A critical examination of Dominica’s Citizenship by Investment (CBI) program has challenged recent attempts to deflect responsibility for its shortcomings onto United States information-sharing policies. The analysis identifies fundamental structural flaws within the program itself, arguing that design, incentive structures, and administration practices—not external factors—create systemic vulnerabilities.
The central critique focuses on Dominica’s profound fiscal dependence on CBI revenue, which accounts for a majority of government income. This economic reality creates an inherent conflict of interest: when passport issuance becomes the state’s primary revenue stream, approval rates and processing speed inevitably receive priority over rigorous vetting. The program’s dominant role in national finances undermines claims that citizenship decisions remain insulated from financial pressures.
Contrary to arguments presented in defense of the program, the analysis emphasizes that information gaps in applicant backgrounds demand enhanced scrutiny—not complacency. International anti-money laundering and counter-terrorism financing standards explicitly require heightened due diligence when dealing with applicants demonstrating identity complexity, legal name changes, or fragmented personal histories. These are global compliance norms, not exclusively American requirements.
The response further challenges the notion that the United States bears responsibility for ‘fixing its databases’ to accommodate CBI programs. Border security begins with the sovereign act of granting citizenship, wherein the issuing nation vouches for the holder’s identity and trustworthiness. This fundamental responsibility cannot be outsourced or deflected to other nations.
The analysis concludes that credible defense of Dominica’s CBI program requires confronting uncomfortable truths: excessive reliance on passport revenue, structural conflicts of interest, and the treatment of citizenship as a transactional commodity rather than a sovereign trust. Accountability must begin with domestic reforms rather than attempts to shift blame internationally.