Comment: Major Restraint On CBI And RBI Industry

Major Restraint On CBI And RBI Industry

• The Presidential Proclamation of December 16, 2025 is an attack on the Citizenship by Investment (CBI) and Residency by Investment (RBI) industry. The proclamation specifically names two countries, Antigua & Dominica, which are being targeted for this reason. The proclamation states: “... some of these countries have offered Citizenship by Investment (CBI) without residency, which poses challenges for screening and vetting purposes. As an example, a foreign national from a country that is subject to travel restrictions could purchase CBI from a second country that is not subject to travel restrictions, obtain a passport in the citizenship of that second country, and subsequently apply for a United States visa for travel to the United States, thus evading the travel restrictions on his or her first country. Additionally, United States law enforcement and the Department of State have found that, historically, CBI programs have been susceptible to several risks. These risks include allowing an individual to conceal his or her identity and assets to circumvent travel restrictions or financial or banking restrictions.” The US has a wide range of tools to pressure small countries like Antigua and Dominica - trade, denying visas to the US, banking, military, diplomatic, aid and others. Countries as small as these cannot stand up to US pressure. 
• The CBI/RBI industry has not yet taken on board the lessons from this action against Antigua and Dominica. The RBI/CBI industry is broadly divided into three categories: (1) English speaking countries: USA, UK, Australia, Canada and New Zealand (2) European Golden Visa countries (3) Small countries, particularly in the Caribbean. The attack that the US government has launched is on the third category of Caribbean small countries. Though Antigua and Dominica are trying to appease the US government with concessions, we do not think this will succeed in the long run. We expect more smaller countries, including those in the Caribbean, to be targeted in the future. US law enforcement is likely to demand, and receive, the entire record of passports and travel documents of these countries. Those who were hoping to be shielded from US law enforcement will find that they do not have privacy from the prying eyes of Uncle Sam. 
• Antigua and Dominica are just the beginning, the US government will eventually target other countries engaging in RBI and CBI programs as well. The fundamental reason is Source of Funds (SOF). SOF in RBI/CBI comes up in two different scenarios: (1) People, looking for a Plan B passport and/or for fleeing high taxes and looking for tax havens–the US has no concerns about this category of people. Some countries make sure that only such people qualify for their RBI and CBI programs, for example, Grenada. (2) Noxious people engaging in human trafficking, drug trafficking, illicit weapons sales, gang activities and murder. These people use the lax and weak controls of some RBI and CBI countries to travel around the world, including to the US. It is this latter category of person that the US is most concerned about. If international criminals are using these programs to victimize people in the US (which being economically strong, rich, and the third most populous country on earth, is a juicy target for international criminals), then the US government is very concerned about the programs of those countries which have lax controls for their travel documents. In many countries in the Caribbean, for example, adequate controls are lacking and these countries will be targeted by the US in the future.

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