US Includes Seven CBI Countries in Travel Ban Memorandum

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Seven nations with active citizenship by investment programs face potential visa bans under a new US State Department directive.

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President Donald Trump is moving to expand the United States’ travel ban to include citizens of 36 countries, among them six nations operating citizenship by investment (CBI) programs.

According to the internal State Department memo reviewed by the Washington Post, the countries of Antigua and Barbuda, Dominica, Saint Kitts and Nevis, Saint Lucia, Vanuatu, Cambodia, and Egypt are in the draft memorandum. This represents the most pointed US action yet implicating the investment migration industry in national security policymaking.

The full list of 36 countries includes:

• Angola
• Antigua and Barbuda
• Benin
• Bhutan
• Burkina Faso
• Cabo Verde
• Cambodia
• Cameroon
• Democratic Republic of Congo
• Djibouti
• Dominica
• Ethiopia
• Egypt
• Gabon
• Gambia
• Ghana
• Ivory Coast
• Kyrgyzstan
• Liberia
• Malawi
• Mauritania
• Niger
• Nigeria
• Saint Kitts and Nevis
• Saint Lucia
• São Tomé and Príncipe
• Senegal
• South Sudan
• Syria
• Tanzania
• Tonga
• Tuvalu
• Uganda
• Vanuatu
• Zambia
• Zimbabwe

The current memo marks an escalation from earlier this year, when similar reports emerged in March claiming the administration had drafted a travel ban list targeting many of the same countries.

State Department spokesperson Tammy Bruce categorically denied those reports, stating “there’s no list” and dismissing the media coverage as inaccurate.

The emergence of another State Department memo now suggests the administration moved from denial to formal action on similar targets. Several of the same CBI countries now reappear in the official directive.

The administration has granted affected countries 60 days to address “deficiencies” in document security, data sharing, and visa overstays.

Countries that do not meet the new requirements face full or partial suspensions on the entry of their nationals.

The memo identifies varied benchmarks that, in the administration’s estimation, these countries fail to meet. Some have “no competent or cooperative central government authority to produce reliable identity documents or other civil documents,” or they suffer from “widespread government fraud.”

Others have large numbers of citizens who overstay their visas in the United States.

The memo explicitly lists “the availability of citizenship by monetary investment without a requirement of residency” as one of the reasons for potential restrictions, making CBI a direct policy target.

It notes “claims of antisemitic and anti-American activity in the United States” by individuals from these countries.

David Lesperance of Lesperance & Associates believes “this memo shows that the US is well aware that nationals of otherwise targeted countries are trying to shake the stigma of their prior nationalities by buying passports in the Caribbean and Vanuatu.”

The memo also states that “countries willing to accept third-country nationals who were removed from the United States or enter a ‘safe third country’ agreement could mitigate other concerns.”

CBI Programs Under Scrutiny

The inclusion of CBI jurisdictions reflects a more direct US linkage between investment migration programs and perceived national security risks.

While US officials have previously criticized certain aspects of CBI programs, this marks the first instance of such programs being explicitly referenced in a policy instrument with immediate visa implications.

Most of the Caribbean’s major CBI jurisdictions appear. Notably absent, however, is Grenada, the only Caribbean country with both an active CBI program and an E-2 visa treaty with the United States. That treaty allows Grenadian nationals to apply for long-term investor visas to the US, but it does not explain the exclusion: Egypt also maintains an E-2 treaty and is nonetheless included.

Lesperance also points out that “the list must have been compiled before Nauru introduced their program, as they are not listed.” He further observes that “Turkey is not on the list, which is probably a function of its size and geopolitical importance to the US.”

Uncertainty Over Implementation

Neither the White House nor the State Department has clarified when the restrictions would take effect or which visa categories they would cover.

The memo indicates that exceptions could apply for lawful permanent residents, existing visa holders, and cases deemed in the US national interest.

Caribbean governments have introduced reforms over the past two years to align their programs with heightened international due diligence standards, often in consultation with US agencies.

The decision to include multiple Caribbean CBI states, despite such efforts, signals a broader shift in how Washington assesses the risks posed by countries offering economic citizenship.

The scope and legal durability of the forthcoming restrictions remain unclear, but the direction is unmistakable: US immigration policy now explicitly targets investment-based citizenship pathways.