ADDITIONAL ELEVENTH HOUR REFORMS BY CARIBBEAN CBI STATES WILL STILL BE INSUFFICIENT TO SAVE THE DAY, AND THE INVESTORS PROBABLY WON'T FOLLOW THEM ANYWAY

The Eastern Caribbean CBI states, visibly anxious to avoid both the loss of visa-free entry to the Members of the European Union, and total travel ban to the United States, added a number of proposed reforms to those in the recently proposed regulations. The problem is, they are probably insufficient to stop both the EU and the US from taking action which will not only affect the central benefits of EC passports, but deter future investors from considering them altogether.

First, they propose a minimal 30 days of actual residency over a five year period, in response to EU and US concerns. Not only is that woefully insufficient to address them, most UHNW buyers will either disregard them totally, or quietly exit their "residence" during period of occupancy, using private transportation, while continuing the fiction that they are actually living in those luxury properties during that time. They will, in essence, cheat, knowing that the CIUs, and the powerless new regulatory body will ignore their violations.

Second, this concession to require buyers learn about the culture, history, language and governance of the Caribbean state who passport they have purchased is pure nonsense. Don't expect wealthy, sophisticated (and busy) passport purchasers to take what amount to remedial courses in what amounts to basic citizenship. They will not leave their own businesses and lives to sit in such classes.

Finally, proposing annual caps on the number of CBI passports issued sounds good, but given the level of systemic corruption we have seen among the five CBI states, outright selling quantities of passports to Chinese company that vastly exceed the amount of funding needed to build minor structures on site, how can anyone trust these CIUs, and indeed the Prime Ministers of the EC states, to follow those restrictions?

These new promises, which simply will not be kept, are merely keen-jerk reactions of frightened Eastern Caribbean government leaders, who are futilely pushing back against the incoming Tsunami of an existential, external response to years of fraud, corruption and money laundering. It will not work, gentlemen.