The European Union has delivered notices to five Caribbean nations, demanding they terminate their citizenship-by-investment programs by 2028 or risk losing visa-free access to Europe's Schengen Area.
This visa-free entry to the 29 Schengen member states is a major selling point for these so-called "golden passport" programs. While some immigration lawyers predict the ultimatum will likely result in a compromise, the EU could also hold its ground.
Currently, foreign nationals can acquire citizenship in one of these countries by making a qualifying investment in its economy, such as purchasing real estate or contributing to a government fund. The passports issued by these nations grant visa-free travel to approximately 140 countries and territories.
These citizenship-by-investment (CBI) programs, starting at around $200,000, represent a significant source of revenue for the Caribbean states. The EU sent its letters to the governments of Antigua and Barbuda, Dominica, Grenada, St. Lucia, and St. Kitts and Nevis in late June.
According to a statement, the affected nations are planning a coordinated response, including sending a delegation to Brussels. "Our CBI programs are a vital pillar of our non-tax revenue base. They cannot be simply abolished without a viable, credible, and sustainable alternative source of income," stated Gaston Browne, Prime Minister of Antigua and Barbuda, in a subsequent release.
The EU has previously targeted other CBI programs, including Malta's. However, according to Ron Krasko, an immigration lawyer and co-founder of the consulting firm Exodus Migration, this demand is unusual because it does not cite specific security concerns or propose remedies to address them. He believes the EU will not back down.
"The EU has consistently pressured Caribbean nations, mainly regarding security issues, and in recent years, all these countries have strengthened security measures in response. This new situation is different," Krasko said. "They are now saying, we object to the very concept of acquiring a passport through a commercial transaction. This strikes at the heart of these programs. If the demand was merely for enhanced security vetting, nations could still find a way forward."
Krasko noted he is advising one of the five affected countries (which he declined to name) on potential reform options aimed at satisfying the EU's demands. Rez Jafari, a senior consultant at law firm Charles Russell Speechlys, views the EU's demand as a starting point for negotiation rather than a final ultimatum.
Jafari, who also leads citizenship and residency advisory firm Dasein Advisors, said several clients have inquired about the situation but are continuing to pursue their applications. "This conversation has been ongoing for as long as I can remember," said the immigration lawyer, who has practiced for 30 years. "I believe the EU likely wants to strengthen due diligence or gain better insight into who is entering and who is not. The Caribbean nations will likely cooperate, as they have no intention of breaking any rules."
At the end of 2024, the EU revoked visa-free Schengen access for the South Pacific island nation of Vanuatu due to security and migration concerns. In 2025, the European Court of Justice ruled Malta's "golden passport" program illegal. Malta has since implemented a points-based system with a residency requirement.
Jafari added that even without a compromise, Caribbean nations are too reliant on CBI revenue to fully eliminate the programs. He noted that over half of his clients are Americans, who do not require visa-free travel as a benefit. "My clients choose these passports because they do not want to travel carrying their own national passport. For them, it's a security issue," he said. "I work with extremely wealthy clients globally. Having a backup citizenship and residency is part of their global planning. They are managing various risks: political, personal, business, and financial."
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