The United States has placed seven countries operating Citizenship-by-Investment (CBI) programs under formal review for potential visa restrictions, according to a classified State Department memorandum signed by Secretary of State Marco Rubio. This marks a significant development in how the U.S. is addressing the intersection of investment migration and national security.
Antigua & Barbuda, Dominica, Saint Kitts & Nevis, Saint Lucia, Vanuatu, Cambodia, and Egypt are the countries identified for review. According to the memo, each has 60 days to address deficiencies related to passport issuance, identity verification, visa compliance, and deportation cooperation, or risk facing full or partial entry suspensions.
This latest action builds on a broader U.S. immigration policy update announced on June 4, 2025, which imposed full travel bans on 12 countries and partial restrictions on seven others. The addition of CBI countries to the watchlist represents a new phase in the U.S. government’s efforts to tighten border access based on global compliance standards.
Grounds for Concern: Document Integrity and Deportation Protocols
The State Department memo outlines three core areas of concern: weak passport and identity documentation, inadequate biometric data sharing, and limited cooperation in accepting the return of
deported individuals. Citizenship-by-investment programs are receiving particular attention due to their speed of processing and, in many cases, limited physical or cultural connection between the applicant and the issuing country.
An official from the State Department emphasized that “CBI programs which offer nationality without a residency requirement pose increased challenges to verifying identity and enforcing immigration outcomes.” The memo also reportedly indicates that misuse of such passports by third-country nationals seeking to circumvent standard U.S. visa procedures remains a persistent concern.
The document makes clear that the 60-day window is not symbolic. Countries that fail to comply may face the same restrictions already applied to states like Cuba, Sierra Leone, and Turkmenistan earlier this month. In those cases, visa issuance for tourism, student, and employment categories has been paused indefinitely for applicants without existing U.S. travel permissions.
Diplomatic Response from the Caribbean
Governments of the four affected Caribbean jurisdictions—Antigua & Barbuda, Dominica, Saint Kitts & Nevis, and Saint Lucia have each initiated diplomatic outreach to the U.S. seeking further clarification on the reasoning behind the memo. According to Caribbean National Weekly, an embassy representative from one of the affected nations stated that the policy shift was “unexpected,” noting that their country already applies comprehensive background checks through Interpol and international due diligence providers as part of its CBI framework.
While CBI may not be formally named as the central issue, its presence in the broader discussion is difficult to ignore. The fact that four of the Caribbean countries under review all operate investment-based citizenship programs has raised questions about whether the speed and structure of these schemes align with U.S. expectations on identity assurance and enforcement cooperation. Officials in Washington have become increasingly vocal in private briefings about the need for tighter controls where citizenship is granted without meaningful residency or long-term ties.
U.S. Officials Weigh National Security Implications
Secretary Rubio, who authorized the memo, has previously advocated for greater integration of immigration policy within national security frameworks. In recent congressional briefings, he emphasized that State Department resources must be aligned with enforcement priorities, particularly where document fraud or deportation resistance is documented.
Separately, Mauricio Claver-Carone, a senior administration figure with oversight on Western Hemisphere policy, has commented publicly on the risks posed by “citizenship-for-sale” schemes. In a March 2025 policy briefing, he noted that “CBI programs with minimal residency and light vetting can attract actors from sanctioned jurisdictions seeking unrestricted mobility,” underscoring the administration’s concer that such schemes may inadvertently facilitate financial crime or unauthorized access to the U.S. market.
When Security and Strategy Override Treaty Privileges
Grenada’s absence from the list stands out, especially given that its Citizenship-by-Investment program has been active for years. While some may point to its E-2 treaty with the United States as a possible factor, the relationship between the two countries runs deeper than a visa agreement. Grenada has historically maintained close diplomatic and security ties with the U.S., including military cooperation and consistent alignment on regional enforcement matters. Its CBI program, while accessible, is also comparatively conservative limiting family dependents, requiring vetted developers for real estate routes, and working with international due diligence firms. These factors contribute to a program that, while commercial in nature, has managed to stay within the boundaries of what many in Washington view as manageable risk.
By contrast, Egypt also benefits from an E-2 treaty, yet appears on the list. This suggests that treaty status alone isn’t sufficient. Broader issues—such as document integrity, overstay enforcement, and the scale of non-compliance—are clearly part of the calculus. The U.S. decision to include Egypt despite its treaty access reflects a wider security lens, not just a legal one.
Turkey, although it runs a CBI program with high volume and global demand, is not included in the review. This is likely a function of its geopolitical weight. As a NATO member, a regional power in both Europe and the Middle East, and a longstanding security partner of the U.S., Turkey holds a level of strategic influence that most CBI countries do not. Its dual E-1 and E-2 treaty status adds structure to its immigration relationship with the U.S., but it is Turkey’s position on the geopolitical chessboard that likely keeps it off the list—for now.
Outlook: Compliance or Consequences
With a fixed 60-day review period now underway, the affected countries are under pressure to demonstrate both technical compliance and political willingness to collaborate on deportation matters. This includes submitting detailed documentation on biometric identity systems, passport issuance protocols, and case histories of deportation cooperation.
For CBI jurisdictions, the U.S. government’s action underscores a broader shift: economic citizenship, even when legally established, must also withstand scrutiny from national security and immigration enforcement authorities. Future access to the U.S. will increasingly depend not just on the legality of passport programs, but on their transparency, enforcement partnerships, and ability to support identity integrity in a high-security environment.
Sources: Reuters: Trump Administration Weighs Adding 36 Countries to Travel Ban
Caribbean National Weekly: Four Caribbean Nations Offering Citizenship by Investment Placed on U.S.
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