RESOLVING THE LEDGER
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The European Union has given five Caribbean nations notice that they need to end their citizenship-by-investment programs or risk losing visa-free access to Europe's Schengen area by 2028.
The ability to enter the 29 countries in the Schengen area can be a substantial selling point for these golden passport programs. While some immigration attorneys told CNBC that the ultimatum will likely end in a compromise, it is possible the EU will stand its ground.
Currently, foreigners can obtain citizenship in one of the countries by making a qualified investment in its economy, such as buying real estate or contributing to a government fund. Passports from one of these nations allow visa-free travel to some 140 countries and territories. With costs starting around $200,000, these citizenship-by-investment, or CBI, programs provide vital revenue to the Caribbean nations.
The EU in late June sent letters to the governments of Antigua and Barbuda, Dominica, Grenada, St. Lucia and St. Kitts and Nevis. The countries are planning a coordinated response, including a mission to Brussels, according to a statement.
"Our citizenship-by-investment programs are critical pillars of our non-tax revenue base. They cannot simply be abandoned without viable, credible and sustainable replacement sources of revenue," said Antigua and Barbuda Prime Minister Gaston Browne in a subsequent statement.
The EU has cracked down on CBI programs in other nations before, including Malta. However, this request is unusual because it doesn't cite specific security concerns or propose remedies to address them, according to Ron Klasko, immigration attorney and co-founder of advisory Exodus Migration. He said he does not expect the EU to back down.
"There's always been pressure from the EU on on the Caribbean countries, mostly related to security issues, and all of them have bolstered their security issues in response to EU requests in recent years. The new thing is different," Klasko said. "They're saying we are opposed to the concept of a commercial transaction resulting in you getting a passport. That goes to the very core of their program, unlike if they're saying we want you to bolster your security, which is where they can do something."
Klasko said he is advising one of the five affected nations, which he declined to name, on possible changes to the program that may satisfy the EU.
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Reaz Jafri, senior counsel at Charles Russell Speechlys, said he views the EU request as a starting point for negotiations rather than a firm ultimatum. Jafri, who also leads Dasein Advisors, a citizenship and residency consultancy, said a few clients have reached out, but they are still going through with their applications.
"This conversation has been going on as long as I can remember," said the immigration attorney of 30 years. "I think the EU is looking to maybe get more diligence or better handle on certain things with regards to who gets in and who doesn't come in, and I think they'll comply because they're not looking to skirt any rules."
In late 2024, the EU revoked visa-free travel to the Schengen region for citizens of Vanuatu, an island nation in the South Pacific, due to security and migration concerns. In 2025, the European Court of Justice struck down Malta's "golden passport" program as illegal. Malta has since implemented a merit-based program with residency requirements.
Even if a compromise can't be reached, Jafri said the Caribbean nations rely too much on revenue from CBI programs to phase them out. More than half of his clients are Americans, who don't need a visa-free perk, he added.
"I've had clients take these passports because they don't want to travel with their American or Israeli or Chinese passport. It's a security issue for them," he said. "I work with very wealthy clientele around the world, and having alternate citizenships and residencies is part of the global planning they do. They're managing different risks: political, personal, commercial, financial and so forth.
"My clients are not doing this for easy access to the EU," he added.
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