Dominica signs MOU to strengthen CBI program

Dominica has joined forces with three other countries in the Caribbean to sign a Memorandum of Understanding which is aimed at strengthening their Citizenship by Investment Programs (CBIP).

The move was championed by the prime minister of St Kitts and Nevis,  Dr Terrance Drew, to assure the international community that the four countries intend to operate their CBI programs using the exchange of best practices, due diligent processes, and intelligence related to potential security or compliance risks.

The four countries are Dominica, Antigua and Barbuda, St Kitts and Nevis and Grenada. They are all members of the Organization of Eastern Caribbean States (OECS).

The signing of the MOU, which was dated March 20, 2024, was praised by Dr Drew, who said that the countries are committed to increase the minimum threshold of their CBIP to at least US$200,000 no later than June 30, 2024. According to dominicacitizenshipbyinvestment.com, a Dominican passport can be obtained for US$100,000.

He also hoped the MOU will bring an end to ‘underselling’ which he said has been a “scourge to the CBI Industry in the recent past.”

“We have therefore agreed that the minimum investment thresholds for our CBIPs shall represent the actual amount of funds received and applied towards an applicant’s qualification under our respective CBIPs, and not the gross amount of funds paid by an applicant from which deductions, including the payment of commissions, are made,” Dr Drew said, according to the St Kitts Observer. “I commend my fellow Prime Ministers for recognizing that CBIPs are too important to our respective economies to act irresponsibly in their operations. This move will show the world that our four nations are responsible and serious about operating investment migration programmes that respect the rule of law, are sustainable and do not offend the interests of our brothers and sisters in the international community.”

According to the MOU, the four countries agreed to the following:

1. share information on CBIP applicants;
2. implement enhanced transparency measures such as the disclosure of funds received by CBIPs, the use of the proceeds of CBIs and to conduct independent financial and operational audits to assess CBIs compliance with best practice standards;
3. assign or establish a regional competent authority to set standards in accordance with international requirements and best practices and to regulate the CBIPs;
4. establish common standards to manage the communications and promotion of the CBIPs;
5. establish common standards for the regulation of agents operating in the CBIPs; and
6. facilitate joint training programs and capacity-building initiatives for their respective officials and agencies involved in the administration of CBIPs.

CBIPs in the Caribbean have been the subject of scrutiny by the European Union (EU) and it has proposed changes that will make it easier to suspend the visas of people who bought passports from countries that sell citizenship to foreigners. It said Caribbean countries, which offers visa-free access to the EU “can result in risks or threats to the public policy or internal security of the Member States, including those related to infiltration of organized crime, money-laundering, tax evasion and corruption.”

EU officials met in Dominica on January 24, 2024 with countries in the Caribbean with CBIPs to discuss concerns. They expressed apprehension over Dominica’s low-cost/high-volume approach to the program.

The United Kingdom (UK) has gone as far as imposing a visa restriction on Dominica because of its CBIP saying it “has shown clear and evident abuse of the scheme, including the granting of citizenship to individuals known to pose a risk to the UK.”

Ireland has also done the same.

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