Round Table by five OECS nations: Transparency and Better practices regarding Citizenship by Investment

The Organisation of Eastern Caribbean States (OECS) has put forth the Memorandum of Agreement (MOA) for the five countries with the CBI Programmes. The MOA was published in March 2024, with the aim to assure adherence to common practicing standards and for information sharing.

Regarding the MOA, all the countries involved, agreed to a minimum price of US $200,000 to be obtained under the donation option and the same shall be effective from July 01, 2024. The Agreement also stated that the minimum sum to be paid into any government fund, government project or private development project regarding the participating countries shall be equivalent to or more than US $200,000.

The Citizenship by Investment (CBI) scheme was emphasized to promote a pathway for individuals of foreign countries to grab the opportunity to obtain citizenship rights for the OECS countries in return of a subsequent investment into the country.

The five countries of the OECS to sign the MOA include Saint Kitts and Nevis, Dominica, Antigua and Barbuda, Grenada and Saint Lucia. The MOA was put into play to solve the issue of varying requirements in terms of investments practiced in different countries and to propose an agreement to a common ground for the same.

Operating with deferred investment requirements did lead to an inconsistency in the commitments in terms of finances at the applicants’ side. Subsequently, this turned into a pricing war which further resulted in the industry ‘to race to the bottom’. It also raised concerns amongst the applicants regarding the programmes’ credibility.

The primary aim for the agreement was to increase transparency and ensure collaboration to tackle the problem of cost-cutting. It was made perfectly clear to the signatories of the MOA that discounting or accepting any amount below the agreed minimum price would be considered illegal.

Apart from the regional regulatory body, the Governments participating in the agreement will appoint a 7-member Interim Regulatory Commission to carry out certain functions like develop and enforce regional standards for the CBI Programmes, monitor compliance of legislation, investigate complaints, and so on.

Country wise update of the price decided, and amendments made:

Saint Kitts and Nevis acted as the pioneer for the agreement by amending the prices in July, last year and also was the one to push forward the other member states to sign the MOA and enhance the effectiveness of the CBI programmes deciding some common practices.

The Island of Saint Kitts and Nevis has set an amount of US $250,000 for single applicants and an amount of US $350,000 for the primary applicant along with up to three dependents. For additional applicants under 18 years of age, US $50,000 and for the 18+, US $75,000 will be applicable per applicant.

For the real estate sector, the investment option for the CBI Programme has been decided to be US $400,000, the highest among all the five member Islands.

The government is to impose a charge of US $25,000 for the main applicant, US $15,000 for the spouse and as for the dependents, US $10,000 for the one below 18 years and US $15,000 for the 18+.

Dominica, another member state of OECS has also issued the new Regulations which reveals that the minimum investment threshold for the single applicant has been increased to US $200,000 which earlier was US $100,000.

An amount of US $250,000 has been decided for the applicant with up to three dependents by the Dominica CBI unit. As for the additional dependents, an amount of US $25,000 for the ones below 18 years and US $40,000 for the 18+ has been decided.

The CBI amounts to US $200,000 for the real estate investment. The government fees for the single applicant will sum up to US $75,000 and for the applicants with dependents will be US $100,000.

Grenada was the first member Island to issue the new Gazetted Regulations that stated the donation options for investment as follows-

Single Applicants – US $235,000.

Applicants with up to three dependents – US $235,000.

For additional dependents,

With additional child/ parents aged 55+ – US $25,000.

With parents aged below 55 – US $50,000.

In the same scenario, applicants with siblings will have to contribute a sum of US $75,000 to qualify for the Citizenship of Grenada.

For the real estate sector, the investment amount is decided to be US $350,000 while for a minimum of two investors, US $27,000 is to be paid per investor.

Additional government fee will be US $50,000 for the applicants with up to three dependents while a contribution of US $25,000 has been set for additional parents of age 55+ and US $50,000 for parents under the age of 55. US $75,000 will be charged for the applicants with siblings.

Antigua and Barbuda have also issued the Regulations regarding the Memorandum and the amounts declared are-

Single Applicants – US $230,000.

Applicants with up to three dependents – US $230,000.

Applicants with a family of five or more – US $245,000.

Processing fee for a family of four – US $30,000.

Processing fee for applicants with additional dependents – US $10,000.

For the real estate sector, the minimum investment threshold has been set as US $325,000 and the government fee has been decided for family of four as US $30,000 and for that of applicants with additional dependents as US $10,000.

Saint Lucia was the last member country to sign the MOA. Its Regulations state the minimum amounts decided for the varying applicants as-

Single Applicants – US $240,000.

Applicants with up to three dependents – US $240,000.

For additional dependents,

With age below 18 – US $10,000.

With age of 18+ – US $20,000.

The CBI amounts to US $300,000 for the real estate investment. The government fees for the single applicant will sum up to US $30,000 and for the applicants with spouse will be US $45,000. As for the dependents under the age of 18 the fees will be US $5000 and for those with age 18 or more will be charged US $10,000.

Saint Lucia has approved the Enterprise options at US $250,000. Besides that, the National Action Bond that was previously set at US $300,000 will remain unchanged.

All the five signatory countries will have to abide by the amendments made and shall bring the Agreement in effect from July 1, 2024. All the mentioned Amendments and Regulations put forward by the member states are focused on best practise of information sharing and enhancing the credibility and integrity of the Citizenship by Investment Programmes.