Dominica’s promotional guidelines for agents read like a list of the first things a growth marketer would write. No references to visa-free travel, including to the EU and the UK. No “sale of passports” or “buying passport”. No prices below the minimum and no “Special Offers”. No claims to affect the decision or the processing time. No applicant numbers or origins unless the unit has published them. No mass texts or push messages, and no images of officials without approval (CBI News, 2024).
In 2024, four of the five Eastern Caribbean programmes went further together. The four-country memorandum set a US$200,000 price floor, and its marketing terms ban “visa-free access” and passport photographs in advertising (IMI Daily, 2024). The OECS put the price rule in one line: “discounting of the agreed minimum price is illegal” (OECS, 2024).
Most firms read these rules as a compliance burden for one region. They are more useful as a style guide for every programme, including the ones that have not written their rules yet.
What the rules ban, and what to write instead
| Banned | Where | Write instead |
|---|---|---|
| Visa-free travel, including to the EU and the UK | Dominica guidelines; 2022 warning to agents | The status itself: citizenship, and the rights that country’s law gives a citizen. Travel rules belong to other states and change. |
| “Visa-free access” and passport photographs in ads | Four-country memorandum, 2024 | Show the process, the documents and the people who handle them. |
| “Sale of passports”, “buying passport” | Dominica guidelines | Contribution, application, approval. |
| Prices below the minimum, “Special Offers”, discounts | Dominica guidelines; OECS | The official amount, exactly, with the regulation named and the fees that come on top. Never “from”, “only” or “starting at”. |
| Claims to influence the decision or the timeline | Dominica guidelines | The steps, in order, and who decides each one. |
| Applicant numbers or origins not officially published | Dominica guidelines | Published statistics only, dated and linked. |
| Mass texts, push messages, officials in images | Dominica guidelines | Answers to people who asked. No officials in visuals. |
| Online promotion without authorization | Antigua and Barbuda CIU | Check the authorization before publishing a programme page. |
The Investment Migration Council’s code of marketing adds the general principle: accuracy, no aggressive advertising, fair comparisons (IMC, 2022). Every line in the table is a version of it.
The words are banned because they became evidence
The rule against visa-free claims did not come from a style committee. The European Commission described Vanuatu’s schemes as “commercially promoted with the expressed purpose of granting visa-free access to the EU” (IMI Daily, 2022). The EU then suspended its visa waiver with Vanuatu in full (Council Decision 2022/2198) and moved the country to the list of those whose nationals need a visa (Regulation 2025/11). The regulation records that screening took at most 14 days, extendable to 30, with no interviews and an “extremely low” rejection rate.
In 2025 the EU moved to make the operation of an investor citizenship scheme a ground for suspending visa-free travel (The Sofia Globe, 2025).
A firm that leads with visa-free access is writing the argument against the product it sells.
The banned words were never the strongest words
Remove “visa-free”, “buy”, “from” and “fast”, and what remains is what a serious buyer was trying to find under them: what the status is, what it costs exactly, what happens in what order, and who decides. That copy is harder to write, because it requires knowing the programme. That is the point. It is the copy a competitor without the knowledge cannot produce.
Four rewrites
- “Visa-free travel to the EU” becomes the legal status and its rights under that country’s law.
- “Second passport from US$200,000” becomes the official minimum, the regulation that sets it, and every fee on top.
- “Approved in 90 days” becomes the steps in order and the office that decides each one.
- “Buy your Plan B” becomes “apply for citizenship by contribution”.
The rewrites also protect the firm in places that have no CBI rules at all. Under Argentina’s consumer law, specific claims made in advertising are part of the contract with the client (Ley 24.240, article 8). For lawyers, the obligation is older than any programme. The Buenos Aires bar’s ethics code asks for “mesura y decoro” in advertising, bans advertising based on fees, and warns against anything that “pueda interpretarse” as exploiting political influence (CPACF, Código de Ética, article 10). Article 19 adds that a lawyer must not create false expectations.
A new programme has no rules yet. Write as if it did.
New programmes publish their marketing rules late. When Argentina announced its citizenship programme on October 2, 2026, the government published amounts and a timeline, and no rules for agents’ marketing (Ministerio de Economía, 2026). Every page written in the weeks that follow will be read again when the rules arrive, by the regulator and by clients comparing firms.
The safe assumption is that the strictest existing code is the floor. Firms that already write to Dominica’s guidelines will have nothing to take down. Firms that wrote “fast-track”, “special launch price” or a count of visa-free countries will have to rewrite, and the old versions stay in search results and screenshots.
Responsibility also travels down the chain. Malta’s agent code made a licensed agent “fully responsible” for its referral sub-agents (Malta Community Agency, 2021). A firm that answers for its introducers needs to hand them its house rules.
