Caribbean Citizenship By Investment Programs Surpass 100,000 Passports Issued

The European Commission’s (EC) Seventh Report under the Visa Suspension Mechanism, released in December 2024, provides insightful statistical data and analyses on the Citizenship by Investment (CBI) programs operated by five Eastern Caribbean nations: Antigua & Barbuda, Dominica, Grenada, St Kitts & Nevis, and St Lucia. Since 2014, these economic citizenship programs have benefited more than 100,000 individuals by granting citizenship, underscoring their solidity in global mobility and investment landscapes.

Since 2020, the EC has been engaging with several visa-free countries operating investor citizenship schemes to obtain relevant information on them. The data contained in the EC reports is frequently incomplete and inconsistent. Nevertheless, it shows the current trends and highlights the Europeans’ concerns regarding CBI programs.

Nearly 50,000 CBI applications have been received by all five Caribbean states operating economic citizenship programs and the bulk portion of it went to Dominica and St. Kitts & Nevis. The number of CBI passports issued has surpassed 100,000. St Kitts & Nevis and Dominica have established themselves as frontrunners in the CBI market. From 2015 to mid-2024, these two countries alone issued over 70,000 passports, representing a substantial share of the region’s total.

St Kitts & Nevis

The EC has not received data on issued CBI passports from St Kitts & Nevis for 2023 and 2024. However, it shows a drastic decline in new CBI applications in 2024, which might be caused by the reforms implemented in the CBI program and the significant increase in the minimum investment requirement.

St Kitts & Nevis has issued 35,577 passports between 2015 and 2022, this program is renowned for its longevity and efficient processing, making it a popular choice. Recent reforms to reduce investment thresholds are intended to boost application numbers following a decline in 2024.

The St Kitts & Nevis CBI program currently offers the following investment avenues:

• Sustainable Island State Contribution (SISC): Main applicant or family of four – minimum donation must be $250,000
• Approved Public Benefit Project: Family of up to four: USD 250,000; adding an additional dependent under 18 will cost $25,000, and over 18 – $50,000.
• Developers’ Real Estate Project approved by the government: Minimum investment: $325,000 (Investment options include freehold property, hotel shares, fractional ownership, or land, and must be retained for at least 7 years)
• Private Real Estate: The minimum investment for a condominium unit must be at least $325,000, and for a single-family home – $600,000

Dominica

The report indicates that some data on Dominica’s CBI program for 2022 is still being verified. Despite setbacks such as the loss of UK visa-free access in mid-2023, Dominica’s program has shown remarkable resilience. With 5,484 passports issued in the first half of 2024, it continues to be a compelling choice for investors looking for cost-effective solutions.

The total number of applications is often lower than the total number of passports issued because one application can cover multiple individuals (e.g., a successful application for a family of four counts as one application but results in several passports issued).

Currently, Dominica offers two avenues for its CBI program:

• Contribution to the Economic Diversification Fund (EDF)
• Investment in a real estate project approved by the government, which must be retained for at least three years.

The minimum investment requirement for both options is $200,000, but this threshold increases if dependents are added to the application.

Antigua & Barbuda

In the second half of 2024, all five Caribbean countries reformed their CBI programs according to the Memorandum of Agreement (MoA) signed in March 2024. The MoA aimed to enhance transparency, collaboration, and adherence to best practices within the Caribbean CBI programs. The most notable change was raising and harmonizing the minimum investment requirement from $100,000 to $200,000. Antigua & Barbuda implemented the reforms a month later than its Caribbean counterparts, introducing increased investment thresholds in August 2024. The EC report does not include data after this increase, but it is likely to negatively affect the number of received applications.

With an average of 413 applications per year between 2014 and 2022, the Antigua & Barbuda CBI program’s consistency and family-friendly pricing have consistently attracted investors. In the first half of 2024 alone, 739 applications were submitted, positioning Antigua for another impressive year.

Antigua & Barbuda’s CBI program offers the following options to qualify:

• A non-refundable contribution to the National Development Fund (NDF): $230,000 for a family of four members
• A non-refundable donation to the University of West Indies (UWI) Fund: $260,000 for a family of six members
• Investment in a government-approved real estate project: $300,000 for a family of four members.
• Investment in a business: at least $1,5 million for a single investor applying with three other family members, and at least $400,000 in the case of joint investment whereas the total budget of the government-approved project must be at least $5 million.

CBI applicants also have to cover processing, due diligence, and passport fees.

Grenada

The Investment Migration Agency (IMA) Grenada, responsible for overseeing the country’s CBI program, published the quarterly CBI statistics in July 2024 marking the first time applicant nationality information has been provided. According to the IMA statistical report, only 148 applications have been received in the first two quarters of 2024. However, IMA Grenada processed 1,314 applications, reducing the backlog of unprocessed files significantly. The report highlights high approval rates, increased efficiency in processing, and a decrease in new applications. Revenues from the program totaled approximately $186 million, and the Chinese and Nigerian applicants were among the largest groups. Most applicants opted for real estate investment over non-refundable contributions. Grenada’s CBI program set multiple records in 2024 with unprecedented application processing efficiency and high approval volumes.

In November 2024, the IMA Grenada published the statistics for the third quarter exposing efficiency in processing applications from the backlog. In the third quarter, 565 applications were processed, with 521 approvals, maintaining a low rejection rate. Real estate investment remains the preferred option among investors. Grenada granted 1,827 new citizenships in Q3, bringing the total to 4,861 for 2024.

The EC’s report does not contain data on the issued CBI passports in Grenada since 2023.

