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# Europe Stopped Selling Citizenship in April. Washington Started Selling Status in September.
- URL: https://www.lacaribenanews.com/europe-stopped-selling-citizenship-us-gold-card-investor-migration-2026/
- Published: 2026-08-15T02:29:39.000Z
- Updated: 2026-08-15T02:29:46.000Z
- Description: The Court of Justice ended Malta’s passport scheme on 29 April 2025 and no European Union state now sells citizenship. Washington created a US$1 million cash-for-status route on 19 September, then restricted two Caribbean states in December for selling citizenship.
- Author: Theon Alleyne
- Tags: Compliance, caribbean, trade, Analysis

**Quick summary:** The Court of Justice ended Malta's citizenship scheme on 29 April 2025, and no European Union state now sells citizenship. Washington created a US$1 million cash-for-status route on 19 September 2025, then restricted two Caribbean states in December for selling citizenship. The largest documented failures in investor migration are Cypriot, British and American.

By La Caribeña News · 14 August 2026

Three dates order this story.

On **29 April 2025** the Court of Justice of the European Union [held that Malta's investor citizenship scheme was unlawful](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62023CJ0181&ref=lacaribenanews.com), and Malta closed it that day. On **19 September 2025** the President of the United States signed [an executive order](https://www.federalregister.gov/documents/2025/09/24/2025-18602/the-gold-card?ref=lacaribenanews.com) creating a route to American immigration status for a gift of one million dollars. On **16 December 2025** the same administration [suspended visas for Antigua and Barbuda and for Dominica](https://www.federalregister.gov/documents/2025/12/19/2025-23570/restricting-and-limiting-the-entry-of-foreign-nationals-to-protect-the-security-of-the-united-states?ref=lacaribenanews.com), on the recited ground that each country has historically sold citizenship without residency.

Between the second date and the third, eighty-eight days.

## What did the Court actually hold?

That selling nationality is the breach, whatever the vetting.

The judgment in Commission v Malta declares that by operating a scheme establishing "a transactional naturalisation procedure in exchange for predetermined payments or investments", Malta had commercialised the grant of its nationality and, through it, citizenship of the Union, and had failed in its obligations under the founding treaties.

Two findings in it are regularly misreported.

The Court did **not** rule that European law requires a genuine link between a person and the state naturalising them. It ruled that a **transactional** scheme is the violation. That is a narrower holding and a harder one.

And Malta's due diligence did not save it. The Court held that such checks "are not intended to assess whether the applicant's situation justifies the grant of Maltese nationality, but only to determine whether certain duly identified risks preclude the grant". Vetting screens for danger. It does not answer why this person should be a national.

That is the direct answer to the defence the Eastern Caribbean programmes have made for a decade, that their screening is rigorous. On the Court's reasoning, rigorous screening is beside the point.

## Is residence the line it is said to be?

The Court itself doubted it.

The distinction usually drawn is that the Caribbean sells citizenship while Europe and the United States sell residence, with naturalisation only after years of living somewhere. At **paragraph 314** the Court noted that Maltese residence could be reduced from three years to one on payment of a further EUR 150,000, and concluded that the residence condition was itself closely linked to the transactional nature of the grant.

Portugal requires seven days a year. What separates its scheme is not presence but the naturalisation clock, and Portugal has just doubled its own from five years to ten under an organic law in force since 19 May 2026\. A country does not double a waiting period it considers adequate.

What is being traded in every one of these schemes is mobility, and the region has been [counting what its own passports open and close](https://www.lacaribenanews.com/guyana-passport-visa-free-countries-2026/) for some time.

## Does anyone in Europe still sell citizenship?

No, and that matters for how this story is told.

Cyprus closed its programme on 1 November 2020\. Bulgaria repealed its own in 2022\. Malta closed on the day of the judgment and repealed the enabling law that July. Malta now operates a residence permit from EUR 37,000, which confers no nationality.

Austria retains a discretionary naturalisation for exceptional contribution to the state. It has no published price, expressly excludes passive investment, and has produced roughly 287 grants since 2007\. Against approximately 107,000 Caribbean passports recorded by the European Commission, that is not an equivalent.

