HAS THE APPROACHING TRIAL DATE OF MONEY LAUNDERER ALEX SAAB MORAN RATTLED ANTIGUA'S LEADER?

For those readers who are not aware of the fast-tracked progress of the latest Federal criminal case pending against the Colombian money launderer (and close associate of former Venezuelan President NICOLAS MADURO MOROS) ALEX SAAB MORAN, it is presently scheduled to go to trial in U.S. District Court in Miami, Florida on NOVEMBER 16, 2026. Saab is accused, this time, of being a money launderer engaged in an international financial conspiracy involving the concealment of millions of dollars tied to the Venezuelan government food import project known as CLAP, and oil reversal schemes that resulted in the illicit diversion of an obscene amount of money abroad for his clients. He was removed from Venezuela earlier this year, after the country's current president removed him from a major Cabinet position and turned him over to U.S. law enforcement, who took him into custody.

Contrast and compare Saab's situation with the 2027 trial date of Maduro in Manhattan, and one might now understand the pointedly erratic behavior of late of the sitting Prime Minister of Antigua & Barbuda, GASTON BROWNE, whose conduct recently has been the subject of widespread attention. It bears mentioning that Saab, formerly Browne's designated Economic Envoy, is alleged to have engaged in major money laundering activities within Antigua's financial system, on behalf of his Venezuelan clients in Maduro's narcotics trafficking cartel; he controlled two Antigua offshore banks, and conducted a substantial amount of illegal money movement through two of the country's principal local banks, one of which was government-owned and controlled.

Given that Saab has a long and sordid history of cooperating with American law enforcement, to keep himself from the consequences of his use of the American financial structure to move and clean narcotics profits, and the proceeds of other criminal activity, legal observers in Miami believe that, as his trial date approaches, Saab will provide Substantial Assistance to the Department of Justice, to reduce the possibility that he spends the rest of his life in an American prison, and that such cooperation will implicate Browne, as well as several other senior government officials who worked with him in his laundering activities in Antigua. 

Since details of any such assistance will be sealed, so long as Browne and other Antiguan targets remain outside the custody of American law enforcement agencies, we will not be privy to such information, and will only learn of its existence after he has been arrested. Whether this will occur under the same circumstances as Maduro's removal from Caracas, we cannot say, but the threat of this occurring would explain Browne's strange conduct in recent weeks. Does he fear the proverbial knock on the door in the middle of the night by an American special operations team? We cannot say, but we will be watching.

CARIBBEAN CITIZENSHIP BY INVESTMENT PROGRAMS AND THE SEARCH FOR TRUTH

"We who Labor here seek only the Truth, " is posted behind the judicial bench in many of the courtrooms here in Miami-Dade County, and it came to mind when my recent article, covering a number of the infrastructure projects completed with Citizenship by Investment (CBI) funding, created a firestorm of controversy, from readers who wondered whether I had abandoned my two decade opposition to the money laundering, fraud and corruption that has long been associated with the administration of such programs in the five Eastern Caribbean states that have offer Economic Citizenship; That is simply not true.

To be blunt, my sometimes scathing exposure of financial crime in CBI programs will continue, but as I am a proponent of also complete disclosure of the truth, even when it might meet with disapproval in some quarterers, I chose to name the CBI projects in the Commonwealth of Dominica. Please do not ignore those achievements because the administrators of the program have allegedly been linked to corruption and financial crime. The statements appearing in the pro-investment migration press, to the effect that I am supporting those leaders, is not correct. In truth and in fact, I continue to be an advocate for a replacement of the corrupt Dominica Labour Party, as the achievements I have detailed have been accomplished despite the party's illegal diversion of CBI revenue, and other financial crimes, which is another truth.

Also, Dominica frankly sits alone as the Caribbean CBI state with a substantial number of completed projects; I have found that Saint Kitts & Nevis, Saint Lucia and Antigua & Barbuda have few concrete results to show for all the millions of US Dollars that have found their way into government accounts; do not lump me into the category of those who are cheerleaders for those programs, which I have condemned, and will continue to call out as having failed in their obligations to fulfill the stated original program goals.

