Last week, just a few days after the European Commission proposed to partially suspend Vanuatu’s visa-waiver agreement with the EU/Schengen area, Dominica’s Citizenship by Investment Unit circulated a letter among its CIP agents, warning them – among other things – not to reference visa-free travel to EU and the UK in their program marketing.
In its announcement on Vanuatu, the European Commission expressed explicitly its apprehensions regarding Vanuatu’s use of visa-free travel to Europe as a selling point in its marketing materials:
“Additionally, investor citizenship schemes operated by Vanuatu since 2015 are commercially promoted with the expressed purpose of granting visa-free access to the EU, while the visa waiver agreement is not aimed at allowing visa-required travellers to circumvent the visa requirement by acquiring Vanuatu citizenship,” wrote the Commission.
In what appears a preventive measure on the part of the Dominica CIU, it issued a letter to agents instructing them to refrain from potentially harmful marketing practices. The CIU said it expected agents to adhere fully to the following guidelines:
- It is prohibited to reference visa-free travel to specific countries, territories, and regions, including the European Union and the United Kingdom, with [sic] which a Dominican passport holder may travel to without needing to first apply for a visa, in any content used.
- It is prohibited to claim that an applicant may receive citizenship through the Programme at investment costs that are lower to [sic] the prescribed minimum amount.
- It is prohibited to display images of the passport of Dominica.
- It is prohibited to use “sale of passports” or similar terminology (including “citizenship sale”, “buying passport”, “purchasing passports”, “paying for passports”).
- It is prohibited to promote or advertise the Programme by using mass texts, text blasts, push messages, and other similar alerts via cell phone, telephone, and social media with text of [sic] messaging services.
- It is prohibited to falsely claim that grant of a Dominican passport is part of the process of the Programme.
- It is prohibited to use images of Government officials or the Unit Head without the approval of the relevant persons to promote the Programme.
- It is prohibited to suggest in any manner whatsoever that you may affect the decision-making process of the Government with respect to applications, including processing times.
- It is prohibited to state the number of applicants who were granted citizenship through the Programme and the country of origin of those applicants, unless this information is formally published by the Government.
- It is prohibited to promote the Programme by falsely associating “Special Offers” or “Special Discounts” to the programme.
- It is prohibited to compare the Programme with similar programmes through information that extends beyond precise fact and deliberately misrepresents details of the Programme that are not in line with those mandated by law, Government guidance or the information on the website of the CBIU.
The letter further stated that the government requested all non-complying content be removed with immediate effect. It also highlighted that it did not matter in which language offending promotional material was distributed; it would not be tolerated.
Transgressing agents, sub-agents, and promoters would be subject to “corrective measures”. Failure to comply with the guidelines, said the CIU, would result in agents being “prominently and permanently” blacklisted on the CIU’s website.
Christian Henrik Nesheim is the founder and editor of Investment Migration Insider, the #1 magazine – online or offline – for residency and citizenship by investment. He is an internationally recognized expert, speaker, documentary producer, and writer on the subject of investment migration, whose work is cited in the Economist, Bloomberg, Fortune, Forbes, Newsweek, and Business Insider. Norwegian by birth, Christian has spent the last 14 years in the United States, China, and Spain.