The Grenada CBI and US E-2 combo: an alternative route to EB-5 for Vietnamese investors

The Grenada CBI and US E-2 combo route is attracting the interest of many Vietnamese investors as an alternative to theVisa EB-5with a lower budget. Because Vietnamese citizens cannot apply directly for an E-2 visa, as Vietnam is not on the US Treaty Country list, the two-step route through Grenadian citizenship has become a viable path to working and doing business lawfully in the United States.

Grenada citizenship by investmentallows investors to obtain a second passport within 3 to 6 months with a budget from $235,000 USD. Grenadian citizens then have the right to apply for theUS E-2 Visa— a temporary residence visa that allows them to run a business in the United States with a flexible investment from $100,000 USD upwards. The total combo budget is usually 40% to 60% lower than EB-5, in exchange for a legal outcome of temporary residence rather than a green card.

This article analyses in detail the two steps of the route, the actual timelines and costs, and an important legal point that arose in 2022 which investors must understand before deciding: the 3-year domicile requirement under the Amigos Act.

Why Grenada is the E-2 gateway for Vietnamese people

Grenadais the only Caribbean country among the 5 with CBI programmes to have signed an E-2 treaty with the United States. The treaty allows Grenadian citizens to apply for E-2 visas with the same rights as citizens of traditional treaty countries such as the UK, France, Germany, Japan and South Korea.

Vietnam is not currently on theUS Department of State’s Treaty Country list. As a result, Vietnamese citizens cannot apply for an E-2 with only a Vietnamese passport. To access the E-2, Vietnamese investors must hold the citizenship of a country with an E-2 treaty — and Grenada stands out for having the fastest and lowest-budget CBI programme among the treaty countries.

Compared with other CBI options with E-2 treaties (Turkey, Bulgaria, Egypt, Jordan, Macedonia, Montenegro), Grenada has three core advantages: the lowest CBI budget ($235,000 USD donation); the fastest processing time (3–6 months); and, notably, a constitutional provision allowing spouses to register for citizenship by marriage — an important mechanism for dealing with the Amigos Act issue analysed below.

Step 1 — Grenada citizenship by investment

The first step in the Grenada CBI and US E-2 combo is obtaining Grenadian citizenship through the CBI programme run by theInvestment Migration Agency (IMA) Grenada. The programme was established in 2013 under the Citizenship by Investment Act No. 15 of 2013.

The programme’s two main investment options:

Option 1 — NTF (National Transformation Fund) donation:a non-refundable contribution of $235,000 USD to the National Transformation Fund. This amount covers a family of up to 4 people (the applicant, spouse and 2 dependants). Each additional member from the 5th onwards costs a further $25,000 USD. The NTF funds infrastructure, tourism, renewable energy and education projects in Grenada.

Option 2 — Real estate investment:buying property in a government-approved project for at least $270,000 USD (shared ownership) or $350,000 USD (sole ownership), plus a $50,000 USD Family Administration fee for a family of 4. The property must be held for at least 5 years before resale.

Besides the main investment, investors must pay fixed government fees: due diligence of $5,000 USD per person over 17; and processing, passport and oath of allegiance fees totalling about $12,000 USD for a family of 4. There are also legal and representation fees paid to an Authorised International Marketing Agent.

Standard processing takes 3 to 6 months. Applicants do not have to travel to Grenada during the review — the entire application can be filed remotely through a licensed agent. Once approved by the government, the applicant receives a Certificate of Naturalization and a Grenadian passport.

The Grenadian passport is valid for 10 years and gives visa-free or visa-on-arrival access to more than 140 countries, including the United Kingdom, the Schengen Area, China and Singapore.

Step 2 — Applying for the US E-2 Visa

Once they have Grenadian citizenship, investors can apply for the US E-2 Visa at a US embassy or consulate. The E-2 process does not go through USCIS but is managed directly by theUS Department of State (DOS).

Core E-2 requirements:
– Citizenship of a country with an E-2 treaty with the United States (met through the Grenadian passport)
– Investing a substantial amount of capital in a US business
– The business must be real and active, not a passive investment
– The investor must hold at least 50% of the shares or have operational control
– The business must create jobs for US citizens and permanent residents and must not be marginal (only enough to support the investor’s family)

The E-2 investment has no hard threshold. In practice, common E-2 cases fall between $100,000 USD and $300,000 USD, depending on the industry and size of the business. Service businesses (restaurants, salons, small shops, consultancies) usually require lower investment; manufacturing, technology or large franchise businesses may need more.

