St Kitts CIP Doubles Min. Investments, Addresses Rumored EU Demands Point by Point

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Earlier today, we covered unconfirmed reports of six specific demands the European Commission has issued to CBI countries:

• Enhanced due diligence on all applicants
• Mandatory interviews of all applicants
• In-person collecting of citizenship documents
• Doubled minimum investment thresholds
• No third-party involvement in transfer of funds
• No use of visa-free Schengen for marketing purposes

Saint Kitts & Nevis’ CIU has today issued a press release detailing entirely new terms for its program, which conform almost precisely to the EU’s demands, and which are effective immediately.

At 12 noon local time today, the Kittitian Citizenship by Investment Unit (CIU) issued the release covering what the CIU characterizes as “groundbreaking” and “monumental” changes to the Saint Kitts & Nevis CIP.

Much of the verbiage employed – such as “preserving the privileged status of being a citizen” – shows Saint Kitts & Nevis is making good-faith attempts to comply with EU demands that the “sanctity” of the citizen-country relationship be upheld.

Prime Minister Terrance Drew said his country was today taking “another bold step in reaffirming our intention to not only offer the best Citizenship by Investment Program in the world but also to offer a program held together by a tight regulatory system designed to be a best-in-practice defense mechanism against illicit actors and those who try to bypass our high-end investment and contribution options.”

The mention of attempts to “bypass” the program’s options refers to the widespread practice among promoters of technically unlawful, practically tolerated discounting and financing schemes.

Minimum donation doubles to US$250,000

Replacing the donation-based Sustainable Growth Fund (SGF) option, SISC requires a donation of US$250,000 for a single applicant – double the minimum SGF contribution.

Contribution	SISC (July 2023)	SGF (now defunct)
Single applicant	US$250,000	US$125,000
Applicant + spouse	US$300,000	US$150,000
Family of up to 4	US$350,000	US$170,000
Each additional minor dependent	not specified	US$10,000
Each additional 18+ dependent	not specified	US$25,000

Minimum real estate investment doubles to US$400,000

The press release states that “the minimum amount for investing in the Developer’s Real Estate Option is now US$400,000,” which presumably means the rule that says two investors can invest US$200,000 each no longer applies.

Investors must still maintain the investment for at least seven years, after which the property may be re-sold once to another CBI investor.

Minimum investment for the Approved Private Home (APH) option gets another layer

Investors can henceforth qualify for the program by acquiring APH – a condominium or single-family dwelling – for either

• US$400,000 if buying a condominium from its owner; or
• US$800,000 if buying a single-family dwelling from its owner.

These homes must also be held for at least seven years, but the CBI investor may not sell it onward to another CBI applicant unless it has been subject to “substantial further investment” in the meantime.

Minimum contribution to Approved Public Benefit projects rises from US$175,000 to US$250,000

Those who would qualify for citizenship through the Approved Public Benefit option will now have to contribute US$250,000 rather than the previous US$175,000.

The option, highlights the announcement, “is limited to Approved Public Benefactors who, by their projects, maximize local employment; embark upon programs including transfer of technology and local capacity building; transfer all real estate to the State on substantial completion; and assume all financial risks.”

Mandatory applicant interviews, effective immediately

Whether virtual or in-person, all applicants must henceforth undergo an interview with either the Unit itself or “an independent professional firm commissioned by the CIU.”

Similarly, the CIU said it would commission “independent professional firms in the UK, US, and Europe” to conduct vetting and due diligence on all its applicants, precisely mirroring one of the core demands reportedly set out by the EU.

Certificates of Citizenship must be collected in person

Applicants must now collect Certificates of Registration, the legal document proving citizenship, in person, either in Saint Kitts & Nevis itself or at a designated diplomatic mission abroad. This addition reflects another one of the European Commission’s chief demands.

“Major limitations” on program marketing methods

Though it did not provide details, the announcement remarked that the updated rules would include “major limitations” regarding the advertising methods of program promoters. Presumably, among them is a rule against using visa-free access to Schengen as a selling point, another EU demand.

Other CBI jurisdictions next?

The positive spin notwithstanding, Saint Kitts & Nevis’ new rules do not make the program more attractive to applicants but, rather, represent a defensive move aimed at mollifying EU concerns and, thereby, preserving visa-free travel to the Schengen zone.

Attention will now be focused on whether other Caribbean CBI jurisdictions follow suit. Presumably, Saint Kitts has not made this decision unilaterally or in a vacuum; they would be unlikely to double the asking price in the absence of regional consensus and concert.

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