Caribbean Compliance: ECCU Moves to Establish Citizenship by Investment Regulator

23 May 2025 | Tags: Second Citizenship

Amid growing international scrutiny and tighter requirements for citizenship by investment (CBI) programmes, five members of the Eastern Caribbean Currency Union (ECCU) are shifting from competition to coordination. The creation of a regional regulator for CBI programmes marks a new chapter for nations that have until now relied on separate, nationally administered frameworks for attracting foreign capital.

In recent years, Caribbean governments have come under heightened pressure from international partners — including the United States and the European Union — as global debates intensify over transparency and oversight in the CBI sector. Particular emphasis has been placed on strengthening due diligence, preventing financial abuse, and ensuring uniform standards of applicant vetting. The signing of a Memorandum of Understanding (MoU) in March 2024 by Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia signalled clear political will for regional convergence.

The next step was the formation of an Interim Regulatory Commission, comprising representatives from ECCU member states and the Eastern Caribbean Central Bank. By January 2025, legal counsel Lydia Elliott — a veteran lawyer with over 40 years of experience — had been appointed. Her mandate includes developing the legal and institutional framework for a future permanent regulator. Beginning in March 2025, Elliott launched a series of consultations across member states to ensure transparency and to involve national legal and administrative institutions in the regulatory design process.

The process reached a new level in May, when Anguilla hosted the seventh meeting of Attorneys General and parliamentary counsel from ECCU jurisdictions. The meeting saw the first draft of a bill to establish the regional CBI regulator formally reviewed. Legal and regulatory delegates from the five CBI-implementing OECS countries — Dominica, Antigua and Barbuda, Grenada, Saint Lucia, and Saint Kitts and Nevis — took part. This development signalled the shift from political consensus to the institutionalisation of a supranational financial oversight mechanism.

The reform aims to introduce harmonised applicant screening protocols, standardised procedures for refusals, and potentially unified pricing structures. The vision is that a rejection in one jurisdiction should apply across all — a model more akin to the Schengen visa zone than sovereign divergence in naturalisation rules.

Particular attention should be paid to Dominica’s leadership role, not only in signing the MoU but in actively shaping the region’s compliance agenda. On 24–25 April 2025, Dominica hosted the first Regional Summit on Compliance and Regulation in Financial Services. Organised by the island’s Financial Services Unit (FSU), the summit brought together regulators and industry experts to discuss reforms aimed at strengthening oversight, identifying risks, and aligning with global transparency standards.

According to the organisers, these steps are merely the beginning of a deeper process of legal and institutional harmonisation. The FSU maintains that only through coordinated action — in vetting, monitoring, and refusal procedures — can the legitimacy of CBI programmes be safeguarded and regional access to global financial systems maintained.

Dominica’s CBI programme, which funds sustainable construction, energy transition, and infrastructure modernisation, demonstrates how investment citizenship can serve not only as a revenue stream but as a tool for strategic development. Hosting the summit reinforced the island’s commitment to institutional integrity, transparency, and international cooperation.

Coordination does not equate to loss of sovereignty. On the contrary, it protects shared interests: reputational resilience, reduced banking risk, and a buffer against external political pressure. For international investors, it signals increased confidence that jurisdictions in the region operate under predictable and unified rules.

Faced with rising demands for CBI transparency from international stakeholders, ECCU members are choosing not token compliance, but institutional renewal. A joint regulator and Dominica’s proactive role in shaping the regional agenda reinforce trust and confirm that the Caribbean is not merely a destination for investment — it is a full-fledged partner committed to sustainable, coordinated solutions.