So the argument that Europe still sells passports cannot be made. What can be said is narrower and more awkward: Europe abolished its numbered, gazetted sales and kept its unnumbered discretionary ones.

## What is the American Gold Card?

A gift, treated as evidence of merit.

[Executive Order 14351](https://www.federalregister.gov/documents/2025/09/24/2025-18602/the-gold-card?ref=lacaribenanews.com) does not create a visa. It creates an evidentiary presumption inside existing employment categories. An applicant who makes a **gift** of one million dollars to the United States, or two million through a corporate sponsor, is to have that payment treated by adjudicators as evidence of exceptional business ability and national benefit.

Three features are worth stating plainly. It requires no investment, no business and no job creation, which distinguishes it from the EB-5 programme it sits beside. A corporate-sponsored place is **transferable to a different individual**. And it creates no new visa numbers and no enforceable right, so it reallocates existing places rather than adding any.

Applications opened on 11 December 2025, five days before the proclamation restricting Antigua and Dominica.

## Where has investor migration actually failed?

In Nicosia, in London and in Vermont.

**Cyprus.** An inquiry led by a former President of the Supreme Court found that **53 per cent of 6,779 citizenships** granted between 2007 and 2020 were unlawful, describing mass illegality in Cabinet decision-making. By September 2025, 332 had been revoked. The Audit Office put the loss at EUR 200 million in value added tax and EUR 25 million in fees.

**The United Kingdom.** The Tier 1 investor visa closed at four o'clock on 17 February 2022\. The review promised after Salisbury was published as a written ministerial statement in January 2023\. The Home Office examined **6,312** investors and adult dependants who obtained leave between June 2008 and April 2015, and reported "a small minority" at high risk of having obtained wealth through corruption or other illicit finance. It attached no number to that phrase. It did state one: **ten oligarchs** who had used the route were later sanctioned. Its conclusion was that there are "inherent difficulties in an investment-based immigration route based on passive wealth", and that high-risk applicants had sought out the financial institutions with the weakest customer checks.

**The United States.** In the Jay Peak affair, roughly US$350 million was raised from EB-5 investors and about US$200 million misused, drawing enforcement by the Securities and Exchange Commission in 2016 and subsequent criminal convictions. More than seven hundred regional centres have since been terminated.

No Caribbean programme has ever been found by its own state's inquiry to have issued a majority of its passports unlawfully. Cyprus was.

**The counterweight belongs in the same paragraph.** Ali Sadr Hashemi Nejad, convicted in the United States over sanctions circumvention, held Dominican citizenship obtained shortly after meeting that country's Prime Minister. Roughly a dozen fugitives have been identified holding Caribbean passports. Those are real, and they are a different order of magnitude from 6,779 grants and 53 per cent.

## Why did none of that cost anyone visa-free access?

Because of jurisdiction, not innocence.

No visa suspension, no Financial Action Task Force finding, no listing and no entry restriction has ever been directed at the United States over EB-5 or at the United Kingdom over Tier 1.

The reason is structural and should be stated rather than implied. The European Union's visa suspension mechanism reaches **third countries** only. Against a member state the instrument is infringement proceedings, which the Commission brought against Malta and which produced a harder outcome than suspension would have: the scheme was not restricted, it was declared unlawful and closed.

That is an explanation. It is not a defence of the asymmetry, because the asymmetry is in who can be judged at all.

The mechanism was then sharpened. [A regulation in force since 30 December 2025](https://eur-lex.europa.eu/eli/reg/2025/2441/oj?ref=lacaribenanews.com) adds a new ground: the operation by a listed third country of "an investor citizenship scheme under which citizenship is granted to a person, in exchange for pre-determined payments or investments, without that person having any genuine link to that third country". A recital explains the purpose, that visa-exempt third countries should be deterred from using visa-free access to the Union as a lever for individual investment. Suspension runs twelve months, extendable by twenty-four, then a further twenty-four while a country is moved onto the visa-required list.

Vanuatu shows what that looks like in practice. Its visa-free access was suspended in May 2022 and made permanent on 12 December 2024.

## What does the Commission's own case say?

Less than the measures suggest.