Given that the European Union policy on shutting the door to CBI in 2028, if there is a chance for the benefits of the Dominica program to continue, perhaps a transition to Residency by Investment (RBI) program could allow infrastructure projects to continue. As the EU allows RBI among its Member states, it might be the solution to the region's problem, regarding a substitute for much-needed government revenue. Whether this will come to pass, we cannot say, but the people of the Eastern Caribbean states must have financial security, and we trust that it can be found, in the short term. There can be no debate over whether that statement is absolutely true.

MEHUL CHOKSI'S UNITED KINGDOM CIVIL SUIT AGAINST THE ALLEGED KIDNAPPING CREW, DISMISSED

 

If you were wondering what became of that civil suit that the fugitive diamond fraudster MEHUL CHOKSI, filed in the United Kingdom in 2024, against the Government of India and the crew that Choksi alleged was involved in his failed kidnapping from Antigua, it has been dismissed by agreement of the parties. You may re all that the Court ordered that the Claimant, a non-resident, to comply with an order requiring him to remit to the Court a substantial cost deposit, which we reported here:  WILL CHOKSKI'S UK CIVIL SUIT AGAINST INDIA BE DISMISSED FOR HIS FAILURE TO TIMELY PAY THE £677,000 COST DEPOSIT?  According to the text of the stipulated Consent, which is the grounds for the Dismissal, he failed to pay that sum into the Court Registry. The Order appears above.

Choksi, having failed in his opposition to extradition from Belgium, where he was detained on the authority of a warrant issued by the Government of India, is awaiting removal to his native country for trial. Choksi has been charged with obtaining the equivalent of USD$2bn in bank loans through fraud, and other crimes and offenses. His flight to Antigua, where he had secured a CIP passport notwithstanding being under criminal investigation, exposed the bogus nature of the country's Due Diligence investigation process. The scandal was made worse when Choksi, with obvious Antiguan government collusion, was able to evade extradition for several years, using the country's corrupt court system to delay matters indefinitely.

We are looking forward to seeing that justice will finally be done in the Choksi case, after an extensive delay which he created, in a futile effort to avoid justice in the courts of India. 

INVESTMENT MIGRATION-FINANCED PRESS PLANS TO SHOOT THE MESSENGER (GREGOR NASSIEF) WHO PUBLICLY EXPOSED DOMINICA'S CORRUPT AND ILLEGAL CBI PASSPORT SALES PROGRAM

If you have been following the news, regarding the public disclosures made by the prominent Dominican hotelier Gregor Nassief, then you know he sent fourteen letters to Dominica's Prime Minister, ROOSEVELT SKERRIT, demanding reform of the country's rogue CITIZENSHIP BY INVESTMENT (CBI) program. That news has sparked a firestorm of very public controversy over his detailed analysis of the systemic corruption, mismanagement and dangers of not only Dominica's program, but the international threats which all five Caribbean CBI & CIP passport sales programs pose, as all have succumbed to corruption, fraud and money laundering, which impact the global financial structure, and the national security of a number of Western democracies.

Our sources have confirmed that the major CBI passport sales consultancies who covertly fund and finance online news services, whose goal is to disseminate pro-CBI infomercials, as well as blatant disinformation and propaganda from outside the Caribbean, have all sent to Mr. Nassief extensive correspondence, in identical multi-page letters, requesting comments on unsubstantiated allegations of corrupt practices and sexual harassment at his hotel establishments. These captive media reportedly plan to publish an " expose" of his businesses and personal life, which is the character assassination method, known as "Shoot the messenger," which they generally engage in when there is any exposure of corrupt and illegal practices of CBI. 

We will be closely following these efforts of these propaganda media services to disparage the one individual who, after more than a dozen private efforts to force Dominica to clean up it CBI program, went public with all of Dominica's dirty CBI laundry. Individuals who trust media to obtain honest assessments of the virtues and abilities of economic passports are subject to mass media misstatements of material facts about CBI, especially the negative issues purchasers could face in the uncertain future of second passports' ability to enjoy visa-free entry to jurisdictions denied to citizens of many countries in the developing world, or nations judged to be high-risk. Learn which media whose rosy pictures of passports' attributes to ignore, and who is behind a well-orchestrated program to deceive CBI consumers. 

WILL THE EUROPEAN UNION NOW TERMINATE VISA-FREE ACCESS FOR DOMINICA FORTHWITH, AS THE CBI STATE CONTINUES TO ALLOW ILLEGAL DISCOUNTS?

