Bayat says Caribbean citizenship programs need independent oversight

Sam Bayat, founder and managing director of Bayat Group, says Caribbean citizenship-by-investment programs keep focusing on the wrong fix as European pressure mounts ahead of a June 2028 phaseout target. He argues the real problem is governance and political control, not applicant vetting.

Why it matters: - Bayat says the biggest risk in Caribbean citizenship-by-investment programs is not the applicant, but who controls the approval process. - The debate matters because the European Commission is pressing five Eastern Caribbean governments to phase out their citizenship-by-investment programs by June 2028. - Bayat argues that stronger oversight could determine whether the region keeps the programs in a form that Europe will tolerate.

What happened: - Sam Bayat, founder and managing director of Bayat Group, said the region’s response to European pressure has focused too much on enhanced applicant vetting. - Bayat said the real failure has been governance, not paperwork. - He said citizenship decisions should be made by a body with no stake in the outcome, not by officials who can be influenced by political pressure or private interests. - Bayat also criticized the way the industry describes most citizenship-by-investment transactions as investments. - He said most applicants make a non-refundable contribution to a government fund in exchange for citizenship, with no return, yield, or exit. - Bayat said real estate and enterprise routes are the exception, not the norm, because those pathways involve ownership or equity.

The details: - Cyprus suspended its Investment Programme in 2020 after Al Jazeera’s undercover “Cyprus Papers” investigation. - The investigation showed senior officials describing ways applicants with criminal records or under investigation could still obtain citizenship if they paid enough and knew whom to approach. - The officials resigned, and four people connected to the operation later faced trial. - In Malta, reporting and litigation around the Individual Investor Programme showed an applicant bypassing standard transparency checks after meetings with the sitting prime minister and the head of the agency running the scheme. - In April 2025, the European Court of Justice ruled the Maltese program unlawful, finding that citizenship had become a commercial transaction rather than a status based on a genuine link with the state. - Bayat said the threat in both cases was not the applicant, but the decision-makers. - He said marketing agents, developers and introducers can be blacklisted by one Caribbean CBI unit and then return as authorized partners in another jurisdiction within months. - Bayat said the Eastern Caribbean Citizenship by Investment Regulatory Authority, or ECCIRA, could help close that gap if it operates as a neutral body. - He said CBI units, decision-makers, due diligence providers and enforcement functions must be free of political direction. - Bayat said a shared blacklist is not enough if a bad actor can simply move to another jurisdiction. - He noted that the European Union’s revised Visa Suspension Mechanism, in force since late 2025, targets the structure of these programs rather than the profile of individual applicants. - Under that approach, the existence of a scheme granting citizenship outside ordinary channels is treated as the risk, regardless of how thoroughly an individual case is vetted.

Between the lines: - Bayat’s argument is that governments are trying to defend a structural problem with a compliance fix. - His comments suggest Europe is looking for independent decision-making, not just stronger background checks. - The push for a neutral regulator would require governments to give up direct control over approvals and enforcement. - Bayat said special projects and development funding routed outside ordinary budget channels also deserve the same scrutiny as the rest of the system.

What's next: - Bayat expects Caribbean governments to respond over the next two years with tighter applicant vetting. - He said that approach will likely get the headline, while staffing, oversight, licensing and enforcement issues receive less attention. - He said a real fix would require a regulator with teeth, including the power to say no to ministerial preferences. - Bayat said that kind of reform would be more likely to influence Brussels than another round of due diligence vendors and paperwork.