A productive roundtable meeting was recently held in Grenada, gathering representatives from the five Eastern Caribbean countries offering Citizenship by Investment (CBI) programs and the United States Department of the Treasury. The focus of the meeting was to discuss the progress made in implementing the Six CBI Principles, a collaborative initiative to bolster these programs’ governance and risk management.
The Six CBI Principles: A Foundation for Trustworthy CBI Programs
The Six CBI Principles, established in February 2023, represent a joint effort to address concerns regarding the potential misuse of CBI programs for illicit activities like money laundering and terrorist financing. These principles prioritize enhancing due diligence procedures for CBI applications, promoting transparency, and facilitating information exchange between participating countries.
- Collective Agreement on Treatment of Denials: A commitment to decline applications from individuals denied in any other participating CBI jurisdiction.
- Interviews: Conducting interviews with applicants as part of the vetting process.
- Additional Checks: Further checks on each applicant will be performed with the relevant country’s Financial Intelligence Unit.
- Audits: Implementing routine independent audits of the CBI programs.
- Retrieval of Revoked Passports: Establishing mechanisms to retrieve passports that have been revoked.
- Treatment of Russians and Belarusians: Suspending the processing of applications from individuals from Russia and Belarus.
Progress Report: Striving for Full Implementation
The Roundtable served as an opportunity for both the US and Caribbean representatives to recognize the substantial progress made by the Caribbean nations in implementing these principles. In particular, four of these principles, 1, 2, 3, and 6, are already fully implemented:
The remaining two principles, pertaining to audits and retrieving revoked passports, are currently in progress. The Caribbean countries reaffirmed their commitment to diligently complete this process and continue collaborating with the US Treasury to ensure full compliance.
Independent Regional Regulator: Enhancing Credibility and Oversight
Beyond the Six Principles, the Roundtable also emphasized the significant development of an independent regional regulator. As outlined in the Memorandum of Agreement signed by all participating Caribbean Citizenship by Investment countries, this regulator will establish standards and oversee the CBI programs. It will also hold the authority to implement corrective actions if deemed necessary. The creation of this independent regulator represents a crucial step towards reinforcing the trustworthiness and accountability of CBI programs in the region.
Navigating a Competitive Investment Migration Landscape
The Caribbean CBI programs have long attracted individuals seeking second citizenship and increased global mobility. However, these programs now face growing competition from similar offerings in other countries. The United States, for example, provides the EB-5 Visa by Investment program, which grants visas leading to Green Cards and potential citizenship for foreign investors. While the EB-5 program demands a significantly higher investment (minimum $1,050,000) and more stringent requirements than the Caribbean CBI programs, it remains a sought-after option for affluent individuals seeking a foothold in the US.
Similarly, other countries, like Ecuador, offer pathways to permanent residency and citizenship through investment, often with lower investment thresholds. However, these programs frequently mandate physical presence in the country for extended periods, unlike the Caribbean CBI programs, which have no residency requirements.
Looking Ahead: A Future of Strengthened CBI Programs
The recent US-Caribbean Roundtable underscores a sustained commitment to enhancing the integrity and efficacy of the Caribbean CBI programs. The progress made in implementing the Six CBI Principles, coupled with establishing an independent regional regulator, demonstrates the region’s dedication to ensuring the highest standards of due diligence and risk mitigation.
As the investment migration landscape continues to evolve with intensifying competition, the Caribbean nations remain resolute in their efforts to enhance their CBI programs. By upholding transparency, promoting good governance, and fostering collaboration with international partners like the United States, they strive to guarantee these programs’ enduring success and sustainability for the foreseeable future.
