Caribbean States to Enact CBI Regional Regulator in September

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Patrick Peters and Kevin Hosam see ECCIRA boosting credibility but warn delays loom if five parliaments don’t ratify in September.

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Five Eastern Caribbean nations will enact legislation in September 2025 establishing the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA), according to the Organisation of Eastern Caribbean States (OECS). 

This marks the transition from two years of consultation and drafting to binding regional oversight for citizenship programs that generate billions in revenue for Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia.

The legislation implements the comprehensive 92-article Agreement Establishing ECCIRA, which introduces mandatory 30-day residency requirements, annual application quotas, enhanced due diligence standards, and unprecedented enforcement mechanisms across participating jurisdictions. 

Establishing ECCIRA results from years of intensive international negotiations that began with the inaugural US-Caribbean Roundtable in February 2023. 

The regulatory authority addresses mounting pressure from Washington, London, and Brussels over program integrity while aiming to preserve revenue streams essential for small island developing states facing climate change and economic vulnerability.

Parliamentary Ratification Across Five Jurisdictions

September’s enactment timeline reflects complex coordination across five sovereign parliamentary systems, each requiring domestic legislative approval before ECCIRA gains binding authority. 

Patrick Peters, CEO of ClientReferrals, notes that “the regulator is an initiative that is being centrally managed by the ECCB, and the five governments will not have to sign on, although there may be consequences for not signing on. It is possible that we see some disagreements on the major issues.”

Kevin Hosam, Founder and Chairman of EC-Holdings, believes “all of these governments need to go to parliament to pass it” before the regulator can become operational. 

The agreement specifies entry into force “on the thirtieth day following the date of deposit of the fifth instrument of ratification,” meaning all five participating states must complete their domestic legislative procedures for ECCIRA to operate with full authority.

The implementation process involves establishing physical infrastructure across participating jurisdictions, with Hosam noting the regulator “will have an office in each of the islands” and “will have to hire staff.” Once parliamentary approval is secured, he expects implementation “within a couple of months, you will start seeing some of these things that they’ve proposed being implemented.”

Legal Drafting Consultant Lydia Elliott, whom authorities appointed through a competitive selection process in February 2025, crafted the legislation following extensive stakeholder consultations between March and July across all participating jurisdictions. 

The Interim Regulatory Commission (IRC), comprising representatives from the five nations plus regional institutions, oversaw the technical preparation under direct supervision from heads of government.

Eastern Caribbean Central Bank Governor Timothy Antoine chairs the IRC, with Lieutenant Colonel Edward Croft of Antigua and Barbuda serving as deputy chair. The commission conducted broad stakeholder engagement involving government officials, industry participants, international partners, and civil society representatives before finalizing the legislative framework.

International Compliance and Economic Sovereignty

September’s enactment addresses escalating international pressure following years of scrutiny over program security and regulatory inconsistencies. The United States, which is considering four Caribbean citizenship by investment (CBI) countries under a new potential travel ban, and the United Kingdom, which revoked Dominica’s visa-free entry, provided feedback on draft legislation shared in July 2025, marking a shift toward cooperative oversight after periods of adversarial relations.

European Union pressure has intensified through proposed legislation allowing suspension of visa-free entry for countries operating citizenship programs, adding urgency to regional coordination efforts. The regulatory framework aims to address these concerns while preserving economic instruments that have proven vital for Caribbean nations.

Antigua and Barbuda Prime Minister Gaston Browne previously acknowledged the economic realities facing small Caribbean states during international negotiations, noting that resistance to international demands might trigger financial sanctions where “all they have to do is issue a sanction stopping us from using the banking system, and then we are in trouble.”

Saint Kitts and Nevis Attorney-General Garth Wilkin characterizes the legislation as the culmination of “a historic reform effort that began in December 2022, when Saint Kitts & Nevis took bold, first-in-region steps to reposition the CBI industry for sustainability, credibility, and resilience.” He says the regional regulator closes “the loop on those reforms” as a governance safeguard for economic security and global reputation.

Peters believes certain jurisdictions are well-positioned for the regulatory transition, noting that “Antigua will have an easier time in this transition given the fact that their program has already been operating with the major proposals, e.g., residency, enhanced due diligence, JRCC, etc.” He also highlights Saint Kitts and Nevis’ readiness, observing that they “have created a dynamic CIU and program that can adapt quickly and efficiently.”

Despite the positive trajectory, both experts acknowledge that ongoing negotiations may affect final implementation. Peters cautions that “if they don’t resolve some material disagreements on the major issues, it is possible that they don’t all sign on or at least that the signing gets delayed.” 

Hosam notes that “not everything that we’re hearing is set in stone” and believes “the units and governments are talking still amongst each other,” particularly regarding key provisions like the 30-day residency requirement.

Operational Implementation and Industry Impact

ECCIRA will operate through a sophisticated governance structure with several key operational components:

• Governing Bodies: A Council of Ministers and Board of Directors comprising representatives from each state plus nominees from regional institutions will oversee operations. The authority gains unprecedented powers to “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.
• Industry Standards: The regulatory framework establishes binding directives and codes of practice covering marketing standards, application integrity, and vetting quality. Industry participants must obtain pre-qualification certificates from ECCIRA, creating regional licensing standards that enable the authority to eliminate bad actors even when local units resist action.

Industry experts offer contrasting perspectives on the regulatory framework’s effectiveness.

Peters anticipates improved industry oversight, noting that “based on my conversations with the IRC, they definitely intend to watch the way our industry is promoted and have consequences for bad actors. If a firm is blacklisted in one program, it will be blacklisted in all.” This cross-jurisdictional enforcement addresses longstanding concerns about inconsistent agent oversight across participating states.

Hosam raises questions about regulatory reach, observing that “bad apples, they will always remain” particularly among foreign actors operating outside Caribbean jurisdiction. The challenge of regulating international marketing networks remains a key implementation consideration.

ECCIRA possesses comprehensive enforcement powers designed to ensure compliance across participating jurisdictions:

• Financial Penalties: The authority may 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.
• Binding Arbitration: After six months of continued non-compliance, participating states may refer matters to binding arbitration, creating interstate accountability mechanisms unprecedented in Caribbean citizenship program coordination.
• Exit Provisions: The agreement includes provisions allowing governments to withdraw from the regulatory framework with six months’ notice. This flexibility mechanism balances regional coordination with national sovereignty concerns. Hosam, however, questions whether “after a few months, whether business slows down or whatnot, are all governments going to play ball?”

The framework mandates comprehensive information sharing through a centralized database that CARICOM IMPACS manages, storing biometric data and application histories while establishing 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.

The agreement also includes provisions allowing governments to withdraw from the regulatory framework with six months’ notice, though Hosam questions whether “after a few months, whether business slows down or whatnot, are all governments going to play ball?” This flexibility mechanism balances regional coordination with national sovereignty concerns.

Peters maintains an optimistic outlook on the regulatory changes, characterizing them as “not so stringent” overall and viewing the initiative as “an overall positive, bringing more credibility to the Caribbean CIPs and hopefully minimizing the impact of bad actors.” He describes the current period as “an exciting time, and with change comes opportunities.”