Enhanced Due Diligence Measures Announced by Dominica Citizenship by Investment Unit
Effective as of July 17th, the Dominica Citizenship by Investment Unit confirmed the introduction of mandatory applicant interviews and enhanced due diligence measures. The imposition of these measures follows the Citizenship by Investment Roundtable held between representatives of the United States of America, all Caribbean territories offering Citizenship by Investment (CBI), the Organisation of Eastern Caribbean States (OECS), and Eastern Caribbean Central Bank. The delegations agreed to a number of principles with the primary aim of safeguarding programme security; these include collective treatment of specified jurisdictions, treatment of denials, and conducting enhanced applicant screening.
Under the Commonwealth of Dominica Statutory Rules and Orders No. 8 of 2023, with respect to the Citizenship Act, the Principal Regulations were amended to confirm:
- Main applicants and relevant dependents domiciled in, or who are citizens of, specified countries or regions will be subject to enhanced due diligence procedures. The comprehensive background checks will be conducted by specialised third party agencies on all individuals aged twelve (12) and over, to confirm that all prospective citizens pose no current or potential risk to the reputational, international relation, or national security interests of the Commonwealth of Dominica. The accompanying government circular named the Republic of Iran as a specified country/region.
- The main applicant and all dependents over sixteen (16) will be required to attend an in person or virtual interview.
Enhanced vs Standard Due Diligence
Due diligence encompasses the multi-stage process by which the suitability of Citizenship by Investment applicants is verified; documentation and background information supporting the applicant’s financial health and source of funds, identity, general health and personal history Preliminary checks are conducted by the authorised agent or relevant investment coordinator through their mandatory ‘Know Your Client (KYC)’ process, and collection of mandatory supporting evidence. The compiled application, and applicants, will then be further vetted by the Citizenship by Investment Unit’s (CBIU) internal due diligence personnel. Third-party agencies, which may be region specific, will simultaneously evaluate and authenticate applicants’ investment profiles before submitting their findings to the CBIU.
Iranian citizens will be required to pay enhanced due diligence costs of $25,000 for the main applicant, $15,000 for the spouse and dependents sixteen (16) and older, and $10,000 for dependents aged between twelve (12) and fifteen (15). The government emphasises that the enhanced due diligence fees are inclusive of, not in addition to, standard due diligence costs where applicable. There will be no additional requirements or measures for Iranian applicants to personally undertake as all enhanced processes will be undertaken by the CBIU, following submission of the complete application.
Due Diligence Cost Comparison
| Applicant | Standard Due Diligence Fees | Enhanced Due Diligence Fees for Iranian Applicants |
| Main Applicant | $7,500 | $25,000 |
| Spouse | $4,000 | $15,000 |
| Dependent (16+) | $4,000 | $15,000 |
| Dependent (12-15) | – | $10,000 |
Mandatory Applicant Interviews
Interviews will now be mandatory for all applicants over the age of sixteen (16), not limited to individuals from specified regions. They will be conducted remotely in the applicant’s language of choice, and must be attended by the individual applying, not a representative or agent. If the applicant is absent from the scheduled interview, they should expect to pay for a separate interview to be conducted.
Dominica has consistently ranked highly in the category of due diligence according to the CBI Index, and remains committed to upholding the reputation, security, and integrity of the Citizenship by Investment Programme. The government expects other Caribbean CBI territories to follow suit, implementing additional screening, transparency, and regulatory measures to safeguard the interests of genuine investors. At $100,000, Dominica’s minimum investment is one of the most economical routes to second citizenship; get in touch to find out what these changes mean for your investment journey.
