4 of 5 Caribbean CIPs Sign MoU on $200,000 Price Floor, Discounts-Prevention, Closer Regulatory Integration

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The Prime Ministers of Antigua & Barbuda, Dominica, Grenada, and Saint Kitts & Nevis this week signed a broad Memorandum of Understanding that will see the countries integrate significant aspects of their citizenship by investment programs by June 30th.

The MoU (full text available here) lists a number of areas in which the four programs commit to cooperate more closely, the most salient of which relate to:

• Pricing: The four countries have agreed to harmonize the minimum investment thresholds for their respective CIPs to an investment sum of US$200,000 by June 30th this year. Any future changes to this minimum must be unanimously adopted across the group. Moreover, this minimum will represent “the actual amount of funds received and applied towards the applicant’s qualification under the CBIP, and not the gross amount of funds paid by an applicant from which deductions, including the payment of commissions, are made.”

• Information sharing and transparency standards: As already agreed between all five Caribbean CIPs as part of their accord with the US Treasury around the “six CBI principles” last year, the countries will share information on applicants with each other. In this MoU, the four signatory countries commit to establish and fund a digital portal with the Joint Regional Communications Centre (JRCC) in Barbados. Furthermore, the four countries commit to enhance program transparency by, for example, disclosing details around program revenues and disbursements.

• Regulation: The four countries have agreed to establish a common regional competent authority to “set standards in accordance with international requirements and best practices and to regulate the programs” by June 30th, 2024.

• Security screening: Beyond what’s already been agreed with the US Treasury regarding applicant vetting, the four MoU signatories also agree to cooperate on post-approval screening of CBI citizens and on the retrieval of canceled passports.

• Regulation of agents; Marketing and promotion of programs: The parties will have common standards for agent regulation and for marketing, which will prohibit, among other things, the use of “visa-free access” and photos of passports in advertisements.

Speaking to media and stakeholders this week on the occasion of the Grenada CIU’s rebranding to “Investment Migration Agency Grenada,” Prime Minister Dickon Mitchell said he had “spent the last six weeks in very intensive discussions” with his counterparts in other OECS countries which had culminated in his signing of the MoU.

Prime Minister Terrance Drew of Saint Kitts & Nevis said that beyond the commitment to instate a US$200,000 price floor, the MoU would “aim to, “more importantly, bring an end to underselling, a scourge on the CBI industry in the recent past.” The problem had also been pervasive in Saint Kitts & Nevis under the previous government, which prompted at least one local project owner to sue the former administration in US court over what he characterized as an “international scam.”

Saint Lucia sitting it out

Conspicuously absent from the list of signatures was that of Saint Lucia’s Prime Minister Philip J Pierre. His country is the only one of the five Caribbean CBI jurisdictions not to take part in the accords.

Observers with whom IMI has been in touch today indicate this may be related to Saint Lucia’s commitment to controversial CBI developer Caribbean Galaxy, which has a track record of self-funding escrow accounts on behalf of their clients in a manner that enables them to receive from applicants an investment amount far below the official rate, while still appearing to have raised US$200,000.

Recently, Saint Lucia’s CIU, which collects government fees of $30,000 or more for each approved real estate investment regardless of whether a bona fide $200,000 investment takes place, reportedly allotted Galaxy another batch of several thousand shares to sell.

IMI has contacted the Saint Lucia CIU for a statement on why it did not sign the MoU.

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