Prices for Caribbean ‘Golden Passports’ Have Grown

In March 2024, four Caribbean jurisdictions administering citizenship-by-investment programs (Antigua and Barbuda, Grenada, the Commonwealth of Dominica, and the Federation of St Kitts and Nevis) came to an agreement on several aspects of the programs. St Lucia later joined them. One of the most important aspects is price harmonization. The countries agreed to raise the prices of ‘golden passports’ to at least US$ 200,000 by July 2024. The deadline has been reached and below we discuss what has changed.

Antigua and Barbuda

The Antiguan Citizenship by Investment Unit (CIU) put out a Memorandum on June 26, 2024 that describes the changes in the local citizenship-by-investment program. The document gives detailed descriptions of the new requirements to the investment amounts and provides recommendations for applicants for Antiguan citizenship.

The pan-Caribbean deadline was initially set at July 1, 2024 but the Antiguan authorities said that they needed 30 more days to finalize the procedures and obtain parliamentary approval of the changes. According to insiders, Antiguans did try to meet the deadline and implement the amendments by June 30, but circumstances beyond their control forced the local government to request an extension.

On the condition that the Parliament approves the amendments, the investment thresholds are going to be as follows in Antigua and Barbuda:

• A non-returnable donation to the National Development Fund (NDF):
  • For a family of 1 to 4 members — US$ 230,000.
  • For a family of 5 and more members — US$ 245,000.
• A non-returnable donation to the University of the West Indies (UWI) Fund — US$ 300,000.
• An investment into real property — US$ 325,000.
• The amounts of investments into business ventures remain the same: US$ 1.5 million for an individual investor and US$ 400,000 for each investor participating in a joint investment project whose total value is at least US$ 5 million.

The document also contains a precise list of documents that applicants for Antiguan citizenship have to submit. The list contains the following documents:

• Completed and signed application forms;
• Personal identification documents;
• Proof of residential address (a utility bill, for instance);
• Confirmation of sources of income;
• Confirmation of sufficiency of investment capital;
• Investment agreements.

You have to bear in mind that applicants for Antiguan citizenship have 21 days to submit the paper versions of the documents that they have submitted in the electronic form.

The application processing fee remains at US$ 30,000 if a family of not more than 4 members is applying. If the applicant is making a donation to the UWI Fund, no application processing fee is charged because it is included in the donation amount.

Application processing fees for families of 5 or more members have been reduced. Previously, US$ 15,000 was charged for each extra family member and now the fee is US$ 10,000 per family member.

The Antiguan CIU stresses that application processing will be launched when physical documents have been supplied and the fees have been paid. Government officials have called upon the immigration agents and authorized representatives to inform their clients about all the requirements related to the application document package.

The CIU officers emphasize that they are not going to process applications for Antiguan citizenship in case certain documents are missing. A foreign applicant for citizenship of the country will be well-advised to submit a full package of application documents to avoid delays in application processing.

Grenada

Thomas Anthony, head of the Grenadian Investment Migration Agency (IMA) made a publication in his LinkedIn account on the same day – June 26, 2024. The publication specifies the new financial requirements to applicants for citizenship of Grenada by investment that come into force on July 1, 2024:

• Donations to the National Transformation Fund (NTF):
  • A single applicant or a family of up to 4 members — US$ 235,000.
  • Each extra family member — US$ $ 25,000/ 50,000 (child/ adult).
  • A sibling — US$ 75,000.
• Investments into an approved development project:
  • A single applicant or a family of up to 4 members — US$ 270,000.
  • Administrative fee — US$ 50,000.
  • Each extra family member — US$ $ 25,000/ 50,000.
  • A sibling — US$ 75,000.

Of the US$ 235,000 donated to the NTF, US$ 200,000 goes directly to the Fund and the remaining amount is the agent’s commission. Of the US$ 270,000 invested into a development project, US$ 230,000 goes to the developer to cover the construction costs and the remaining amount is the agent’s commission. These are general regulations and slight deviations are possible.

Grenada’s citizenship-by-investment program is in full compliance with the agreements between the five countries in the region. Head of IMA Grenada has assured the public that ‘they mean what they say’ and confirmed that further integration is critically important for ensuring the sustainability of Caribbean ‘golden passport’ programs, which are an important source of non-tax revenues for the countries.

