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Caribbean Citizenship by Investment: Recent Changes in the Procedure of Acquiring a Caribbean Passport

Grenada and Dominica now conduct personal interviews with all candidates for economic citizenship. St Kitts and Nevis raises the ‘price’ of the passport. Antigua and Barbuda is thinking of terminating the national citizenship-by-investment program. These are only a few reactions to the pressure applied by the USA, EU, and Great Britain to the Caribbean countries ‘selling’ their citizenship to foreigners. Below we discuss these and other related issues and contemplate how the increased pressure from the ‘big and powerful’ may affect other countries in the Caribbean region.

Caribbean Citizenship by Investment:

The context

To make sense of the changes that happened in the Caribbean in late July – early August, we have to put them in context. Let’s see what happened earlier in 2023.

  • Agreement between the USA and Caribbean countries. In March 2023, Prime Ministers of five Caribbean countries that issue ‘golden passports’ to foreign investors had a meeting with representatives of the US administration. As a result of the meeting, they agreed to six new principles of granting economic citizenship to foreign nationals. The US administration insisted on introducing these principles. In exchange, however, the US promised to publicly support the Caribbean citizenship-by-investment programs and give incentives to the banking institutions that participate in the processes of second citizenship acquisition. According to unofficial information, the US authorities threatened to apply sanctions to the Caribbean banking sector in case their proposals were not accepted. Below please find a list of the new principles that are currently in force:
    • Exchange of information about rejected applications for citizenship. From now on, all Caribbean countries granting citizenship to foreign investors will automatically exchange the information about rejected applications. Thus, if citizenship has been denied to a foreign applicant in one Caribbean country, no other country in the region will accept an application for citizenship from him/ her.  
    • Interviews. Applicants for second citizenship now have to have personal interviews regardless of what Caribbean country they choose. The interviews can be conducted in the host country or with the help of a videoconferencing application. No personal interviews were required before.
    • Stricter control. The financial auditing and monitoring procedures have become stricter.
    • Audit of the programs. All national citizenship-by-investment programs in the Caribbean are now going to be audited by international experts annually or biannually.
    • Withdrawal of annulled identification documents. Law enforcement agencies are now going to be involved in withdrawing annulled passports from the foreign investors. 
    • Service denial to Russians and Belarussians. Citizens of the Russian Federation and Belarus have been unable to file applications for Caribbean citizenship since March 31, 2023.  
  • Cancelation of visa-free entry to Great Britain. Since July 19, 2023, citizens of the Caribbean state of Dominica have been denied visa-free entry to the UK. The same holds for citizens of the South Pacific state of Vanuatu that also issues passports to foreign investors. The UK authorities said they were concerned about the reliability of some Dominica and Vanuatu passport holders. The Minister of the Interior suggested that the cancellation of the visa-free regime was not a sign of poor relations between the countries. She said that scrupulous analysis of the citizenship-by-investment programs showed some conspicuous abuses. One such abuse was granting citizenship to foreign investors who had been denied British visas before. The Vanuatu and Dominica authorities, in their turn, expressed deep dissatisfaction with the UK’s decision. We have to note that citizens of Vanuatu were denied visa-free access to the EU on February 4, 2023. Because Great Britain is not an EU member any longer, it had to make its own decision and so it did. The Vanuatu authorities say they are working hard to meet all the EU requirements but we will have to wait and see if they are successful at that. As far as Dominica is concerned, some experts believe that it is not the last Caribbean country to lose visa-free access to the UK and the EU. Other countries in the region that ‘sell’ their citizenship to foreigners may soon follow the same path and their citizens will also have to apply for UK and Schengen visas.  
  • EU recommendations. On July 26, 2023, unofficial information came out about the intention of the European Commission to issue guidelines for those national states that administer citizenship-by-investment programs. The news was published in Associates Times in particular with references to some insiders. The European Commission has not made any official announcements nor press releases concerning the matter as of today. According to the journalists, a special Committee is going to be created soon that will oversee the economic citizenship programs administered by non-EU countries. It is expected that the Committee will put forward requirements that are similar to those initiated by the US Administration. The EU authorities want the Caribbean countries to take the following measures:
    • Introduce enhanced due diligence procedures that have to be carried out by reputable international agencies based in the EU, the USA, or Great Britain.
    • Conduct personal interviews with all applicants for citizenship (virtual interviews are acceptable).
    • Stop using mail or courier services to deliver official documents and passports to applicants for citizenship. The foreign nationals have to collect the documents in person. They can do so in the host country or at the diplomatic mission (embassy or consulate) that the host country has elsewhere.
    • Raise the investment thresholds. The EU administration recommends that the minimum investment amount be increased to US$200,000 for those making non-returnable donations and to US$400,000 for those buying property in the Caribbean country of their choice. Supposedly, the increase will repel those foreigners who are unable to bring sizable contributions to the host country’s economy. In addition, the larger sum of money will demonstrate that the investor is serious about complying with all the new obligations that citizenship of a foreign country entails. 
    • Strengthen financial monitoring. The AML/KYC procedures have to be enhanced. The transfer of money from the investor should be made directly to the host country’s Government, not via an intermediary. This measure will contribute to combating money laundering and tax evasion.
    • Stop using the visa-free regime with the EU as an argument for applying for a Caribbean passport. The marketing materials shall not mention this as an advantage of acquiring Caribbean citizenship.

