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Caribbean Nations Propose 30-Day Residency Requirement, Annual CBI Application Caps

New potential rules could force CBI applicants to stay to play, or risk losing out for failing to prove “genuine links.”

New potential rules could force CBI applicants to stay to play, or risk losing out for failing to prove “genuine links.”

A draft agreement between the Caribbean Five, Antigua and Barbuda, Dominica, Grenada, Saint Kitts & Nevis, and Saint Lucia, proposes the creation of a regional regulatory authority to oversee citizenship by investment (CBI) programs.

The proposal, dated July 1, 2025, outlines plans to introduce mandatory residency requirements, annual limits on approved applications, and uniform administrative standards. The authority would monitor compliance, enforce rules, and coordinate policy across participating jurisdictions.

The 92-article Agreement Establishing the Eastern Caribbean Citizenship by Investment Regulatory Authority (EC CIRA) represents the most ambitious attempt yet to coordinate regional CBI oversight following years of international pressure from the United States Treasury and European Union.

Mandatory Physical Presence

The most transformative provision requires all new citizens to maintain “being physically present within the territory of the Participating State for an aggregate of at least thirty days during or up to any of the first five calendar years after the date of the grant of the certificate of citizenship or naturalization.”

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This marks the first time Eastern Caribbean states (except Antigua & Barbuda) would impose binding residency obligations across their programs.

The requirement extends beyond mere physical presence. Applicants must “participate in a mandatory integration program” encompassing civic education about “the laws, history, and constitutional principles of the Participating State” and cultural orientation activities.

Failure to comply could result in administrative fines “not exceeding ten per cent of the value of the qualifying investment” and potential passport revocation.

Annual Application Caps

The agreement establishes a quota system whereby “the Board shall recommend to the Council a maximum number of applicants who may be granted citizenship by investment in each Participating State in a financial year, based on an annual assessment of global demand, economic impact, national absorptive capacity and reputational risk.”

States would report monthly to the new regulatory authority on approvals granted.

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This represents a departure from the current market-driven approach, where Caribbean states compete for applicants. The caps aim to prevent “over-commercialization” of citizenship and preserve passport value through controlled supply.

Regional Regulatory Framework

The proposed Eastern Caribbean Citizenship by Investment Regulatory Authority would operate with unprecedented powers over participating states’ programs.

The body would “develop, implement and enforce uniform standards and procedures governing the operation and regulation of the industry” while maintaining authority to “conduct investigations, impose sanctions” on violators.

The authority would include a Council of Ministers and a Board of Directors comprising representatives from each state, plus nominees from regional institutions.

Centralized Rulemaking Powers

The Authority gains sweeping regulatory control through its ability to issue binding directives and codes of practice.

The agreement empowers EC CIRA to “by notice in writing, direct a licensee or other authorized, registered, or regulated person and a Competent Authority of a Participating State to take such measures or cease such activities as may be necessary” for compliance.

These directives would function as enforceable regulations covering marketing practices, application integrity, and vetting quality standards. The Authority may also “issue codes of practice relating to licensees and other authorized, registered, or regulated person, the Unit and other competent authorities of a Participating State,” with violations constituting breaches of licensing conditions.

This represents a marked shift from autonomous local interpretation of best practices to centralized rulemaking authority, fundamentally altering the relationship between national CBI units and regional oversight.

Enhanced Due Diligence Requirements

The agreement mandates comprehensive background checks including “identity verification against, national, regional and international watchlists, politically exposed persons databases, and sanctions lists” and “criminal background checks from all jurisdictions where the Applicant has resided or held citizenship within the ten years period immediately preceding the date of the application.”

Mandatory interviews become standard, with applicants required to “undergo a personal interview as a mandatory component of the due diligence and application assessment process.” The requirement extends to dependents over 18 and those over 12 who raise concerns during vetting.

Regional Enforcement and Investigation Powers

The Authority would wield direct policing powers previously absent from Caribbean CBI coordination.

