Dominica and St Kitts and Nevis raises economic citizenship industry standards

The Citizenship by Investment Programmes of Dominica and St Kitts and Nevis are two of the oldest, most respected programmes in the industry breaking and are widely known for their commitment to conducting stringent due diligence.

The CBI Index, a publication by the Financial Times’ Professional Wealth Management magazine, has awarded Dominica and St Kitts and Nevis with a perfect score for due diligence every year since its inception in 2017. But what makes the applicant vetting process under these two Programmes so robust?

A Multi-Tiered Approach

Due diligence in Dominica and St Kitts and Nevis follows a multi-tiered structure.

The process begins with the Programmes’ agents, who are responsible for submitting applications for citizenship on behalf of applicants (known as Authorised Agents in Dominica and Authorised Persons in St Kitts and Nevis). Agents are expected to conduct know-your-client checks on all applicants, including through the use of databases such as World Check.

Agents then submit applications to the relevant Citizenship by Investment Unit. In Dominica and St Kitts and Nevis, the Citizenship by Investment Unit is the body responsible for assessing applications for citizenship. The Units ensure the performance of both internal and external due diligence on both the main applicant and all dependents under an application.
Internal due diligence is carried out by Unit staff made up of experts in document review, anti-money laundering, and counter-terrorism financing.

Additionally, external due diligence is carried out by one or more of the Units’ mandated, independent due diligence firms. Such firms are top-tier, international firms based in countries such as the United Kingdom and the United States. These firms conduct in-depth, on-the-ground research to verify every piece of information provided in an application. They are experts in establishing an individual’s character, business profile, source of funds, criminal background, and potential political exposure.

Applications are also checked against the databases of regional and international law enforcement agencies, including the Joint Regional Communications Centre and Interpol.

The Citizenship by Investment Units of Dominica and St Kitts and Nevis will not make a decision in relation to an application until they have received the external due diligence report. Further, the Units will decline an application if a red flag is raised in relation to any individual included in that application.

Interestingly, the due diligence process do not only involve the main applicant, but all the dependents under the Citizenship including spouse, children, parents or any other eligible person will have to undergo a thorough due diligence processing for stronger future security.

Additional Safeguards

The Citizenship by Investment Programmes of Dominica and St Kitts and Nevis also implement additional safeguards to ensure that only investors of the highest calibre can obtain citizenship.

Such safeguards include banning certain nationalities from applying to the Programmes altogether, in recognition of the fact that it is difficult to perform adequate on-the-ground due diligence in these countries.

Moreover, both Programmes prohibit applications from persons who have been denied a visa to a nation with which the relevant country has signed a visa-free agreement. This ensures the protection of citizens of the two countries, as well as the protection of partner nations.

An Example to Follow

Due diligence has often been called the ‘cornerstone’ of the citizenship by investment industry insofar as it ensures the protection of the international community, and it is therefore no surprise that Dominica and St Kitts and Nevis remain at the forefront of the industry. Their robust vetting procedures have raised the bar extremely high for citizenship by investment programmes across the world, and it is time that all such programmes followed the stellar example set by Dominica and St Kitts and Nevis.

Published: 14 October 2020 

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