After months of extensive consultations, the five Eastern Caribbean countries offering Citizenship By Investment Programmes (CBI/CIP) are on the cusp of enacting a new law to establish a regional regulator. This legislation is set to be passed by all member states in September 2025.
The introduction of this law marks the culmination of an intense and historic period of cooperation surrounding these programmes, which play a vital role in the fiscal and financial stability and resilience of the member countries.
Key milestones in the engagement process include:
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The inaugural US-Caribbean Roundtable in February 2023, where an agreement on six principles was signed between the United States and the five CBI/CIP countries in St. Kitts and Nevis.
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Follow-up roundtables with the USA in October 2023 and with the USA, UK, and EU in August 2024 (Grenada) and January 2025 (London).
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Signing of Memoranda of Agreement among CBI/CIP Heads in March and June 2024.
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Introduction of a minimum programme price of US$200,000 from July 2024.
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Broad-based stakeholder consultations on the establishment of the regional regulator from March to July 2025.
Throughout these dialogues, all partners have recognized that CBI/CIP programmes provide a legitimate service and are crucial for funding major infrastructure and development projects. They have also acknowledged the programmes’ importance in helping these small island states withstand existential threats such as the climate emergency, the COVID-19 pandemic, and global conflicts like the ongoing war in Ukraine.
Dismantling the programmes, officials say, would severely harm the prosperity of these countries and trigger negative social consequences.
The CBI/CIP countries have reaffirmed their commitment to collectively safeguard their financial systems against illicit activities, including money laundering, fraud, terrorist financing, and proliferation financing.
Key provisions of the forthcoming legislation include:
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The establishment and funding of a regional CBI/CIP regulator tasked with enhancing transparency, security, and sustainability. The regulator will issue binding standards on all Citizenship by Investment Units (CIUs) and licensees.
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Strong enforcement mechanisms, including the power to hold CIUs and licensees accountable and the publication of annual compliance reports.
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Mandatory biometric collection for all new applicants during interviews, strengthening the vetting process.
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A residency requirement for all approved applicants to reinforce their link to their new countries, enhance biometric verification, and boost tourism and economic opportunities.
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Financial support for CARICOM IMPACS/JRCC to enhance the Joint Regional Communications Centre’s vetting capabilities. The JRCC plays a central role in screening applicants; no application is approved without its clearance.
The drafting of the law has been led by an Interim Regulatory Commission (IRC) comprising representatives from the five countries, the Organisation of Eastern Caribbean States (OECS) Commission, CARICOM IMPACS/JRCC, and the Eastern Caribbean Central Bank (ECCB). Legal Drafting Consultant Ms. Lydia Elliott has guided the process. The IRC’s work has been overseen by the Heads of Government of Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia.
The CBI/CIP countries expressed gratitude to international partners, particularly the United States and the United Kingdom, for their constructive feedback on the draft legislation shared in July 2025. Appreciation was also extended to local stakeholders, including Attorneys General, Chief Parliamentary Counsel, CIUs, and industry participants.