St Kitts raises the prices

St Kitts and Nevis Citizenship by Investment Unit (CIU) published new requirements for obtaining citizenship of the country on July 27, 2023. The document calls the changes ‘innovative’ and ‘monumental’ but it says nothing about the pressure from the EU and UK being the main reason for introducing the changes. Below please find a list of the new requirements in St Kitts and Nevis:

  • Rebranding. The Sustainable Growth Fund (SGF) where the donations used to be transferred to is liquidated. The new alternative financial scheme is called Sustainable Island State Contribution (SISC). The money that the new fund accumulates will be used to promote sustainable development in St Kitts and Nevis. In particular, the following tasks are prioritized:
    • Increase of local food items production;
    • Transition to clean energy;
    • Diversification of national economy;
    • Investment into ecologically sustainable sectors of economy and their development;
    • Promotion of a creative economy;
    • Handling the consequences of the COVID-19 pandemic;
    • Enhancement of social security.
  • Early termination of the discount program. St Kitts and Nevis used to have a limited-time discount offer for those who wished to make donations to the SGF. The offer was extended until January 31, 2024 at some point but then the extension was canceled. So this opportunity is not available any longer.  
  • Increase of the minimum donation amount. Currently, the required donation amount is twice as high as it used to be under the special offer. Please see the table below to find out about the new ‘prices’ of St Kitts and Nevis passports for those who are prepared to make non-returnable donations:
Number of applicants for citizenshipSISC (beginning July 27, 2023)SGF (discount offer)
Single applicantUS$250,000US$125,000
Main applicant + spouseUS$300,000US$150,000
Family of up to 4US$350,000US$175,000
Ever extra underage dependent family memberNot specifiedUS$10,000
Ever extra dependent family member of age (18+)Not specifiedUS$25,000
  • Increase of the minimum amount of investment in real property. The amount has doubled. The following options were available before: two foreign investors could put US$ 200,000 each in an approved development project in St Kitts and Nevis and keep the property in their possession for 7 years. After the period expired, they could sell the property and keep their citizenship. If they invested US$ 400,000 each, they could sell the property back after 5 years. These opportunities are not available anymore. Now you have to invest at least US$ 400,000 into property and keep it in your possession for 7 years if you are to qualify for citizenship of St Kitts and Nevis. What is more, the property can be resold to another candidate for St Kitts and Nevis citizenship only once. After that, the property can be sold as many times as possible but the buyer will not be able to qualify for citizenship of the country by investment.
  • New requirements for foreigners investing in private homes. It is possible to invest in an Approved Private Home (APH) or an apartment in an approved condominium thus qualifying for citizenship of St Kitts and Nevis. The investment amounts have been altered, however. You have to invest at least US$ 400,000 in an apartment or at least US$ 800,000 in a one-family home. You have to keep the property in your possession for 7 years. After that, you can resell it to another candidate for citizenship of St Kitts only if the property has been ‘substantially redesigned’ and the redesign has required additional investments.
  • Increase in the required contribution to community service projects. There is one more investment opportunity in St Kitts and Nevis and it is called Approved Public Benefit (APB). While you could invest US$ 175,000 in a public service project to qualify for citizenship before, you have to bring at least US$ 250,000 now. The projects shall serve the following purposes:
    • Provide employment to local people;
    • Employ the newest technologies;
    • Help the local society grow and develop.
  • Obligatory interviews with the candidates. All candidates for citizenship of St Kitts shall have interviews with officials – in person or via the Internet. The interviews will be carried out whether by the CIU officers or by ‘independent professional agencies authorized by the CIU’.
  • Due diligence. The CIU will authorize ‘independent professional agencies’ based in Great Britain, Europe, or the USA to conduct complex due diligence checks when foreign investors apply for citizenship of St Kitts and Nevis. This is in compliance with the requirements formulated by the EU and US administrations (see above).
  • The citizenship certificate shall be collected in person. You can pick the document whether in St Kitts and Nevis or at a diplomatic mission of the country in other countries. This is what the European Commission has recommended.
  • Restrictions for marketing materials. Some restrictions are going to be introduced concerning the use of information in promotional materials. The program promoters have yet to find out about the exact restrictions. Presumably, references to the visa-free regime with the Schengen zone countries will be prohibited and it is still unknown what other restrictions are going to apply.

