The European Court of Justice (ECJ) ruled in April 2025 that Malta’s “golden passport” scheme violated EU law by effectively selling citizenship to wealthy investors without requiring a genuine connection to the country. This landmark decision sets a strong precedent that could pressure Caribbean nations such as Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis, and St Lucia, which operate similar citizenship-by-investment (CBI) programs. Although these countries are not bound by EU law, the ruling invites increased scrutiny from international bodies and the EU, which may demand stricter due diligence or threaten visa-free access to the Schengen Zone. The EU has already warned Caribbean CBI nations to tighten regulations or risk losing this privilege, which would significantly diminish the appeal of their programs.
The EU and major economies like the U.S. could impose sanctions, visa restrictions, or financial blacklisting to deter Caribbean citizenship-by-investment (CBI) programs. Already, Trump-era visa curbs targeted these nations, and further measures could devastate their tourism-dependent economies. The Bahamas offers a safer option with its Permanent Residency program which provides long-term stability without citizenship controversies or EU backlash. Unlike CBI schemes, it avoids “passport selling” scrutiny while still attracting investment. The ECJ’s crackdown accelerates global oversight, whether Caribbean nations adapt depends on how severely sanctions hit their tourism and mobility privileges.
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