Currently, the Grenada CBI program offers two options:

• Making a non-refundable contribution to the National Transformation Fund (NTF) of at least $235,000 allowing an investor with up to three dependents to qualify for citizenship
• Investing at least $270,000 in a real estate project approved by the government, plus the Government contribution fee of $50,000 for a family of four. Investment must be kept for at least five years.

Grenada’s CBI program is unique among its regional counterparts. It is the only nation in the Eastern Caribbean with a special treaty with the USA, allowing Grenadian nationals to apply for an E-2 Investor Visa in America.

St Lucia

St Lucia joined the MoA several months after it was signed, in June 2024. The EC report indicates a drastic increase in CBI applications in 2023, with St. Lucia’s Citizenship by Investment Unit receiving more applications than in the previous seven years combined.

From 2015 to 2022, the country saw an average of just 252 applications per year. However, in 2023, this number surged to 4,076 applications, marking a staggering 1,520% increase. Although there was a slight dip in applications in the first half of 2024, St Lucia’s performance underscores its growing prominence among Caribbean CBI options.

St Lucia’s CBI Program now offers the following options:

• Making a non-refundable contribution to the National Economic Fund (NEF) of at least $240,000 allowing a family of four to qualify for citizenship
• Investing at least $200,000 in a real estate project approved by the government and cover Administrative Fees per number of persons included in the CBI application.
• Investing in an Approved Enterprise Project with three different options. For a single investor, the minimum investment requirement is $3,5 million; in the case of a joint venture each applicant must contribute at least $1 million provided that the total budget of the project is at least $6 million; and the third option is to invest at least $250,000 in a National Infrastructure Improvement Project Approved by the Government allowing family of four to qualify
• Making a zero-interest investment in Government bonds with at least $300,000, plus $50,000 of Administrative Fees allowing family of any size to qualify.

Application Process

The EC’s report highlights the application process across Caribbean nations generally involves five key steps:

• Engagement of Licensed Marketing Agents: These agents identify potential investors internationally.
• Submission via Authorized Local Agents: Prospective investors submit their applications through authorized local agents to the respective CBI Units.
• Comprehensive Vetting Process: This includes financial due diligence by banks, identity and security checks by international firms, and assessments of security and immigration risks by the CARICOM Implementation Agency for Crime and Security’s Joint Regional Communications Centre (JRCC).
• CBI Unit Decision: Based on the vetting outcomes, the CBI unit approves or rejects applications.
• Final Approval: For approved applications, the competent minister grants citizenship.

The total number of passports issued exceeds the number of applications due to the inclusion of family members in single applications.

Applicant Demographics

The successful applicants continue to include mostly nationals who would otherwise require a visa to enter the EU. Between 2023 and 2024, the primary nationalities included Iran (1,918 applicants), China (1,099), Syria (747), Iraq (425), Nigeria (308), and Lebanon (149). Notably, following the Russian aggression against Ukraine, all five countries suspended applications from Russian and Belarusian nationals. However, in 2023, Grenada processed approximately 2,300 pending applications from Russian nationals, with 87 still outstanding as of September 2024.

EU Concerns and the MoA

The EC has raised concerns that the screening and vetting processes of the five Caribbean countries might be inadequate in preventing applicants who pose potential security risks from traveling visa-free to the EU. Its assessment raises two basic concerns regarding these CBI programs:

• Lack of Residency Requirements: None of the five countries mandate residence or physical presence before granting citizenship, resulting in the absence of biometric data for successful applicants.
• Name Change Provisions: All five countries permit successful applicants to change their names post-citizenship acquisition, with varying timeframes and conditions.

These factors may pose potential security risks to the EU, given the visa-free access granted to citizens of these countries.

The EC has acknowledged the efforts made by these countries to enhance their CBI procedures. All five countries have demonstrated a heightened awareness of the need to improve their due diligence and security screening systems, as well as a willingness to make significant improvements with the help of their international partners. In response, the Commission has engaged in ongoing dialogue with the five nations.

In early 2024, high-level meetings and technical fact-finding missions were conducted, leading to the signing of the MoA among the countries. Along with increasing and harmonizing the minimum investment thresholds to $200,000, the MoA provisions include:

• Enhancing Information Sharing: Facilitating better cooperation on applicant data.
• Implementing Transparency Measures: Improving the openness of the programs.
• Establishment of a Regional Regulatory Authority: Overseeing the programs collectively.
• Strengthening Security Screening Frameworks: Enhancing due diligence processes.
• Setting Common Standards for Agents and Marketing: Ensuring uniformity in promotion and operation.

Economic and Political Significance

The CBI programs are economically and politically significant for these Eastern Caribbean nations. They provide substantial revenue streams and investment inflows, contributing to national development. The willingness of these countries to engage with the EU and implement reforms reflects an understanding of the need to balance economic benefits with international security concerns.

Conclusion

The EC acknowledges the steps taken by the Caribbean countries to enhance the security and integrity of their CBI programs. The EC will continue to monitor the implementation of the agreed reforms, assessing their effectiveness in mitigating potential security risks associated with visa-free access to the EU. This collaborative approach aims to ensure that the benefits of the CBI programs are realized while maintaining the security and public policy interests of the EU and its member states.

The global interest in Caribbean CBI programs is steady, as highlighted in the EC’s report. Since 2014, over 100,000 CBI passports have been issued, providing valuable insights into the development of these programs and their significance in offering mobility, security, and investment opportunities to individuals worldwide.

Governments in Antigua & Barbuda, Dominica, Grenada, St Kitts & Nevis, and St Lucia have shown a commitment to strengthening due diligence and security measures. This partnership ensures the programs remain attractive to investors while addressing EU concerns about public policy and security risks.