In a significant move to uphold the integrity of its Citizenship by Investment (CBI) Program, Grenada’s Investment Migration Agency (IMA) – the government body in charge of receiving and processing CBI applications has announced the rejection of eight applications and the initiation of citizenship revocation for one individual, all linked to illegal discounting practices. This action underscores Grenada’s unwavering commitment to maintaining the credibility and transparency of its CBI Program.
On March 5, 2025, the IMA issued Circular No. 2 of 2025, highlighting recent discoveries of unlawful discounting and unauthorized financing arrangements within the CBI Program. Specifically, a marketing agent affiliated with a developer, along with several sub-agents, were found to be offering illegal financing schemes to potential applicants. Documented evidence revealed that applicants received loans of $100,000 from a developer registered in Grenada, a clear violation of the program’s regulations.
Such actions not only breach legal and regulatory frameworks but also undermine the integrity of Grenada’s CBI Programme and the broader investment migration industry. The IMA has unequivocally condemned these practices and reaffirmed its dedication to ensuring that all stakeholders adhere to the highest ethical standards.
In response to these violations, the IMA has taken the following actions:
- Application Rejections: Six applications were denied in the latter half of 2024, with two additional denials in early 2025. A third denial is anticipated imminently due to involvement in illegal discounting practices.
- Citizenship Revocation: The revocation process has commenced for one approved applicant who benefited from the discounted pricing, emphasizing the agency’s commitment to rooting out illegal practices.
- Agent Scrutiny: Due diligence firms have been directed to closely monitor applications submitted by the implicated marketing agent and its sub-agents.
- Termination of Relationships: The CBI Committee has mandated the termination of relationships with offending sub-agents involved in these malpractices.
The IMA has also intensified its monitoring efforts, employing advanced technology and on-ground intelligence to detect and prevent illegal activities within the CBI program.
To prevent future violations, the IMA has reiterated the minimum investment requirements for the CBI Programme:
- Approved Real Estate Projects: A minimum investment of $270,000 to the developer and an additional $50,000 to the government.
- Non-Tourism Sector Projects: A minimum investment of $350,000.
- National Transformation Fund (NTF): A minimum non-refundable contribution of $235,000
These investment thresholds apply to a single applicant or a family of up to four individuals.
Regional Collaboration Against Illegal Discounting
Grenada’s actions align with a broader regional effort to combat illegal discounting in CBI programs. Last year, five Caribbean nations—Saint Kitts & Nevis, Antigua & Barbuda, Grenada, Saint Lucia, and Dominica—signed a Memorandum of Agreement (MOA) to harmonize their CBI programs and eliminate underselling practices. The MOA emphasizes that any discounting of the agreed minimum investment amounts is illegal and calls for cooperation among member states to uphold these standards.
The MOA outlines several key provisions:
- Establishing a minimum investment threshold of at least $200,000 to harmonize pricing structures across participating countries.
- Sharing information and maintaining transparency by enhancing cooperation among member states. This should ensure compliance with agreed standards and prevent illegal practices.
- Establishing a regional regulatory body to oversee the implementation and adherence to the MoA’s provisions.
Grenada’s recent enforcement actions reflect its commitment to these regional standards, reinforcing the collective effort to preserve the reputation and effectiveness of Caribbean CBI programs.
The IMA has issued a stern warning to all stakeholders, including local agents, marketing agents, sub-agents, and potential applicants, regarding the consequences of engaging in illegal discounting or unauthorized financing arrangements. Such actions may result in:
- Revocation of Licenses: Agents found complicit in illegal practices risk losing their authorization to operate within the CBI Program.
- Application Denials: Applications associated with illegal discounting will be rejected, preventing individuals from obtaining Grenadian citizenship.
- Citizenship Revocation: Individuals who have obtained citizenship through fraudulent means may have their citizenship status revoked.
- Project Decertification: Development projects involved in illegal practices may lose their approved status, affecting their eligibility within the CBI Program.
These measures underscore the IMA’s dedication to maintaining the integrity of Grenada’s CBI Program and ensuring that all participants adhere to established legal and ethical standards.
By rejecting applications linked to illegal discounting and initiating citizenship revocation processes, Grenada sends a clear message that such practices will not be tolerated. This unified stance among Caribbean nations aims to ensure the sustainability and credibility of their CBI programs, fostering trust among investors and stakeholders.