The Commission's most recent report under the mechanism, published on 19 December 2025, records approximately 107,000 passports issued by the Eastern Caribbean programmes, 13,113 applications in 2023 and 10,573 in 2024, and 2024 rejection rates of 1.7 per cent in Antigua and Barbuda, 5.3 per cent in Saint Lucia and 6.5 per cent in Dominica. It gives no rejection rate for Grenada or Saint Kitts and Nevis.

**It advances no documented instance of a Caribbean passport being used to evade sanctions or to commit an identified crime.** The case is built on scale, on low rejection rates, on the circumvention of visa procedures, on name changes, and on the absence of a genuine link.

On 25 June the Commissioner for Home Affairs wrote to Antigua and Barbuda asking it to phase its programme out by 1 June 2028, with a twenty-four month transition and reinforced vetting by September 2026, according to the Antiguan Office of the Prime Minister, which published the request. The Commission has not published the letters.

There is no treaty hook against the demand. The economic partnership agreement between the Caribbean Forum and the European Union expressly provides that its services title does not apply to measures regarding citizenship, residence or permanent employment.

What replaces the revenue is unsettled. None of the five has published a costed plan, and the argument for building something else has been made from within the region, most recently by Suriname's oil minister warning about [an economy resting on a single source of receipts](https://www.lacaribenanews.com/suriname-summit-duurzaam-3-0-oil-diversification-local-content-2026/). Capital does move around the region on ordinary commercial terms, as when [a Guyanese company backed a St Kitts development](https://www.lacaribenanews.com/ddl-st-kitts-investment-guyana-outward-capital-world-trade-centre-2026/) without a passport attached to it.

## What is on nobody's list?

The two largest programmes in the world.

The United Arab Emirates has issued in the order of 250,000 golden visas, which is understood to be around four fifths of the global residence-by-investment market. Comoros has issued roughly 50,000 passports. Neither has been restricted by the United States, the United Kingdom or the European Union.

When Singapore prosecuted a large money laundering network, the passports in evidence were Cambodian and Vanuatuan.

Washington has also reached [the visas of individual directors to change a company's commercial decision](https://www.lacaribenanews.com/huawei-visa-warning-calf-neuquen-caribbean-telecoms-boards-2026/) in this hemisphere.

Set against that, the five Eastern Caribbean states are the most measured, most reported and most acted-against operators of a practice that is larger elsewhere and unexamined there. Washington has meanwhile [bonded three of the five while leaving the two that price highest untouched](https://www.lacaribenanews.com/us-visa-bond-caribbean-overstay-rates-cbi-designations-2026/), and a Dominican hotelier has spent seven years telling his own government that [citizenship was being sold below the price the law sets](https://www.lacaribenanews.com/dominica-cbi-discounting-nassief-inquiry-demand-2026/).

