Under pressure from the USA, the Caribbean countries of Dominica, Granada, Antigua, St Lucia, and St Kitts have introduced certain changes to their citizenship-by-investment programs. One of the most prominent changes is the introduction of the personal interview requirement. Below we discuss the pros and cons of the new rules and the interview requirement in particular and show that a personal interview is a positive change for the benefit of all parties.
The background
At the end of February 2023, Prime Ministers and heads of the Citizenship by Investment Units (CIU) of the five Caribbean countries issuing golden passports had talks with senior officials from the US Ministry of Finance on investment immigration issues.
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The negotiations became necessary because the USA had been considering introducing sanctions against those Caribbean states that administer citizenship-by-investment programs. Insiders claimed that the US administration had been pondering the possibility of sanctioning the Caribbean banks that provided services to foreign candidates for Caribbean citizenship. As a result of the talks, all six suggestions made by the Americans were accepted by the Caribbean delegations. The table below lists the new regulations that have been introduced.
| Service denial to citizens of Russia and Belarus | Since March 31, 2023 acceptance of applications for citizenship by investment from Russians and Belarusians has been suspended. |
| Exchange of information about rejected applications | The Caribbean states have agreed to exchange the information about the application for citizenship that each of them has rejected. In this way, the person who has failed to qualify for citizenship of one Caribbean country will be barred from applying for citizenship of another country in the region. |
| Program audits | National citizenship-by-investment will be periodically audited from now on. International audit standards will be applied. The audits will take place every year or once every two years. |
| Involvement of law enforcement agencies in passport retrieval | Law enforcement agencies will now be involved in retrieving the annulled passports of the Caribbean countries. |
| Additional due diligence procedures | All candidates for economic citizenship will have to undergo additional due diligence checks that will be performed by various financial monitoring agencies. |
| Personal interviews | The Caribbean officials will conduct interviews with candidates for economic citizenship – via the Internet or in person. |
Because the five Caribbean states agreed to introduce the abovementioned regulations, the US officials recognized the legitimacy of the citizenship-by-investment schemes and their importance for the economies of the host countries.
As far as the technical details of each new requirement are concerned, they are expected to be finalized before August 2023. According to analysts, the introduction of the personal interview requirement is the most notable change of all. Previously, personal interviews were conducted only in exceptional cases in the Caribbean.
Formalization of the already-existing practices
Independent experts have commented on the results of the negotiations between the American and Caribbean delegations. They have noted that most of the ‘new’ principles of granting Caribbean citizenship to people from other countries have been applied before in this or that form. So most of the principles are not actually new. For instance, Russians and Belarusians have been unable to apply for Caribbean citizenship for a few months already. What has changed is that now there are legislative frameworks that make these practices official and obligatory for all Caribbean countries running citizenship-by-investment programs.
As of June 2023, the Caribbean CIUs have not presented any concrete information about the time when the new principles will be fully implemented. They all agree, however, that the new regulations have to be applied in any case.
Experts expect that important announcements are going to be made in the near future. They also believe that there will be a transition period that the immigration authorities of Dominica, Antigua, Granada, St Lucia, and St Kitts will use to test the new procedures.
Introduction of the interview requirement: prospected consequences
The decision to interview all prospective candidates for Caribbean citizenship stands out against the background of all other new requirements. Some experts initially gave a negative evaluation of the interview requirement. They put forward two main arguments. First, the obligation to have an interview will make the process of Caribbean citizenship acquisition more cumbersome. Second, the ‘human factor’ will play a serious role as the interpretation of the interview results is going to rest with the immigration service officers.
Other experts disagree. They believe that the introduction of the interview requirement is the best thing that can happen to the Caribbean citizenship-by-investment programs. The logic behind this opinion is rather complex but it can make sense if you look closely at the matter. Below we discuss the main reasons that the supporters of the interview requirement offer.
- Improved legitimacy of the programs: Anyone who has worked in the investment immigration industry will confirm that he or she has come across clients that are highly skeptical about the legitimacy of the Caribbean citizenship-by-investment programs. Everybody will have heard of Spain or Great Britain but many people know absolutely nothing about the Federation of Saint Kitts and Nevis, for example, as well as many other Caribbean countries. If a prospective client has never heard the name of the country that offers citizenship-by-investment opportunities (as it turns out), he or she will expectedly have doubts about the legality of the program. What if it is just some sort of a complicated fraudulent scheme? On the other hand, if the foreign national looking to acquire second citizenship talks to the Government officials in Grenada or another Caribbean country in person, he or she will have a chance to learn that the local citizenship-by-investment program is 100% legitimate. Moreover, the interviewee will see that the program is actually one of the pillars of the local economy. In addition, an interview will let the Government officials ascertain that the foreigner is applying for Caribbean citizenship via a licensed immigration agent and not via a self-imposed fraudster.
- Faster remedial action: Another important advantage of a personal interview is the opportunity to quickly correct possible mistakes and information gaps. When scrutinizing the application documents, the CIU officer can visualize the applicant only by looking at his/ her photograph. If the officer finds that some information is missing, he/ she will have to email the applicant. Due to cultural differences, misunderstanding may occur and the CIU officer will have to ask the same question several times, rephrasing it every time he/ she sends a new email to the prospective citizen. This certainly slows down the process of Caribbean citizenship acquisition. In some extreme cases, the CIU may reject the application if its officers fail to reach an understanding with the foreign applicant. A personal interview will greatly contribute to solving this problem. All the issues can be quickly resolved in the course of personal communication with the applicant and the immigration agent. Those skeptical about the ‘human error’ should be reminded of the following fact: exchange of email messages is ripe with possible misinterpretation and misunderstanding to a much greater degree than personal communication is.
- Improved communication: An interview is a session where parties exchange opinions. It is a focused discussion between the applicant, the immigration agent, and the Government official. The latter interview participant will pose questions and the applicant together with the immigration agent will have every opportunity to clarify anything that they don’t quite understand and make sure that their interpretation of the question is correct.
- Source of new data to improve the procedures: Finally, the interviews are going to contribute to the overall improvement of the application processing procedures. Both the CIU officers and the immigration agents will be able to collect a lot of first-hand information from the interviews. For example, the CIU officer will have a better understanding of the problems that foreign applicants for Caribbean citizenship face. The immigration agent, in his/ her turn, will have a better chance to understand what the immigration authorities are looking for, what their preferences are, and how the agent’s approach to providing services can be changed, if necessary. The immigration agent can also keep track of the latest trends and tendencies in the CIU and inform a new client, for example, that a former client of his/ hers was asked about the foreign countries that he/ she had visited. In this way, the new client can come for an interview well prepared.
A step in the right direction
The introduction of the personal interview requirement may prove the most efficient mechanism of the six new mechanisms that have been agreed upon. Most licensed immigration agents believe that this is a positive change. It is going to facilitate the process of economic citizenship acquisition.
Immigration agents have already started adjusting their procedures to the new requirements. Admittedly, some of them are going to be faster and more inventive in the process than others. Our team of experts will be happy to put you through to the smartest and most reliable immigration agents in the Caribbean country whose citizenship you seek to acquire. You are welcome to apply for a free consultation on the matter.
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