Dominica Suspends CBI Applications from Iranian Nationals

Official CBI Unit Memorandum

The Commonwealth of Dominica, through its Ministry of Finance and Citizenship by Investment Unit, issued an official memorandum on March 23, 2026, addressed to all authorized agents of the Citizenship by Investment Programme. The memorandum, signed by Gregory McDougall, Officer in Charge, communicates the government's decision to suspend the processing of applications from Iranian nationals.

The suspension takes effect on March 24, 2026. The memorandum specifies that applications from Iranian nationals will only be accepted if the applicant satisfies all three conditions outlined by the CBI Unit. The directive applies to new applications submitted from the effective date forward.

This is a formal regulatory action issued through the established channel between the CBI Unit and its authorized agents, consistent with the government's authority under the Dominica Citizenship by Investment programme framework to adjust eligibility criteria and due diligence requirements.

Three Conditions for Exception

The memorandum establishes that Iranian nationals may still be considered for the Dominica CBI programme if, and only if, they satisfy all three of the following conditions:

These conditions are cumulative, meaning all three must be met simultaneously. An applicant who has been outside Iran for over a decade but retains business operations or substantial assets there would not qualify under the exception framework.

The language of the third condition is notably broad: "in whole or in part, in or with Iran" captures not only direct Iranian business operations but also partial involvement in enterprises connected to Iran. This includes partnerships, joint ventures, supply chain relationships, and any commercial activity that involves Iranian counterparties.

Regulatory Context and Compliance Implications

Dominica's decision aligns with a broader pattern of Caribbean CBI jurisdictions strengthening their due diligence frameworks in response to evolving international compliance standards. The due diligence process for CBI programmes has become increasingly rigorous across all participating jurisdictions.

The Commonwealth of Dominica maintains its CBI programme under the framework administered by the Ministry of Finance. As a jurisdiction that has invested significantly in programme integrity, Dominica's approach to nationality-based risk assessment reflects its alignment with international financial regulatory standards, including those set by the Financial Action Task Force (FATF) and the Organisation for Economic Co-operation and Development (OECD).

For authorized agents, this directive requires immediate adjustment to pre-screening protocols. Iranian nationals who approach NTL or any other authorized agent for the Dominica programme must be assessed against all three conditions before any application materials are prepared or submitted to the CBI Unit.

Implications for Due Diligence Standards

The memorandum signals that Dominica's CBI Unit is applying enhanced scrutiny to applicants from jurisdictions subject to international sanctions or heightened financial monitoring. This is consistent with the programme's established practice of adapting eligibility criteria based on geopolitical and regulatory developments.

For the CBI industry as a whole, this type of targeted regulatory action reinforces the credibility of well-managed programmes. Jurisdictions that proactively address compliance risks tend to maintain stronger international recognition of their citizenship documents, which directly benefits all programme participants.

Impact on Current and Prospective Applicants

For Iranian Nationals Considering CBI

Iranian nationals who have maintained a long-term residence outside Iran, who have divested from Iranian assets, and who have no continuing business ties with Iran may still be eligible under the exception framework. The ten-year residency requirement is the clearest benchmark; the asset and business activity conditions require a more detailed case-by-case assessment.

Prospective applicants should gather comprehensive documentation to demonstrate compliance with all three conditions before initiating the application process. This includes proof of residency in a third country, evidence of asset divestiture, and confirmation of the absence of business ties with Iran.

For Existing Dominica CBI Passport Holders

The official memorandum addresses the processing of new applications specifically. It does not reference the status of existing Dominica citizenship holders who obtained their passport through the CBI programme. Individuals with concerns about their current status should consult directly with their authorized agent for guidance.

Broader Impact on CBI Programme Selection

Iranian nationals seeking Caribbean citizenship through investment now face an additional layer of consideration when selecting a programme. Each Caribbean CBI jurisdiction applies its own due diligence criteria and nationality restrictions, making it essential to conduct a thorough cross-programme eligibility assessment before committing to any particular application.

Alternative CBI Programmes

NTL operates as an authorized agent across multiple CBI jurisdictions in the Caribbean, Africa, and beyond. The top citizenship by investment programmes in 2026 each maintain their own eligibility frameworks, due diligence standards, and investment thresholds. For Iranian nationals affected by the Dominica suspension, exploring alternative jurisdictions requires a comprehensive assessment of each programme's current acceptance policies and due diligence requirements.

Caribbean Programmes

The St. Kitts and Nevis CBI Programme, Grenada CBI Programme, Saint Lucia CBI Programme, and Antigua and Barbuda CBI Programme are among the Caribbean jurisdictions where NTL holds authorized agent status. Each programme maintains independent eligibility criteria that may differ from Dominica's current position.

For applicants whose primary motivation includes access to the United States through a treaty investor visa, the Grenada CBI programme remains the only Caribbean jurisdiction offering E-2 treaty eligibility. This consideration may be particularly relevant for Iranian nationals evaluating their options in light of the Dominica suspension.

Türkiye Citizenship by Investment

The Türkiye Citizenship by Investment Programme offers an alternative pathway through real estate or capital investment. Türkiye's programme has historically maintained a broad acceptance policy across nationalities, and its geographic position between Europe and Asia provides strategic travel and business access. Iranian nationals have been among the active applicant groups for Turkish citizenship through investment, subject to Türkiye's own due diligence and security screening requirements. Applicants should verify current acceptance policies through an eligibility assessment before proceeding.

Egypt Citizenship by Investment

The Egypt Citizenship by Investment Programme provides a pathway through investment in designated sectors. Egypt's programme operates under its own regulatory framework with independent eligibility criteria. For Iranian nationals, the programme's acceptance policies and due diligence requirements should be assessed on a case-by-case basis through NTL's specialized team.

São Tomé and Príncipe Citizenship by Investment

The São Tomé and Príncipe Citizenship by Investment Programme is an additional jurisdiction where NTL holds authorized agent status. The programme applies its own due diligence standards and eligibility criteria. For a detailed assessment of the programme's key legal verification points, prospective applicants should consult with NTL's specialized team to determine eligibility under current regulations.

Each of the above programmes maintains independent acceptance policies that are subject to change. NTL recommends a comprehensive cross-programme eligibility assessment before committing to any specific application.

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