Dominica CBI Agents’ Annual Fee Up 500% in New Regulations, Antigua Issues Guidance on Interviews

---

Antigua & Barbuda’s Citizenship by Investment Unit has issued guidelines for the new applicant interviews, while Dominica has issued a new set of CBI regulations that, among other effects, will prohibit applicants from changing their names within five years of approval.

All applications submitted to the Antigua & Barbuda CIU after Dec 15th will be subject to applicant interviews, which will also come with an additional $1,500 interview fee. The CIU said in a circular this week that it had received several practical questions from stakeholders about the format of the interviews, to which the CIU has provided answers in Q&A format.

Salient points include:

• Third-party service providers proficient in the applicant’s preferred language will conduct the interviews. The applicant’s agent is not required to participate.
• All parties to the application will be interviewed simultaneously, rather than separate interviews for each family member.
• Applicants will receive at least three date- and time-options for the scheduling of the interview.
• All applicants aged 16 or above must attend the interview.
• There is no penalty for missing the scheduled interview, though it is likely to unnecessarily delay the application process.
• See the full list of questions and answers.

Dominica’s CIU, meanwhile, issued a new set of regulations for the country’s CIP this Tuesday. The new rules primarily enshrine in regulation Dominica’s commitment to the 6 CBI Principles, which the five Caribbean CIP countries have agreed to with the US Treasury. Highlights include:

• Interviews are now mandatory, and the corresponding $1,000 fee is now enshrined in regulation.
• Common treatment of denied applicants across the Caribbean.
• Automatic information-sharing with the Joint Regional Communications Centre (JRCC).
• The government now has expanded powers to revoke a citizenship and recall the passport if, for example, an applicant later receives a significant prison sentence, or if they change their names within five years of approval.

As our IMI Pro members have already been aware of for some time, thanks to our Private Briefings, the possibility of name changes during or soon after approval has been a serious point of controversy for Caribbean CIPs. Dominica was the last of the five countries to disallow the practice, which it has now formalized through regulation. Turkey’s CIP, meanwhile, still permits the changing of names during the application process.

Authorized agents must henceforth pay an initial fee of US$20,000 before they can submit applications to the Unit, and $15,500 annually thereafter. This is up from $5,000 and $2,000, respectively. Licensed promoters must similarly pay an initial fee of US$20,000 before they are permitted to promote the program, and $15,500 annually thereafter.

Adult children must now be fully (previously, the requirement was “substantially”) supported by the main applicant or the applicant’s spouse and must also provide evidence to prove they are in full-time attendance at an institution of higher learning unless they are handicapped or are unmarried daughters under the age of 25 living with the main applicant.

Dominica’s new regulations also tightened the requirements for authorized local agents and international promoters. For example, authorized agents are now formally responsible for the marketing conduct of their sub-agents or international partners, and may not work with any such promoters who are not registered and licensed by Dominica.

The authorized agents – who must be citizens of Dominica and maintain office premises and at least three local staff – are also responsible for ensuring the their partners’ prompt payment of the pertinent annual fees.

IMI Pros who can help with Caribbean CBI programs