Eastern Caribbean Citizenship by Investment: Enhanced Legal Framework, New Regional Cooperation

The Organization of Eastern Caribbean States (OECS) has announced that the five Eastern Caribbean countries offering Citizenship by Investment (CBI) programs are moving towards establishing a regional CBI regulatory body.

This development follows the third U.S.-Caribbean CBI Roundtable held in Grenada on August 29, 2024. The OECS described the meeting as “productive” and highlighted progress in implementing the six CBI principles agreed upon in February 2023.

Governor Timothy N.J. Antoine of the Eastern Caribbean Central Bank, who co-chaired the dialogue with Acting Assistant Secretary of the Treasury Warren Ryan, revealed that “the region will soon announce the appointment of an Interim Regulatory Commission tasked with establishing the regional regulatory body.” The primary objective of the regulatory body is to set standards, regulate, and oversee CBI programs in Antigua & Barbuda, Dominica, Grenada, St. Kitts & Nevis, and St. Lucia (collectively known as the Caribbean Five). The body will also have the authority to impose corrective measures when necessary.

Delegates at the dialogue acknowledged the “region’s concerted efforts toward full implementation of the principles.” The Caribbean Five has completed four of the six principles:

• Common agreement on the rejection of applications, preventing individuals rejected in one country from applying in another.
• Mandatory interviews for all applicants.
• Conducting additional checks with each country’s Financial Intelligence Unit.
• Suspending the processing of applications for Russian and Belarusian citizens.

The remaining two principles, focusing on audits and the revocation of passports, are being “actively pursued for full implementation.” These efforts align with the Memorandum of Understanding (MoA) signed by all CBI countries in March 2024. The U.S. delegation “welcomed the region’s progress towards establishing an independent regional regulator, as envisioned in the MoA.”

While not part of the six principles agreed upon with the U.S., it is noteworthy that all CBI countries in the Caribbean have increased their minimum investment amounts. This increase followed closely after the Caribbean was reported to have agreed to six other principles with the European Union (EU).

The OECS emphasized that CBI countries “remain steadfast” in their commitment to enhancing risk management and mitigating risks to CBI programs, and “greatly appreciate the continued support of the U.S. Department of the Treasury.”