Dominica’s Citizenship by Investment Unit (CIU) has suspended the processing of applications from Iranian nationals, according to a memorandum dated March 23, 2026, and circulated to authorized agents. The suspension takes effect today.
The CIU will accept Iranian nationals only if they meet all three of the following conditions: They have not lived in Iran for at least ten years, they hold no substantial assets there, and they have not performed any business or similar activity, in whole or in part, in or with Iran. Gregory McDougall, Officer in Charge of the CIU, signed the memorandum on behalf of the Director.
From Banned to Welcome to Restricted, in Four Years
Dominica’s treatment of Iranian applicants has shifted repeatedly over the past half-decade. Before May 2022, Iranians appeared on the program’s restricted nationalities list and could apply only under conditions identical to those now being reimposed. That month, the CIU lifted the restriction entirely, making Iranians eligible without preconditions.
The open door lasted barely a year. In July 2023, Dominica imposed mandatory interviews and enhanced due diligence fees on Iranian applicants, with costs for a family of four reaching up to US$70,000. Agents with Iranian clients scrambled to file applications within the five-day window before those fees took effect.
The memorandum goes further still. Where enhanced due diligence previously allowed Iranians with ties to Iran to apply at a higher cost, the suspension now bars any Iranian who has lived in the country, held assets there, or conducted business with Iranian counterparts within the past decade.
Wartime Backdrop
The timing tracks closely with the ongoing US-Iran military conflict and a broader international tightening of posture toward Tehran. The US Treasury has sanctioned Iranian officials and shadow banking networks in recent months, and OFAC on March 20 issued a temporary general license releasing approximately 140 million barrels of Iranian oil stranded at sea to ease wartime price pressure.
Dominica itself already faces sustained US scrutiny over its citizenship by investment (CBI) program. President Trump’s December 2025 proclamation imposed partial travel restrictions on Dominican nationals, explicitly citing the CBI program as the rationale.
Washington then froze immigrant visa processing for 75 countries in January 2026, Dominica among them. Weeks later, the State Department cut US visa validity for Dominican nationals from ten years to three months.
The EU, separately, warned in December that operating a CBI program “in itself” constitutes grounds for visa suspension. EU reports have specifically criticized Caribbean CBI jurisdictions for granting citizenship to Iranian nationals who subsequently changed their names.
Narrowing Options for Iranian Applicants
Dominica’s suspension further reduces the already limited set of Caribbean CBI programs available to Iranians. Saint Kitts and Nevis and Saint Lucia both ban Iranian applicants outright, without exceptions.
Grenada and Antigua and Barbuda each apply conditional restrictions: Iranians may qualify only if they emigrated before the age of majority or maintained permanent residence in approved Western or Gulf jurisdictions for at least ten years, with no economic ties to Iran.
Among the Caribbean five, Dominica had served as the most permissive option since 2022, accepting Iranian applicants subject to enhanced due diligence rather than barring them conditionally.
That distinction no longer holds. Iranians who can demonstrate a full decade of separation from Iran remain eligible in principle, but this population narrows by design: The conditions function less as an accommodation and more as a near-ban dressed in conditional language.
For a full breakdown of which nationalities each CBI program restricts, consult the complete CBI banned nationalities overview.
Dominica’s Restricted Nationalities Regime
The three conditions Dominica now applies to Iranians mirror those it applies to nationals of North Korea and Sudan. Belarus, Russia, Northern Iraq, and Yemen face outright bans with no exceptions. The CIU has revoked 68 CBI passports since 2024 for fraud, with Iraqis comprising the majority and Iranians accounting for 6% of those affected.
Dominica offered no public explanation for the policy shift beyond the memorandum itself. Whether the suspension signals a permanent realignment or a temporary wartime measure depends on developments that Roseau does not control.
