U.S. Expands Travel Ban: Antigua and Barbuda and Dominica Respond to Visa Restrictions

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On December 16, 2025, the Trump administration announced a significant expansion of U.S. travel restrictions, citing national security concerns. The updated proclamation includes:

Full Travel Ban vs. Partial Visa Restrictions

• Full Travel Ban: A complete prohibition on entry into the U.S. for nationals of the listed countries, regardless of visa type. This applies to Burkina Faso, Mali, Niger, South Sudan, Syria, and individuals traveling on Palestinian Authority-issued documents.
• Partial Visa Restrictions: Targeted limitations on certain visa categories (such as immigrant visas or specific non-immigrant classes) for nationals of 15 countries. These restrictions do not amount to a total ban but significantly limit access to U.S. visas. This applies to 15 nations, including Antigua and Barbuda, Dominica, Nigeria, Senegal, Tanzania, and others.

Exemptions apply to lawful permanent residents, existing visa holders, diplomats, athletes, and travelers tied to U.S. national interests.

Why Antigua and Barbuda and Dominica Were Added

The rationale provided around Antigua and Barbuda and Dominica stems from U.S. concerns over Citizenship by Investment (CBI) programs, which allow foreign nationals to acquire citizenship through investment. Washington cited potential vulnerabilities in vetting processes as a contributing factor.

Caribbean Leaders Demand Clarification

The inclusion of Antigua and Barbuda and Dominica in the partial ban has sparked immediate diplomatic engagement:

• Antigua and Barbuda: Prime Minister Gaston Browne criticized the decision, noting that all Caribbean countries operating Citizenship by Investment programs will soon implement a minimum 30-day physical residence requirement for applicants to strengthen compliance and integrity. Browne confirmed that Antigua and Barbuda has contacted the U.S. State Department, which reportedly expressed surprise at the inclusion. Antigua plans to escalate the matter directly to President Trump and Secretary of State Marco Rubio. Additionally, Ambassador Sir Ronald Sanders confirmed after discussions with U.S. officials that all existing visas for Antigua and Barbuda nationals remain valid and will not be revoked. However, new visa applications after December 31, 2025, will require updated biometric data aligned with U.S. systems. The government reaffirmed its commitment to U.S. security while ensuring continued legitimate travel and cooperation between both nations.
• Dominica: Prime Minister Roosevelt Skerrit echoed similar concerns, calling the ban an “error.” Dominica highlighted its ongoing reforms to align its CBI program with international security standards and is actively engaging U.S. officials for clarification.

Implications for CBI Clients in Antigua and Barbuda and Dominica

For individuals who obtained citizenship through Antigua and Barbuda and Dominica’s CBI programs, the impact is notable but manageable. While the U.S. restrictions may temporarily limit visa access for certain categories, existing exemptions and diplomatic efforts provide reassurance that solutions are being pursued. Here are the key considerations:

• Travel Planning: CBI clients may need to adjust short-term travel plans to the U.S., particularly for business or education, until there is further clarity.
• Investment Confidence: Antigua and Barbuda and Dominica have committed to implementing stronger compliance measures in line with regional regulator recommendations, which include a 30-day residency requirement. While full details have not yet been formally released, these commitments position their programs favorably for future policy reviews.
• Long-Term Outlook: Regional leaders are actively engaging with U.S. authorities, and both nations remain committed to maintaining the integrity of their CBI programs. These steps aim to reassure investors and preserve the global reputation of Caribbean citizenship offerings.

Risk for Other Caribbean CBI Nations

Although St. Lucia, Grenada, and St. Kitts and Nevis are not currently included on the U.S. restricted list, their Citizenship by Investment programs remain under scrutiny due to the historical absence of any physical residency requirement. This gap has long been highlighted by international stakeholders as a potential weakness in identity verification and due diligence processes. Applying the same rationale, other programs with similar characteristics could also face risk exposure. In contrast, Antigua and Barbuda is generally regarded as more secure, given its strong compliance standards, rigorous due diligence procedures, and its mandatory residency requirement in place since the program’s inception.

The inclusion of Antigua and Dominica, specifically due to their CBI programs, signals that similar offerings in other Caribbean nations could face future scrutiny. U.S. authorities have made it clear that programs perceived as “passport-for-sale” without robust residency and vetting standards are high-risk.

Current Measures Across the Region

In response to growing international pressure, Caribbean nations with CBI programs are implementing reforms to strengthen compliance and transparency. These measures include:

• Introducing Physical Residency Requirements: All 5 Caribbean CBI countries are moving toward a mandatory 30-day physical residency period for new CBI citizens to demonstrate genuine ties to the jurisdiction.
• Enhanced Due Diligence: Governments are adopting stricter vetting processes, including biometric checks, third-party verification, financial transparency audits, and mandatory interviews.
• Legislative Updates: New laws are being drafted to embed residency obligations, advanced biometric verification, and e-passport security features.
• Quota and Net Worth Controls: All Caribbean CBI jurisdictions have committed to implementing annual application caps and minimum wealth thresholds under the new ECCIRA regulatory framework, ensuring consistency and program integrity across the region.

These steps aim to align Caribbean CBI programs with global best practices. However, until the U.S. completes its review, all nations offering CBI remain on alert and must actively demonstrate compliance to avoid inclusion in future restrictions.

Next Steps

• Diplomatic Negotiations: Antigua and Barbuda and Dominica are pressing for detailed justifications and removal from the restricted list.
• Policy Reforms: Caribbean nations are spotlighting recent legislative changes to strengthen compliance and transparency.
• Awaiting U.S. Response: The coming weeks will determine whether diplomatic efforts succeed before the January implementation date.