SAINT LUCIA AND DOMINICA CONTINUE TO SUPPORT ILLEGAL DISCOUNTING OF PASSPORT SALES; BLUMINA IS RIGHT UP THERE WITH THEM

For all those in the investment migration industry who are busy assuring their new clients that the new Caribbean regulatory agency, which is intended to supervise the five Eastern Caribbean CBI and CIP states, is working, we note that a few months ago, those five countries held the CARIBBEAN INVESTMENT SUMMIT 2026, in Saint Lucia, between May 6th and May 9th. The esteemed Guest of Honor was the CEO of Amman, Jordan based BLUMINA CITIZENSHIP AND RESIDENCY, BASHAR AL DAOUD. We know this because Daoud posted photograph oF the event on his SOCIAL MEDIA, showing him next to Prime Minister PHILIP J. PIERRE, and several other senior Caribbean government leaders.

As most professionals in the economic passport sales business know, Bluemina is known as essentially the founding father and originator of the illegal deep discounting practice on the pricing of second passports from the Caribbean; he also serves as the designated Marketing Agent for Saint Lucia's CIP program. Saint Lucia, together with the Commonwealth of Dominica, are engaged in the illicit dumping of discounted of passports, fast-tracking their applications as rapidly as their CIU staff can approve them, as they desperately seek to maximize revenue, ahead of the ordered June 2028 EU-ordered termination of all Caribbean second passport programs.

All these fancy international industry programs, the purpose of which is to present what have been referred to as Silver Bullet Solutions to prospective purchasers, are little more than shiny misrepresentations of the truth, offering buyers something with absolutely no substance in an industry with a dark future, whose customers will be acquiring an "asset" with a probable expiration date, subject to revocation by a successor government or court, and having no substance. In essence, they are selling iceboxes to eskimos, at illegal prices.  How can any consumer have any faith in anything these people do? 

TERRENCE CROSSMAN, MANAGING DIRECTOR OF SAINT KITTS-NEVIS-ANGUILLA NATIONAL BANK, TERMINATED FOR MISCONDUCT

Our sources in Saint Kitts and Nevis have reported that TERRENCE CROSSMAN, the Managing Director and First Vice Chair of SAINT KITTS-NEVIS-ANGUILLA NATIONAL BANK, has been terminated, with prejudice, for misconduct. Crossman has been accused of overcharging the bank in its purchases from a company in the United States which he controlled, which the bank learned after conducting an internal investigation.

Crossman, appointed by the Labour Party government of Prime Minister TERRANCE DREW, and who earned EC $90,000 a month as MD, as part of a two year contract for EC$2m, at first had the balance forfeited, but later, due to political pressure, was paid the remainder owed on the EC$2m contract . It has been rumoured that, due to his involvement in payments from in the CBI, the bank feared he might make incriminating statements, such as have been made by former Saint Kitts CIU CEO LES KHAN. He was formerly the Chief Executive officer of the country's Sugar Investment Diversification Foundation (SIDF), where he was also terminated, in 2016, following an internal investigation conducted there into the foundation's finances.The SIDF would not disclose the reason he was cashiered.

This is just one more incident in Saint Kitts and Nevis, which the government has tried to keep quiet, but which has exploded into a public scandal.

THE ILLEGALLY DISCOUNTED DOMINICA CBI PASSPORTS FOR OPEN SALE AT RICHKEY CAPITAL; THE UNREGULATED CHARADE MARCHES ON

In the UAE, the hits just keep on coming. RICHKEY CAPITAL is offering them at $89,000, and warning their prospective clients that the price will soon do up $21,000, unless they buy IMMEDIATELY, in a classic take on marketing arrogance. The Government of Dominica apparently does not care who breaks their laws, since CBI fund the construction of their new international airport, and patyments are slow coming in. Should the country's Prime Minister ROOSEVELT SKERRIT, who allows this illicit madness, be cashiered? You be the judge, but no banker will be accepting Dominica passports as proof of identity, if he or she has any sense. These passports could end up revoked, which won't stop the holders from using them as identification.

HOW WILL U.S. PROPOSAL OF $100,000 VISA FEE FOR POST-UNIVERSITY FOREIGN STUDENTS TO WORK IN AMERICA AFFECT EXISTING CARIBBEAN STUDENTS?

