whether the issuing country retains strong diplomatic standing, credible due diligence, secure documents, lawful pricing and cooperation with international partners.
For that reason, Moore Law treats regulatory risk as part of the advice. It is not fine print at the bottom of a brochure. It is central to programme selection.
A second citizenship is only useful if it remains respected.
Current risk snapshot.
Last reviewed:
| Issue | Dominica | St Kitts and Nevis | Moore Law position |
|---|---|---|---|
| US visa restrictions | Current US partial visa restrictions affect Dominican nationals in certain visa categories | Not subject to the same Dominica-specific position | Dominica requires careful review where US travel is material |
| EU/Schengen visa-waiver risk | Relevant | Relevant | Treat Schengen access as subject to policy change |
| OECS minimum pricing | Applies | Applies | Use official pricing only |
| Illegal discounting | Red flag | Red flag | Discount-driven CBI marketing should be rejected |
| Regional regulator and common standards | Relevant | Relevant | Stronger oversight is part of the direction of travel |
| Biometrics and document integrity | Check at application stage | New biometric-enrolment programme live | Document integrity is now commercially important |
| Tax-residence misconception | Common risk | Common risk | Citizenship is not tax residence |
| No guarantee of approval | Applies | Applies | Final decisions rest with the government authority |
US position.
The current US position is a material distinction between Dominica and St Kitts and Nevis. From 1 January 2026, the United States partially suspended visa issuance to nationals of several countries, including Dominica, for B-1/B-2 visitor visas, F, M and J student or exchange visitor visas and all immigrant visas, subject to stated exceptions.
The White House proclamation states that Dominica has historically had citizenship by investment without residency and suspends entry for Dominican nationals in specified immigrant and non-immigrant categories, subject to the scope and exceptions in the proclamation.
Moore Law position. Any client considering Dominica for US travel, study, business visitor access or immigration optionality should treat this as a central issue, not a footnote. St Kitts and Nevis currently has the stronger US-positioning story, but all US travel analysis must be checked against the client’s nationality, visa history and the rules in force at the time of travel.
A passport does not create a right to enter the United States. US entry depends on US law, visa eligibility, admissibility and policy in force at the relevant time.
EU and Schengen position.
Schengen access is a major part of the commercial appeal of Caribbean CBI programmes, but it is not fixed. The EU’s revised visa-suspension mechanism expressly allows the EU to act where a third country operates an investor citizenship scheme under which citizenship is granted to people who have no genuine link to the country in exchange for predetermined payments or investments.
This does not mean that Schengen access is automatically lost. It does mean that CBI programmes are now expressly within the regulatory field of vision.
Moore Law position. Clients should treat UK and Schengen access as current travel-access benefits, not permanent guarantees. Any decision that depends heavily on Schengen access should be made with that risk in view.
Travel-access value can change after citizenship is granted.
Pricing, discounting and regional oversight.
The OECS has confirmed that participating Caribbean CBI countries agreed to a minimum CBI price of US$200,000 from 1 July 2024 and that the memorandum of agreement was intended to support cooperation, information sharing, common best-practice standards and regulatory oversight.
Moore Law position. CBI should not be marketed or purchased on the basis of unofficial discounts, rebates or price shortcuts. If a route depends on a discount below official programme thresholds, the problem is not only commercial. It is a legal and reputational warning sign.
Official pricing, authorised channels and documented funds are part of programme integrity.
Moore Law compliance position.
Moore Law advises on citizenship matters from a legal, tax and private-client perspective. The following positions apply across the second-citizenship section.
Eligibility before budget.
We assess whether the client should apply before discussing which route appears cheapest.
Authorised channels only.
The formal application is submitted through a government-authorised agent in the issuing jurisdiction.
No approval guarantees.
No adviser, agent or intermediary can guarantee government approval.
No permanent travel-access promises.
Visa-free access is subject to policy, immigration law and diplomatic arrangements.
No automatic tax outcome.
Citizenship does not, by itself, create tax residence or end tax obligations elsewhere.
Source-of-funds discipline.
The client must be able to evidence lawful funds and a coherent source-of-wealth position.
Regulatory monitoring.
Programme rules, government fees, visa-waiver arrangements and document requirements are checked before the client commits.
Post-approval planning.
A citizenship should be integrated into the client’s corporate, banking, residence and family position where relevant.
The regulatory position is subject to change. These official sources should be checked before relying on any programme, pricing or travel-access statement.
- OECS CBI Memorandum implementation
- EU visa suspension mechanism
- US State Department visa suspension note
- White House Proclamation 10998
- Dominica CBIU
- St Kitts and Nevis CIU
External government and institutional sources. Programme figures and regulatory positions should be verified against these before they are relied upon.
Regulatory questions.
Does this mean Dominica should be avoided?
Not necessarily. Dominica may still be suitable for clients who value cost efficiency, family inclusion and current China access, and who do not rely on the passport for US travel. The current US position must be assessed before choosing the route.
Does this mean St Kitts is risk-free?
No. St Kitts and Nevis currently has a stronger US-positioning story than Dominica, but it remains a CBI programme and is still subject to EU/Schengen, pricing, due-diligence and document-integrity scrutiny.
Can Schengen access be guaranteed?
No. Schengen access depends on visa-waiver arrangements and EU policy. It should be treated as a current benefit, not a permanent guarantee.
Are CBI discounts acceptable?
Moore Law’s position is that clients should use official pricing and authorised channels only. Discount-driven marketing is a serious warning sign in the Caribbean CBI market.
Does citizenship create tax residence?
No. Citizenship and tax residence are separate questions. Tax residence depends on facts, law and the client’s wider position.
When should the regulatory position be checked?
Before programme selection, before engagement of an authorised agent, before funds are committed and again before relying on any travel-access benefit.
The information on this page is provided for general guidance only and does not constitute legal, tax, immigration, investment or financial advice. Citizenship and residency programmes are governed by the laws and policies of the relevant jurisdictions and may change without notice. Applications are subject to eligibility requirements, due diligence, document review, investment completion and final approval by the competent government authority. No adviser, agent or intermediary can guarantee citizenship, passport issuance, visa-free access or any tax outcome. © 2026 Moore Law. All rights reserved.