Documents to prepare for the E-2: a detailed business plan, records of the capital transferred into the US business, proof of a lawful source of funds, a premises lease or ownership documents, and business registration in the state where it will operate.

After filing the DS-160 and booking an interview, the time from booking to receiving the visa is usually 1 to 3 months. The E-2 visa is usually issued for an initial 2 to 5 years depending on each country’s reciprocity arrangement. For Grenada, the E-2 validity is usually 5 years and can be renewed indefinitely as long as the business is still operating.

The Amigos Act 2022 — the 3-year domicile requirement

This is the most important legal point that investors considering the Grenada CBI and US E-2 combo must understand.

In December 2022, the US Congress passed the National Defense Authorization Act for Fiscal Year 2023, which contained a provision informally known as the “Amigos Act”. The new rule amended 8 U.S.C. § 1101(a)(15)(E) by adding a requirement: if an E-1 or E-2 applicant acquired the treaty country’s nationality through a “financial investment” and has never previously been issued an E-visa, the applicant must have been domiciled in that treaty country continuously for at least 3 years at any time before applying for the E-visa.

The rule aims to limit the use of CBI as a “shortcut” into the United States and took effect as soon as it was signed into law. People who had already been issued an E-visa before the law took effect are exempt from the new rule.

For Grenada, there are two aspects to note:

Aspect 1 — Distinguishing a donation from an investment:Some immigration lawyers argue that the NTF donation is not a “financial investment” in the legal sense — there is no ownership, no capital at risk and no expectation of financial return — so applicants on the NTF route may be exempt from the 3-year domicile requirement. However, this is the interpretation of some lawyers and has not been confirmed by any official precedent. According to reports updated to February 2026, no E-2 application has yet been refused on the basis of the 3-year domicile rule.

Aspect 2 — The spousal registration route:Grenada’s constitution allows the spouse of a Grenadian citizen to register for citizenship through marriage (citizenship by registration) without a residence requirement. If the main applicant obtains citizenship through CBI and is caught by the 3-year rule, the spouse can register for Grenadian citizenship through marriage (not through CBI) and then apply for the E-2 as the main applicant. The original CBI applicant can then accompany them as a derivative spouse. This mechanism is specific to Grenada and does not exist in Turkey.

Domicile is not the same as residence:According to lawyers specialising in E-visas, “domicile” in US law does not mean day-to-day physical residence. Domicile is determined by a combination of factors: habitual residence, intention to stay long-term, and assets and economic activity in that country. Some Grenadian lawyers can issue a legal opinion on domicile based on actual time spent in Grenada plus objective evidence such as a lease, a local bank account and business activity.

Disclaimer: determining whether the NTF route is exempt from the 3-year rule, and fully assessing the spousal registration strategy, requires consultation with a US-licensed immigration lawyer. The information in this article is for reference only.

Comparing the total budget of the combo and EB-5

The table below compares the total budget of the Grenada CBI and US E-2 combo route with the EB-5 programme for a family of 4:

Item	Combo CBI Grenada → E-2	EB-5
Main investment	$235,000 USD (NTF) or $270,000 USD (real estate)	$800,000 USD (TEA) or $1,050,000 USD
US business investment	$100,000 — $300,000 USD	Included in the EB-5 capital
Grenada government fees	~$25,000 — $35,000 USD	Not applicable
Regional Center / legal fees	$15.000 — $30.000 USD (E-2 lawyer)	$50,000 — $100,000 USD
USCIS / DOS fees	~$5,000 — $10,000 USD	~$30,000 — $50,000 USD
Total budget	$400,000 — $600,000 USD	$900,000 — $1,250,000 USD
Ability to recover capital	Grenada real estate (after 5 years) + the US business	EB-5 capital (after the project cycle)

So the Grenada CBI and US E-2 combo saves about $400,000 to $700,000 USD compared with EB-5 for a family of 4. In return, the outcome is temporary residence (a 5-year renewable E-2 visa) rather than a permanent green card.

