The regulatory reality.
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.
The investment-migration landscape in 2026.
This is the section the brokers omit. The investment-migration field has tightened materially, and any honest overview must say so.
- The European Union has effectively closed the citizenship-by-investment door. Cyprus terminated its programme in 2020; Bulgaria followed in 2022; and on 29 April 2025 the Court of Justice of the European Union ruled, in Commission v. Malta (C-181/23), that granting citizenship in exchange for predetermined payments is incompatible with EU law. Malta has discontinued its investor route and replaced it with a narrow, discretionary citizenship-by-merit framework. There is, today, no straightforward route to buy an EU passport. Anyone telling you otherwise is selling a product that no longer exists.
- The Caribbean has consolidated. Following a 2024 regional agreement, the five Eastern Caribbean programmes now share a minimum investment floor of USD 200,000, alongside mandatory applicant interviews, enhanced biometrics and intensified due diligence.
- Mobility is not permanent. Visa-free access is granted by other countries and can be withdrawn — Vanuatu’s loss of EU visa-free travel is the cautionary example, and the UK has recently introduced visa requirements for several Caribbean nationalities.
- Scrutiny is increasing, from the OECD, the EU and major economies. The programmes that endure will be those with credible governance; programme selection is therefore a judgement about the future, not only the present.
We regard this environment not as a deterrent but as the reason to take proper advice. The right citizenship, acquired now and correctly, remains a sound and durable decision.
Current risk snapshot.
Last reviewed:
| Issue | Dominica | St Kitts and Nevis | Moore Law position |
|---|---|---|---|
| US visa restrictions | Subject to a current Dominica-specific partial US visa suspension affecting certain categories | Not listed in the Dominica-specific suspension; no US visa or entry outcome is guaranteed | Dominica requires careful review where US travel is material |
| China travel access | Current China–Dominica mutual visa exemption for eligible ordinary passport holders | No equivalent current ordinary-passport advantage identified | A current benefit for Dominica that must be verified before travel, not assumed |
| 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 | Mandatory, fee-bearing biometric enrolment for new applications from 14 April 2026; existing CBI citizens must enrol by 31 July 2027 | Document integrity is now commercially important, and the fees must be budgeted |
| 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 is not listed in the current Dominica-specific partial US visa suspension, which is a meaningful distinction, but that is not the same as guaranteed US entry. No US visa or entry outcome should be assumed for either programme, and 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.
China travel access.
One current point of difference between the two programmes is China travel access. A mutual visa-exemption arrangement currently allows eligible ordinary passport holders of Dominica and the People’s Republic of China to travel between the two countries without a visa for short stays, subject to the conditions and categories set out in the arrangement. No equivalent current ordinary-passport advantage has been identified for St Kitts and Nevis in this review.
Moore Law position. Where China access is genuinely relevant to a client, Dominica may carry a real advantage. That advantage should be treated as a current benefit that must be verified against the rules in force at the time of travel, not as a permanent or guaranteed feature of the passport.
Visa-exemption arrangements can be amended or suspended. Any China-access benefit should be confirmed against the official position before travel is planned or advice is relied upon.
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.
Biometrics and document integrity.
St Kitts and Nevis has introduced a mandatory biometric-enrolment requirement. Biometric enrolment is required for new applications submitted from 14 April 2026, and existing Citizenship Programme citizens must enrol by 31 July 2027. Passports issued before 14 April 2026 remain valid during a transition period, after which biometric enrolment becomes a condition of continued passport service. Enrolment carries per-applicant fees, and a passport-modernisation programme accompanies the change.
Moore Law position. Biometric enrolment is not an administrative afterthought. It carries real cost and logistics that should be budgeted from the start of a St Kitts and Nevis file rather than discovered later. More broadly, document integrity and biometric capture reflect the direction of travel for the Caribbean CBI sector, where credible documents are becoming central to a programme’s standing.
For St Kitts and Nevis, biometric-enrolment and passport-modernisation charges apply per applicant and should be modelled as part of the government-file cost, not treated as optional.
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
- St Kitts Biometrics
- China–Dominica Mutual Visa Exemption
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 is not listed in the current Dominica-specific partial US visa suspension, which is a meaningful distinction, but that does not guarantee US entry, and it remains a CBI programme still subject to EU/Schengen, pricing, due-diligence and document-integrity scrutiny, including mandatory biometric enrolment.
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.