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If CBI Must Go, What Comes Next for the Caribbean?
Commentary by Terrance Rey
Back in the day, when Dr. Claude Wathey was the dominant political figure in St. Maarten, I remember hearing about an idea that sounded very much like what today we would call an economic citizenship or Citizenship by Investment programme.
I was a young kid then. Politics, whether local or international, was hardly at the top of my list of concerns. I was more interested in whether Paper Garden had received the latest Spider-Man, Superman, Batman, Avengers and Fantastic Four comic books so that I would not fall behind on what was happening in the Marvel and DC universes.
My recollection is that whatever Wathey was proposing did not get very far with the Dutch authorities.
But memory is not history, and after looking deeper into it, I have not been able to find enough documentary evidence to state exactly what Wathey proposed, whether it involved citizenship, passports, residency or work permits. So I will not turn a childhood recollection into a historical fact simply because, decades later, it seems to fit today’s argument.
What we do know is something more important.
St. Maarten is not in the same constitutional position as Dominica, St. Kitts and Nevis, Antigua and Barbuda, Grenada or Saint Lucia. Those are sovereign countries that control their own nationality laws. St. Maarten is a country within the Kingdom of the Netherlands, and Dutch nationality law is a Kingdom responsibility. St. Maarten cannot simply create its own separate nationality and sell a Dutch passport to investors.
That distinction matters today because the Citizenship by Investment (CBI) programmes of the independent Eastern Caribbean countries are under perhaps the greatest external pressure they have ever faced.
The European Union has told Dominica and its fellow CBI countries that they are expected to transition away from these programmes by June 2028 if they want to preserve visa-free access to the Schengen Area. The EU has changed its rules so that granting citizenship to investors who have no genuine link to a country can itself become grounds for suspending visa-free travel.
And this is not an empty threat. The EU already went down that road with Vanuatu and eventually removed its visa-free access.
Neither is Europe alone in raising concerns.
Canada imposed visas on St. Kitts and Nevis citizens in 2014 because of concerns about passport issuance and identity management connected with its CBI programme. The United States’ FinCEN also issued an advisory that year warning that illicit actors were abusing the St. Kitts and Nevis programme to disguise their identities and backgrounds. That particular advisory was eventually rescinded in 2026, following years of reforms, but the episode shows how seriously major international partners have treated weaknesses in these programmes.
And for anybody wondering about the United Kingdom, Britain has already acted. In July 2023, the UK imposed a visa requirement on Dominican citizens after saying it had found clear and evident abuse of Dominica’s CBI scheme, including citizenship having been granted to persons considered a risk to the UK.
Still, none of that changes another reality.
CBI has been enormously important to some of these small Caribbean economies.
In Dominica alone, the World Bank says CBI brought in more than EC$602 million in fiscal year 2023/24. That was equivalent to 33.8 percent of the country’s GDP and almost 55 percent of total government revenue. That is not pocket change. You do not remove a revenue stream of that magnitude from a small island economy on Friday and simply open another one on Monday.
The money has helped build infrastructure, finance reconstruction after disasters and fund development that might otherwise have required higher taxes or more borrowing. The IMF confirms that Dominica has become highly dependent on CBI to finance strategic development projects.
St. Kitts and Nevis has its own long history with CBI. There have been controversies and serious international concerns over the years, but there is no reasonable argument that the programme has not also produced very substantial revenues and financed development.
So we arrive at the uncomfortable question.
What replaces it?
That, to me, is where the Caribbean conversation now needs to go.
It is not enough to complain that Europe is being unfair. It is not enough for Europe to tell vulnerable island economies to shut down a major revenue source without acknowledging the economic consequences. And it is not enough for us in the Caribbean to believe that a few more background checks and another regulatory body will necessarily make the political problem disappear.
The proposed Eastern Caribbean Citizenship by Investment Regulatory Authority, ECCIRA, is a sensible response to years of concerns about due diligence and inconsistent standards. A regional regulator with common rules, stronger screening and better information sharing should make the system more credible.
But here is the problem.
The EU’s new position goes beyond due diligence. Brussels is increasingly questioning whether citizenship should be granted principally because somebody has enough money to buy it without establishing a genuine connection to the country.
You can therefore build the cleanest, best regulated passport-selling operation in the world and still be left with the question: should citizenship itself be the product being sold?
Maybe that is where the next Caribbean leader needs to be creative.
Instead of Citizenship by Investment, perhaps the next model should be Residency by Investment.
Bring your capital. Invest in productive businesses, hotels, renewable energy, agriculture, technology, housing or infrastructure. Create jobs. Maintain your investment. Live in the country for a meaningful period. Pay your taxes. Become part of the community. And after establishing a genuine relationship with that country, qualify for citizenship under normal naturalisation rules.
That would not produce the same easy money. Let us be honest about that.
A wealthy investor will pay much more for an immediate passport with visa-free travel privileges than for the possibility of becoming a citizen several years down the road.
But perhaps the era of easy passport money is ending anyway.
If that is the case, then the alternative cannot be one magic programme designed to replace another. It will have to be a combination of tourism, renewable energy, productive foreign investment, climate financing, better tax collection, property development, agriculture, technology, regional capital markets and new ways of converting the Caribbean’s natural and strategic assets into sustainable income.
The World Bank has already identified room for Dominica to broaden its tax base, improve property and income taxation, rationalise exemptions and make better use of environmental and tourism-related taxes. The OECS itself is looking at nature financing, carbon markets and climate-resilience investment.
None of those, by itself, will replace CBI.
Together, over time, perhaps they can reduce the dependence.
And that may be the real challenge presented by this European ultimatum.
For decades, these countries found a way to turn one of the few things they controlled absolutely, their sovereign right to grant citizenship, into a valuable economic asset.
It worked.
Perhaps it worked too well.
Now the international community is effectively saying that the economic value of that citizenship cannot be separated from the travel privileges other countries agree to give its holders. Europe is reminding the Caribbean that a passport may be issued by one country, but its usefulness abroad depends on decisions made by many others.
That is the leverage Brussels has.
The Caribbean now needs leverage of its own.
So rather than merely asking whether the CBI programmes can be saved, I believe our leaders should be asking the bigger question:
What can we build that earns the same kind of international investment without having to sell citizenship to get it?
Necessity has always been the mother of invention.
The pressure is certainly there.
The money at stake is certainly there.
The deadline is now there.
Can the next Caribbean leader stand up with the alternative?
That, more than the future of CBI itself, may become one of the most important economic questions facing the Eastern Caribbean over the next few years.
Terrance Rey
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Related articles:
Dominica Seeks Economic Safeguards as EU Pressures Caribbean Nations to End Citizenship Programmes
The Caribbean Must Stop Exporting Its Tourism Dollars
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