Comparing the timeline of the Grenada CBI and US E-2 combo with EB-5

The Grenada CBI and US E-2 combo has a major time advantage over EB-5.

Total time from filing the Grenada application to entering the United States on an E-2 visa:
– Step 1 — Grenada CBI: 3 to 6 months to obtain citizenship
– Interval — preparing the business plan and the US business: 2 to 4 months
– Step 2 — E-2 visa: 1 to 3 months from the DS-160 to the interview
– Total: 6 to 13 months if the 3-year domicile requirement does not apply

If the 3-year domicile requirement under the Amigos Act does apply, the total time will be considerably longer — an extra 3 years, or the spousal registration strategy will be needed. This is an important variable to weigh when planning finances and the family’s timeline.

EB-5, meanwhile, usually takes 4 to 7 years from filing the I-526E to a conditional green card for Vietnamese cases, because of the priority date backlog.

Rights and limitations of the E-2 visa

On entering the United States on an E-2 visa through Grenadian citizenship, the investor and family receive the following benefits:
– Living and working in the United States for the visa’s validity (usually 5 years), with unlimited renewals
– Spouses are granted work authorisation and can work for any business in the United States
– Children under 21 accompany the investor as E-2 dependants and attend public schools free of charge
– Freedom to enter and leave the United States during the visa’s validity

Important limitations:
– The E-2 does not lead to a green card and the time does not count towards the naturalisation requirement
– Children cannot keep E-2 status after turning 21
– The investor incurs US tax obligations on income from the US business; spending more than 183 days a year there can make them a tax resident taxed on worldwide income
– E-2 status ends if the business closes or goes bankrupt
– The US business must be maintained for as long as the visa is held

A combined route from E-2 to EB-5 or a green card

A common strategy for Grenada CBI and US E-2 combo investors is to use the E-2 as an intermediate stage and then move to a green card when finances allow. Some switching options:

Switching to EB-5:after running the E-2 business in the United States and accumulating more capital, the investor can invest an additional $800,000 USD in an EB-5 project to move to aUS permanent resident card. This process is particularly convenient because both programmes are investment-based.

Switching to EB-1C:for investors who have run a successful E-2 business of significant size and meet the “multinational manager or executive” criteria ofVisa EB-1.

Switching toEB-2or EB-2 NIW:for investors with exceptional expertise or a significant contribution to the US national interest.

This combined route lets investors enter the United States quickly through the Grenada CBI and US E-2 combo, and then use the time running their business to build the basis for moving to a green card once they are firmly established.

Detailed article onEB-5 vs the US E-2 visa.

Which option suits Vietnamese investors

The Grenada CBI and US E-2 combo suits Vietnamese investors with the following characteristics:
– A budget of $400,000 — $600,000 USD, not enough for or not wanting to invest $850,000 USD or more in EB-5
– Young and dynamic, with business experience and willing to run a business in the United States
– Wanting to get to the United States quickly, not willing to wait many years for EB-5 because of the priority date
– Prioritising a second passport (Grenada) with visa-free access to 140+ countries
– Accepting nonimmigrant status conditional on keeping the business going
– Having a long-term strategy to move to a green card through EB-5 or EB-1C in future

The combo does not suit established, older investors who want a green card straight away to retire or to have their children attend university as citizens/residents — in that case, EB-5 remains the better choice despite the higher budget.

Summary

The Grenada CBI and US E-2 combo is a sensible alternative to EB-5 for Vietnamese investors with a mid-sized budget who prioritise speed and are willing to run a business in the United States. With a total cost of $400,000 — $600,000 USD and a timeline of about 6 to 13 months, the route delivers two results at once: a permanent Grenadian passport and temporary residence rights in the United States.

However, the 3-year domicile requirement under the Amigos Act 2022 is an important legal variable that must be carefully assessed for each specific case. The choice between the NTF and real estate routes, together with the spousal registration strategy if needed, affects the actual time and cost of the route.

PLI’s team of immigration specialists recommends that investors fully weigh three factors before deciding: their actual budget and tolerance for an unrecoverable capital outlay (the NTF donation); their long-term plans for a green card and US citizenship; and their actual ability to run a business in the United States. Consulting both a US immigration lawyer and a licensed CBI agent in Grenada is an essential step before committing a large sum to this route.