In 2026 the process for verifying a citizenship‑by‑investment (CBI) agent has become more precise, but the stakes remain high: a mis‑chosen agent can jeopardise the entire application, the invested funds, or even the citizenship itself.
Start with the official register
- Seven Caribbean programmes publish updated lists of authorized agents.
- IMI maintains an aggregated index of both approved and black‑listed agents for those jurisdictions.
- Absence from a list can mean the firm never held authorisation, lost it, or operates only as a sub‑agent.
When a licence is claimed on a website, request the license number and verify it against the government register. For example:
- Grenada prints each appointment in the Government Gazette with a number such as
GCBI-MA-089and the signature of the Investment Migration Agency chief executive. - Saint Lucia lists the licence number beside the individual’s name.
A failure to produce a matching number is a clear red flag.
Look beyond the register
A licence check is only the first step. Before signing any agreement, confirm:
- The specific person who will manage the file.
- The firm’s length of operation in investment migration.
- The due‑diligence procedures it applies before accepting a client.
- How client funds are held (e.g., escrow accounts).
- Whether the firm carries professional indemnity insurance.
- The existence of a verifiable physical presence and track record in the jurisdiction.
Understand the two‑tier (or multi‑tier) structure
Many programmes separate the marketing agent that interacts with the client from the local licensed agent that actually files the application:
| Programme | Marketing/Client‑facing agent | Local filing agent |
|---|---|---|
| Grenada | Authorized international marketing agent | Authorized local agent (sole party permitted to submit to the government) |
| Antigua & Barbuda | Representative that markets and pre‑screens | Licensed Antigua‑based agent that reviews and submits the file |
| Dominica | Authorized agents at the top, then licensed promoters and sub‑agents | The top‑level authorized agent must register and monitor all downstream promoters/sub‑agents |
Applicants who contact only the marketing side may have little control over the actual submission.
Verify the agent’s local presence
- Dominica – Authorized agents must be Dominican citizens, reside on the island or maintain a registered office with at least three staff, and pass background checks by independent due‑diligence firms and the Joint Regional Communications Centre (JRCC). Disqualification occurs if any owner, partner, shareholder, or director holds a parliamentary seat, works for the Citizenship by Investment Unit (CBIU), is a close family member of such a person, or is under investigation for fraud, money‑laundering, or similar crimes.
- Saint Lucia – Requires a physical business location on the island, a written agreement with the Citizenship by Investment Board, and proof of professional qualifications, resources, experience, and integrity.
- Nauru – Lists only a clean criminal record (including for shareholders and directors), prior investment‑migration expertise, and unrestricted access to a recognised due‑diligence database.
Watch for changes in the registers
Registers are dynamic; agents can be added or removed within months. Best practice:
- Check the register before the first conversation.
- Re‑check immediately before any payment is made.
Some programmes, such as Saint Kitts and Nevis, also publish a blacklist and a separate “suspended” list. The Citizenship by Investment Unit may keep an agent on probation, allowing applications to continue while monitoring conduct. An agent on the approved list can still be under active review.
Discount offers are a major warning sign
Selling the programme below the statutory minimum is illegal across the Eastern Caribbean. The regional floor is now US $200,000 (including the government contribution, qualifying investment, and due‑diligence fees).
- A quote below this amount either reflects a hidden rebate to the government or a fraudulent discount.
- Legitimate agents may discount their own professional fees, but any reduction in the government‑mandated amount is prohibited.
An itemised quotation that separates:
- Qualifying investment
- Government fees (contribution, due‑diligence, processing)
- Professional fees
helps expose any illicit discount.
The new regional regulator (ECCIRA)
In September 2025 five Eastern Caribbean states (Antigua & Barbuda, Dominica, Grenada, Saint Kitts & Nevis, Saint Lucia) signed the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA) agreement, now enacted into national law. Key points:
- A single 92‑article framework will licence and monitor agents, developers, due‑diligence providers, and escrow agents across the bloc.
- ECCIRA can impose fines up to US $250,000, revoke licences, maintain a regional register, and publish annual compliance reports from its Grenada headquarters.
- Operations are slated to begin in September 2026, pending final ratification by Saint Lucia.
The regulator may eliminate the current sub‑agent tier, meaning applicants could deal directly with the licensed filing agent rather than an intermediary marketing firm.
External pressures and program stability
- A U.S. White House proclamation (effective 1 January 2026) placed partial visa restrictions on Antigua & Barbuda and Dominica.
- The European Commission (25 June 2026) requested that all five Eastern Caribbean programmes be phased out by 1 June 2028.
Neither action has yet withdrawn visa‑free access or closed the programmes, but a serious agent should discuss the potential impact of a programme suspension on an ongoing investment.
Practical checklist for vetting a CBI agent in 2026
- Confirm licence number against the official government register.
- Identify the filing agent (local licensed entity) and ensure you will have direct contact.
- Validate local presence requirements for the jurisdiction (citizenship, office, staff, background checks).
- Request an itemised quotation that separates government fees from professional fees; verify the total meets the statutory minimum.
- Check for recent updates to the approved/blacklist registers before any payment.
- Ask about insurance (professional indemnity) and escrow arrangements for client funds.
- Inquire about the regulator (ECCIRA) status and whether the agent is already compliant.
- Discuss contingency plans if the programme is suspended or altered mid‑application.
Following these steps reduces the risk of losing money, time, or the coveted citizenship.
Source article: www.imidaily.com
