Of sovereignty, sandals, and the supreme art of passport retail

By Mikhail Charles

Welcome to the grand bazaar of citizenship

St. Vincent and the Grenadines (SVG), known for its idyllic beauty and its conspicuous abstention from the regional trend of selling passports, is now the setting for a fierce debate: Should we embrace a citizenship by investment (CBI) programme or continue to treat our nationality as sacrosanct?

Dr. Jason Haynes argues yes — emphatically. Luke Browne counters with an equally emphatic no. The result? A philosophical clash of sovereign pride versus economic pragmatism, wrapped in legal nuance and, occasionally, moral grandstanding.

I attempt to explore both perspectives, situate them in SVG’s legal framework, and propose something tragically radical: a clear, public, rules-based policy governing how our prime minister exercises his discretionary power to grant citizenship.

Dr. Jason Haynes — economic sovereignty in practice
Dr. Haynes argues that SVG’s economy — buffeted by natural disasters, a faltering agricultural sector, and declining tourism — is in dire need of revenue. A well-regulated CBI programme, he posits, could generate EC$150–200 million annually, citing Dominica and Antigua & Barbuda as success stories.

More interestingly, Haynes reframes CBI as not just a financial tool but a postcolonial declaration of self-determination. He challenges the European fixation on the “genuine link” doctrine, noting that Caribbean peoples were historically denied citizenship despite their indisputable ties to land and labour. If European courts insist on solidarity, Haynes quips, they could start with reparations.

He also notes the Advocate General’s opinion in the ECJ’s Malta case: international law does not require a genuine link. States remain free to define their own criteria for nationality — a position arguably more in line with international norms than the ECJ’s restrictive ruling.

Haynes supports his argument with comparative regional data, referencing how Dominica used CBI funds to rebuild post-Hurricane Maria, with thousands of climate-resilient homes financed through the programme. Antigua and Barbuda, meanwhile, has funded university campuses and infrastructure. It’s not just cash in hand — it’s transformative capital.

Luke Browne: principled, if predictably so, the party line
Luke Browne’s argument is equal parts cautionary tale and moral plea. He opposes CBI on the ground that citizenship should not be sold to those who lack a genuine connection to the country. He cites the European Court of Justice ruling in the Malta case and leans into a value-driven interpretation of citizenship.

However, Browne’s rhetorical framing deserves scrutiny. His invocation of SVG’s relatively strong growth post-pandemic omits key facts: that this growth was aided by external grants, remittances, and unsustainable debt. His argument that SVG doesn’t need CBI, then, is at best incomplete and at worst misleading.

His concern that SVG would become a haven for tax dodgers and shadowy businessmen is a legitimate one — but one that can be addressed through robust due diligence and regional cooperation. Indeed, the ECCB has proposed a regional regulatory authority to address precisely those issues. Why omit this detail? A rhetorical convenience, perhaps.

And while Browne worries about the “commodification” of citizenship, he fails to mention that Section 9 of the Citizenship Act already allows the Prime Minister to bestow citizenship on economic grounds — just without structure or transparency. To defend the status quo as virtuous is to ignore the real risk of abuse that already exists.

The legal framework: broad discretion meets narrow visibility
SVG’s Citizenship Act (No. 12 of 1984) governs the acquisition of citizenship.

Apart from birth and descent, the most intriguing — and under-discussed — provision is Section 9, which empowers the Minister (i.e., the prime minister) to grant citizenship by registration to any individual who:

• Is of good character,
• Has an adequate knowledge of English and the responsibilities of citizenship,
• And has, over at least five years, made a substantial contribution to the economic or cultural development of SVG.

On paper, this section appears to offer a balanced approach.

But its implementation reveals the flaws: the discretion is broad, unfettered, and not subject to any statutory or judicial oversight.

This is compounded by Section 18, which states that decisions made under the Act are final, not subject to appeal or legal challenge, and need not be accompanied by reasons. One might say the process is less of a policy and more of a shrug.

Indeed, Dave Ames (and the current factual fracas around what status he actually holds) — whose acquisition of citizenship and subsequent fraud conviction in the UK — demonstrated just how easily the current legal framework can be manipulated. And while Ames is an outlier, the system’s openness to such outcomes should concern any self-respecting rule-of-law jurisdiction.

Regional comparators: what the neighbours are doing
In St. Kitts and Nevis, the CBI programme generates approximately 25–30% of GDP. Dominica has reinvested proceeds into public housing, storm-resilient infrastructure, and budgetary support. St. Lucia has introduced bond and donation options. Grenada links CBI to hotel developments and job creation.

Each of these programmes has had its teething issues — allegations of corruption, lack of transparency, and external pressures. Yet reforms have followed. Enhanced due diligence, third-party vetting (e.g., S-RM, Exiger), caps on applications, and published reports have improved accountability. SVG could, quite literally, copy and paste the best practices, sidestep the mistakes, and implement a leaner, smarter model.

A modest proposal: publish the policy
Regardless of whether SVG launches a full-scale CBI programme, it must address the current opacity.

A formal, public citizenship discretion policy should outline:

• Clear criteria for eligibility (including a minimum investment amount and proof of source of funds),
• An independent citizenship commission to vet applications,
• A procedural framework with third-party due diligence and international AML checks,
• A requirement for independent verification of contribution claims,
• Public reporting obligations — including number of citizenships granted, country of origin of applicants, and investment types,
• And an express prohibition on the grant of citizenship to individuals under international sanctions, or subject to extradition requests.

Transparency is not the enemy of discretion — it is its best defence. Such a policy would allow SVG to maintain control over its citizenship, avoid the perception of impropriety, and signal to domestic and international observers that it takes governance seriously.

Conclusion: policy, not posturing
Whether one agrees with Haynes or Browne, the lack of policy clarity is untenable.

Browne’s moral objections, while earnest, risk romanticising a status quo in which citizenship can already be quietly sold without safeguards.

Haynes’ enthusiasm for CBI, while economically rational, needs to be tethered to institutional discipline.

In short, SVG should not fear discretion — but it should fear discretion without guidance. A transparent citizenship policy, properly implemented, would allow the country to assert its sovereignty, enhance its credibility, and honour the genuine link that matters most: a commitment to its people’s long-term development.

Mikhail Charles is a barrister-at-law admitted in multiple jurisdictions, hon. legal advisor to a foreign government and is usually seen in Vermont with his grandmother eating bakes and saltfish on the porch with a malt from time to time.

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