Dominica Bans Syrians, Kurds from Applying for Citizenship by Investment Program

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With immediate effect as of last week, Syrians and nationals from “Northern Iraq” are restricted from applying to Dominica’s citizenship by investment program, according to a statement on the Dominica CIU’s website. The CIU did not provide further details as to what motivated the ban.

“Northern Iraq”, in this case, is a diplomatic euphemism for Iraqi Kurdistan, as evidenced by the CIU’s statement, which mentions a number Kurdish-administered cities specifically:

[…]This includes specific nationals from the Kurdistan region of Iraq, namely nationals from the cities of Erbil, Amedi, Dahuk, Kirkuk, Lalish, Raniya, Soran, Sulaymaniyah and Zakho.

While excluding nationals from a sub-national polity is unorthodox, it is not entirely without precedent in the CBI market; In 2018, Dominica barred individuals from Chechnya, which is formally part of Russia, from applying. That restriction was later removed but, as of March this year, Chechens are once again ineligible for Dominica citizenship by investment; this time, not for being Chechens specifically but by virtue of their Russian nationality.

Define “Kurd”

While the citizenships of particular individuals are readily determined, defining their origins at the sub-national level is a more knotty proposition; For example, will an investor born in Erbil (Kurdistan’s regional capital) but raised in Baghdad now be precluded from applying for Dominica citizenship? Industry practitioners will require more precise guidance from Dominica’s CIU.

In addition to Syrians and Kurds, nationals of Russia and Belarus are also banned outright from the Dominica CIP, while those of North Korea and Sudan (but not South-Sudan) will only be considered if such persons

• have not lived in these countries for the last 10 years;
• have no substantial assets there; and
• are not performing and have not performed any business or similar activity, in whole or in part, in or with these countries.

Citizens of Iran, who until recently featured on Dominica’s banned nationalities list, are no longer barred from applying.

See our complete overview of each CBI country’s nationalities lists here.

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