### The data in this article

- Commission v Malta, Court of Justice of the European Union, Grand Chamber, judgment of 29 April 2025: operating a scheme establishing a transactional naturalisation procedure in exchange for predetermined payments or investments amounts to commercialisation of nationality and of Union citizenship, in breach of the founding treaties. Due diligence checks were held to determine whether identified risks preclude a grant, not whether the applicant's situation justifies it. At paragraph 314 the Court noted Maltese residence could be reduced from three years to one for EUR 150,000.
- European Union states selling citizenship today: none. Cyprus closed 1 November 2020, Bulgaria repealed in 2022, Malta closed 29 April 2025 and repealed the enabling law that July. Malta now operates a residence permit from EUR 37,000\. Austria's discretionary naturalisation for exceptional contribution has no published price, excludes passive investment, and has produced about 287 grants since 2007.
- Portugal: residence requirement of seven days a year; property route removed 7 October 2023; naturalisation period doubled from five years to ten under an organic law in force 19 May 2026; approximately 12,700 principal grants and 20,400 to family members. Spain closed its scheme on 3 April 2025 on housing grounds. Greece sets tiers at EUR 800,000, 400,000 and 250,000, with naturalisation after seven years at 183 days a year plus a language requirement. Italy and Hungary sell residence only.
- Executive Order 14351, signed 19 September 2025, applications from 11 December 2025: a gift of US$1 million, or US$2 million corporate, to be treated as evidence of exceptional business ability and national benefit within existing categories. No investment, business or job creation required. A corporate-sponsored place is transferable to a different individual. It creates no new visa numbers and no enforceable right.
- Cyprus: inquiry chaired by a former President of the Supreme Court found 53 per cent of 6,779 citizenships granted 2007 to 2020 unlawful; 332 revoked by September 2025; Audit Office loss of EUR 200 million in value added tax and EUR 25 million in fees.
- United Kingdom Tier 1 (Investor): closed 17 February 2022\. Written ministerial statement of January 2023 reviewed 6,312 investors and adult dependants who obtained leave between 30 June 2008 and 6 April 2015, found "a small minority" at high risk without attaching a number, and recorded ten sanctioned individuals who had used the route. Its conclusion was that there are inherent difficulties in an investment-based route founded on passive wealth.
- United States EB-5: in the Jay Peak matter roughly US$350 million was raised and about US$200 million misused; Securities and Exchange Commission enforcement in 2016 and later criminal convictions; more than 700 regional centres terminated.
- No visa suspension, Financial Action Task Force finding, listing or entry restriction has been directed at the United States over EB-5 or the United Kingdom over Tier 1\. The European visa suspension mechanism applies to third countries only; against a member state the instrument is infringement proceedings.
- Regulation in force 30 December 2025 adds a suspension ground: operation by a listed third country of an investor citizenship scheme granting citizenship in exchange for pre-determined payments or investments without a genuine link. Suspension runs 12 months, extendable by 24, then a further 24 pending transfer to the visa-required list. Vanuatu was suspended in May 2022 and permanently in December 2024.
- European Commission report of 19 December 2025: approximately 107,000 passports issued by the Eastern Caribbean programmes; 13,113 applications in 2023 and 10,573 in 2024; 2024 rejection rates of 1.7 per cent for Antigua and Barbuda, 5.3 per cent for Saint Lucia and 6.5 per cent for Dominica, with none given for Grenada or Saint Kitts and Nevis. The report advances no documented instance of a Caribbean passport being used to evade sanctions or commit an identified crime.
- The CARIFORUM-European Union Economic Partnership Agreement provides that its services title does not apply to measures regarding citizenship, residence or employment on a permanent basis.
- United Arab Emirates: approximately 250,000 golden visas issued, understood to be around 80 per cent of the global residence-by-investment market. Comoros: approximately 50,000 passports. Neither has been restricted by the United States, the United Kingdom or the European Union.

## Frequently Asked Questions

**What did the Court of Justice decide about Malta?** That operating an institutionalised scheme granting nationality in exchange for predetermined payments amounts to commercialising citizenship of a member state and of the Union, in breach of the founding treaties. Malta closed the scheme the same day and repealed the enabling law in July 2025.

**Does strong vetting answer the objection?** Not on the Court's reasoning. It held that due diligence determines whether identified risks preclude a grant, rather than whether the applicant's situation justifies nationality. Screening tests for danger, not for entitlement.

**Do European Union countries still sell citizenship?** No. Cyprus closed in 2020, Bulgaria repealed in 2022 and Malta closed in April 2025\. Several states sell residence, including Portugal, Greece, Italy and Hungary, with citizenship available only through ordinary naturalisation. Austria retains a discretionary naturalisation with no price that has produced about 287 grants since 2007.

**What is the United States Gold Card?** An executive order signed on 19 September 2025 under which a gift of US$1 million, or US$2 million through a corporate sponsor, is treated as evidence of exceptional ability within existing immigration categories. It requires no investment, business or job creation, creates no new visa numbers, and a corporate-sponsored place may be transferred to a different individual.

**Which investor migration programme has failed most seriously?** On the published record, Cyprus. Its own inquiry found 53 per cent of 6,779 citizenships unlawful. The United Kingdom reviewed 6,312 investor cases and later sanctioned ten people who had used the route. In the United States the Jay Peak matter involved roughly US$350 million raised and about US$200 million misused.

**Why has no action been taken against the United States or the United Kingdom?** The European visa suspension mechanism reaches third countries only. Against a member state the instrument is infringement proceedings, which the Commission used against Malta. No comparable mechanism has been applied to the American or British schemes by any party.