Dual Citizenship for Americans: Caribbean, Malta and European Options Compared

Yes.

U.S. law does not require you to give up your American passport when you acquire a second nationality, and Malta and other Caribbean countries, in which it is possible to apply for a second citizenship, place no restrictions on dual or multiple citizenship. That is why more Americans are comparing second-passport and European residence programs, whether for travel flexibility, family planning or simple optionality.

The options fall into two groups, and mixing them up is the most common mistake:

• Citizenship programs or regulations, which give you a second passport: the Caribbean Five (Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis, St Lucia) and Malta's citizenship by merit.
• Residence programs, which give you the right to live in a country but not a passport: the Malta Permanent Residence Programme (MPRP), the Greece Golden Visa and the Portugal Golden Visa.

Five Caribbean nations offer citizenship in return for a qualifying contribution: Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis, and St Lucia.

In practice there are two main routes or options.

1. A non-refundable donation. Entry prices for a single applicant are roughly:

• Dominica: $200,000
• Antigua and Barbuda: about $230,000
• Grenada: $235,000
• St Lucia: $240,000
• St Kitts and Nevis: $250,000

2. An approved real estate investment, often shares in a hotel. Instead of making a non-refundable donation, the applicant invests into a government-approved project, such as a share in a hotel or resort, a villa or a condominium. Such an option generally starts between $200,000 and $400,000 depending on the island and project, and government fees are charged on top. Because it is an asset, it can potentially be resold after the mandatory holding period, commonly around five years and longer in some programs, though resale is not guaranteed.

Some hotel-share structures also include a few weeks of stay per year and a potential income payout, but returns are not assured.

• None of the five programs gives visa-free access to the U.S. for tourism, and only Grenada has an E-2 investor visa treaty with the United States.
• Most applications can be handled remotely, with processing times of roughly 5 to 12 months depending on the country.

Malta has long been recognised as a European jurisdiction offering pathways to citizenship for international individuals and families. Following the judgment of the Court of Justice of the European Union on 29 April 2025, Malta has since moved away from its former investor citizenship framework and has introduced a strengthened citizenship by merit framework.

The current framework builds on Malta’s longstanding concept of citizenship by merit, first introduced in 2017, and was further developed through the Maltese Citizenship (Amendment) Act 2025 and Legal Notice 159 of 2025. It provides a discretionary route for individuals who can demonstrate exceptional services or contributions to Malta, including in fields such as entrepreneurship, science, technology, philanthropy, sport, the arts and culture.

For American nationals, this means that Malta continues to offer a potential pathway to citizenship, but one based on merit, contribution and the national interest. The process is discretionary and subject to a rigorous assessment of the applicant and their proposed contribution to Malta.

What the Malta Citizenship by Merit framework recognises

Malta's merit framework is governed by the Maltese Citizenship Act and its implementing regulations. It allows citizenship to be granted to people who bring exceptional value to Malta or make an exceptional financial contribution. That includes contributions to philanthropy and achievement in science, sport, technology, entrepreneurship and the arts, as well as initiatives that create jobs, opportunities or social impact. It also covers people whose skills, talents or expertise are considered to be of significant national interest. Eligible applicants can be naturalised together with their spouse and children.

Who qualifies for Maltese Citizenship by Merit

Applicants must meet at least one of three criteria:

1. Exceptional service: major achievements or contributions to Malta in a specific field.
2. Notable contribution: for example, philanthropy, research funds, restoration of local heritage or entrepreneurship that generates employment and opportunities.
3. National interest: skills, qualities, talents or expertise considered vital to advancing Malta's national priorities and long-term interests.

Recognised fields include:

• Science and research
• Sports and athletics
• Arts and culture
• Entrepreneurship and philanthropy
• Technology and innovation
• Other areas where expertise or influence adds value to Malta

The central step is a comprehensive submission setting out your achievements, a detailed description of the service, contribution or interest you are relying on, and a clear plan for how you will keep contributing to Malta. In practice the process runs in four stages.

1. Residence Applcation. Applicants first apply for residence in Malta. Once that is approved, a residence card is issued for 18 months.

2. Due diligence. Standard checks cover identity, background and the source of funds behind any financial or philanthropic contribution. Their purpose is to confirm that the applicant meets the "fit and proper person" requirement in the legislation.

