On July 1, 2024 the five OECS Caribbean CBI jurisdictions signed the Memorandum of Agreement that pinned any qualifying investment option at a US$200,000 minimum. Two years on, in May 2026, the live question is not whether that floor still holds. It does, and any agent quoting below it is openly violating the regional MOA. The live question is whether the 200k in Dominica is the government fund 200k or the real estate 200k. Those two numbers carry very different cash flow and lock-up structures behind them.
I am Ken Huang. I have run Caribbean CBI files out of my home in LA for eleven years, working as a government-licensed agent for Saint Kitts, Saint Lucia, Grenada and Dominica. In our Dominica book, applicants choosing the government fund versus real estate route split roughly four to one. The split is not because real estate is more expensive on the headline number. It is because most clients undercount what real estate actually costs once it is on the table.
The Government Fund Route - The Honest Three-Person Family Number
The Economic Diversification Fund (EDF) contribution starts at 200,000 USD, non-refundable. Main applicant due diligence sits at 7,500 USD. Each dependant aged 16 or above adds another 4,000 USD in due diligence fees. Then there are government processing fees, passport fees and certificate fees that scale with family size. A standard three-person file, main applicant, spouse, one minor child, lands at about 226,000 USD all-in: 200k contribution, 11k due diligence, and roughly 15k of stacked government and processing line items.
That number is one of the cleanest entries among the nine active CBI passports. Sao Tome opens at 95k. Vanuatu at 130k. But Sao Tome carries no Schengen, no UK, no US E-2 access, and Vanuatu lost Schengen in 2024 and UK back in 2023. The Dominica 200k floor buys 140-plus visa-free destinations including Schengen. The price reflects the outcome, not a markup.
Real Estate at 200k - Why That Number Is Not Really 200k
The real estate option starts at the same 200,000 USD floor, but the buyer takes a share in a CBIU-approved development rather than a standalone deed. The theoretical case is that after a three-year hold (extending to five years if the next buyer is also a CBI applicant), the share can be resold to recover a portion of the capital. The trade-off lives on top of the headline price. Dominica charges a separate government investment fee for the real estate route, around 35,000 USD for a family of three, plus the same due diligence and processing stack. Total cash out the door lands at roughly 270k to 285k USD. About 50,000 above the fund route.
So why does the remaining 20 percent of our book still pick real estate? The recovery story on the 200k share. Two details, however, sit underneath the developer marketing decks and they rarely make it into client calls before contract signing. First, the buyer takes a share, not a freehold title. Secondary market liquidity sits entirely on the project itself absorbing the next round of CBI applicants. Over the past twelve months across the five-country Caribbean shared market, secondary share turnover has stretched from about eight months to roughly fourteen. Second, during the three-year lock, the share holder is not the independent owner of an income-producing asset. If the developer hits cash flow trouble in that window, the recovery thesis dilutes quickly.
The 2026 Variable Is Not Price - It Is Diligence
Beyond the MOA, FATF and EU pressure through 2025 and 2026 pushed the CBIU to standardize enhanced due diligence at 4 to 7 months for all applicants. Every applicant aged 16 or above runs through a four-tier check: criminal history, source of funds, politically exposed person status, and international sanctions screening. Our 2026 Dominica family files have hit a median 5.5 months from filing to enhanced due diligence outcome. Add government decision and passport print, and the realistic timeline from contract signed to passport in hand is 7 to 9 months.
Any agent still selling a three-month Dominica timeline in May 2026 either has not closed a current case under the new diligence regime or knows the truth and chooses not to share it. Our work as a government-licensed agent does not have room to compromise that line. The reputational cost to our practice from a single bad-faith promise outlives any single fee.
What Actually Gets Files Stuck Is Source-of-Funds, Not Investment Size
Across our 2025-2026 Dominica family files, the recurring EDD bounce-back has not been the money itself. It is the documentary chain on how the money got there. A 500,000 USD offshore balance that the client remembers as fifteen years of trading profit has to be reconstructed as a chain: account opening date, counterparties on the largest five-year wire flows, matching tax filings or business registrations. Any gap in the chain triggers an EDD Request for Information. Each RFI round takes three to five weeks. Our internal pre-review on source-of-funds runs harder than what EDD asks for, not to inconvenience the client but to keep the file from collapsing in month five and pushing the whole timeline back by two months.
A second detail surfaced in 2026: the Caribbean shared due diligence database now matches at the individual application level. A family rejected in Grenada eighteen months ago that re-files in Dominica through a different agent will hit a shared-database flag and route automatically into enhanced review. This rule does not appear in any public document, but our case work confirmed it twice this year. If a client has prior Caribbean filings, we walk through that history first before deciding whether Dominica is the right next move.
Who This Passport Fits, and Who Should Look Elsewhere
Dominica fund route fits a client whose budget sits in the 200k to 280k band, whose family structure is straightforward, who does not need the US E-2 route, who does not require UK 180-day access, and who can absorb the 7 to 9 month real timeline. In that profile, Dominica remains a clean entry-level CBI in the nine-passport pool.
If part of the brief is recovering capital after the lock period, the real estate route deserves a sober second look at actual secondary market velocity rather than developer 2018-vintage transfer data. The 2025-2026 secondary market is not the 2018 market. If US E-2 access is genuinely on the list, only Malta historically and Grenada or Turkey under deep-presence binding ever delivered that route. Malta closed in April 2026. Grenada and Turkey remain on the table only with substantial actual residence and business activity in country.
WhatsApp +1 559 566 6666, message Dominica Honest Ledger. I will send the full cost breakdown and the three real-case timelines from our 2026 Dominica book directly. No email capture, no phone call required. Read it, then decide whether this passport fits your file.
