The current round of dialogue between the European Commission and the Caribbean citizenship states is being reported as an existential threat. Read the working papers rather than the press summaries and a different picture emerges: the Commission is asking for harmonised due diligence standards, mandatory applicant interviews, biometric sharing and a common price floor. Every one of those measures has already been adopted, in some form, by the programmes themselves.
That distinction matters for clients. A programme that is being asked to raise its standards is not a programme that is being closed. The states that struggle will be those without the administrative capacity to evidence compliance, not those with the highest thresholds.
Our guidance to clients is unchanged and deliberately unexciting. If a Caribbean citizenship forms part of your mobility strategy, the cost of waiting is measured in rising thresholds and lengthening due diligence timelines, not in the risk of the door closing overnight. Programmes give notice. Prices do not.
We continue to prepare files on the assumption that interviews are mandatory, that source of wealth documentation will be tested to private banking standards, and that biometric enrolment will be required in person. Files built to that standard age well.
Eleanor Kent
Hampton & Kent