3. Proposal and evaluation. The applicant prepares a detailed proposal giving an overview of the applicants’ background, achievements and proposed contribution to Malta. The Community Malta Agency and an independent evaluation board review it and make a recommendation to the Minister responsible for citizenship.

4. Formal application and ministerial decision. If the proposal is approved, a formal naturalisation application can be filed once the 8 months legal residence requirement is met. The Minister may then approve the application, and a Letter of Approval is issued.

5. Investment Completion & Oath of Allegiance. The applicant must then take the Oath of Allegiance within six months after having completed the contribution which was mentioned in the proposal letter.

Where citizenship is not the immediate objective, European residence can provide an attractive alternative. Residence programmes can offer the right to live in an EU country, together with visa-free travel throughout the Schengen Area. Importantly, residence and citizenship are distinct legal pathways, with citizenship subject to its own application process and eligibility requirements.

Malta Permanent Residence Programme (MPRP)

The MPRP offers permanent residence in Malta, providing a long-term European residence solution for individuals and families. It is a residence programme in its own right and is separate from Malta’s discretionary citizenship framework. For a single applicant, the typical costs include:

• 60,000 administrative fee, paid in stages, €15,000 on submission and €45,000 on approval in principle
• €37,000 government contribution, a flat amount since Legal Notice 146 of 2025
• €2,000 donation to a registered NGO
• €500 residence card per person
• Qualifying property: buy for at least €375,000, or rent for at least €14,000 a year, retained for five years and followed by an ongoing obligation to keep a residence in Malta

Greece Golden Visa

Greece offers a renewable five-year residence permit through qualifying investment, with no minimum stay requirement. Since the 2024 overhaul, real estate thresholds are:

• €800,000 in Attica, Thessaloniki, Mykonos, Santorini and islands with more than 3,100 residents
• €400,000 in the rest of Greece
• €250,000 for commercial-to-residential conversions or restoring listed buildings

Portugal Golden Visa

Portugal's program has changed the most:

• Real estate was removed as a qualifying route in October 2023, leaving mainly investment funds, from about €500,000.
• Citizenship now takes 10 years of legal residence for most nationalities, including Americans, and 7 years for EU and Portuguese-speaking-country nationals. This is under Lei Orgânica 1/2026, in force since 19 May 2026. The earlier period was 5 years.
• The residence clock starts when your first residence card is issued, and card delays at AIMA have run to 12 to 36 months.
• The visa itself requires only about 7 days a year in Portugal, but citizenship also requires A2-level Portuguese and civic knowledge.
• Permanent residence is still available after 5 years.

The most appropriate pathway depends on your objectives, circumstances and willingness to meet the relevant requirements:

• If your priority is a second citizenship within a relatively short timeframe: Caribbean citizenship programmes remain the principal options to consider. The comparison will typically come down to the contribution or investment required, processing timelines, family eligibility and any applicable real estate holding requirements.
• If your priority is European citizenship: Malta’s citizenship by merit framework provides a pathway to Maltese citizenship for individuals who can demonstrate an exceptional contribution or service to Malta. Applicants should generally expect a contribution in excess of €1 million, alongside the other applicable requirements and assessments.
• If your priority is establishing a long-term base in Europe: the comparison is more appropriately between European residence programmes such as the Malta Permanent Residence Programme (MPRP), Greece and Portugal. Here, the key considerations are the overall cost, residence requirements, family eligibility, lifestyle and the extent to which you want to establish a genuine connection with your chosen country over the longer term.

Can a U.S. citizen have dual citizenship? Yes. The United States does not require you to renounce your citizenship when you acquire another one.

Is Malta citizenship by investment still available? No. The investment-based program was closed in 2025 after an EU Court of Justice ruling. Citizenship is now granted through a new regulation known as Citizenship by merit.

What is the cheapest Caribbean citizenship by investment? Dominica has the lowest entry price at $200,000 through its donation route, with Antigua and Barbuda, Grenada, St Lucia and St Kitts and Nevis between about $230,000 and $250,000.

Does the Portugal Golden Visa still lead to citizenship? Yes, but not after 5 years. Most nationalities need 10 years of legal residence plus language and integration requirements.

Does the Malta MPRP lead to citizenship? Not automatically. The MPRP grants permanent residence only. Ordinary naturalisation requires at least 5 years of physical residence however in practice, it takes more.