WASHINGTON, Unites States (CMC) – Four of the five Eastern Caribbean nations offering citizenship by investment (CBI) programmes have found themselves on a new US State Department watchlist.

Antigua and Barbuda, Dominica, St Kitts and Nevis, and St Lucia are listed in a leaked State Department memo obtained by The Washington Post, which reveals that the Donald Trump Administration is reviewing potential visa bans or other restrictions for nationals of 36 additional countries.

The four Caribbean countries named in the memo have previously defended their CBI programmes as legitimate tools for economic development, with safeguards, including rigorous due diligence.

According to The Post, the memo – signed by Secretary of State Marco Rubio and circulated to US diplomatic missions over the weekend – gives the listed governments 60 days to meet newly-defined benchmarks. Governments have been given a deadline of 8:00 am next Wednesday to submit an initial action plan outlining how they intend to meet the requirements, according to the Washington Post.

A key concern cited in the memo is the sale of citizenship without a residency requirement. The memo also referenced other issues, such as alleged incidents of “anti-American activity” in the US by nationals of listed countries.

However, the memo also suggests that countries willing to accept third-country nationals removed from the US, or to enter a “safe third country” agreement, could alleviate some of Washington’s concerns.

In addition to the Caribbean nations, the list includes 25 African countries and several from Central Asia and the Pacific. The memo represents a significant expansion of a presidential proclamation issued on June 4, which imposed full travel bans on nationals from 12 countries – Afghanistan, Myanmar, Chad, the Republic of Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, and Yemen. Partial restrictions were also applied to Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela under that order.

The full list of countries facing scrutiny in the new memo is: Angola; Antigua and Barbuda; Benin; Bhutan; Burkina Faso; Cabo Verde; Cambodia; Cameroon; Côte d’Ivoire; Democratic Republic of Congo; Djibouti; Dominica; Ethiopia; Egypt; Gabon; Gambia; Ghana; Kyrgyzstan; Liberia; Malawi; Mauritania; Niger; Nigeria; Saint Kitts and Nevis; Saint Lucia; Sao Tome and Principe; Senegal; South Sudan; Syria; Tanzania; Tonga; Tuvalu; Uganda; Vanuatu; Zambia; and Zimbabwe.

There has been no official response from the White House so far. A State Department spokesperson declined to comment, saying the agency would not comment on internal deliberations or communications, The Washington Post reported.