By Caribbean News Global 
CANADA / UAE – As the European Commission’s 2028 deadline for phasing out Eastern Caribbean Citizenship by Investment (CBI) programs approaches, the five Caribbean governments involved (Saint Lucia, St Kitts and Nevis, Dominica, Grenada, Antigua and Barbuda) have moved quickly to show Brussels they are serious about reform.
Caribbean News Global (CNG) sat down with Sam Bayat, founder and managing director of Bayat Group, the Dubai-based immigration law firm that has advised on Caribbean CBI matters for more than three decades, to examine what is being proposed and what he believes is still missing.
Let’s start with what’s already changed. What reforms are the five governments actually putting forward?
Bayat: There’s a real package on the table, and it shouldn’t be dismissed. All five programs have harmonised their minimum investment at $200,000, up from the old $100,000 floor that everyone agreed had become too low. Dominica has introduced a mandatory in-person visit, so citizenship is no longer issued to someone who has never set foot on the island.
The wider Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA) agreement includes a 30-day physical presence requirement to be met within the first five years of citizenship, escrow accounts for qualifying investment funds, biometric collection at the interview, and a shared regional database so the five CBI units can see what each other are doing. On paper, that is a serious list.
Is that list enough to change Brussels’ mind?
Bayat: It’s enough to show good faith. It’s not enough to change the Commission’s underlying objection, and I think the region needs to be honest with itself about why. Read the language of the revised Visa Suspension Mechanism carefully: the EU is not saying your due diligence on applicants is too weak. It’s saying the mere existence of a program that can grant citizenship outside the ordinary channel is the risk, no matter how the applicant is vetted. A 30-day stay, a biometric scan, a higher price tag: these all make the applicant’s file cleaner. None of them addresses the actual objection, which is about who controls the decision and whether that person can be influenced.
So where should the reform effort actually be pointed?
Bayat: At the people making the decisions and at the people selling the programs, not at the people buying them!
I want to be precise about this, because it’s often misunderstood: I am not saying applicant due diligence is unnecessary. It is necessary; it should stay rigorous, and none of what I’m about to say is an argument for lowering it. But due diligence on the applicant has been the industry’s answer to every single scandal for over a decade, and it has never been the only answer, because it has never addressed the part of the system that actually failed.
When these programs have collapsed, whether in Cyprus, Malta, or elsewhere, the failure was that a decision could be swayed by a phone call to the right official, or that an agent penalised in one jurisdiction could simply reopen shop in the next one with nobody asking why. That is a governance and conduct problem, on the government side and on the industry side, and no applicant questionnaire fixes it.
You’ve used the word ‘sacrifice’ to describe what you think is actually required. What do you mean by that?
Bayat: I mean, politicians have to give something up, and it will not be comfortable. It means the CBI units, the approval process, and the enforcement function need to operate independently of ministerial discretion, not as a favour granted case by case. It means the industry actors, the marketing agents, the developers, and the due diligence subcontractors need to answer to a regulator with real teeth, including the power to ensure that ALL five islands operate as one jurisdiction. And it means any special project or development scheme tied to CBI funding gets the same transparency and oversight as the main program, instead of sitting in a corner where nobody is asked to explain how the money moved.
None of that is politically free. Independence means a minister loses the ability to personally approve a case or personally place a discretionary project with a favoured developer. That is the sacrifice, and it is the one nobody wants to be first to make.
What about ECCIRA? Isn’t regional coordination meant to solve exactly this?
Bayat: Coordination is good, and honestly it’s overdue. A shared database, common minimums, one regulator instead of five uncoordinated ones: all of that is progress, and I don’t want to undersell it. But coordination is not the same as independence, and it is not the ultimate answer on its own.
Five governments agreeing to talk to each other and use the same forms does not, by itself, remove the possibility that any-one-of them still lets a minister override the process, or still looks the other way on an agent everyone in the industry already knows is a problem. You can coordinate five compromised systems and still get a compromised outcome. Coordination is a floor. Independence is the ceiling, and that’s the part that’s still missing.
Realistically, does the region have time to make that change before 2028?
Bayat: It has time, but only if it starts now and stops treating this as a paperwork exercise. The mission to Brussels matters, the joint statement matters, but what will actually move the Commission is seeing that a citizenship decision in these countries can no longer be shaped by politics, that a penalised agent can’t simply relocate, and that the money behind these programs is fully visible. That is a harder ask than another due diligence form. It is also the only version of reform that answers the question the EU is actually asking.
Bayat’s comments echo the argument he has made publicly since the European Commission’s letter first surfaced in June: that the Caribbean’s credibility problem was never really about the people applying for these passports, but about the institutions that decide who gets them. Whether the five governments are willing to make that trade before the 2028 deadline, he says, “will determine whether Brussels sees genuine reform or simply a longer list of the same paperwork it has already dismissed once.”
Sam Bayat is the founder and managing director of Bayat Group, a Dubai-based law firm specialising in residency, citizenship, and immigration solutions. A Canadian-licensed lawyer, he founded the firm in 1993 and was among the early pioneers of investment migration in the Middle East.
Bayat Group’s practice spans citizenship by investment programs in the Caribbean and beyond, residency by investment routes in the European Union, and UAE-based solutions including golden visas, and maintains ongoing monitoring of the EU–Caribbean CBI dialogue on behalf of current and prospective applicants.
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