For many expatriates in the UAE, acquiring a second passport through Citizenship by Investment (CBI) programs has become a popular route to global mobility, offering visa-free access to key destinations like the UK, Schengen area, and other countries. Unlike in their home countries, where restrictions on visas or passports may limit global movement, UAE residents benefit from rules that allow dual citizenship, making it easier to pursue CBI options in countries like Dominica, Saint Kitts and Nevis, Saint Lucia, Cambodia, and Egypt. These countries offer pathways to citizenship in exchange for hefty financial investments. However, recent developments have cast a shadow over these investments, leaving many in a state of uncertainty as the global landscape for CBI programmes shifts dramatically.
The Impending Storm: US and EU Crackdowns on CBI Programmes
On June 14, US Secretary of State Marco Rubio signed a memorandum setting a 60-day deadline for 36 countries, including many with CBI programmes, to meet rigorous vetting and information-sharing standards. These standards are designed to address concerns over security risks and the integrity of the programmes. The deadline, which ends on August 13, 2025, brings with it the threat of visa bans for nations that fail to comply. Similarly, the European Union is progressing with legislation to suspend visa-free Schengen access for countries that have weak oversight, with a law expected to come into force by September. For many expatriates in the UAE, this could mean losing access to one of the main benefits of CBI passports—visa-free travel to a range of countries. As Sam Bayat, founder of Dubai-based Bayat Legal Services, explained to the local media outlet Gulf News: “It’s a perfect storm, and many passport holders didn’t see it coming.” Bayat, a pioneer in international investment migration, further emphasized the scale of the situation: “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.”
The UAE: A Hotspot for CBI Applications
The impact of these changes is most pronounced in the UAE, where expatriates make up almost 90% of the population. Bayat estimates that over 10,000 applications have been filed from the region in recent years, suggesting that around 30,000 individuals could be affected by these new restrictions. This number is based on the assumption that each application involves multiple family members, making the potential fallout substantial. Among those most vulnerable are Indian nationals in the UAE. Since India does not allow dual citizenship, many individuals who acquired second passports had to renounce their Indian nationality. In 2023, Henley & Partners’ Private Wealth Migration Report highlighted that 4,300 wealthy Indians gave up their citizenship, with many opting for CBI programmes in the Caribbean or other regions while residing in the Gulf. One Indian expat, who acquired a Saint Lucia passport in 2022, told Gulf News: “We took this step thinking we were securing our future. Now it feels like everything’s up in the air. I’m following the developments and hoping it doesn’t come to a point where we’re left without real options.” For many, this isn’t just a policy shift, it’s a personal crisis. Bayat adds, “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. They may feel betrayed, especially those who renounced their nationalities.”
Local Agencies Under Pressure: The End of an Era?
The local agencies in the Gulf that marketed these CBI programmes as low-risk, high-reward investments are also facing pressure. Bayat suggests that many of these firms, which built their business models around facilitating Caribbean passport acquisitions, may not survive the fallout. “This could be the end of the road for dozens of firms that built their businesses on Caribbean passports,” he warns. A 2023 European Commission report raised concerns about the lax due diligence of several Caribbean states issuing “golden passports.” According to the report, these countries have issued a large number of passports with weak vetting processes, which has drawn the attention of both the US and EU. But the issues aren’t limited to the Caribbean. The US memorandum also targets Cambodia and Egypt, signaling that the problem is now global. In light of this, Bayat argues that “cosmetic changes” to the CBI programmes won’t suffice. He calls for “a phased, credibility-first model” to restore trust in these schemes, warning that without meaningful reform, CBI programmes risk being viewed as a “security threat” rather than a legitimate development tool.
The Growing Shift Toward Secure Alternatives
As CBI programs face mounting scrutiny, many affected individuals are beginning to explore more secure and credible alternatives. The UAE’s 10-year Golden Visa, for instance, has gained popularity as a stable long-term option. Rayad Kamal Ayub, Managing Director of Rayad Group Immigration Services, points to this shift: “We are navigating a significant transformation in the citizenship-by-investment landscape. The shift away from off-the-shelf passport purchases indicates a move toward more sustainable and legitimate pathways.” Ayub’s firm has set up a help desk to assist those who are facing the fallout from these changes, as rules around CBI programs continue to evolve. He highlights the credibility of programmes like the UAE Golden Visa, which focus on long-term residency and integration, rather than simply paying for citizenship. Similarly, points-based immigration systems in countries like Canada, Australia, and New Zealand are becoming increasingly popular, as nations prioritize applicants’ qualifications and long-term contributions over cash. Bayat concurs that the idea of investment migration itself is not under attack, but rather how it has been misused. He asserts: “Citizenship is a sovereign right, but it carries responsibilities for both the issuing state and the individual. The US and EU message is loud and clear – adapt or be shut out.”
The Stakes for CBI Countries: Economic and Political Ramifications
For the countries that rely heavily on the revenue generated from CBI programmes, the stakes couldn’t be higher. Nations like Saint Kitts and Nevis and Dominica use the proceeds from citizenship sales to fund critical infrastructure, schools, and healthcare. A US visa ban or Schengen suspension would not only devastate their economies but also likely confuse and anger their populations, who may not fully understand the reasons behind the changes.Bayat sums up the situation by stressing the need for greater transparency and accountability in CBI programmes: “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.” He further adds, “Commonwealth ties or past diplomatic goodwill won’t protect countries from enforcement if their citizenship programmes fail to meet modern standards of integrity.”
