Attorney: Citizenship by investment under fire, but Cayman safe

A Cayman attorney says there is no reason for alarm following a leaked memo from the United States government that threatens potential travel restrictions against countries offering citizenship by investment or golden passport programmes. According to Cline Glidden Jr. of Ogier law firm, Cayman’s residency by investment model is fundamentally different, offering no shortcuts to nationality without residency.

The memo, dated 14 June and signed by US Secretary of State Marco Rubio, names four Caribbean nations – Antigua and Barbuda, Dominica, St. Lucia, and St. Kitts and Nevis – among a list of 36 “countries of concern” being reviewed for potential entry restrictions into the United States. At the heart of the concern is the practice of granting citizenship by investment or “the availability of citizenship by monetary investment without a requirement of residency.”

Glidden makes one thing clear: Cayman is not in that game.

“Cayman does not sell citizenship,” said Glidden in an interview with the Compass. “All we offer is the right to reside – and even that comes with substantial conditions and oversight. It’s not a loophole for gaining a second passport.”

The leaked US State Department document warns that failure to meet specific benchmarks within 60 days could lead to travel restrictions for the named countries. The Caribbean nations being targeted have longstanding citizenship by investment programmes.

As a British Overseas Territory, the Cayman Islands does not, and cannot, issue citizenship in exchange for investment. Local citizenship is regulated by the British Nationality Act and any eventual path to citizenship requires years of genuine residency and rigorous vetting by the United Kingdom.

“Even for those who qualify for unlimited residency, all they are receiving is the right to live in Cayman – not to work and not to obtain a Caymanian passport,” Glidden explained. “All you’re getting is residency. And if you don’t make use of that residency, then you basically wasted the investment, because the only thing you’re getting is residency.”

What Is Cayman’s Residency-by-Investment?

Cayman’s residency by investment program is designed to allow high-net-worth individuals to live – not work – in the Cayman Islands. It is geared toward those who have made their wealth elsewhere and are looking for a secure, high-quality lifestyle in a jurisdiction where they can enjoy their property and contribute to the local economy.

“Cayman sees that as being a benefit, because they’re going to come, they’re going to live here, they’re going to pay fees to government for residency, but all they’re going to be able to do is enjoy the standard of living and quality of life that Cayman allows for and consume and contribute,” said Glidden.

There are two primary pathways to permanent residency via investment:

Certificate of Permanent Residency for Persons of Independent Means (Unlimited Residency):

• Requires a CI$2 million investment in developed real estate (Immigration Minister Michael Myles has stated a definition of “developed real estate,” that makes it clear the property must have a structure, is expected to be part of upcoming law changes).
• A one-time government fee of CI$100,000.
• The applicant need only spend one day per year in Cayman to maintain this status.

25-Year Residency Certificate (Renewable):

• Requires a minimum investment of CI$1 million in real estate.
• A one-time government fee of CI$20,000.
• Requires 30 days per year of physical presence in Cayman.

In both cases, applicants must also hold local medical insurance, show proof of financial self-sufficiency (typically CI$150,000/year in income or assets), provide a clean police record and submit due diligence documentation, including character references and financial statements certified by a professional accountant.

Importantly, residency does not grant the right to work. Should an individual wish to work, a separate work permit – similar to what applies to Cayman’s 39,000 work permit holders – is required.

In contrast to Caribbean jurisdictions that offer citizenship by investment, where foreigners can purchase citizenship for as little as US$200,000 (in the case of Dominica) and obtain a passport with no physical presence, Cayman’s path to citizenship is rooted in long-term presence and contribution.

Moreover, those who wish to apply for British Overseas Territories Citizenship must live in Cayman for at least five years, without being absent for more than 90 days in any given year, and remain free from immigration control for 12 months prior to applying.

“Because we’re a British Overseas Territory, the issuing of citizenship doesn’t come from Cayman,” Glidden stressed. “It’s issued under the British Nationality Act and is based on a permanent connection with the territory. But you have to prove that you have a permanent connection and that Cayman is your primary home, and this is after five years of having this connection.” The UK extensively vets candidates and ultimately determines whether an individual qualifies.

“If someone is trying to buy a second passport or skirt immigration rules in another country, Cayman is not the place to do it,” Glidden said.

While residents of Cayman who hold passports from the four named Caribbean countries could face travel difficulties if US restrictions are imposed, the jurisdiction itself is unlikely to face any repercussions, thanks to the design and oversight of its residency regime.

The US memo marks a clear escalation in global scrutiny of citizenship by investment programmes, which critics warn are a threat to democratic integrity and can open the door to national security risks.

Cayman’s model, in contrast, prioritises transparency, due diligence and a meaningful connection to the country.

“We offer a secure, stable, and sophisticated place to live,” said Glidden. “But we don’t offer citizenship by investment. That’s never been who we are.”