St. Kitts and Nevis Announces Sweeping Changes to Citizenship by Investment Programme

Significant amendments to the St. Kitts and Nevis Citizenship by Investment (CBI) programme were announced this July, taking immediate effect and overriding the previously announced extension to the Limited Time Offer on Sustainable Growth Fund donations. The changes, as published on the 27^th of July (2023) in the Statutory Rules and Orders of the St. Kitts and Nevis Citizenship by Substantial Investment (CSI) Regulations and supporting circulars, outline updates to investment options, investment minimums, due diligence practices and dependent eligibility. 

The government of St. Kitts and Nevis has reiterated its intention to uphold investor confidence and maintain the international reputation, integrity, and exclusivity of the programme. The Hon Dr. Terrence Drew, Prime Minster of St. Kitts and Nevis, expressed the ongoing commitment to the stringent due diligence practices and investment quality valued by high-net-worth individuals.

Citizenship Routes and Investment Minimums

The Sustainable Growth Fund (SGF) has been replaced, effective immediately, with the Sustainable Island State Contribution (SISC). The SISC is an alternative donation route that aim to directly contribute to the acceleration of national development via economic diversification, increased domestic food production, implementation of green energy and climate resilience initiatives, nurturing sustainable industry, ‘pandemic recovery’, and expansion of social services.

Non-refundable SISC contributions begin at $250,000 for sole main applicants, doubling the previous discounted minimum investment of $125,000 required under the Sustainable Growth Fund, exclusive of fees.

• Main applicant: $250,000
• Main applicant and spouse or qualifying dependent: $300,000
• Main applicant, and spouse and up to two qualifying dependents or two or three dependents: $350,000

Real estate minimum investments have doubled from $200,000 to $400,000. This investment threshold includes the purchase of real estate shares in an approved government real estate development.  As tourism is one of the largest industries on island, touristic developments such as hotels, condominiums, luxury villas and shopping plazas make up the majority of approved projects. The Private Home Sale investment option qualifies properties for Citizenship by Investment if the minimum investment is $400,000, for condominium units, or $800,000 for private single-family homes.

Both development shares and private home investments may be resold after 7 years. Development shares can be resold, once by the original purchaser, to another individual applying for Citizenship by Investment. Properties purchased via the Approved Private Home route cannot be resold to a buyer intending to apply for Citizenship by Investment unless the Federal Cabinet deems the property has been substantially renovated, enhanced or subject to additional significant investment.

The Public Benefit Option is an alternative donation, replacing The Public Good Investment Option (PGIO), that allows applicants to contribute to a government approved project aimed at creating local employment and implementing developing technology under ventures that will transferred to the state upon completion. The minimum contribution is $250,000, an increase from the $175,000 minimum of the PGIO.

Application Procedures, Due Diligence and Interviews

Due diligence fees for main applicants have increased from $7,500 to $10,000, and from $4,000 to $7,500 for all dependents aged sixteen (16) and over. Under the new regulations, financial sponsorship, where an individual other than the main applicant funds the investment, is no longer recognised and sponsored applications will no longer be accepted by the CIU. The Accelerated Application Process (AAP), which shortened the processing time to sixty (60) days via the payment of enhanced due diligence fees, is no longer available.

All main applicants will be required to attend an interview, either virtually, in person in St. Kitts and Nevis, or at a location specified by the Citizenship by Investment Unit and approved by the Board of Governors; dependents aged sixteen (16) and above may also be subject to mandatory interview measures as deemed necessary.  These mandatory interviews will be conducted by an independent, third-party firm as part of the pre-approval due diligence process. Upon approval, the issued Certificate of Registration must now be collected by the main applicant in person from St. Kitts and Nevis or a specified embassy or consulate.

Additions, Eligibility and Exclusion

The eligible dependent category has been narrowed, removing siblings and grandparents entirely, increasing the minimum age of dependent parents from fifty-five (55) years old, and decreasing the maximum age of dependent children. The following individuals are recognised as qualifying dependents and may be included under the main applicant in a single application:

• Spouse of the main applicant,
• Children of the main applicant under eighteen (18) years old,
• Children of the main applicant between eighteen (18) and twenty-five (25) years old enrolled in full time education and supported financially by the parent,
• Children of the main applicant eighteen (18) years and older who are mentally or physically challenged,
• Parents of the main applicant or their spouse, sixty-five (65) years or older living with and fully supported by the main applicant.
• The addition of dependents to applications in process is not permitted. Any post-citizenship addition of eligible dependents must now be made a minimum of ninety (90) days after approval and issuance of the main applicant’s Certificate of Registration (COR), as highlighted in an August 2023 government memo.

St. Kitts and Nevis has reiterated that although Ukraine is not an excluded territory (SR&O No. 27, 2023), applications from citizens and residents are currently suspended due to difficulties conducting thorough due diligence in the region. The following countries remain ineligible for Citizenship by Investment in St. Kitts and Nevis:

• The Islamic Republic of Afghanistan
• The Republic of Belarus
• The Islamic Republic of Iran
• The Republic of Iraq
• The Democratic People’s Republic of Korea (North Korea)
• The Russian Federation