New Common Standard Rules for the Caribbean Citizenship by Investment Programs

What are the New Common Standard Rules for the Caribbean Citizenship by Investment Programs?

The Memorandum of Agreement (MoA) focuses on 5 main pillars: pricing, information sharing and transparency, regulation, security screening and framework, and standardizing programs’ marketing efforts.

On the matter at hand, Saint Kitts and Nevis Prime Minister, Dr. Terrence Drew commented that “the four small island developing states who signed this Memorandum have committed to increase and harmonize the minimum investment threshold of their CBIPs to an investment sum of at least US$200,000 no later than June 30, 2024, and more importantly, to bring an end to ‘underselling’, a scourge on 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.”

Pricing

The most noteworthy change the signing countries have agreed to is the standardization of pricing across its Citizenship by Investment programs. From June 30th onward, the minimum investment threshold will be USD $200,000. Any future possible increases will have to be mutually agreed upon by the countries.

Information Sharing and Transparency

The MoA seeks to reinforce an already mutually established pillar: sharing information on Citizenship by Investment program applicants, and transparency, while committing to data protection Back in October 2023, the participatory countries gathered with U.S. Department of Treasury officials to iron out the details, and this MoA further cements this pillar, and goes even forward with the creation of a digital portal, accessible only by vetted officials, at the Joint Regional Communications Center.  Transparency is also further enhanced with the countries proceeding to share obtained revenue from the Citizenship by Investment programs and agreeing to independent financial audits.

Regulation

The participatory countries have agreed to mutually create a competent regional authority with the sole focus on regulating the Caribbean Citizenship by Investment programs in accordance with the best international standards and practices. This authority is expected to be created no later than June 30th 2024.

Security Screening and Framework

If information sharing and transparency focus on vetting applicants before Citizenship, this pillar is further reinforced with a revamped focus on security not only during but also after the Citizenship acquisition process, including measures like the establishment of common denials procedures, applicants’ interviews, further due diligence checks post-approvals, and even the retrieval of canceled passports.

New Common Marketing Efforts

Antigua and Barbuda, Dominica, Grenada and Saint Kitts and Nevis officials have agreed on a common set of standard practices and procedures to be applied when it comes to the promotion and marketing of their Citizenship by Investment programs. These include prohibiting the use of terms like “visa-free access” and the usage of the countries’ passports in advertisements.

Other Measures

The signing countries have also established other collaborative-driven measures to ensure there is a wider harmonization and standardization of the Citizenship by Investment programs. These include the creation of mutual training initiatives and skills development programs to ensure there is e broader understanding, effective management, and more secure Citizenship by Investment programs.

Saint Lucia Opts Out

It is noteworthy to point out that only 4 countries have signed this Memorandum of Agreement (MoA), despite there being 5 Eastern Caribbean countries offering Citizenship by Investment programs. In particular, Saint Lucia has decided not to sign the MoA.  

However, it bears in mind that this MoA does not constitute a legal obligation. Even the full text made public and available points it out, particularly in paragraphs 9 and 10. The former states that “A Party (referring to each individual country) may terminate its participation in this MoA by providing written notice to the other Parties.” The latter informs that “this MoA is a statement of intent and does not create legal obligations under international or domestic law. It does not constitute a legally binding agreement and is not enforceable in any court of law.” 

The country may have decided that, due to the MoA’s weak positioning in terms of legal standing, it may not be worth it for its own interests. Furthermore, Saint Lucia has also recently launched a new Citizenship by Investment option, in order to further compete with the other Caribbean countries and make itself more internationally appealing to foreign investors.

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With this Memorandum of Agreement (MoA), the four participating countries have agreed to increase the minimum investment amount to USD $200,000. While not explicit, this increase will most likely only apply to certain “introductory” investment options. Other options, which require more capital from the investor, may either remain unchanged or even witness a price increase, considering the minimum threshold has now been raised to USD $200,000 across the board. 

Antigua and Barbuda, for example, has 4 investment options, 2 of which are under USD $200,000: a donation to the National Development Fund and a contribution to the University of the West Indies. The other 2 options pertain to Real Estate investment, at a minimum of USD $200,000, and a business investment, starting at USD $1,5 million. With the 2 options increasing to USD $200,000, the Real Estate and the Business Investment options are likely increasing in the near future. 

Dominica only has 2 options for its Citizenship by Investment program, which are 1) a donation to the country’s Economic Diversification Fund, and 2) a Real Estate investment. While the first has sub-options ranging from USD $100,000 to $175,000 depending on family size, with the new MoA taking effect, it will increase to a minimum of $200,000, with the larger the family size, possibly the higher investment required. The Real Estate sub-option, which starts at $200,000, could potentially increase due to the minimum threshold rising.

Grenada only has 2 options as well. One of them directed to Grenada’s National Transformation Fund, requiring a minimum contribution of USD $150,000 for a single applicant. The other option is focused on Real Estate investments, starting at $200,000. Due to the short difference between the 2 options, it is likely that, as the minimum contribution rises, so does the threshold for Real Estate. 

Saint Kitts and Nevis, by virtue of having the oldest program, established in 1984, has several options, some dedicated to donations, and others to Real Estate investments. However, the country already has a minimum threshold of USD $250,000 and has other options that go up to $800,000. Considering 4 of the 5 countries have agreed to raise the minimum amount, it is not out of the realm of possibility that Saint Kitts and Nevis could raise their own even further. 

With almost every Eastern Caribbean country seeking to standardize their Citizenship by Investment program, and with the future being uncertain in terms of pricing for the other options, the deciding factor may yet rely on what each island, individually, has to offer. Crucial factors to consider when choosing your next dreamy paradise is the cost of living and choosing the cheapest Caribbean Island may prove decisive. 

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