Thousands of UAE residents who invested in Citizenship by Investment (CBI) programmes across the Caribbean, Africa, and Asia now face mounting uncertainty as Western governments tighten scrutiny of such schemes. The United States and the European Union are taking coordinated steps to restrict visa-free access for countries deemed to have weak citizenship controls — a development that could upend the lives of tens of thousands of expatriates in the Gulf.
On June 14, U.S. Secretary of State Marco Rubio signed a memorandum giving 36 countries, including several popular CBI jurisdictions such as Dominica, Saint Kitts and Nevis, Saint Lucia, Cambodia, and Egypt, a 60-day deadline — ending August 13, 2025 — to comply with enhanced vetting and information-sharing standards. Failure to do so may result in visa bans for their passport holders. Concurrently, the European Union is advancing legislation to suspend Schengen visa waivers for nations with insufficient due diligence procedures. If approved, the regulation could take effect as early as September.
For expatriates in the UAE — particularly from India, South Asia, and the Middle East — the policy shift could be devastating. In recent years, many turned to second citizenships as a route to global mobility, tax planning, and long-term residency flexibility. Investments for such passports typically ranged from $115,000 to $330,000, offering visa-free travel to more than 140 countries.
“It’s a perfect storm, and many passport holders didn’t see it coming,” said Sam Bayat, founder of Dubai-based Bayat Legal Services and a regional pioneer in international investment migration. “People invested hundreds of thousands of dollars into citizenship programmes, believing it was their ticket to global freedom. Now, they’re facing sudden restrictions that could render those passports practically useless.”
While exact nationality breakdowns remain unavailable, Bayat estimates more than 10,000 CBI applications have been filed from the UAE region in recent years. “Assuming three individuals per application, we’re easily looking at 30,000 people, many of them UAE-based, who could be affected,” he added.
The crisis is particularly acute for Indian nationals residing in the UAE. India does not allow dual citizenship, meaning individuals who acquired second nationalities through CBI schemes had to surrender their Indian passports. According to the 2024 Private Wealth Migration Report by Henley & Partners, 4,300 affluent Indians renounced Indian citizenship in 2023 — many choosing Caribbean options while residing in the Gulf.
“We took this step thinking we were securing our future. Now it feels like everything’s up in the air,” said a Dubai-based Indian expatriate who obtained a Saint Lucia passport in 2022. “I’m following the developments and hoping it doesn’t come to a point where we’re left without real options.”
“For families who sold property or dipped into savings to secure their second passports, this is more than a policy change — it’s a personal crisis,” Bayat said. “They may feel betrayed, especially those who renounced their nationalities.”
CBI has been aggressively marketed across the Gulf as a low-risk, high-reward proposition, often by firms that now face their own moment of reckoning. “This could be the end of the road for dozens of firms that built their businesses on Caribbean passports,” Bayat noted.
A 2023 European Commission report flagged over 88,000 so-called “golden passports” issued by Caribbean states between 2014 and 2023, citing lax due diligence and high-risk applicants. The U.S. memorandum further highlights concerns with Egypt and Cambodia — expanding the scope of scrutiny beyond the Caribbean basin.
Despite pledges of reform from several countries, Bayat is skeptical. “Cosmetic change is not enough. A phased, credibility-first model is the only path forward. Without structural reform, CBI risks being viewed as a security threat rather than a legitimate development tool.”
He added, “Commonwealth ties or past diplomatic goodwill won’t protect countries from enforcement if their citizenship programmes fail to meet modern standards of integrity.”
Recent European precedents underscore the seriousness of the shift. The EU’s suspension of visa-free travel for Vanuatu and the Court of Justice of the European Union’s ruling against Malta’s individual investor programme have firmly established that CBI schemes must be grounded in genuine residency, integration, and transparency.
“Visa-free access to the UK or Schengen is not a birthright; it’s a privilege based on trust. And that trust is eroding fast for countries that continue to operate opaque or outdated CBI models,” Bayat said.
The stakes are especially high for small nations such as Saint Kitts and Nevis and Dominica, which rely heavily on citizenship sales to fund public services, infrastructure, and education. “A U.S. travel ban would devastate their local economies, and most of their populations won’t understand the reason,” Bayat warned.
In response to the shifting landscape, some CBI passport holders are now exploring alternatives. Interest is growing in secure residency schemes such as the UAE’s 10-year Golden Visa, which provides long-term stability without requiring a change in citizenship.
As international pressure mounts, experts caution that the era of unrestricted, pay-for-passport programmes may be drawing to a close — and those who bought into the promise are now left in limbo
Read more via Khaleej Times/Times of India
