Dominica’s Citizenship by Investment Unit (CIU) has announced the suspension of citizenship by investment applications from Iranian nationals, according to a memorandum circulated to authorized agents on March 23, 2026. The measure took effect immediately.
Under the updated policy, Iranian nationals will only be considered for the program if they can demonstrate a long-term separation from Iran. Applicants must meet all of the following criteria:
- They have not lived in Iran for at least ten years
- They hold no significant assets in Iran
- They have not conducted business or commercial activity involving Iran during that period
The memorandum was signed by Gregory McDougall, Officer in Charge of the CIU, on behalf of the Director.
While the policy stops short of an outright ban, the conditions substantially limit eligibility and effectively exclude most applicants with recent ties to Iran.
A Policy That Has Shifted Several Times
Dominica’s position on Iranian applicants has changed multiple times in recent years.
Prior to May 2022, Iranian nationals were already subject to strict eligibility conditions similar to those now being reintroduced. At that time, applicants could only proceed if they had lived outside Iran for at least a decade and demonstrated no ongoing financial or business links to the country.
In May 2022, Dominica removed those restrictions entirely, allowing Iranian nationals to apply without special conditions.
That open policy was relatively short lived. In July 2023, the government introduced mandatory interviews and enhanced due diligence requirements for Iranian applicants. These additional background checks significantly increased the cost of applying, with due diligence fees alone reaching as much as US$70,000 for a family of four.
The latest memorandum goes further than the 2023 changes. Instead of allowing applicants with Iranian ties to proceed through enhanced screening, the CIU has now restricted eligibility to those who can demonstrate complete disengagement from Iran for at least ten years.
Increasing International Pressure
The decision also comes at a time of heightened geopolitical tension and increased scrutiny of citizenship by investment programs globally.
Several Western governments and regulatory bodies have called for stronger oversight of investor migration programs. In recent years, both the United States and the European Union have raised concerns regarding the issuance of citizenship to individuals from jurisdictions considered higher risk from a sanctions or compliance perspective.
Dominica’s citizenship program has already been subject to additional attention from Washington. In December 2025, the United States introduced partial travel restrictions affecting Dominican nationals and cited the country’s citizenship by investment program as part of its reasoning.
Subsequent policy changes have also affected visa arrangements. Earlier this year, the validity of U.S. visitor visas for Dominican nationals was reduced from ten years to three months.
Against this backdrop, Caribbean governments have been under increasing pressure to strengthen due diligence procedures and refine their eligibility policies.
Implications for Citizenship by Investment Applicants
The change further reduces the number of Caribbean citizenship by investment programs available to Iranian nationals.
Several programs in the region already impose strict limitations. Saint Kitts and Nevis and Saint Lucia prohibit Iranian applicants entirely. Other programs, including Antigua and Barbuda and Grenada, apply conditional eligibility rules requiring long-term residence outside Iran and the absence of economic ties to the country.
Dominica had previously been viewed as one of the more accessible options, particularly after removing restrictions in 2022. With the latest policy update, the practical path for Iranian applicants has narrowed considerably.
Applicants who can demonstrate more than ten years of residence outside Iran and no remaining economic connections may still qualify in principle. In practice, however, these criteria significantly reduce the eligible applicant pool.
Ongoing Evolution of Caribbean CBI Programs
Citizenship by investment programs across the Caribbean continue to evolve as governments respond to international regulatory expectations and geopolitical developments.
Over the past several years, regional programs have strengthened due diligence frameworks, introduced mandatory interviews, and implemented more robust background screening processes.
These adjustments reflect the importance Caribbean governments place on maintaining the credibility of their programs while preserving the economic benefits that citizenship by investment brings to their economies.
For investors and families considering second citizenship, the developments also reinforce the importance of working with experienced advisors who closely monitor policy changes and program requirements. Please do not hesitate to set up a personalized consultation with our team.
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