Dominica Suspends CBI Applications From Iranian Nationals

Dominica has suspended the processing of Citizenship by Investment applications from Iranian nationals, according to a memorandum dated 23 March 2026 and circulated to authorised agents.

The suspension took effect immediately. However, the restriction is not absolute.

Under the memo, Iranian nationals may still be considered only if they meet all three of the following conditions:

• they have not lived in Iran for at least 10 years
• they hold no substantial assets in Iran
• they have not carried out any business or similar activity, in whole or in part, in or with Iran

The memorandum was signed by Gregory McDougall, Officer in Charge of the Citizenship by Investment Unit, on behalf of the Director.

A Policy Shift for Iranian Applicants

This marks another change in Dominica’s approach to Iranian applicants under its Citizenship by Investment Program.

Before May 2022, Iranian nationals were already subject to similar restrictions and could apply only under strict conditions. In May 2022, those restrictions were lifted, reopening the program to Iranian nationals without those preconditions.

That changed again in July 2023, when Dominica introduced mandatory interviews and enhanced due diligence fees for Iranian applicants. At that stage, applications were still possible, but the process became more expensive and more closely scrutinised.

The new memorandum goes further. Instead of allowing applicants with Iranian ties to proceed under stricter checks, the current measure effectively blocks anyone who has lived in Iran, held assets there, or done business connected to Iran within the past decade.

What This Means in Practice

In practical terms, the new rule leaves only a narrow path open.

Iranian nationals who have been fully outside Iran for at least 10 years, and who can show no meaningful financial or business connection to the country during that period, may still qualify in principle. For most applicants, however, the new framework will be difficult to satisfy.

While the memo does not describe this as a full ban, the effect is much closer to a near-complete suspension than a standard restriction.