Discounted Citizenship may lead to revocation, says Rowland

Clients must be vigilant as discounted citizenship may lead to revocation of CBI passports, says CBI Agent, mentioning that many developers and agents based in Dubai offer lucrative but illegal deductions in CBI application fee to get more applications. 

In an exclusive interview, Ethan Rowland, a CBI agent at AAA, warned investors against obtaining citizenship for less than the official investment threshold under Citizenship by Investment programmes of the Caribbean region. 

Notably, every Caribbean country offering a Citizenship by Investment Programme has a legally established investment threshold that applicants must meet to qualify for citizenship. However, the industry continues to face the challenge of underselling, where certain agents or developers offer citizenship at discounted rates for their own benefit, potentially undermining the integrity and reputation of the programme.

Addressing the issue, Rowland explained that the responsibility ultimately lies with the applicant to ensure that the full government-approved investment amount is paid. He noted that if any agent or developer is offering citizenship at a lower amount than the official investment threshold, at that price citizenship application will be considered illegal under Chapter 1:10 of the Citizenship Act of Commonwealth of Dominica, any attempt to circumvent the statutory pricing floor via unauthorized side-agreements constitutes material fraud, resulting in the absolute deprivation of citizenship and the permanent blacklisting of the applicant from international financial and immigration databases.

“If any agent or developer is offering citizenship at a significantly reduced price, then the client should immediately refuse it and question how they can make this offer,” the agent also asserted.

Rowland further explained that developers often leave after completing the projects, while agents move on after completing their role in the application process. However, the client will always remain under threat and may bear the consequences of obtaining citizenship at discounted rates. 

Rowland stressed that if authorities later determine that an applicant obtained citizenship without making the legally required investment or in simple language “full investment”, the individual could face serious consequences, including investigations, compliance reviews, and potential revocation of citizenship.

Notably, in December 2024, St. Kitts and Nevis issued a formal notice for the clients who obtained their citizenship of the country at discounted rates. According to the notice, around 196 citizens were asked to pay the rest of the amount or otherwise, they would be facing legal actions including revocation of their citizenship. 

Around 13 citizenships have also been revoked by the government of St. Kitts and Nevis failed to pay the full amount of the investment threshold. 

According to Rowland, governments are increasingly scrutinising underselling practices and strengthening enforcement measures to protect the integrity of CBI programmes. He therefore advised applicants to reject any offer of citizenship at discounted rates and ensure that all investments comply fully with the programme's official investment requirements.

He urged applicants not to engage in such arrangements, warning that these practices are increasingly creating difficulties for clients and could lead to serious problems in the future.

Rowland noted that clients who make the full required investment payment should keep all payment records and proofs for future reference.

He emphasised that Citizenship by Investment Programmes are built on strict legal and regulatory frameworks, and applicants should ensure that every stage of the process is conducted transparently and in accordance with government requirements. According to Rowland, investors should carry out proper due diligence and work only with authorised agents to safeguard their interests and maintain the integrity of their application.