Caribbean Citizenship by Investment Programmes Introduce Interviews

In early 2023, delegates from Antigua and Barbuda, Dominica, Grenada, St. Kitts and Nevis, St. Lucia, The Organisation of Eastern Caribbean States (OECS) and Eastern Caribbean Central Bank convened with representatives of the United States of America; this US- Caribbean roundtable served as a platform to evaluate the current and future state of Citizenship by investment (CBI). The adoption of pro-active measures to safeguard the credibility of the investment programmes was agreed and summarised into six principles:

1. Interviews: Mandatory interviews, either in person or via virtual and remote mediums, for citizenship programme applicants with the potential to include their dependents. Third party diligence firms will be involved to further evaluate the degree of applicant eligibility preceding the approval stage.
   
2. Enhanced Checks: To mitigate risks associated with money laundering, prohibited financial activities, illegitimate fund sources and associated financial risks, each jurisdiction will carry out checks on applications with their respective Financial Intelligence Units (FIU).

• Collective Agreement on Treatment of Denials: The five (5) CBI territories have reiterated that applicants who have been denied in one CBI jurisdiction will not be processed in an alternative CBI jurisdiction; all territories will collaborate, sharing information on denials to definitively deny rejected individuals attempting to circumvent eligibility laws.

• Audits: Programmes are to be audited annually or biennially as per international standards to maintain transparency and ensure both the governments and local service providers are adhering to regulations. These inspections should serve as opportunities to gauge compliance and uncover inconsistencies.
  
• Passport Retrieval: Law enforcement officials will be actively involved in the recovery of revoked or recalled passports.
  
• Treatment of Russians and Belarusians: Applications from Russian and Belarusian citizens suspended as of March 2023 throughout the CBI 5. Applications registered and submitted before this date were processed under enhanced due diligence measures. 

The introduction of these measures will enhance the security of the programmes and strengthen the already robust due diligence practices in place, adding an additional layer of vetting to the application process. Interviews have been implemented in all five Caribbean CBI territories with varying requirements from investors. All interviews can be conducted in the applicant’s native or specified language and are not limited to English, and cannot be attended by the licensed local agent.

Antigua and Barbuda

As announced in a November 2023 memorandum, the Antigua and Barbuda Citizenship by Investment Unit confirmed the implementation of mandatory interviews, effective as of the 15^th of December 2023. Virtual interviews must be attended by all applicants, with the exception of dependent children below sixteen (16), at an appointed date and time specified by the independent due diligence service provider. Applicants should have the identification documents supporting their citizenship application available for verification.

Dominica

The Dominica Citizenship by Investment Unit also confirmed that all prospective applicants sixteen (16) years-old and over will be subject to virtual interviews as of July 2023. Applicants will be contacted directly to confirm their interview date; any individuals who are not present at the grouped interview for the application will be subject to an additional fee to cover their separate interview. Applicants must ensure they have any identification and supporting documents requested by the authorised interviewer.

Grenada

From September 2023 the Grenada Citizenship by Investment Unit notified interested investors that all applicants seventeen (17) years-old and over will required to undergo a mandatory interview. An Interview Application Form must be submitted by each applicant with the balance of the citizenship application documentation. Applicants will be emailed directly with instructions on how to complete the pre-screening process and provide photographic identification to verify themselves. The applicant will be contacted to confirm their next interview stage, an evaluation of approximately thirty (30) minutes by an appointed due diligence/screening company.

St. Kitts and Nevis

From July 2023, applicants for citizenship by investment of St. Kitts and Nevis will be required to attend interviews, either virtual or in person, as part of the due diligence process; interviews requiring the applicant’s physical presence may be held in St. Kitts or another location approved by the CIU. The updated diligence fees, of $10,000 and $7,500 for main applicants and dependents sixteen (16) years-old and over respectively, are inclusive of interview costs.

St. Lucia

From September 2023, a $500 addition to due diligence fees was introduced as a mandatory interview fee. Main applicants will now be required to attend a virtual identify verification and interview session at the due diligence phase of the application.

These additional due diligence measures to the Citizenship by Investment process serve to bolster the already robust security and verification systems in place, create the most comprehensive applicant profile possible by querying gaps in information, and honour the commitment to the six roundtable principles established by the CBI territories. Mandatory interviews do not affect the accessibility of the wealth of Citizenship by Investment options available in the Caribbean; to explore your options by reaching out to our expert advisors today.