FACING AN EXISTENTIAL CRISIS; THE CARIBBEAN CBI STATES PROPOSE DETAILS FOR REFORM THROUGH SELF-REGULATION; TOO LITTLE, TOO LATE?

Sixteen months after five Caribbean countries that offer Citizenship by Investment (CBI/CIP) offered to create an interim regulatory commission for their industry, detailed draft legislation has been published by the Eastern Caribbean Central Bank, establishing an Eastern Caribbean Citizenship by Investment Regulatory Authority. Readers unfamiliar with the details can review the draft proposal here: https://lnkd.in/euYjD9sF

A July 16, 2025 deadline has been set for the submission of public comments, and Ratification of any final version of the Agreement, as and if amended, is required by all the CBI states. We note that the Government of Saint Lucia delayed placing its signature on the original Memorandum of Agreement for several months, and there is no indication that any deadline exists for Ratification by the respective states, meaning that any effective date, after all negotiation of the provisions has been agreed to, could be substantially delayed.

Given that such regulatory reform is being considered in the face of what could be considered existential threats to what is understood to be the primary benefit of CBI programs, visa-free entry to the European Union, and direct action, by the United States, to block all visa entry into America of citizens from four of the EC CBI states, we ask whether the proposal is not being made in Good Faith, and only as a half-hearted belated effort now to respond to external action, coming years too late to block accountability for program administration failures, and threats to the National Security of other jurisdictions, has been raised. Additionally, whether there will actually be bona fide international enforcement of the regulatory authority's provisions, in states with rampant corruption, a long history of allowing money laundering activities, and being under undue foreign influence, is a major concern.

Whether the actions of external forces render these proposals moot we cannot say, but unfolding events in the international arena will soon have a direct, and most likely adverse, effect on the second passport industry as a whole, which Caribbean states' efforts may be unable to adequately respond to, and which may be existential in nature. We will be monitoring the situation, and will be reporting on al developments as they occur.