In April 2025, 13 investors and their dependents lost citizenship of Saint Kitts and Nevis. Their marketing agents had sold them the program below the statutory minimum, and a Ministry of National Security investigation covering 158 applications ended with a deprivation order, two international marketing agents blacklisted, and no refunds.
Picking an agent is the decision that carries a citizenship by investment (CBI) application on its back. Get it wrong and the file, the money, or both can go.
The warning signs themselves are well established. What is new in 2026 is that the tools vetting an agent are getting sharper.
These licensing regimes vary widely. Five Caribbean programs license their agents, publish the lists, and are now handing that authority to a shared regulator. On the other hand, open markets such as Turkey run no central registry at all, so verification there relies on bar admissions, company registrations, and track record.
Start With the Register
Seven programs publish updated lists of authorized agents. IMI maintains an aggregated index of approved and blacklisted agents across those jurisdictions.
Absence from a list usually means one of three things: the firm lost its authorization, never held it, or works as a sub-agent under someone who does.
A certificate on a website proves very little and is easy to fake, so ask for the license number instead. Real licenses come with a paper trail an applicant can check: Grenada, for one, prints every appointment in its official Government Gazette, with a license number in the format GCBI-MA-089 and the signature of the Investment Migration Agency (IMA) chief executive. Saint Lucia publishes numbers beside the named individual who holds them.
Knowing what a genuine record looks like is the point. An agent who cannot produce a number matching the published register has already answered the question of whether he is legitimate or not.
A license check is where due diligence starts, not where it ends. No register vets how a firm will actually handle the file it is handed.
Before signing, applicants should establish who will personally manage the application, how long the firm has operated in investment migration, and what screening it runs before accepting a client.
Equally telling are how client funds are held, whether the firm carries professional indemnity insurance, and whether its physical presence in the jurisdiction and its track record can be independently verified.
A name on a government list is a floor. An application of this consequence should never rest on that alone.
Two Tiers of Agent, One Can File
Applicants routinely miss the difference between the firm they deal with and the firm that actually lodges the application.
🇬🇩 Grenada draws it sharply. Applicants contact an authorized international marketing agent, the client-facing firm, which then works with an authorized local agent, the only party permitted to submit to the government. Applicants may not contact local agents directly at all.
🇦🇬 Antigua and Barbuda follows a similar split. The representative markets the program and pre-screens the applicant, then engages a licensed agent based in Antigua who reviews the file and submits it in person with the required payments.
🇩🇲 Dominica runs three tiers: authorized agents at the top, then licensed promoters and sub-agents beneath them. The authorized agent must register every promoter and sub-agent with the government, monitor their activities and marketing, and carry responsibility for everything they publish. If a promoter makes a promise nobody can keep, the licensed agent above him wears it.
Where the Agent is Based
🇩🇲 Dominica sets the strictest local presence rules in the region. Authorized agents must be citizens of the Commonwealth of Dominica, must reside there or keep a main registered office there with a minimum of three staff, and must pass background checks by independent due diligence firms and the Joint Regional Communications Centre (JRCC).
Disqualification runs wide. A firm does not qualify if any owner, partner, shareholder, or director sits in Parliament or works for the Citizenship by Investment Unit (CBIU), or is the spouse, partner, or child of someone who does, or has been convicted of or is under investigation for fraud, money laundering, or other financial crimes anywhere in the world.
🇱🇨 Saint Lucia requires that an authorized agent maintain a place of business on the island, sign a written agreement with the Citizenship by Investment Board, and produce evidence of professional qualifications, resources, experience, and integrity.
🇳🇷 Nauru publishes the plainest criteria of any program: a clean criminal record extending to shareholders and directors, prior expertise in investment migration, and unrestricted access to a recognized due diligence database.
A Listing is Not a Clean Record
Firms get added to and removed from these registers, sometimes within months, so a list checked in January may not reflect the market in June. Applicants should check the list once before the first conversation, and again before any money moves.
🇰🇳 Saint Kitts and Nevis publishes a blacklist and keeps a separate section for suspended agents. It also runs a probation tier that most coverage ignores: the Citizenship by Investment Unit (CIU) may keep accepting applications from an agent on probation while monitoring his conduct, with revocation available if the conditions go unmet.
An agent can appear on the approved list and still be under active review. IMI’s CBI Agent Risk Checker scores a prospective agent against these criteria in a few minutes.
Discounts Are the Loudest Warning
Selling below the statutory minimum is what cost those 13 Saint Kitts investors their citizenship, and it remains the single most reliable indicator that something is wrong.
The rule is not ambiguous anywhere in the region. Dominica’s CBIU told agents in October 2018 that special offers and discounts were contrary to law and prohibited any claim in January 2022 that citizenship could be had below the prescribed minimum. In 2024, the country’s Prime Minister warned that legislation would let the state revoke citizenships obtained below the threshold. All five Eastern Caribbean programs have since harmonized at a $200,000 regional floor.
Governments and due diligence providers set their own fees and publish them. An agent has no authority to discount what he does not control, so a quote below the published minimum is either a margin giveaway or a sign that the full amount is not reaching the government.
The line worth drawing runs between the agent’s fees and the government’s. A firm may discount its own professional fees, and doing so transparently signals nothing sinister. No agent can reduce, rebate, or route around a statutory investment, contribution, or government fee.
The protection is paperwork. A fully itemized quotation separating the qualifying investment, government fees, due diligence costs, and professional fees leaves nowhere for a fake discount to hide, and economics that look too good to be true should be treated as exactly that.
The Caribbean Regulator Arriving This Year
Five governments signed the agreement establishing the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA) in September 2025, and all five parliaments have since enacted it into national law. A single 92-article framework now covers Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia.
ECCIRA will license and monitor agents, developers, due diligence providers, and escrow agents across the bloc. It can fine up to $250,000, revoke licenses, maintain regional registers, and publish annual compliance reports from a headquarters in Grenada. Operations are expected to begin in September, once Saint Lucia deposits the ratification the other four states have completed.
Grenada’s implementing bill, tabled on 28 July, shows what that looks like in practice. A local committee would assess applicants against fit-and-proper criteria, then send the file to ECCIRA, which gets 30 days to decide; a marketing license granted without its no-objection notice would be void, and any registration issued after a refusal would be null.
One consequence is still unsettled. If every participant needs regulator approval, the sub-agent tier that currently sits beneath licensed agents may not survive in its present form, which would change who an applicant is actually dealing with.
Outside pressure is building at the same time. A White House proclamation effective 1 January 2026 placed partial visa restrictions on Antigua and Barbuda and Dominica, and the European Commission wrote to all five states on 25 June asking that they phase out their programs by 1 June 2028. However, nothing has closed, no visa-free access has been withdrawn, and pending files still stand.
A serious agent raises all of this before being asked, alongside what happens to an investment if a program is suspended mid-application. Silence on it is the more telling signal.
