Caribbean nations offering Citizenship by Investment (CBI) programs are swiftly enacting a Memorandum of Agreement (MoA) designed to enhance cooperation and standardization. The official press release published on the Organization of Eastern Caribbean States (OESC) website shows that St Lucia has joined the MoA. Hence, the signatories of this pivotal agreement include Antigua & Barbuda, the Commonwealth of Dominica, Grenada, St. Kitts & Nevis, and Saint Lucia. This agreement, published in March 2024, aims to foster cooperation, information sharing, and adherence to common standards and regulatory oversight.
From July 1, 2024, all participating countries agree to enforce a new minimum investment threshold of USD 200,000 for any CBI option. The MoA explicitly prohibits any discounting of this agreed minimum price. Market actors, including marketing agents, local agents, and developers, are required to report any attempts or instances of discounting to the relevant authorities, including the CBI Unit, Investment Migration Agency, or Financial Intelligence Units of the respective countries.
Participant countries agreed to establish an Interim Regulatory Commission for further improvement of regulatory oversight. This body will function until enabling legislation for a regional regulatory entity is enacted. The seven-member commission will include representatives from each participating country, the OECS Commission, and the Eastern Caribbean Central Bank.
The regional regulatory body will develop and implement regional standards for CBI programs, monitor compliance with legislation, regulations, and standards, and ensure adherence to international agreements. Additionally, the commission will investigate complaints and facilitate information sharing and engagements with regional and international stakeholders.
Workstreams have been assigned to all articles of the MOA, and the CBI countries have committed to providing regular updates on the implementation progress. This coordinated effort aims to enhance the integrity and appeal of CBI programs in the Caribbean.
The MOA marks a significant step toward harmonizing CBI programs across the region, ensuring they operate under unified standards and robust regulatory oversight. This initiative is expected to boost investor confidence while safeguarding the reputations of the participating countries through adherence to stringent best practices and regulatory measures.
As the MoA’s implementation advances, stakeholders in the investment migration industry doubt whether the intended reforms will meet the June 30th, 2024, deadline, as the signatory countries need to amend their national legislation.
In conclusion, the Caribbean countries’ commitment to the MoA signifies a proactive approach to strengthening their CBI programs, promoting transparency, and ensuring long-term sustainability. The MoA provisions correspond to the six principles agreed during the US-Caribbean round table talks, which took place in February 2023. These principles include not processing applications from individuals denied in other jurisdictions; conducting interviews with applicants; running checks through Financial Intelligence Units; auditing the CBI programs regularly; retrieving revoked or recalled passports with law enforcement help, and suspending applications from Russians and Belarusians.
The MoA is a step forward in strengthening international confidence in Caribbean nations. This collaborative effort underscores the importance of regional cooperation in maximizing the economic benefits of CBI programs and addressing concerns raised by Western countries, primarily the USA and Europe, while maintaining strict regulatory standards.