While ANTIGUA and BARBUDA and DOMINICA must now live with the reality of visa restrictions that, in essence, prohibit most of their students from attending American colleges and universities, now President Donald Trump has added another obstacle to the mix: he plans to impose a USD$100,000 payment upon foreign students who are graduates of American colleges, who wish to remain in the United States, to work for three years, under an existing program.

This means that 99% of the recent and new Antiguan & Dominican college graduates will not be able to stay on an accept employment, as the astronomical cost will make their participation impossible. Even if a foreign student somehow get that precious student visa to attend an American college, he or she will have no chance to stay on after graduation, to enter into gainful employment.

They will have to return home, which to Caribbean students who come from one of the five CBI passport-issuing states, which will be terminating their programs in 2028, causing a large number of individuals in government jobs to be furloughed, for lack of funding, and those experienced jobseekers will have an advantage over the new graduates. They will most likely be either underemployed, or even unemployed, as the result.

Bad economic news seems to continue for Antiguans and Dominicans, everywhere that they turn, all relating back to their longtime choice to keep corrupt CBI programs, which have incurred the wrath of the current American government, in place for far too long. The people are now reaping the whirlwind of their decision to retain in office leaders who failed to heed the warning signs from America, the UK and the EU.

THE USE OF FACIAL RECOGNITION SOFTWARE TO PHYSICALLY STOP MONEY LAUNDERERS AND FRAUDSTERS FROM USING THE FACILITIES OF A FINANCIAL INSTITUTION

Which one is the money launderer entering your bank?

As a former career money launderer (10 years experience), I know how easy it is, with the right credentials, for anyone to enter a financial institution, to move money, commit a fraudulent act, or even provide financial assistance to a terrorist organization America's success rate with stopping such criminal acts, in real time, is abysmal, looking at the statistics.

If you are following the most recent developments in the use of next generation facial recognition software, you know that it is becoming more common for certain types of establishments, that serve the general public, to employ closed circuit cameras connected to such platforms, to be able to identify and target specific persons, so that such individuals can be either banned, removed, or closely monitored, to ascertain whether they pose a distinct threat to the premises, its staff, its operations, or could be collecting intelligence or information deemed to be possible existential or commercial threat.

Now take that existing solution, and apply it to financial institutions open to the general public. Could commercial banks use facial recognition software to identify potential financial crime threat actors, as they enter the premises, and therefore reduce the risk that they succeed at the tellers' windows, or with the account representatives, through the use of an alert system, advising staff that a dangerous individual was indeed inside the bank? I know you might consider there to be both privacy concerns, accuracy concerns, and even due process issues, but remember this: the law does not require that banks must offer their services to all persons, without exception. Banks can, and often do, deny services on a risk management basis.

As to what must be in that unique facial recognition platform, which will give a specific bank's security team the ability to know who the bad actors are, especially those who have never been convicted of a crime, I have a specific answer to that question, which I learned from my laundryman days, but disclosing it here in a public sphere, would give away the edger which banks need to stop financial crime in real time, in its tracks. They are the methods money launderers use to keep from getting caught in the first place. If you are a bold risk management professional who is not afraid to travel new roads, reach put to me, and we can have that conversation. I can be found at: miamicompliance@gmail.com

DID SAINT LUCIA'S PRIME MINISTER ORDER THE BURNING OF INCRIMINATING SSDF FILES BEHIND MINISTRY HEADQUARTERS?

The ongoing Saint Lucia Social Development Fund corruption scandal in SAINT LUCIA, involving allegations that Minister RICHARD FREDERICK paid romantic partners for years, by checks from a government fund intended to help needy citizens, has just gotten worse. The matter is one of great international importance, as a portion of the funding comes from several Western countries, and massive theft of this money may constitute a crime under the laws of the donor nations.

The latest chapter in this unfolding involved a Cabinet meeting this past week, when Saint Lucia Prime Minister PHILIP J PIERRE threatened to expose all the other individuals who are said to have stolen from the SSDF fund, in the event his role in the corruption is made public. Issues with a lack of audits have surfaced, and the PM is ultimately responsible for oversight and supervision of public funds.

The most egregious new allegations are first-hand statements by witnesses to the effect that they witnessed the burning of Saint Lucia files behind ministry headquarters. We are investigating this matter, and will rep[ort back to our readers when more details are available.

