Photo by Emily Bauman on Unsplash
On 25 February 2023, a historic US-Caribbean Roundtable on Citizenship by Investment was held in Saint Christopher (St Kitts) and Nevis.
The highly productive and mutually beneficial engagement involved delegations of the five Eastern Caribbean states with Citizenship by Investment (CBI) Programmes led by their Prime Ministers and a delegation of the Government of the United States led by the Deputy Assistant Secretary of the US Department of the Treasury. Also in attendance was the Governor of the Eastern Caribbean Central Bank and the Director General of the Organisation of Eastern Caribbean States.
Both parties engaged in a frank discussion on the threats and challenges faced by these programmes and the important contribution that they have made to national development in these small states.
The US recognised that the CBI Programmes provide a legitimate service and have assisted in the survival of the participating economies by providing revenues, particularly considering the existential threat to our vulnerable small island states - emanating from the climate emergency - and the onslaught of recent adverse external shocks, including the ongoing war in Ukraine. CBI revenues are invaluable for funding major infrastructural and development projects, and for building resilience.
It was accepted that dismantling these Programmes would severely compromise the prosperity and prospects of the countries, triggering a plethora of negative social consequences domestically and potentially leading to an upsurge in criminality, among other pathologies.
Both parties affirmed their commitment to a collective fight to safeguard their respective financial systems against threats posed by illicit actors. The five Governments collectively committed to six CBI principles proposed by the US, several of which had previously been proactively adopted by the OECS states of their own volition as part of their risk management framework to strengthen and safeguard the integrity of their CBI Programmes.
The six principles agreed to are the following:
- Single applicant – US$ 125,000
- Collective agreement on treatment of denials: Not to process applications from persons whose applications have been denied in another CBI jurisdiction, by proactively sharing information on denials.
- Interviews: Conduct interviews with applicants, whether virtual or in- person.
- Additional checks: Each jurisdiction will run checks on each application with the Financial Intelligence Unit of its respective country.
- Audits: Audit the Programme annually or every two years in accordance with internationally accepted standards.
- Retrieval of passports: Request law enforcement assistance to retrieve revoked/recalled passports.
- Treatment of Russians and Belarusians: Suspend processing applications from Russians and Belarusians. Four jurisdictions have already suspended applications and Grenada which processes applications from Russians and Belarusians with enhanced due diligence, will suspend processing new applications from Russia and Belarus fromMarch 31, 2023.
It was recognized and accepted that the implementation of this measure has and will continue to have significant adverse revenue impact for the CBI states.
Both Parties also agreed to convene a technical discussion within the next four to six months to assess the status of implementation of the agreed six principles. Additionally, at this next engagement, the OECS States requested further discussion on the US Government’s risk management framework for the EB-5 Immigrant Investor Program as it relates to the processing of applications from Russians.
Given these agreements, the CBI States requested that the US Government facilitate a similar engagement with the European and United Kingdom Governments based on the six agreed principles. Both Parties reiterated their commitment to ongoing constructive engagement that takes account of the special circumstances of small states and their needs.
Source: Investment Migration Council Press Release
What should you do now?
"You may reconsider your application time. The sooner, the better. The above principles will make the due diligence more strict and processing time longer and more difficult. My advice, act as soon as possible"
commented Laszlo Gaal, head of RCP.
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