Caribbean Five to Reopen CBI Files: EC-CIRA to Audit Past Caribbean Citizenships

EC-CIRA’s mandate casts a long shadow back over those who already obtained citizenship through the CBI programme. According to the draft agreement dated 1 July 2025, the regulator authority can demand proof of investment and in some cases the source of funds from existing economic citizens, not just new applicants.

It now becomes largely important for applicants to ensure that they have made full payment (minimum threshold) indicated by the government of their respective country. Meanwhile, secure the proof of payments for future inquiries as at any moment the authority can ask an investor for the payment proof, source of funds and mode of payment. If an investor fails to surface required proof of payments to the authority, it is likely that they will be required to make the pending payment or in some cases their citizenship might get revoked. 

This sweeping, retroactive oversight is a shift for Caribbean CBI programmes. Until now, once an investor’s check cleared and the citizenship was in hand, their dealings with the government were largely over. EC-CIRA blows that complacency apart. It introduces ongoing monitoring and the very real possibility that even current economic citizenship holders could be called back to prove they paid every dollar and that their money was clean. Such authority is virtually unheard of in the CBI industry and has sent shockwaves through investor circles. 

Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis and Saint Lucia in a draft agreement dated 1 July 2025 details plans to establish the Eastern Caribbean Citizenship by Investment Regulatory Authority (EC-CIRA), a regional watchdog intended to standardize and strengthen oversight of all five nations’ CBI programmes. 

Read the full draft agreement here

For Caribbean governments, EC-CIRA promises a unified front to protect the integrity and reputation of their programmes, but for investors, it represents a new layer of scrutiny.

For international investors, this development raises pointed questions about certainty and risk. Could the new regulator go after past citizenships it deems questionable? The language of the draft suggests “yes”. EC-CIRA is tasked with enforcing uniform standards and ensuring no one slips through the cracks, even if that means revisiting already-approved files. By empowering a regional authority to “audit...and enforce uniform standards” across jurisdictions, the Caribbean Five are telegraphing that previously tolerated loopholes are closing. 

The government of St. Kitts and Nevis, one of the five partners in the new Authority tightened its grip on rule-breakers late last year after it was revealed that developer Caribbean Galaxy Real Estate Corporation provided citizenship at discounted prices, targeting dozens of people who had obtained citizenship below the mandatory investment threshold. In a first-of-its-kind crackdown, 15 economic citizens who had contributed less than the minimum required investment were ordered to pay up the outstanding amounts after receiving official warning letters. 

An additional 80+ individuals have been contacted by authorities to either provide proof of full payment or settle their shortfall immediately. These investors were essentially told to put in the money they initially under-paid or risk losing their new nationality. St. Kitts gave them until 31 December 2024 to comply, making clear that failure to do so would result in revocation of their citizenship.

This aggressive move underscores a zero-tolerance stance on so-called “CBI underselling.” St. Kitts officials have framed it as safeguarding the programme’s integrity: no more discounts, no more quiet deals with developers to bypass the system. 

Read the full draft agreement here

Observers noted that CBI units across the Caribbean were watching closely, interpreting the action as part of a “region-wide push for greater accountability and transparency in economic citizenship programmes.” In other words, what started on one island is spread to all. The forthcoming EC-CIRA is the mechanism by which that spread will happen.

Under draft Article 46, even after a citizenship is granted, citizens must file annual declarations confirming they fulfilled the required investment and residency commitments, which the Authority will independently verify via immigration and financial records. 

A CBI industry expert further clarified that the new measures will affect applicants, not developers. “The developer’s only responsibility is to complete the project, after which they often move on to new developments in other countries. However, if EC-CIRA or the respective country requests proof of full payment, it is the applicant who will face consequences especially if they paid less than the required minimum investment amount.”

The initial passport validity will be cut to five years, with a renewal contingent on proof that all obligations (like the 30-day residency rule) have been met. Failure to comply without a valid excuse invites a hefty fine (up to 10% of the investment value) and possible revocation of citizenship. 

EC-CIRA is charged with conducting periodic audits of files of both applicants and already-approved citizens, a clear signal that no one is “grandfathered in” beyond the regulator’s reach.