By Denny Titre, Apex Capital Partners, Financial Director, Dominica
Come with me on a journey, take a moment to visualize rivers of crystal-clear fresh water entwined in some lush, green forest. The sound of chirping birds that melodiously greet you every morning. Watch the sunset while relaxing on a black sand beach as you dabble your feet in the waves – maybe with some coconut rum punch if you’re into that. Yes, some call it a vacation, I call it home.
Dominica is known for its untouched landscape and the rich culture of the 70,000 people, like me, who have the luxury of calling it our home. It’s easy to see why applicants under the Citizenship By Investment (CBI) program choose this Caribbean beauty as their second passport option.
Dominica, however, is not immune to global matters that plague the more economically developed countries. Likewise, we have to monitor the global market trends and mitigate against risk, similarly, we have to manage the challenges brought on by the COVID-19 pandemic. We also share the lifelong wish that the inhabitants of planet earth will all get along irrespective of political and socio-economic differences, and yes, banking here can also be a nightmare.
Applicants under the Dominica CBI Program must process payment of the relevant fees at the country’s only indigenous bank – National Bank of Dominica (NBD). NBD has two correspondent banks: Bank of America (BOA) in the USA and Lloyds Bank in the UK. Since NBD is unable to directly receive funds from international banks, applicants must utilize either one of its two correspondent banks via the Society for Worldwide Interbank Financial Telecommunication (SWIFT) system. With the figures for the CBI program quoted in USD, it is a lot easier to follow the BOA route – here is where things get complicated.
The correspondent banks, theoretically, is the main link between NBD and the global banking system. This important collaboration is what enables applicants all around the world to send wire transfers to Apex Dominica and to the Government of Dominica to complete their respective CBI applications. The harsh reality is, NBD will do everything possible to protect their correspondent banking relationships.
Although the applicant may be halfway around the world, all banks are required to verify the identity, suitability, and risks involved in maintaining banking relationships in accordance with Know Your Customer (KYC) and Anti-Money Laundering (AML) policies. This is a mandatory, crucial, and independent procedure carried out by banks to protect themselves and stakeholders from being used by criminal elements for clandestine purposes.
Herein lies the reason why so many different documents are required when sending CBI application funds. Let us use Johnny as an example to explain what is required by the bank. He wishes to apply for Dominican Citizenship under the Donation option of the CBI program. This is the process he has to follow:
- Step 1 – Johnny contacts Apex Dominica’s Managing Director Ms. Lucina Bruno, or he gets into contact with one of Apex’s many authorized agents all around the world and expresses his interest in the program. Our team does an initial background check on Johnny to confirm his eligibility. Fees are discussed, an agreement is signed and Johnny begins his application process by filling out the required forms and gathering the necessary documents.
- Step 2 – Once Johnny’s application is ready for submission, an invoice will be prepared for settlement. The wire transfer to Apex Dominica MUST be sent from Johnny’s bank account. If he is unable to use his account, it can be sent by either his wife, his parent, his child, or his sibling. If Johnny is the beneficial owner of a company or he owns 25% or more of the company’s shares, the company can send the wire transfer on his behalf providing that the remittance information clearly states the wire transfer is for Johnny’s application. Neither Johnny’s friend nor his lawyer can send the funds on his behalf. Apex Dominica will then provide NBD with Johnny’s Birth Certificate, Passport(s), Police Record(s), Proof of Address, Bank Reference Letter, and Government of Dominica Disclosure Form for review. Once the payment has been released by the bank, Apex will submit Johnny’s application for processing by the Dominica CBI Unit and provide updates on its progress.
- Step 3 – When Johnny gets approved, he will be required to pay his Donation Fee to the Government of Dominica as per the CBI agreement. He must follow the same steps as before when he made his initial payment. In addition to the documents initially submitted on his behalf, Apex Dominica will be required to provide NBD with Johnny’s bank statements dating back 12 months prior to payment of his Donation Fee for review. It is important that the Donation Fee is paid from the same bank account that Johnny intends to submit the 12-month history for. NBD may, at its sole discretion, make requests for additional documents and/or explanation of transactions posted on the submitted bank statements.
- Step 4 – Once the funds are cleared and released to the Government of Dominica, Johnny will receive his Certificate of Naturalization which declares him a Dominican. By virtue of his new citizenship, he is now eligible for a Dominican Passport which Apex Dominica can apply for on his behalf.
At the end of it all, Apex Dominica will be right there to guide you, just like Johnny, through the entire application process. Though the bank’s role may seem somewhat tedious from the outside looking in, it has a very significant role to play as NBD ensures the integrity of the process is upheld. Neither Apex nor the Government of Dominica has any influence over NBD’s procedures as the bank, at all times, must maintain its independence. Complying with inundating requests from the bank may seem like a daunting task but the sooner you can look past this perceived hurdle, the sooner you can move forward from having a mere visualization of our vacation paradise to the new reality of also calling it your home.