In Cryptic Circular, Antigua & Barbuda CIU Re-Suspends Applications from Russians

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On March 4th, Antigua & Barbuda’s Citizenship by Investment Unit (CIU) temporarily suspended the receipt of citizenship by investment program applications from Russians, Belarusians, and – notably – Ukrainians, citing an inability to carry out adequate due diligence in the countries in question.

Some four months later, on July 8th, Antigua & Barbuda re-opened for applicants from Russia and Belarus, though not for those from Ukraine, again citing an inability to conduct vetting in the war-ravaged country.

In a circular to stakeholders issued yesterday, however, the Antigua & Barbuda CIU advises that [emphasis ours]:

[…] effective 28th July 2022, the receipt and processing of applications from Russian and Belarusian nationals under the Citizenship by Investment Programme has been suspended, notwithstanding its previous policy decision as communicated in the Unit’s Memorandum dated 8th July 2022.”

The government remains committed to operating the Programme with the highest level of transparency and integrity while upholding its international obligations.

The ability to conduct investigations in Ukraine remains constrained. Therefore, until otherwise advised, the Unit remains unable to process applications from Ukrainian nationals.

Antigua and Barbuda will continue to monitor the developments resulting from Russia’s invasion of Ukraine.

In brief, Russian and Belarusian applicants are now, once again, excluded from the program. Ukrainians also remain excluded, as they have been without interruption since March.

The CIU did not provide any explanation for why the policy would have retroactive effect going back to July 28th (the policy change was only published yesterday), nor which circumstances of the ongoing war in Eastern Europe have changed since its July 8th decision to motivate this most recent policy-reversal.

Note also that while the CIU points to its inability to carry out due diligence in Ukraine as its reason for suspending that country, it does not offer the same explanation (nor, indeed, any explanation) for its decision to suspend Russians and Belarusians. Whereas the exclusion of Ukrainians is prompted by practical limitations, the inclusion of the phrase “upholding its international obligations” intimate that political considerations may have informed the decision to suspend Russian and Belarusian applicants.

More on Caribbean CIP suspensions of Russians and Belarusians: