The citizenship‑by‑investment (CBI) market is split between programs that openly list the nationalities they refuse and those that rely on unwritten or indirect restrictions. Knowing which approach a program follows determines whether an applicant can assess eligibility before filing.
Programs that publish a restricted‑nationality list
| Program | Published list (date) | Countries excluded | Exceptions / conditions |
|---|---|---|---|
| Antigua and Barbuda | FAQ page, updated 26 Feb 2020 | Afghanistan, Iran, North Korea, Somalia, Sudan, Yemen | Applicants born in the country and who migrated before age 18, or who have ten years of permanent residence in a non‑listed country and no economic ties to a restricted country, may still qualify. Russian and Belarusian nationals were suspended on 28 Jul 2022 (later reinstated); Ukraine was suspended in Mar 2022 and reopened in 2024, though neither appears on the list. |
| Dominica | Dedicated “banned‑nationalities” page | Belarus, Russia, Yemen, “Northern Iraq” (nine Kurdish cities) | Iran, North Korea and Sudan face conditional refusals: they must have been away for at least ten years, own no substantial assets there, and have no business ties. |
| Grenada | Circular No 1 / 2024 (effective 1 Apr 2024) | Iran, North Korea, Russia, Belarus, Sudan, Yemen, Afghanistan (residents, not nationals) | Iran, Sudan, Yemen and Afghanistan can qualify if they migrated before the age of majority or have ten years of permanent residence (or a valid visa) in Canada, the UK, a Schengen state, the US, Australia, New Zealand, Saudi Arabia, or the UAE, and have no economic ties to any restricted country and can be investigated in‑country. No path back is provided for North Korea, Russia or Belarus. |
| Saint Kitts and Nevis | Eligibility page | Afghanistan, Belarus, Iran, Iraq, North Korea, Russia | No exceptions; the list is justified on “national security and public safety”. |
| El Salvador | “Prohibited Jurisdictions” page | Cuba, North Korea, Iran, Syria, Crimea, Donetsk, Luhansk, Kherson, Zaporizhzhia (self‑proclaimed republics) | Also excludes anyone on the OFAC sanctioned persons list. |
Key observations
- All four Eastern Caribbean programs (Antigua & Barbuda, Dominica, Grenada, Saint Kitts & Nevis) publish lists, but the exact countries and the wording differ.
- Iran and North Korea appear on every list, but the treatment varies: outright bans (Saint Kitts & Nevis), conditional bans (Dominica, Grenada), or bans with limited exceptions (Antigua & Barbuda).
- Russia and Belarus are listed by three of the four Caribbean programs; Antigua & Barbuda omits them from its public list despite having suspended them in 2022.
- Some programs restrict residence rather than nationality (Grenada), while others focus on the applicant’s citizenship (most others).
Programs that exclude without publishing a list
- Nauru – Eligibility requires that the applicant not be a citizen of a “high‑risk” country as defined by United Nations Security Council resolutions. The list changes automatically with UN designations; no specific countries are named on the website.
- Turkey – The $400,000 property‑investment route is limited by a Cabinet decision on which nationalities may acquire property. The list of permitted countries is not publicly disclosed.
- Egypt – The General Authority for Investment requires approval from “relevant security authorities” on national‑security grounds; no countries are named.
- Jordan – The investor‑citizenship criteria contain no nationality exclusions. Syrian and Iraqi investors have been the most common recipients, showing that the absence of a list does not imply a ban.
- Saint Lucia – A 2022 memorandum suspended Russian and Belarusian applications; legislation itself names no country. IMI reports an outright ban on Iranian applicants that is not reflected on the program’s site.
- Vanuatu – No eligibility page lists restricted nationalities. A brief addition of Russia and Sudan to a restricted list on 10 Mar 2026 was withdrawn the next day as a clerical error.
- Cambodia – The nationality law gives the government discretionary power to grant naturalisation; no explicit nationality bans are published.
- São Tomé and Principe – Article 17 of the 2025 decree‑law allows exclusion of applicants from countries under sanctions or without judicial cooperation, but the specific countries are defined only by a non‑published Council‑of‑Ministers resolution.
Rapid reversals and updates
- Vanuatu – Added Russia and Sudan on 10 Mar 2026, withdrew the addition on 11 Mar 2026, citing a clerical error.
- Grenada – In Dec 2023 a minister announced openness to all nationalities; the CBI unit corrected the statement the next day, confirming that Russia, Belarus, North Korea and Iran remained barred. By Mar 2024 the list expanded to seven countries, with Iran moving from a flat ban to a conditional one.
- Antigua and Barbuda – The public list was last updated in Feb 2020; subsequent circulars (2022) suspended Russia, Belarus and Ukraine without ever amending the list, and the Ukrainian suspension was lifted in 2024 without a list update.
Regulatory drivers
- EU Regulation 2025/2441 (effective 30 Dec 2025) makes an investor‑citizenship programme a ground for suspending visa‑free EU access. The European Commission requested a phase‑out of the five Eastern Caribbean CBI programmes by 1 Jun 2028 (letter dated 25 Jun 2026). The request is not yet law.
- U.S. policy – Drafts leaked in Mar and Jun 2025 listed several CBI programmes (including Saint Kitts & Nevis, Saint Lucia, Vanuatu, Cambodia) for possible sanctions. The final proclamation on 16 Dec 2025 omitted all except Antigua & Barbuda and Dominica.
- Caribbean coordination – In Sep 2025 the five Eastern Caribbean programmes signed an agreement establishing the Eastern Caribbean Citizenship by Investment Regulatory Authority. The authority had not begun operations at the time of writing.
Practical guidance for applicants
- Check the program’s own website first. The published list (if any) is the authoritative source; secondary summaries may miss recent suspensions or reinstatements.
- Pay special attention to exception pathways. Grenada, Antigua & Barbuda and Dominica allow qualification through long‑term residence in specified third‑country jurisdictions (e.g., Canada, UK, Schengen states, US, Australia, New Zealand, Saudi Arabia, UAE).
- Consider the volatility of unpublished restrictions. Programs that rely on internal Cabinet decisions or UN designations can change eligibility without public notice, affecting both filing strategy and due‑diligence costs.
- Monitor regulatory developments. The EU phase‑out request and U.S. sanction lists could alter the attractiveness of certain programmes, especially those under the Eastern Caribbean regulator.
- Assess due‑diligence implications. Grenada’s conditional pathways require in‑country investigations, potentially increasing costs and processing time.
If a nationality appears on a published restricted list, the applicant must either meet the stated exception criteria or select a different programme. When no list is published, the applicant should seek clarification directly from the relevant investment authority, recognizing that the lack of transparency itself is a risk factor.
Source article: www.imidaily.com
