Commonwealth of Dominica: The Commonwealth of Dominica Enhances Security and Management of the Citizenship by Investment Programme

Source: financialpost.com

Published: 29 August 2023

The Commonwealth of Dominica has taken significant steps to bolster the security and management protocols for its Citizenship by Investment Programme, aimed at fortifying the integrity and longevity of the programme. 

Dr. Roosevelt Skerrit, the Prime Minister of Dominica, has been collaborating closely with various stakeholders, including international consultants, to conduct a comprehensive audit of the investment migration programme. Building on an initial audit undertaken last year by a UK consulting firm, the government has been actively implementing new and improved processes through the Citizenship by Investment Unit. 

During his recent Budget Speech, the Prime Minister unveiled plans to enlist a globally vetted management consulting firm to oversee the overall operations and management of the Citizenship by Investment Programme. While Dominica already boasts a proactive due diligence process, the government is committed to its further reinforcement, vowing “to leave no stone unturned to strengthen it.” 

“We take this matter very seriously and will increase our efforts in showcasing our robust due diligence and risk mitigation efforts on all fronts.” the Prime Minister affirmed. 

Over the past 18 months, the Government of Dominica has undertaken several measures to elevate the security of its investment migration programme. 

A United States-based firm has already conducted anti-money laundering and counter-terrorism financing training for all Citizenship by Investment Unit staff as the Unit undergoes restructuring. The CBIU was restructured under the supervision of an expert compliance officer to ensure that all procedures were updated, quality control measures strictly followed, and all IT systems upgraded. 

The government made a bold move at the start of the year, giving notice of its intent to revoke the citizenship of those who made false declarations or misrepresentations in their applications, particularly relating to previous visa rejections from countries with which Dominica has visa-free treaties. 

Dominica has also introduced biometric travel documents and updated its naturalisation certificate, enhancing its security features. 

Citizens of the Kurdistan region in Iraq, Russia and Belarus do not qualify for citizenship in Dominica as international security authorities have flagged the regions as high risk. Moreover, the government introduced legislation providing an enhanced due diligence fee for applicants from specific countries. This enhanced due diligence fee offers the government additional resources to thoroughly scrutinise applicants from these countries. 

The country also issued regulations to restrict citizens from changing their names. 

Dominica has distinguished itself as the first Caribbean country to implement mandatory interviews as part of the citizenship by investment application process – a requirement agreed upon with the United States at a roundtable earlier this year. 

“We also devised a new rigorous risk assessment and hired firms from the United States and the United Kingdom to begin interviews with all CBI applicants,” Prime Minister Skerrit said in the Parliament. 

In addition to international firms in the US and UK conducting due diligence checks, Dominica’s Financial Intelligence Unit will also assist with the due diligence process. This includes reporting rejected applicants to the JRCC monthly and permitting the JRCC to share that information with the other CBI jurisdictions in the OECS. 

Dominica is leading discussions in the region to collaborate on safeguarding the citizenship by investment industry; and has taken measures to emphasise its dedication to cooperating with global stakeholders and enhance the due diligence process to reduce threats from illicit actors.  

In addition to these recent changes, new risk mitigation actions include: 

  • Thorough assessment and reduction of the number of agents and promoters of the country’s Citizenship by Investment Programme, who will be strictly monitored, along with developers, to ensure compliance with current regulations governing the advertisement of Dominica’s Citizenship by Investment Programme.
  • Strict enforcement of regulated citizenship fees to prevent any undercutting.
  • Strengthening of policies and legislation to maintain competitiveness and alignment with international best practices.

Dominica’s rigorous due diligence and vetting processes make it extremely difficult for any illicit individual to qualify for citizenship. Background checks occur on the ground where the applicant lives and works, via online databases and now in person. 

The Prime Minister has reiterated that Dominica will maintain robust due diligence processes to ensure the country meets international standards and alleviates any security concerns. 

“We have fresh impetus to go back and relook where we can do even better in giving our international counterparts confidence in our security measures – which are already some of the most robust in the world compared to other jurisdictions,” he said. 

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