Even though the authorities of St Kitts and Nevis try to present the changes in a positive light, it is obvious that they have made the national citizenship-by-investment program less attractive for potential customers. The changes have been introduced for one simple reason: to calm down the EU authorities and to preserve the opportunity for St Kitts citizens to enter the Schengen zone without visas.

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The situation in the Caribbean investment immigration market is becoming worse. However, the Caribbean region is not the only option that you can consider if you are after a second passport. For instance, Turkey has been highly popular with foreign investors ‘buying’ its citizenship and the national program has been well tested by now. Besides, some new ambitious players are entering the market such as Egypt, for example. Please learn more about economic citizenship opportunities by supplying your email address in the form below. We always respond quickly!

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Are other Caribbean countries issuing passports to foreign investors going to follow suit? Experts believe that they are. This concerns the raising of the prices in the first place. It is unlikely that the administration of St Kitts and Nevis has raised the investment thresholds without consulting the neighbors. It is reasonable to assume that there is consensus in the region as far as the ‘price’ of the Caribbean passport is concerned: it will probably rise in all Caribbean countries soon.

Interviews in Grenada

On August 1, 2023, the Grenadian CIU informed all the licensed immigration agents that it was now mandatory to interview all prospective candidates for citizenship of Grenada by investment.

Interviews in Grenada

Every applicant above the age of 17 shall be interviewed. The interviews will start on September 1, 2023. It is not impossible that the administrative fees are going to become higher due to the need to conduct interviews.

Dominica: interviews and enhanced due diligence

On August 2, 2023, the Commonwealth of Dominica announced amendments to its citizenship-by-investment program. The Prime Minister informed the Parliament that the conditions were going to be changed soon following the recommendations from the USA. The Prime Minister emphasized that some of the recommendations had already been fulfilled.  

Now citizens of Iraq, Russia, and Belarus are ineligible to apply for citizenship of Dominica any longer. The Government has also disallowed changing personal names when applying for foreign citizenship. In addition, it is applying a more sophisticated risk assessment methodology now. Special agencies from the United States of America and Great Britain have been hired to conduct interviews with applicants for Dominican citizenship.

The immigration authorities of Dominica are also planning to annul the passports of those foreign investors who supplied false information when applying for economic citizenship of the country. It has been found out, for example, that some individuals suppressed the information about visa denials. In accordance with the rules, if the applicant for Dominican citizenship has been denied a visa to any country that has a visa-free travel agreement with Dominica, he or she is not eligible for a Dominican passport.

