Caribbean Citizenship by Investment: Stricter Legal Framework

Five Eastern Caribbean countries offering Citizenship by Investment (CBI) programs are moving forward with the establishment of a regional regulatory body for CBI. This development follows the third U.S.-Caribbean CBI Roundtable held in Grenada on August 29, 2024. The OECS deemed the meeting “productive” and highlighted progress in implementing the six CBI principles agreed upon in February 2023.

Eastern Caribbean Central Bank Governor Timothy N.J. Antoine, 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 Committee tasked with establishing the regional regulator.” The primary goal of this regulatory body is to standardize, regulate, and oversee CBI programs in Antigua & Barbuda, Dominica, Grenada, St. Kitts & Nevis, and St. Lucia (collectively known as the Caribbean Five). It will also have the authority to impose corrective measures as needed.

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:

• Mutual agreement to reject 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 andBelarusian citizens.

The remaining two principles, focusing on audits and the revocation of passports, are “being actively pursued for full implementation.”

These efforts align with a Memorandum of Agreement (MoA) signed by all CBI countries in March 2024. The U.S. delegation “welcomed the region’s progress in establishing an independent regional regulator, as envisioned in the MoA.”

While not part of the six principles agreed upon with th

e U.S., it’s noteworthy that all CBI countries in the Caribbean have increased their minimum investment levels. These increases came shortly 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 enhancing risk management and mitigating risks to CBI programs, and “greatly appreciates the continued support of the U.S. Department of the Treasury.”