Saint Lucia’s Citizenship by Investment Program (CIP) received 5,642 applications in the fiscal year ending March 31, 2024, a 424% increase over the 1,076 received in FY23.
The Citizenship by Investment Unit (CIU) granted 1,171 applications, more than double the 544 approved the previous year, and denied 77.
FY24’s intake alone exceeds the program’s entire prior history combined. Across the preceding seven fiscal years, Saint Lucia received a cumulative 2,768 applications.
Record Revenue and Costs
Total revenue reached EC$240.3 million (approximately US$89 million), up 296% from EC$60.6 million in FY23. Due diligence fees accounted for the largest share at EC$133.1 million, driven by the surge in applications. Administrative fees from real estate investment, the second-largest line item, came in at EC$88 million.
By contrast, donations to the National Economic Fund (NEF) fell 60% year-on-year. The CIU’s 20% marketing allotment from NEF contributions dropped from EC$12 million to EC$4.8 million, reflecting a continued shift away from the donation route toward real estate.
Real estate administrative fees generated roughly 18 times more revenue than the NEF allotment. “The donation model was a shortcut; convenient, fast, low friction,” observes Adam Juchniewicz, founder of 21 CBI.
He argues that “governments figured out that real estate creates jobs, builds infrastructure, and gives the program political cover. If you are advising clients and you are not fluent in property due diligence, title verification, and developer risk, you are already behind.”
Processing fees totaled EC$3.7 million, while COVID-19 bond administrative fees contributed EC$3.7 million. A new revenue line appeared in FY24: Administrative fees from the National Action Bond, introduced in late 2022, which generated EC$270,000 from two bonds.
Other income, which includes items not separately disclosed, rose from EC$577,000 to EC$4.6 million.
Program costs quadrupled to EC$143.5 million from EC$33.8 million. Due diligence expenses alone consumed EC$88.3 million, or 61% of program costs, reflecting the per-applicant fees paid to the CIU’s four due diligence providers: S-RM, BDO, Exiger, and FACT.
Commissions to authorized agents and promoters reached EC$41.5 million, while marketing agent commissions hit EC$12.1 million. Business travel spending declined slightly to EC$1.1 million.
Operating expenses grew 70% to EC$6.8 million from EC$4 million, a modest increase relative to the revenue expansion. Payroll costs rose 31% to EC$3 million following new hires. Bank charges tripled to EC$1.5 million, driven by transaction volumes and a 0.05% account maintenance fee.
Depreciation jumped to EC$814,000 from EC$234,000 after the CIU invested in new leasehold improvements and office space. Foreign currency translation costs increased to EC$326,000, up from EC$46,000.
Healthy Surplus Despite Growing Costs
After all costs, the CIU recorded a surplus of EC$89.9 million (approximately US$33.3 million), nearly four times the EC$22.8 million surplus in FY23. Of that, EC$58.6 million (approximately US$21.7 million) went to the government’s Consolidated Fund.
An additional EC$41 million from the CIU’s operating surplus was transferred to the NEF in support of government priorities. Total remittances to the government and its funds reached approximately EC$64.1 million for the year.
Cash holdings nearly doubled, rising EC$65.8 million to reach EC$137.8 million by March 31, 2024. Assets across the board expanded, with the total climbing EC$78 million to EC$151.4 million. Accounts receivable surged to EC$8 million from EC$810,000, largely from outstanding due diligence fees.
Total current liabilities more than doubled to EC$80.9 million, driven by accrued due diligence expenses (EC$26.3 million), marketing agent commissions (EC$10.9 million), and a VAT provision of EC$15.1 million. The working capital ratio dipped from 2.15 to 1.82.
Due Diligence Operations and Applicant Nationalities
Saint Lucia has not published applicant nationality data since FY21, making the geographic breakdowns disclosed by individual due diligence providers the closest available proxy.
The report contains submissions from each of the CIU’s four due diligence providers. Exiger processed 1,164 orders covering 1,995 subjects during the period, while S-RM delivered 1,007 reports. BDO handled over 360 requests covering more than 550 subjects, and FACT received 420 applications.
Two providers disclose geographic data on their caseloads, though both categorize applicants by country of residence rather than nationality.
China accounted for the largest share of Exiger’s due diligence subjects (548), followed by the United Arab Emirates (412), Iraq (221), and Saudi Arabia (156). Seventy percent of Exiger’s risk matrix scores fell in the low range, with 26% medium and 4% high.
A similar geographic pattern emerges from BDO’s data. The Middle East and North Africa accounted for 58% of its subjects, with China, Hong Kong, and Taiwan at 27%, Africa at 7%, and Southeast Asia at 3%.
UAE’s prominence across providers likely reflects the large expatriate populations from Iraq, Syria, Lebanon, and other MENA countries residing there, rather than Emirati nationals applying. No nationality-level data for applicants appear anywhere in the report.
“When 58% of your applicant pool comes from MENA conflict zones, you either screen harder or you lose your Schengen-free access,” argues Juchniewicz. “Saint Lucia chose correctly. The programs that survive the next five years will be the ones that said no often enough.”
All four providers introduced applicant interviews during the fiscal year, following the CIU’s September 2023 directive requiring that all main applicants undergo identity verification interviews and Financial Intelligence Authority screening. FACT alone conducted 225 interviews between October 2023 and March 2024.
FY25 Targets
CEO Mc Claude Emmanuel set ambitious targets for the following fiscal year (FY25): A minimum 100% improvement in the rate of processing and a 20% uplift in the annual surplus. Emmanuel characterized the targets as a stretch but achievable.
The backlog implicit in the data, however, is considerable. IMI’s processing time tool recorded an 18-month average wait for Saint Lucia approvals as of Q4 2025, with the longest reported case reaching 26 months.
“If you filed in Q4 2024, you are sitting in a queue behind thousands of applicants,” notes Juchniewicz. “Any agent telling clients this is a 90-day program right now is not being straight with them.”
What the Report Does Not Disclose
The report describes real estate as “now the dominant investment category” and attributes the program’s growth to “the exceptional rise in applications, particularly in Real Estate Investment.”
Yet for a third consecutive year, the CIU’s annual report omits breakdowns of applications by investment category, the number of individuals (as opposed to applications) granted citizenship, and applicant nationality data.
Saint Lucia discontinued these disclosures beginning with its FY22 report, a departure that has coincided with the program’s rapid growth and controversies surrounding its real estate option. Also absent, as in the preceding two reports, is the total capital invested through the real estate route.
Only the CIU’s administrative fees on real estate approvals (EC$88 million) appear in the financials, not the underlying investment amounts flowing to approved developments.
Without category-level data, it is impossible to determine from the report alone how many of the 5,642 applications came through the real estate route versus the NEF donation, COVID-19 bond, or National Action Bond options. Prior reports, through FY21, included both application breakdowns by category and total real estate investment figures.
The real estate option in Saint Lucia has been the subject of political controversy, a now-dismissed US federal RICO lawsuit, and opposition legal challenges. Separately, the UK Home Office cited the rapid application growth reflected in this report as a factor in its March 2026 decision to strip Saint Lucian nationals of visa-free access to the United Kingdom.