Both PM Pierre and Deputy PM and Investment Minister ERNEST HILAIRE, are known to have immediately left St. Lucia, with their current whereabouts being unknown. Whether they are truly on holiday, both at the same time, has not been confirmed. Meanwhile, rumours are flying around CASTRIES that they have delegated the quiet sacking of Minister Frederick to a subordinate, but whether that will occur, given that he reportedly has serious incriminating evidence of corruption and money laundering on the PM, we cannot say. Stay tuned.

DOMINICA'S MOST PROMINENT CITIZEN CONDEMNS HIS COUNTRY'S ROGUE CITIZENSHIP BY INVESTMENT PROGRAM, AND DEMANDS REFORM FROM ROOSEVELT SKERRIT

       

IF YOU READ ANYTHING THIS WEEK, REGARDING CITIZENSHIP BY INVESTMENT IN THE EASTERN CARIBBEAN, READ THIS:

Dear Hon. Prime Minister and Hon. Leader of the Opposition

Re: A CBI Programme Completely out of Control

I write with profound regret to state that, despite all efforts on my part and, I am sure, on the part of others, the current state of the country's CBI programme and related development projects is untenable.

ILLICIT MONEY

Although it lies squarely within the Prime Minister's power and purview to stop it, and despite my thirteen letters over seven years enclosing hundreds of pages of evidence, our major CBI projects continue to be funded by illicit money. Our principal developers, led by MMC, are breaking Dominica's laws daily by offering illegal discounts on citizenship. My last letter of 21 October 2024 contained over forty pages of evidence, demonstrating that approximately 80% of the CBI transactions surveyed were illegal. More recently, through my investigative channels, I have again surveyed the market and, of the developers and service providers reviewed, 100% demonstrated illegal pricing, averaging a 55% discount on the legal price. In previous letters I shared the relevant evidence of illegal pricing with the Prime Minister, hoping and expecting that he would act. I do so again, attaching previous letters along with the most recent evidence referenced above, in the expectation that it will now be acted upon.

DETRIMENTAL ARRANGEMENTS

The developer of the cable car project, ABL Holdings Ltd., has been allocated over 400 citizenships to finance the project and granted a 999-year lease over lands in our Morne Trois Pitons National Park, a UNESCO World Heritage Site, with no defined annual lease rent, concession fee, revenue share, or other recurring benefit to the Government. In other words, the State is effectively providing financing through citizenship, while the developer receives, in substance, freehold ownership of strategic national assets for the next 35-40 generations, even though ABL Holdings Ltd. is majority-owned by a BVI company with undisclosed shareholders.

ILLEGAL CONSTRUCTION

he Prime Minister is aware, as we all are, that the airport, cable car and marina projects do not have formal and final planning approval. This has been confirmed to me in writing by Physical Planning as at 26 January 2026 for the cable car and marina projects, and as at 5 March 2026 for the international airpor project, and these projects have all been under construction for between two and three years. Our major infrastructure projects are being funded through illicit transactions, structured through opaque and detrimental arrangements, and are being constructed in violation of our planning laws.

DELIBERATE OPACITY

t appears that few, if any, members of Cabinet, far less Parliament, have had the opportunity to review debate and provide feedback on contractual arrangements with MMC, ABL and Range, the country's primary CBI infrastructure development partners. None of these developers and related projects-worth billions of dollars- has gone through a competitive bidding or tender process. There is no periodic project-level public information on citizenships sold, monies raised, monies deployed, or the payment of monies due to the Government. These issues are closely connected to the misuse of CBI revenues and, in my view, warrant separate, detailed examination in their own right at the appropriate time.

CONSEQUENCES

Passport volumes surged after Maria, driven in large part by illegal discounting that undercut Dominica':s official CBI programme. EU-derived data indicate that Dominica granted about 34,596 CBI passports in just ive years (2018-2022), followed by another 9,539 in 2023 and 5,484 in the first half of 2024. Taker together, this amounts to at least 49,619 passports from 2018 to mid-2024-more than in all prior programme history combined-- on the back of a high-volume, heavily discounted model that systematically drained lawful revenue from the Treasury, channelled billions into the hands of third-party developers, and left Government's EDF (Economic Diversification Fund, or direct investment) optior uncompetitive. The effects are visible in the Treasury's chronic inability to meet Parliament-approvec budgets for basic services, from solid waste and tourism to health and education. The loss of UK visa-free access and the heightened risk of EU visa-free suspension reflect, in no small measure, the unprecedented flow of economic citizens relying on CBI passports and arriving at UK and EU borders expecting visa-free entry. The tightening of US visa rules for Dominicans is part of the same pattern of international concerr about the integrity of CBI programme.