Grenadians have called upon their colleagues in the other four countries to accelerate the implementation of the new standards as has been agreed. Harmonization of the financial requirements is an important tool for promoting all the citizenship-by-investment programs administered in the Caribbean.  

Dominica

The Dominican authorities confirmed their preparedness to harmonize the financial requirements in March 2024 but they have been silent after that.

A March press release from the Government of Dominica expressed its intention to standardize the ‘golden passport’-related legislation and to enhance cooperation with others in the following spheres:

• Best practice sharing;
• Due diligence procedures;
• Setting the lower threshold at US$ 200,000;
• Exchange of foreign applicants’ data;
• Program transparency enhancement including disclosure of financial information;
• Involvement of independent auditors into the financial and organizational process  ;
• Establishment of a regional agency to set the standards;
• Adoption of unified communication and promotion standards;
• Regulation of the licensed immigration agents’ activities;
• Implementation of joint training programs for Government officials.

The Commonwealth of Dominica published new citizenship-by-investment regulations on June 28, 2024. They went into force on the date of publication. The document contains a new pricelist and the donation and investment amounts have been raised. This is in compliance with the Memorandum signed by the country in March 2024. The new regulations cancel the previously published ones.   

The document describes the instances when applications for citizenship of Dominica by investment may be rejected. Besides, it explains why economic citizenship can be annulled. The roles of authorized agents and license promoters are clarified and detailed. Key takeaways: 

Financial requirements  

• Donation to the Economic Diversification Fund (EDF):
  • US$ 200,000 for the main applicant;
  • US$ 250,000 for the main applicant and not more than three qualified dependents;
  • US$ 25,000 for any extra dependent family member below 18;
  • US$ 40,000 for any extra dependent family member above 18;
• Investment into property:
  • The required investment amount remains the same at US$ 200,000.
• State duties (payable only by investors into property):
  • US$ 75,000 for the main applicant;
  • US$ 100,000 for the main applicant and not more than three dependents;
  • US$ 25,000 for any extra dependent family member below 18;
  • US$ 40,000 for any extra dependent family member above 18;
• Complex security checks:
  • US$ 7,500 for verifying the facts of the main applicant’s biography; and
  • US$ 4,000 for verifying the facts of each adult (16+) family member’s biography;
• Interview fee is US$ 1,000. 

Family members that can be added to the application for citizenship

 The following family members can be added to a family application for citizenship of Dominica: 

• Main applicant’s spouse;
• Child of the main applicant and/ or his/ her spouse below the age of 18;
• Child of the main applicant and/ or his/ her spouse between 18 and 30 years of age who is attending a recognized university and who is financially dependent on the main applicant and/ or his/ her spouse;
• Unmarried daughter of the main applicant and/ or his/ her spouse below the age of 25 who lives with the main applicant and/ or his/ her spouse and who is financially dependent on them;
• Child with physical or mental disabilities above the age of 18 who is financially dependent on the main applicant and/ or his/ her spouse;
• Parents and grandparents of the main applicant and/ or his/ her spouse above the age of 65 who are financially dependent on the main applicant and/ or his/ her spouse. 

Adding new family members to the application after citizenship of Dominica has been granted to the main applicant

• Child. If an economic citizen of Dominica gives birth to or adopts a child below 18 within 5 years from the date of acquiring citizenship, the child will qualify for citizenship of Dominica by naturalization. The application processing fee is US$ 2,000.
• Spouse. If an economic citizen marries after acquiring citizenship of Dominica, his/ her spouse is entitled to become a naturalized citizen of the country. A state duty of US$ 75,000 is payable. Besides, a due diligence fee has to be paid in a year.
• Dependents. An economic citizen of Dominica can apply for citizenship for a dependent family member who was not included in the original application for citizenship. A state duty of US$ 50,000 is payable. Besides, a due diligence fee has to be paid in a year. 

Transition period  

The CIU has also announced a transition period for those immigration agents who had started negotiating with potential clients before the regulations were amended and who had been paid before that time. They have the right to apply for citizenship of Dominica on behalf of their clients using the old pricelist. 

