St Kitts & Nevis, a pioneer in the citizenship by investment (CBI) industry, has updated the investment thresholds for its economic citizenship program. Effective from July 8, 2024, and published in the official gazette as the Saint Christopher and Nevis Citizenship by Substantial Investment Regulations, 2024 (CSI Regs 2024), these changes aim to align the price structure of the CBI program with other OECS (Organization of Eastern Caribbean States) nations, which operate similar schemes. Following a Memorandum of Agreement (MoA) signed in March 2024, Antigua & Barbuda, Dominica, Grenada, and St. Lucia increased minimum investment requirements for their respective CBI programs in July 2024. The agreement, actively supported by Prime Minister Dr. Terrance Drew of St Kitts & Nevis, who chaired the OECS at the time, set a minimum investment threshold of USD 200,000 for all CBI options, including government funds, projects, or private developments.
However, St Kitts & Nevis had previously reformed the CBI program and drastically increased minimum investment requirements in July 2023, significantly exceeding the threshold defined in the MoA. With the implementation of the new 2024 Regulations, authorities in St Kitts & Nevis aim to harmonize CBI price tags with their Caribbean counterparts.
New Investment Thresholds
The revised CBI investment thresholds reflect the government’s efforts to make the economic citizenship program more attractive to potential investors while maintaining the country’s commitment to sustainable development, economic growth, and international obligations. From July 8th, the following investment thresholds are effective:
- Sustainable Island State Contribution (SISC) (Regulation 21):
- USD 250,000 for a main applicant or a family of up to 4 persons, including a main applicant with a spouse and up to two dependents or a main applicant with up to three dependents.
- USD 25,000 for each additional minor dependent (under 18 years old).
- USD 50,000 for each additional adult dependent (over 18 years old).
- Developer’s Real Estate Investment (Regulation 20):
- The minimum investment remains at USD 400,000, with properties resaleable after seven years.
- Private Real Estate Investment (Regulation 22):
- USD 400,000 for a condominium unit or share in a real estate development (resaleable after seven years).
- USD 800,000 for a single-family private dwelling home (resaleable after seven years).
- Public Benefit Option (Regulation 23):
- A minimum investment of USD 250,000 in a unit of an Approved Public Benefit Project.
Alongside the adjusted investment thresholds, the post-approval in-principle fees for CBI applications have also been updated:
- USD 25,000 for the main applicant (not for the Public Benefit Option).
- USD 15,000 for the spouse of the main applicant.
- USD 10,000 for each minor dependent.
- USD 15,000 for each adult dependent.
The due diligence fees and other government fees remain unchanged:
- USD 10,000 for the main applicant.
- USD 7,500 for the spouse and each dependent 16 years old or over.
- USD 250 application processing fee per applicant.
- USD 50 Certificate of Registration fee per applicant.
Background
The CBI program of St Kitts and Nevis, established in 1984, is the world’s oldest and has set a high standard for other nations to follow. Over the years, it has been instrumental in attracting foreign investment, boosting the local economy, and funding public infrastructure and social programs. The recent adjustments continue the trend to ensure that the program remains competitive and appealing to high-net-worth individuals globally.
Prime Minister Dr. Terrance Drew has consistently highlighted the government’s dedication to offering a world-class CBI program underpinned by rigorous due diligence and a robust regulatory framework. The introduction of the SISC, replacing the Sustainable Growth Fund (SGF), underscores the country’s commitment to sustainable development across various sectors, including green energy, local food production, and economic diversification.
The revised thresholds and enhanced scrutiny measures are designed to attract distinguished investors who can contribute to the nation’s long-term prosperity while preserving the prestige associated with St Kitts & Nevis citizenship. Along with increased and harmonized minimum investment thresholds, the provisions of the MoA included the standardization of the CBI programs across participating countries, enhancing the integrity and credibility of these programs, and promoting cooperation and information sharing between member states. The MoA prohibits discounting the minimum investment amount and encourages transparency measures like disclosing received funds and conducting independent audits.
The MoA corresponds to the ‘six principles’ agreed upon at the US-Caribbean roundtable discussion in February 2023. These ‘six principles’ included an agreement on sharing information on denied CBI applications, so that no other country would process applications from individuals previously denied in other CBI jurisdictions. It also established the rule of mandatory interviews for CBI applicants, enhanced due diligence checks, periodic audits with international standards, the ban on Russian and Belarusian nationals applying to any CBI program, and mechanisms to retrieve revoked or recalled passports with the help of law enforcement.
The EU, UK, and US have expressed concerns about Caribbean CBI programs for years, citing potential security risks from lax vetting and visa-free travel abuse. They also worry about program integrity. Critics argue that CBI programs can be exploited by individuals seeking to evade legal repercussions or facilitate money laundering and other illicit activities. The visa-free travel privileges granted to Caribbean citizens raise concerns that bad actors could utilize these programs to gain access to the EU and other developed nations.
These concerns have led to increased scrutiny and calls for reform of CBI programs by Western countries. The signing of the MoA and active implementation of its provisions showcase that Caribbean leaders are committed to addressing all foreign worries regarding CBI programs and present themselves as reputable international partners.