CITIZENSHIP AND RESIDENCY: Caribbean CBI Programmes Set to Adopt Six Guiding Principles by June 2023.

As published on associatestimes.com, Tuesday 2 May, 2023.

Following the round-table meeting with the officials from the US to improve Citizenship by Investment (CBI) programmes, five Caribbean countries have already initiated their work on mutually agreed six principles.

The countries have swiftly embarked on implementing the six agreed-upon principles to enhance the integrity, transparency, and security of their respective CBI programmes.

Leaders from Antigua and Barbuda, Dominica, Grenada, St Kitts and Nevis, and Saint Lucia have demonstrated a strong commitment to adhere to the principles, working diligently towards the implementation of all six by the beginning of June 2023.

The proactive approach showcases their dedication to fostering a more robust and reliable environment for citizenship investors while promoting regional collaboration and harmonization with their international partners.

Notably, the implementation of the six principles for Citizenship by Investment (CBI) programmes will be relatively smooth for the most part, with five of the principles proving to be not too difficult to put into practice.

These principles have been agreed upon in order to maintain the integrity and trustworthiness of citizenship initiatives and to address the suggestions and recommendations of the US, the UK, and Europe.

However, the sixth principle, which calls for conducting interviews of applicants either in-person or virtually, has proven to be significantly more challenging. A primary reason for this difficulty is the wide geographical spread of applicants from countries and regions such as India, China, the Middle East, Sri Lanka, Europe, etc. with time differences reaching up to nine hours and more.

This vast discrepancy in time zones complicates the scheduling of interviews, as daytime in the Caribbean often corresponds with night time or evening hours in the Asian region, making it tough to find mutually suitable timings for both parties.

Moreover, the language barrier is another major hurdle in implementing the sixth principle, as many of the applicants do not speak English. It is estimated that at least 20 language professionals would be required to facilitate communication during the interviews.

Despite the considerable challenges faced in implementing the sixth principle of the CBI programme, three out of the five participating countries have announced that they will begin conducting interviews from the first week of June 2023.

This move clearly demonstrates the commitment of these three countries to adhere to the advice of their international partners, and highlights their dedication to maintaining the integrity and trustworthiness of their CBI programmes. By taking these decisive steps, these countries are showing their willingness to overcome obstacles and work collaboratively in order to uphold the highest standards for their citizenship initiative.

As the June 1, 2023 approaches, it remains to be seen which of the five Eastern Caribbean states will successfully implement all agreed-upon principles in their Citizenship by Investment programmes.

Each country faces unique challenges that may impact the speed and efficacy of their efforts. However, the spirit of cooperation and determination exhibited during the round-table meeting suggests that these nations are genuinely committed to achieving their common goals.

All eyes will be on these countries to evaluate their progress and the impact of the adopted principles on the overall quality, security, and attractiveness of their CBI programmes.

Notably, on February 25, 2023 a United States government delegation led by Anna Morris, the Department of Treasury’s deputy assistant secretary held a meeting in St Kitts and Nevis. The meeting was attended by the heads of governments as well as citizenship by investment unit heads of the five Caribbean countries offering CBI programmes.

6 principles

Collective agreement on the treatment of denials:
One significant principle reached during the round-table meeting was the collective agreement on the treatment of denials among the states. The countries pledged not to process applications from individuals whose CBI submissions have been denied in another participating jurisdiction. This measure aims to bolster the integrity and security of their Citizenship by Investment programmes by preventing applicants from exploiting potential loopholes in the system. To effectively enforce this principle, the participating nations agreed to proactively share information on denials, fostering a higher level of transparency and cooperation among the jurisdictions. This collaborative approach will serve to fortify the region’s CBI schemes against potential risks and safeguard the reputation of these programmes on a global scale.


Additionally, it was also agreed on the importance of conducting interviews with Citizenship by Investment applicants, whether through virtual or in-person means. This principle aims to enhance the due diligence process and further assess the eligibility and intentions of prospective investors. By engaging in direct communication, authorities will be better equipped to evaluate the applicants’ background, motivations, and overall suitability for their respective CBI programmes. Implementing interviews as a standard practice ensures a more comprehensive assessment of candidates, ultimately contributing to the long-term sustainability and integrity of these schemes while maintaining the confidence of both the international community and the host nations.

Additional checks:
The third principle was agreed to perform additional checks on each Citizenship by Investment application by involving their respective Financial Intelligence Units (FIUs). This measure is designed to strengthen the scrutiny of applicants and to mitigate potential financial risks associated with CBI programmes. By engaging FIUs in the evaluation process, countries can better identify potential money laundering, terrorism financing, or other illicit financial activities tied to prospective investors. This will ensure that only applicants who meet the highest standards of integrity and financial compliance are granted citizenship, thus protecting the region’s reputation and economic stability.

A key principle established was the commitment to regularly audit their Citizenship by Investment programmes. Each country agreed to conduct audits either annually or biennially (every two years). Regular audits play a crucial role in maintaining the transparency, credibility, and effectiveness of CBI by identifying areas of improvement, ensuring compliance with relevant regulations, and detecting potential vulnerabilities or irregularities.

Retrieval of Passports:
Enlisting law enforcement assistance in the retrieval of revoked or recalled passports issued under their Citizenship by Investment programmes. This principle emphasizes the need for a coordinated approach to ensure that individuals whose citizenship has been revoked, due to fraud, criminal activities, or other reasons, are no longer able to exploit the benefits associated with their previously granted status. By collaborating with law enforcement agencies, countries can effectively mitigate the risks of unauthorized travel, illegal entry, and other security concerns that may arise from misuse of revoked or recalled passports. This cooperative strategy further demonstrates the commitment of these nations to uphold the integrity, security, and credibility of their respective CBI schemes.

Treatment of Russians and Belarusians:
The meeting also addressed the treatment of Citizenship by Investment applications from Russian and Belarusian nationals. In light of recent geopolitical developments and concerns, they collectively decided to suspend the processing of applications from these two countries. Four of the jurisdictions had already put this suspension into effect, while Grenada, which previously processed applications from Russian and Belarusian nationals with enhanced due diligence, committed to suspending new applications from these countries as of March 31, 2023.

Proactive and collaborative efforts following the round-table meeting on Citizenship by Investment Programmes demonstrate a strong commitment to enhancing the integrity, security, and transparency of their respective CBI schemes.

The adoption and implementation of the six agreed-upon principles, such as treatment of denials, conducting interviews, and additional checks involving Financial Intelligence Units, are vital steps towards achieving a more robust and reliable environment for citizenship investors. The united decision to suspend applications from Russian and Belarusian nationals exemplifies their ability to adapt to changing global circumstances and prioritize the security and stability of their programmes.

By working together and sharing information on denials and revoked passports, as well as conducting regular audits, these Eastern Caribbean states will not only strengthen their individual CBI programmes, but also contribute to the harmonization and credibility of the entire region’s offerings. Through these collaborative efforts, they will be better positioned to face challenges and maintain the trust of the international community and potential investors in their Citizenship by Investment schemes.

The meeting was attended by Prime Minister of Antigua and Barbuda, Gaston Browne; Prime Minister of Dominica, Roosevelt Skerrit; Prime Minister of Grenada, Dickon Mitchell; Prime Minister of St Kitts and Nevis, Dr Terrance Drew and Prime Minister of Saint Lucia, Philip Pierre.