
Thousands of UAE residents who bought second passport face uncertainty
On June 14, US Secretary of State Marco Rubio signed a memorandum giving 36 countries — including several with CBI programmes — a 60-day deadline, ending August 13, 2025, to meet stringent vetting and information-sharing standards or face visa bans. The European Union is also advancing legislation to suspend visa-free Schengen access for nations with weak oversight. If passed, the law could come into force by September.
For expatriates from India, South Asia, and the Middle East, the implications are severe. Second citizenships had become a popular route to global travel and financial flexibility. Families typically spent between $115,000 and $330,000 on passports from Caribbean and other CBI jurisdictions that promised access to more than 140 countries.
'It's a perfect storm, and many passport holders didn't see it coming,' says Sam Bayat, founder of Dubai-based Bayat Legal Services and a pioneer in international investment migration in the region. 'People invested hundreds of thousands of dollars into citizenship programmes, believing it was their ticket to global freedom. Now, they're facing sudden restrictions that could render those passports practically useless.'
The fallout is being felt most acutely in the UAE, where expats make up nearly 90 per cent of the population. While exact nationality data is unavailable, Bayat estimates that more than 10,000 applications have been filed from the region in recent years. 'Assuming three individuals per application, we're easily looking at 30,000 people, many of them UAE-based, who could be affected.'
In limbo
According to data shared by the European Commission, five Eastern Caribbean CBI jurisdictions — Antigua & Barbuda, Dominica, Grenada, Saint Kitts & Nevis, and Saint Lucia — have collectively issued over 100,000 citizenships between 2014 and mid-2024.
The crisis is particularly acute for Indian nationals in the UAE. India does not allow dual citizenship, so many who opted for a second nationality had to relinquish their Indian passports. Henley & Partners' 2024 Private Wealth Migration Report notes that 4,300 wealthy Indians gave up their citizenship in 2023, with many choosing Caribbean or other CBI programmes while living in the Gulf.
"We took this step thinking we were securing our future. Now it feels like everything's up in the air," said a Dubai-based Indian expat who acquired a Saint Lucia passport in 2022. "I'm following the developments and hoping it doesn't come to a point where we're left without real options,' he added.
'For families who sold property or dipped into savings to secure their second passports, this is more than a policy change — it's a personal crisis,' said Bayat. 'They may feel betrayed, especially those who renounced their nationalities."
Local agencies in the Gulf, many of which aggressively marketed these programmes as low-risk, high-reward investments, are under pressure too. 'This could be the end of the road for dozens of firms that built their businesses on Caribbean passports,' says Bayat.
'Cosmetic change not enough'
A 2023 European Commission report flagged 88,000 'golden passports' issued by Caribbean states, raising concerns about lax due diligence and high-risk applicants. The US memorandum also targets Cambodia and Egypt — a sign that the issue is no longer confined to the Caribbean.
Many countries are pledging reforms, but Bayat argues that cosmetic changes won't suffice. 'A phased, credibility-first model is the only path forward. Without structural reform, CBI risks being viewed as a security threat rather than a legitimate development tool.'
He warns: 'Commonwealth ties or past diplomatic goodwill won't protect countries from enforceent if their citizenship programmes fail to meet modern standards of integrity.'
'The EU's suspension of Vanuatu and the CJEU ruling against Malta have created a clear legal and policy precedent — CBI must involve genuine residency, integration, and public accountability, or face consequences.'
'Visa-free access to the UK or Schengen is not a birthright, it's a privilege based on trust. And that trust is eroding fast for countries that continue to operate opaque or outdated CBI models.'
For countries like Saint Kitts and Nevis or Dominica, which rely heavily on revenue from citizenship sales to fund infrastructure, schools, and hospitals, the stakes are high. 'A US travel ban would devastate their local economies, and most of their populations won't understand the reason,' said Bayat.
Secure alternatives
Amid growing uncertainty, many affected individuals are exploring secure alternatives, particularly the UAE's 10-year Golden Visa.
'We are navigating a significant transformation in the citizenship by investment landscape,' says Rayyad Kamal Ayub, managing director of Rayad Group Immigration Services. 'The shift away from off-the-shelf passport purchases indicates a move toward more sustainable and legitimate pathways.'
His firm has set up a help desk to assist affected individuals as the rules evolve. 'The growing appeal of programmes like the UAE Golden Visa lies in their credibility,' Rayyad says. 'Points-based systems in Canada, Australia, and New Zealand are also gaining traction, as countries prioritise applicants' qualifications and long-term value over cash.'
Bayat is clear: The idea of investment migration isn't under attack, only the way it has been misused. 'Citizenship is a sovereign right, but it carries responsibilities for both the issuing state and the individual,' he says. 'The US and EU message is loud and clear: adapt or be shut out.'
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