Dominica

It will be interesting to note that Dominica made personal interviews obligatory (for all applicants above the age of 16) on July 17, 2023. This was two days before Dominicans were denied visa-free access to Great Britain. As far as Iranian applicants for citizenship of Dominica are concerned, they have to go through enhanced due diligence procedures, which also comes at a higher price for them.

Return of the ‘5 days over 5 years’ requirement and rumors about the closure of Antiguan CBI program

On July 20, 2023, the Antigua and Barbuda Cabinet of Ministers returned the physical presence requirement. Article 4 (1) of the Investment Citizenship Act from 2016 makes it obligatory for all new citizens of Antigua and Barbuda to spend at least five days in the country within the first five years of holding the passport. This requirement was abandoned for the time of the pandemic but it is back in force now. The good news is that while the first Antiguan passport is valid for only five years, the second is valid for 10 years now.  

Antiguan CBI program

On July 31, 2023, the former deputy minister of finance disclosed the original intentions of the Antiguan Government in 2014 when the citizenship-by-investment program was launched. Apparently, the program was not supposed to be a never-ending source of revenue. The politician said:

“We knew that the program would remain functional for some 10 to 15 years. There were many debates and my own position remained quite clear: it was a way to earn a lot of money but ‘selling’ citizenship was morally wrong, in my opinion. However, when we took office, we had to face the reality. We had to repay the IMF loans and other debts. We had little money for that. […] As history shows, every time when a Caribbean or an African country finds a way to make progress, the industrialized countries of the West come up with some new rules that disallow achieving our goals. We had an offshore banking industry and it was destroyed by overregulation.”

The politician also warned that the potential closure of the Antiguan CBI program would bring about undesirable consequences:

“The monthly payroll [of state employees] is thirty million [East Caribbean] dollars. If the salaries are not paid, small shops and larger supermarkets will have no customers. We also need money to pay back the debts. The country cannot afford reducing the amount of its income at the moment.”

According to the official data, the Antiguan citizenship-by-investment program brought 88.8 million East Caribbean dollars in 2022. This is almost 60% of the total non-fiscal revenue. State spending increased to 1.08 billion dollars in 2022 and the total payroll in the state sector exceeded 423 million East Caribbean dollars.

St Lucia takes a wait-and-see approach

On July 30, 2023, during an interview with local media agencies, the St Lucian deputy Prime Minister informed the journalists about the Government’s intention to keep the economic citizenship program going. The deputy said that the fears on the part of the opposition and other skeptics were ungrounded and that the UK authorities were not going to cancel the visa-free travel agreement with St Lucia.

The politician noted that London had been very clear about the issue: the sanctions were directed at Dominica exclusively. “They have never mentioned St Lucia, nor St Kitts, nor Antigua, nor Grenada”, said he.

The Vice Premier assured the journalists that the program was going to be administered ‘in an open and transparent manner’. Otherwise, it would not last long, according to him. The politician emphasized the fact that St Lucia was the last country in the region to launch a CBI program, which gave it a chance to learn from others’ mistakes.

St Vincent and the Grenadines is not joining the team despite the opposition’s arguments 

The administration of St Vincent and the Grenadines has been considering the possibility to launch a national CBI program for quite a long time. The recent events, however, has made the Government disregard this opportunity. The Prime Minister of the country has been a persistent opponent of the economic citizenship scheme and he confirmed that his attitude had not changed at a press conference on July 31, 2023.

Referring to some unknown sources, the Prime Minister claimed that the UK administration was going to cancel visa-free travel agreements with all Caribbean countries running citizenship-by-investment programs. He refused to comment on the suggestion that the EU would possibly follow suit.

The local leader of the opposition, however, continues to lobby the citizenship-by-investment initiative. In his opinion, the success of such a program depends on how well it is administered. He said that if his National Democratic Party wins the elections, the new government would launch a CBI program notwithstanding the pressure on the part of the EU, UK, and USA.

Professional assistance in building a passport collection

It is becoming more burdensome and more expensive to acquire Caribbean citizenship by investment. However, this option is still affordable for a large number of people. What is more, there are a few other countries that entice foreign investors by offering them second citizenship opportunities. Our experts will be delighted to help you make the best choice!

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