Inspectors may “require the production of documents, records, or data” and “enter or inspect any premises, owned, leased, or occupied by the licensee or other authorized or registered person” during investigations.

The agreement grants investigators authority to “seize, remove or impound any documents, records, or electronic storage devices where necessary” and even “seize any relevant equipment or other apparatus” with appropriate warrants.

This enforcement capability extends to region-wide license suspensions and revocations, enabling EC CIRA to eliminate bad actors even when local units resist action.

Passport Validity Overhaul

The proposal effectively creates a two-tier system where “a passport issued to an Applicant or citizen shall carry an initial validity of five years, renewable for a full ten-year period only upon certification by the Unit or other Competent Authority of a Participating State that the requirements under this Article have been fulfilled.”

Three countries would need to alter their current passport issuance practices. Saint Kitts & Nevis, Saint Lucia, and Dominica currently issue ten-year passports from the start, but would need to switch to five-year initial terms under the proposal.

Only Antigua and Barbuda already operate a similar system with five-year initial validity extending to ten years upon renewal, while Grenada issues five-year passports throughout but would gain the option for ten-year extensions upon compliance verification.

The compliance-linked renewal system prevents citizenship from becoming a one-time transaction, creating ongoing obligations for residency, integration, and other post-naturalization requirements throughout the citizen’s relationship with their adopted country.

Escrow Account Management

The draft introduces mandatory escrow requirements whereby states must ensure that “qualifying investments or financial contributions required under a Regulatory Law are deposited into a designated escrow account, established and managed as specified by the Authority.”

This centralizes financial oversight and prevents premature release of investor funds before due diligence completion.

The Authority would issue guidelines regarding “the form and content of an escrow agreement” and specify “approved institutions for holding an escrow account,” creating standardized financial safeguards across all participating programs.

Information Sharing and Denied Applications

Perhaps most importantly for pan-Caribbean integration, the agreement establishes that states “shall not accept, process, or approve any application for citizenship by investment from an individual whose application has been denied by another Participating State” except under exceptional circumstances with written authority approval.

A centralized database managed by CARICOM IMPACS (the regional security and crime prevention agency) would store biometric data and application histories, creating an unprecedented regional intelligence-sharing mechanism for CBI oversight.

Pre-qualification Certificate System

The agreement introduces mandatory pre-qualification for all industry participants. States “shall not accept an application for, nor issue, renew or transfer, a license or other authorization for any agent, authorized agent, marketing agent, promoter, sub-agent, developer, due-diligence provider or escrow agent unless the applicant for the license holds a current pre-qualification certificate granted by the Authority.”

This creates regional licensing standards and enables the Authority to suspend or revoke certificates where holders “no longer satisfy a fit-and-proper test” or “supplied false or misleading information.”

Enforcement Mechanisms

The Authority would wield substantial enforcement powers, including the ability to impose “a reduction of the annual maximum number of approved applicants” and “a pecuniary levy of a prescribed amount, per unrectified breach, payable into a Compliance Fund” for non-compliant states.

After six months of continued non-compliance, any participating state may refer matters to binding arbitration, creating interstate accountability mechanisms unprecedented in Caribbean CBI coordination.

Legislative Path to Implementation

The agreement requires complex multilateral ratification before taking effect. Government representatives must first sign the agreement to indicate “initial political support and intent to participate,” though this constitutes merely “the handshake, not the contract.”

Each participating state must then formally ratify the agreement through its own parliamentary process, typically involving tabling in parliament, committee review, and passage of ratification legislation.

The agreement specifies entry into force “on the thirtieth day following the date of deposit of the fifth instrument of ratification,” meaning at least five states must complete their domestic legislative processes.

States may implement provisions provisionally through Article 90, allowing operational aspects like board formation and fee collection to commence while formal approval proceeds. The agreement permits later accession by other Caribbean states meeting prescribed standards.

The success of ratification efforts across five different parliamentary systems will determine whether this regulatory revolution proceeds from proposal to binding law.

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