By Bayat Group
Recent developments in European legal circles have spotlighted citizenship by investment (CBI) programs worldwide. In particular, the Court of Justice of the European Union’s (CJEU) ruling against Malta’s investor citizenship programme has reignited concerns over what some critics describe as the “commodification” of citizenship. The court’s decision asserts that citizenship should not be granted solely based on financial investment, especially when that citizenship grants access to rights across a supranational bloc like the European Union (EU).
This renewed scrutiny has also stirred broader media narratives that conflate all CBI programs into a single, problematic category. But this is a mischaracterisation — and an increasingly dangerous one. “Not all passports are created equal”, and not all CBI programs function under the same assumptions, frameworks, or goals.
It is critical to draw a clear distinction between different models of investment migration. The Caribbean, particularly countries like St Kitts and Nevis — widely regarded as the birthplace of modern CBI — offers a fundamentally different approach, one rooted not in supranational access but in national sovereignty, transparent governance, and responsible economic development.
The EU and Caribbean CBI programs
The European Commission and the CJEU have long been concerned about the idea of “golden passports” within the EU, and for good reason. Citizenship in one EU member state effectively grants an individual access to live, work, and move freely across all 27 member states. This unique feature of EU citizenship — its supranational nature — places the responsibility of one member state’s citizenship decisions on the entire Union.
In contrast, the CBI programs offered by Caribbean nations such as St. Kitts and Nevis, Antigua and Barbuda, Dominica, Grenada, and Saint Lucia confer no such rights. Citizenship in these countries is precisely that — citizenship of a single sovereign state. While visa-free travel to many countries, including Schengen states, may be a benefit, it is not equivalent to the right to reside, work, or settle in those countries. These visa arrangements are negotiated bilaterally and can be suspended or revoked unilaterally by any country if concerns arise.
As the Citizenship by Investment Unit (CIU) of St Kitts and Nevis recently stated: “We do not sell access to any other state; we offer inclusion into our own.” This point is more than rhetorical. It reflects the core legal and ethical structure of the Caribbean CBI model: it is a sovereign offering, carefully regulated within national borders and explicitly not designed to circumvent the immigration systems of other nations.
Governance, reform, and responsibility
In recent years, Caribbean countries have made sustained efforts to enhance the credibility, transparency, and due diligence mechanisms of their CBI programs. Nowhere is this more evident than in St Kitts and Nevis, where the government has implemented comprehensive reforms to raise standards and bolster international confidence.
Key reforms include:
- The government has enhanced Due Diligence. Background checks are now performed by multiple independent international firms, with additional vetting mechanisms for high-risk applicants.
- The Minimum Investment Thresholds have been increased under the historic Memorandum of Agreement (MOA) signed in 2024 among the five OECS countries with CBI offerings. Governments have agreed to harmonise minimum investment levels to prevent unhealthy competition and maintain programs’ integrity.
- The CIU of St Kitts and Nevis has transitioned into a more independent, corporate-style body to improve operational efficiency and accountability.
- Sustainable Island State Contribution (SISC): Introduced in 2023, this innovative mechanism directs investment into national development projects, ensuring that the benefits of CBI reach local communities and support sustainable growth.
These reforms are not cosmetic — they are structural, and they send a clear message to international partners: the Caribbean is committed to doing this right.
Toward a unified Caribbean standard
Perhaps the most compelling evidence of this commitment is the recent move to establish a Regional Regulator for CBI programs among the five OECS member states with active citizenship schemes. In May 2025, the draft legislation for this regional authority was reviewed at the Eastern Caribbean Currency Union (ECCU) legal meeting in Anguilla. This milestone follows months of regional cooperation and public consultation.
The proposed regulator would be a legally independent body tasked with:
- Issuing unified policies and operational standards;
- Licensing and monitoring CBI agents and promoters;
- Approving due diligence frameworks;
- Auditing national CBI units;
- Maintaining a public register of licensees;
- And deterring deceptive or non-compliant practices.
Once enacted, this legislation will mark a major step toward institutionalizing good governance and regional coherence in the CBI industry. It will also send a strong signal to the global community that the Caribbean is not only open for responsible investment but is leading the way in creating a credible, transparent, and sustainable CBI ecosystem.
Rethinking citizenship, responsibly
At a time when global debates around migration, borders, and sovereignty are more polarized than ever, the Caribbean offers a model worth understanding — and respecting. Citizenship, in this context, is not about buying your way into another country’s system. It is about making a conscious, governed invitation into a nation’s story — under its laws, for its benefit, and in a way that upholds international trust.
Scrutiny encourages improvement. But it is equally important to be precise in how citizenship by investment programs are described, compared, and evaluated. Conflating the Caribbean’s sovereign, development-focused models with the controversies surrounding European programs misrepresents the facts and undermines the legitimate efforts of governments working to uphold integrity and international trust.
The Caribbean CBI model is not without its challenges—no system is—but it is evolving with clarity, responsibility, and a commitment to global standards. It deserves an attitude that recognizes its distinct structure, values, and contribution to the international investment migration landscape.
The post ‘Not all CBI programmes are created equal’: Why The Caribbean economic citizenship model deserves a different attitude appeared first on Caribbean News Global.
