Samoa Considers Halving CBI Threshold as Gov’t Bans Applicants with Foreign Government Ties

Chamber proposes SAT$2M threshold tied to creating 15 skilled jobs or 50 total positions depending on sector.

Samoa’s business lobby has urged the government to slash its Citizenship by Investment (CBI) program minimum from SAT$4 million (US$1.42 million) to SAT$2 million (US$710,000), arguing the current requirement leaves the island nation uncompetitive in the global residency-for-investment market, according to the Samoa Observer.

The Samoa Chamber of Commerce and Industry (SCCI) made the recommendation in its draft policy framework submitted to government officials reviewing the program. Established under the Citizenship Investment Act 2015, the existing program has attracted limited interest since its launch.

SCCI’s proposal ties the reduced threshold directly to employment generation and local business engagement. Under the chamber’s framework, investors contributing SAT$2 million would need to create “either 15 skilled jobs or 50 jobs in total,” depending on the sector, according to the draft policy.

The chamber also recommends that 70% of the program focus on active business investments rather than passive financial instruments. Bond purchases and similar vehicles “provide limited long-term benefits to the local economy,” the SCCI draft states.

Lita Lui, SCCI Chief Executive Officer

Implementing the chamber’s proposal requires amending the Citizenship Investment Act 2015 through Samoa’s parliamentary process. The Cabinet must first endorse the policy before the Attorney General’s Office drafts an amendment bill.

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The bill would undergo legal vetting to ensure it doesn’t contradict existing laws, financial review by the Ministry of Finance, and compliance checks against international anti-money laundering and anti-corruption standards. Bills then pass through Parliament’s Legislative Assembly in three readings.

After the introduction at First Reading, the Minister presents the bill’s purpose at Second Reading, where members debate its principles. The legislation moves to the Finance and Expenditure Committee, which can call for public submissions from organizations like SCCI, question ministry officials, and recommend amendments before Parliament votes at Third Reading.

If passed by majority vote, the bill requires assent from the Head of State (O le Ao o le Malo) to become law. The Ministry of Commerce, Industry and Labour would then draft implementing regulations covering application procedures, fees, due diligence processes, and job verification methods.

Current regulations require applicants to maintain a minimum net worth of SAT$2.5 million (US$907,000) and invest across seven qualifying sectors. These include tourism, agricultural processing, fishery manufacturing, renewable energy generation, information technology, government land development, and contributions to a state development fund.

Successful applicants must retain permanent resident status for three years before becoming eligible for citizenship. During this period, they must spend at least 15 days annually in Samoa and maintain 15% of their original investment in a fixed deposit account.

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Processing time for permanent residency applications runs approximately three months. Applicants must file for citizenship within three months before their permanent residency permit expires.

Samoa’s passport currently ranks 42nd globally, offering visa-free access to 129 countries. This includes European Union member states, the United Kingdom, and Electronic Travel Authorization (ETA) eligibility for Canada.

Foreign Government Ties Trigger Automatic Disqualification

The Ministry of Commerce, Industry and Labour (MCIL) has clarified that investors with foreign government ties face automatic disqualification, the Observer reported. Acting MCIL Chief Executive Officer Fuimaono Christopher Smith confirmed that state ownership triggers immediate rejection under national security protocols.

The Citizenship Investment Regulations 2016 mandate that due diligence “must utilise intelligence from both formal government and local, on-the-ground sources,” Fuimaono told the Observer. This framework gives the Citizenship Investment Committee authority to investigate any aspect of an applicant’s background.

Discovering state ownership triggers classification as a direct security risk and automatically disqualifies applicants under national integrity rules, Fuimaono explained.

Acting MCIL Chief Executive Officer Fuimaono Christopher Smith

Five senior officials comprise the committee through ex officio appointments. Members include the Chief Executive Officers of the Ministry of Finance (Saoleititi Maeva Betham-Vaai), Ministry of Customs and Revenue (Fonoti Talaitupu Li’a Taefu), and Ministry of the Prime Minister and Cabinet (Agafili Tomaimanō Shem Leo), along with Central Bank Governor Maiava Atalina Emma Ainuu-Enari.

The MCIL CEO chairs the committee, though that position remains vacant as the Public Service Commission finalizes recruitment. Committee members “sit on the committee automatically because of the high-ranking government positions they hold,” Fuimaono explained.

Government officials support adding immunity provisions to protect committee members making good-faith decisions. These clauses would shield officials from personal liability and enable decisive action without exposure to frivolous litigation.

The SCCI cautioned against rushing implementation, emphasizing the need for careful rollout procedures. Chamber President Faasootauloa Sam did not respond to requests for comment from the Observer.

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