A MEANS TO AN END?

It is neither reasonable nor acceptable that, to develop Dominica--to build an airport, a cable car, a marina and other infrastructure assets --we must break our own laws and hand over our future to interests that are not aligned with Dominica's, under a veil of secrecy and opacity. Development anc integrity are not, and must never be, mutually exclusive. If this reckless, lawless course is seen as a means to an end, are we, as a nation, to feel proud that the island's critical infrastructure has been built on a foundation of ilicit money, illegal construction and opaque, detrimental arrangements? Or will we, in the, words of Matthew 7:24-27, be remembered as the foolish who built our house on sand?

NOWHERE ELSE TO TURN

The Prime Minister knows that my efforts over the past seven years have been sincere, made in good faith and with only the best interests of the country at heart. After a dozen letters and several meetings, I hope vou will both agree that I have fullv exhausted my--now clearlv naïve--optimism and hope that the Prime Minister would act to reform our hijacked CBI programme and, in so doing, steer our country onto the right development path.

At the 25 March 2026 press conference, in response to a journalist's question regarding discounting, the Prime Minister stated: "With regards to the CBI and the allegations of underselling, the reality is anybody who violates the provisions of the CBI law, the CBI regulations, will be taken to task and if we have evidence of that taking place, then those persons who would have gotten citizenship, that means that their citizenship would be immediately revoked, simple as that. And those who engaged in it, their icences would be revoked, and the law makes provision for fines. We've heard those things, it's a matte for us to get the evidence and to have this thing prosecuted properly.

The evidence has been in front of the Prime Minister since 2019, yet he has not lifted a finger to stop it and his inaction has been the wind in the sails of the serial violation of our laws and the steady depletior of our Treasury. While I acknowledge that there has been a tightening of the laws, this is futile if nc decisive action is taken under those laws Let us be clear, and those who have managed the CBIU for years can attest to this: at any time, the Prime Minister could have brought this to a halt within 48 hours--if he had wanted to.

IN CLOSING

I am therefore formally requesting a hearing with Parliamentarians to look at and discuss the issue: raised. I propose that this could be done either through the setting up of a Special Committee of the whole House for the purpose of looking at the issues, or a formal meeting otherwise at another suitable venue. I wish to have in attendance up to six concerned citizens, including the President of the Bar Association, Mrs Noelize Knight-Didier, Deacon Val Cuffy, trade unionist Mr. Thomas Letang, and three additional representatives from the private sector of my choosing. The presence of all members of Cabinet and Parliament is requested, including the heads of the FIU and CBIU. Should this request for a hearing be refused, or the outcome yield no restorative results, 1 will pursue all available legal options, including judicial review and the petitioning of a commission of inquiry and, through one or both, an independent forensic financial audit of the CBI programme over the last ten years. Should I not receive a response within three (3) weeks of the date of this letter, this will be taken as a refusal of my request. This letter, including my request for a hearing, is copied to Cabinet, Parliament, the FIU and the CBIU, in the hope that others will now act where the Prime Minister has chosen not to.

THE EU MUST IMMEDIATELY SUSPEND DOMINICA'S VISA-FREE STATUS, DUE TO UNIVERSAL ILLEGAL DISCOUNTING OF DOMINICA CBI PASSPORTS IN THE MIDDLE EAST

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• Dominica priced its illegal, discounted passport at $90,000 to match the entry prices of São Tomé and Príncipe and Nauru. This allows them to camouflage Dominica's illicit promotion within legitimate program pricing.

• Agents are aggressively promoting Dominica's discounted passport, using the EU's 2028 deadline as a marketing incentive for clients to seize this opportunity while it lasts.

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• While the Pakistani agent mistakenly revealed the country's name alongside the price, others are being highly cautious. However, once you contact them, they reveal that the $90,000 price is for Dominica.

• Unless the EU takes immediate action to temporarily suspend Dominica's visa waiver, this practice will unfortunately continue. In fact, the EU has unknowingly given this discounting practice an adrenaline boost by setting a 2028 deadline without matching it with firm enforcement action.