The CIU was accepting notifications of such cases until midnight June 30. The immigration agents had to specify their clients’ names, the selected financial routes, their passport numbers, and the number of qualified dependents.   

Later, however, the deadline was extended to July 31, 2024. In addition to the information specified above, confirmation of payments from the client’s bank account is required to make sure that the CIU costs are covered.

Saint Lucia

Initially, one of the Caribbean countries that issued ‘golden passports’ did not join the agreement between the other four. The authorities of St Lucia requested additional time to solve some issues and discuss legal obligations with their partners.

However, according to the press release from the Organization of Eastern Caribbean States (OECS) that came out on June 22, 2024, St Lucia has now joined the agreement signed by other countries in March 2024.

The press release states that ‘selling’ citizenship at a price below the set threshold will be deemed illegal. The document also calls on national CIUs, agents, and developers to report any attempts or instances of unjustified discounts to the relevant authorities.

The press release also says that the Government of the signatory states will create an Interim Regulatory Commission that is going to have 7 members: representatives of the 5 countries, an OECS Commission representative and an representative of the Eastern Caribbean Central Bank. This is going to be a regional regulatory agency. The Interim Commission is going to remain functional until a permanent Commission is established. Its functions are going to include the following ones:

• Developing and enforcing regional standards for all economic citizenship programs;
• Monitoring compliance with national legislations and international agreements;
• Dealing with complaints;
• Facilitating information exchange and interaction with regional and international stakeholders.

The Caribbean countries administering ‘golden passport’ programs will have to provide the Commission with periodic updates on the progress of the agreement implementation.

The St Lucian CIU has distributed an official memorandum to licensed immigration agents and other stakeholders informing them about the changes in the prices. The changes went into effect on July 1, 2024. The prices are in compliance with the agreement set out in the memorandum of March 2024. Key takeaways:

New prices: 

• Non-returnable donation to the Saint Lucia National Economic Fund:
  • Main applicant with up to 3 qualified dependents — US$ 240,000;
  • Each extra dependent family member below 18 – US$ 10,000;
  • Each extra dependent family member above 18 – US$ 20,000.
  • Child below 12 months US$ 5,000;
  • Main applicant’ spouse – US$ 35,000;
  • Other adult dependent family members — US$ 25,000 each.
• Investment into property (an approved development project):
  • Main applicant with up to 3 dependents — US$ 300,000 plus administrative fees;
• Investment into an approved corporate project:
  • Main applicant with up to 3 dependents — US$ 250,000 plus administrative fees.

Saint Kitts and Nevis

The authorities of St Kitts and Nevis raised the prices on July 27, 2023. On that day, the local CIU issued a press release with the new rules of acquiring a ‘golden passport’. According to independent experts, the changes were made under pressure from Brussels and London. The authorities of St Kitts and Nevis did not want their visa-free agreements with Great Britain to be canceled, as had been the case for Vanuatu and Dominica. Besides, the threat of losing visa-free access to the Schengen zone was also growing for citizens of St Kitts and Nevis.

As a result, the program has been rebranded and the prices have been raised. The Sustainable Growth Fund (SGF) that used to accept donations has been replaced by the Sustainable Island State Contribution option (SISC). The required donation amount has grown from US$ 125,000 to US$ 250,000.

The required investment amount has also been raised significantly. Previously, 2 foreign investors could make a joint investment putting US$ 200,000 each in a Government approved development project to qualify for citizenship of St Kitts and Nevis. They had to keep the property in their possession for 7 years. If a single investor put US$ 400,000 into real property, he/ she could sell it back after 5 years. Now a foreign national has to invest at least US$ 400,000 into a development project and keep the property in his/ her possession for 7 years to obtain a passport of St Kitts and Nevis.

Conclusion 

Thus, all the five Caribbean countries have raised the ‘price’ of economic citizenship. The Federation of St Kitts and Nevis introduced new requirements a year before. The new regulations went into force in Grenada, Dominica, and St Lucia on July 1, 2024. Antigua and Barbuda has requested a 30-day deadline extension. Let’s put the figures in a table: