Caribbean Memorandum of Agreement Implementation (Almost) Fully in Effect: What are the New Citizenship by Investment Changes?

The Caribbean Memorandum of Agreement: What Is It?

On March 2024, 4 out of the 5 Eastern Caribbean countries with Citizenship by Investment (CBI) programs – Antigua and Barbuda, Dominica, Grenada and Saint Kitts and Nevis – jointly announced they had signed a Memorandum of Agreement, revealing their intent to raise the minimum investment amount of their CBI programs to SD $200,000. The absence of Saint Lucia was heavily noted at the time, but the fifth Caribbean country also eventually joined the fold, signing the Memorandum of Agreement as well.

June 30th 2024 – the original MoA implementation deadline – has come and passed, which means it is now (almost) fully in effect. All 5 Eastern Caribbean countries have made significant changes to their CBI programs – some more so than others.

Antigua and Barbuda

Antigua and Barbuda stands out from the remaining Caribbean countries since it requested an additional 30 days before fully implementing the MoA and increasing the minimum investment amount threshold to USD $200,000. As of the time of the writing of this article, Antigua and Barbuda remains the only country in which it is still possible to obtain Citizenship through the minimum donation option at USD $100,000 – at least until July 30th 2024.

In a memo released by the Antigua and Barbuda Citizenship by Investment Unit, the entity responsible for overseeing and managing the program, several key points are highlighted: 

• The minimum donation option to the National Development Fund has been increased from USD $100,000 to USD $230,000. This amount includes up to a family of 4, increasing even further when adding other family members. 

• The minimum donation option to the University of the West Indies has been increased from USD $150,000 to USD $300,000.  

• The minimum business investment option will remain at USD $1,5 million. 

• The minimum Real Estate investment threshold will increase from USD $200,000 to USD $325,000. 

The processing fees remain unchanged at USD $30,000 for up to a family of 4 for all options, excluding the donation to the University of West Indies, since it is waived. For a family of 5 or more, the processing fees have been reduced to USD $10,000 for each additional dependent.

Dominica

Dominica also released a statement officializing its formal increase of the minimum amount from USD $100,000 to USD $200,000 to its Economic Diversification Fund. This increase applies only to a single applicant and goes up to USD $250,000 for a family of 4.

Dominica’s program, which has only one investment option – in Real Estate – keeps the same minimum amount. Purchasing eligible property in the amount of USD $200,000 in Dominica still qualifies the applicant for Citizenship. However, while the government has not changed the minimum amount, it has increased the fees associated with the program.

The following government fees regarding the Real Estate investment option are as follows: 

• USD $75,000 for the main applicant; 

• USD $100,000 for a family of 4 - the main applicant, plus 3 other dependents; 

• USD $25,000 for each additional dependent under 18; 

• USD $40,000 for each additional dependent over 18; 

Dominica’s Citizenship by Investment program also has other add-ons, including fees for processing, due diligence, the certificate of naturalization, and for the interviews. However, no alteration has been made to these.

Grenada

Following in line with all the other Eastern Caribbean countries, Grenada also made public the changes it made to its Citizenship by Investment (CBI) program. Like Dominica, Grenada also only has 2 options – Donation & Real Estate investment.  

The donation option to the Grenadian National Transformation Fund witnessed an increase from USD $150,000 to USD $200,000 for a single applicant. It also surged from USD $200,000 up to USD $235,000 for a family of 4. 

Regarding the Real Estate option, the minimum investment amount did not increase staggeringly. The threshold, before the Memorandum of Agreement, had been at USD $220,000. It has since increased to USD $270,000 for partial ownership of a unit in a larger building and remained at USD $350,000 for full acquisition of a property.

The government of Grenada also enacted changes to the associated fees. A family of 4 will have to contribute an additional USD $50,000 when acquiring Real Estate, plus further fees when including additional family members. 

With the recent events unfolding in the Caribbean region, particularly Hurricane Beryl, IMA Grenada, the responsible entity for overseeing the CBI program, announced it would extend the deadline until July 12 2024 – providing a last call for people to get on board the Grenadian program before the price ultimately increases.

Saint Lucia

Despite having signed the Memorandum of Agreement later, Saint Lucia announced it would increase its price effective immediately on July 1st 2024. Whereas there were multiple prices depending on the amount of number family members included in the application, Saint Lucia fully standardized the minimum donation amount, increasing it to USD $240,000 across the board – regardless if it only includes the main applicant, or up to 3 dependents under 18 – though extra fees apply depending on the number of dependents and their relation to the main applicant.

Saint Lucia, like Antigua and Barbuda, also has other options underneath its Citizenship by Investment program: while the National Action Bond option has remained at USD $300,000, the Enterprise Project category has witnessed some changes. Particularly referring to the third sub-option, which had its minimum threshold at USD $100,000 – it increased to USD $250,000. 

The Real Estate investment option has also undergone a price increase, going from USD $200,000 to USD $300,000 plus the associated fees, which vary depending upon the number of family members included in the application.

Saint Kitts and Nevis

Saint Kitts and Nevis, known for pioneering the investment immigration industry with the launch of its Citizenship by Investment (CBI) initiative 40 years ago, was the first country to step forward when announcing the program overhaul. In fact, the country had already significantly altered the program in 2023 with the replacement of the Sustainable Growth Fund for the Sustainable Island State Contribution (SISC). Back then, the amount doubled from USD $125,000 to USD $250,000. 

Though Saint Kitts and Nevis pushed for the implementation of the Memorandum of Agreement (MoA), it did not actively increase this particular donation option any further with the MoA. For a single applicant, the amount remains at USD $250,000, and USD $350,000 for a family of 4. 

The second donation option, involving the Approved Public Benefit Project, remains a viable CBI alternative. The contribution amount is unchanged by the Memorandum of Agreement and is still USD $250,000.

There have also been some significant changes regarding the 2 distinct Real Estate investment options in the past few years. 

Considering the Approved Development Unit option, which focused on the purchase of a Unit from a Developer, the statement uses noticeably clear and precise wording. “The minimum amount for investing in the Developer’s Real Estate Option is now US$400,000.” However, the amount for this option was already set at USD $400,000. Though it is yet to be clarified, we can assume that the possibility of 2 individuals each investing USD $200,000 no longer applies. 

The second Real Estate option - to purchase an Approved Private Home, which itself can be either a unit in a condominium; or a single-family, detached property, also continues to qualify for CBI. When it comes to the former, the threshold amount continues to be USD $400,000; and for the latter – USD $800,000.

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The investment immigration industry is undergoing interesting times. The Caribbean countries have collectively decided to increase their minimum thresholds, while the European landscape presents a direr situation – with programs being changed, reinvented, or sometimes scrapped altogether. What few other options remain out there may or may not meet your desires or goals, leaving you feeling helpless and unsure where to turn to next. 

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