What is the Caribbean Memorandum of Agreement?
The Memorandum of Agreement (MoA) is a non-binding document signed originally by 4 of the 5 Eastern Caribbean countries with Citizenship by Investment (CBI) programs. Though the document does not hold any legal force, it aims to set new common standard rules to bring all the countries to equal ground, and harmonize the CBI programs across five main pillars: pricing, information sharing and transparency, regulation, security screening and framework, and standardizing programs’ marketing efforts.
However, the most notable part of the MoA is reflected upon in the pricing section. The minimum investment threshold for the Citizenship programs will be restructured and increased to USD $200,000 across the board from June 30th 2024.
Saint Lucia Joining the Caribbean MoA: What Does it Mean?
Following the expressed intent to join, Saint Lucia’s Prime Minister, Mr. Philip J. Pierre, also released a statement on June 3rd 2024. Specifically, the Head of Government referred that, in addition to signing the document, Saint Lucia suggested further changes to the document. These changes, which have already been accepted by the other Caribbean countries’ governments, include legislative modifications meant to address requests regarding the legal changing of names.
Saint Lucia has also made more proposals to implement in the MoA in the near future, to improve and strengthen international cooperation between the countries and solidify the standing of the Caribbean Citizenship by Investment programs. Here are the following proposals Saint Lucia has suggested:
- An annual quota, possibly limiting the number of Citizenship by Investment applications each Caribbean country can receive in a single year;
- A minimum net-worth for applicants, probably to further disincentivize any ill-intentioned application;
- Escrow accounts, to be held in each island operating the respective Citizenship by Investment program, adding a further layer of transparency;
- Only allowing licensed promoters to submit applications to local authorized agents;
- Requiring due diligence on all applicants submitting their Citizenship application from the promoters and the licensed agents.
In the same statement, the Saint Lucian Prime Minister also reiterates all the improvements the country has already implemented over the years, including banning certain nationalities from applying, enforcing interviewing processes, vetting applicants through its local authorities, and sharing denied applications with the Joint Regional Communication Center (JRCC). Furthermore, Saint Lucia’s Prime Minister also revealed that its Citizenship by Investment program will be reviewed by an international consultancy company, and that it will request international support to recover revoked passports.
Why did Saint Lucia Originally Opt Out of the Caribbean MoA?
When the news broke out that 4 of the 5 Eastern Caribbean countries with Citizenship by Investment programs signed a Memorandum of Agreement, the absence of Saint Lucia among them was heavily noted. Considering the original Agreement does not hold any legal force, nor is it binding, which is specifically noted in the original document, the Saint Lucia government, back in March 2024, did not sign the MoA.
Paragraphs 9 and 10 of the Caribbean MoA specifically stated that “each country is allowed to terminate participation in the MoA by providing written notice”, and that the MoA is a “statement of intent” which “does not create legal obligations under domestic or international law.” Nevertheless, by signing the MoA in early June 2024, Saint Lucia is further highlighting its commitment to the integrity of its Citizenship by Investment program.
Back in March, Saint Lucia officials did not reveal any opposition to the MoA, citing that the country simple needed more time to “address legal obligations” and to “take care of some housekeeping issues.” It may have also been that the country, in the meantime, has decided that signing the MoA will further benefit its own interests, as opposed to sitting out of the MoA. It is noteworthy that Saint Lucia has recently launched a new Citizenship by Investment Option and it may have played a role.
Live the Caribbean Life with Investment Visa
Now that all the 5 Eastern Caribbean countries are on board, having signed the MoA and agreed to increase the minimum investment threshold to USD $200,000 - and with further bureaucratic steps being taken, it seems that the dream of sailing off to the high seas and settling in the Caribbean is further away.
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