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By Jason Haynes, PhD
In May of this year, I made the argument that St Vincent and the Grenadines should strenuously pursue a well-regulated Citizenship-By-Investment (CBI) programme as a means of diversifying our struggling economy. In that piece, I argued that pursuing a CBI programme will not only bring tangible economic benefits but will also align our economic policy on this issue with that of other progressive independent Eastern Caribbean countries. I further contended that CBI is part of our thrust towards post-colonial liberation; in the absence of reparations for the transatlantic slave trade, we must pursue imaginative strategies to bolster our economies, as we are on our own in this increasingly polarised geopolitical environment. No one is coming to save us. We must save ourselves.
In this piece, I turn my attention to some of the key facts about CBI which should provide readers on either side of the political spectrum with an empirical base for evaluating the efficacy of CBI as an aspect (though not by any means the sole aspect) of our thrust towards a diversified economic portfolio.
At present, St Vincent and the Grenadines is the only independent Eastern Caribbean country that does not have a CBI programme. In respect of Antigua and Barbuda, Dominica, Grenada, St Lucia and St Kitts and Nevis, which all have CBI programmes, the IMF recently reported that “over the past decade, the CBI programs have become an important source of government revenue in the ECCU. Although globally a niche market, the scale of the investment flows can be substantial to small island state governments. For the five ECCU members with existing programs, government CBI revenue averaged 6½ percent of GDP between 2019 and 2023 and increased to nearly a third of total non-grant revenue in 2023. These funds have primarily financed public capital investment, but the level of budget dependency on CBI revenue varies considerably among the individual members.”
Facts and Figures
Antigua and Barbuda
Prime Minister Gaston Browne, in his 2023 budget presentation, reported that “receipts from the Citizenship by Investment programme accounted for nearly 60 per cent of non-tax revenue and amounted to EC $88.8 million” (i.e. USD $32,857,856). The ECCBreported that in 2022, CBI revenues were EC $68.7 million (i.e. USD $ 25,420,436).
The majority of applicants were from the following countries:
2023
1) Nigeria – 16.71%
2) China, Turkey, Lebanon – 23.60%
3) USA – 10.30%
4) Russia – 3.10%
2024:
1) China, Turkey, Lebanon – 24.90%
2) Nigeria – 9.07%
3) USA – 10.96%
There have also been a number of applicants from the United Kingdom, India, Ghana, France, Switzerland, Germany, and Canada.
Dominica
The IMF reported that CBI accounted for 36.6% ofDominica’s GDP in 2022 (EC$599.40 million or US$222.00 million) and 18.0% of GDP in 2023 (EC$317.84 million or US$117.72 million). The IMF further reported that “annual real growth is projected to average 4.4 during 2024-25, supported by investments in key large infrastructure projects mainly financed by CBI—including the geothermal plant, a new international airport, and a variety of climate-resilient infrastructure and hotel projects—which are expected to also boost tourism’s growth contribution and lead to a further improvement in the current account balance.”
While Dominica has not published data on the home countries from which applicants originate, a Guardian Newspaper report, which identifies a number of loopholes in Dominica’s CBI programme, estimates that many of the applicants have been from Russia, Afghanistan and Turkey. Dominica, however, has since announced that it has either banned or suspended applications from nationals from Belarus, Russia, Northern Iraq, Yemen, North Korea and Sudan.
Grenada
Investment Migration Agency (IMA) Grenada has reported that Grenada’s CBI programme generated EC$ 493,728,392.76 or US$ 183,739,000 in revenue in 2024, and EC$ 44,239,159 or US$ 16,450,000 in 2025 (thus far). Most of the applications have been in respect of the National Transformation Fund and real estate (government contribution for approved projects).
In 2023, most of the CBI applications were received from:
1) China – 51%
2) Nigeria – 18%
3) Russia / ex-USSR region (mainly Ukraine + other) – 6%
4) India – 5%
5) USA – 3%
2024:
1) China – 24.4%
2) Nigeria – 23.8%
3) USA – 5.9%
4) Ukraine – 5.9%
5) Lebanon – 4.3%
2025 (thus far):
1) Uzbekistan 10%
2) Uganda 9%
3) Saudi Arabia 6%
4) Philippines 4%
5) South Africa 4%
St Kitts and Nevis
The IMF has reported that, in 2023, CBI revenue amounted to 22 percent of St Kitts and Nevis’ 2023 GDP (EC$ 634.5 million or US$234.9 million. Meanwhile, in 2024, CBI revenue accounted for 8 percent of the 2024 GDP (EC$ 241.4 million or US$89.4 million). While there is no information on the countries from which most applicants originate, the CEO of the Citizenship By Investment Unit (CIU), Michael Martin, has explained that “There have been Small Business Development Programmes that were done through the SIDF (Sugar Industry Diversification Fund), which was a CBI Programme, where Small Business Owners were trained [on] how to set up a business, how to run it, how to keep it running and quite a number of them are still in business.” He further explained that the Government of St. Kitts and Nevis introduced a CBI dividend whereby citizens and residents received a share of the profits and retained earnings received from the Citizenship by Investment Programme, facilitated through the St. Christopher and Nevis Social Security Board (some received EC $250.00 and others EC $500.00).
St Lucia
The Chairman (Julian Charles) of the Citizenship by Investment Programme of Saint Lucia recently reported that the total CBI revenue received by St Lucia for the period 2023/2024 was EC$240.3M (89.0M USD), exceeding the 2022/2023 revenue of EC$60.6M (22.4M USD) by EC$179.6M (66.5M USD) or 296%. A significant portion of this revenue was pumped into the Chaussee Road Rehabilitation Project.
Most of the applications in 2023/2024 were received from nationals from:
1) Middle East and North Africa – 58.15%
2) China, Hong Kong, and Taiwan – 26.93%
3) Africa – 6.86%
4) Southeast Asia – 3.43%
5) Canada, United States, and United Kingdom – 2.74%
6) Europe 1.37%
The views of economic/geopolitical agencies
The IMF has cautioned that “investor demand in [the CBI]market can be highly unpredictable, especially as the programs have come under increased international scrutiny… there is a need for ongoing regional efforts to reduce the CBI programs’ risk susceptibility as well as to strengthen management of residual risks, including through: (i) clearer provisions for CBI revenues’ budget use to mitigate fiscal risks; and (ii) enhanced transparency standards and ex-post assessments of CBI projects to inform regional best practices, assessments of the program’s systemic significance, and development of contingency plans.” The IMF report, however, goes on to note that “CBI programs appear to have become an increasingly important source of FDI and foreign exchange in the ECCU. Staff estimates suggest the total 2023 CBI inflows may have amounted to around a fifth of the union’s GDP (approximately US$700–800 million per year), far exceeding recorded government revenue. This scale suggests a substantial contribution to private construction and tourism development, though high import-content may temper their GDP growth impact.”
While the European Commission (an organ of the European Union) has cautioned that the “investor citizenship schemes cannot be zero-security-risk”, it has nevertheless acknowledged “the economic and political importance of those schemes for the five [Eastern Caribbean] countries.” To this end, “the Commission has continued the engagement with the five countries, at both political and technical level. On 12 January 2024, the Commission held a high-level meeting with the Prime Ministers of the five countries, which was followed by a technical fact-finding mission of the Commission services to the region in January 2024 and exchanges of information in writing.” It goes on to note that “over the past months all five countries have showed an increased awareness of the need to strengthen their due diligence and security screening systems, and openness to substantial improvements with the support of their international partners. In particular, inthe first months of 2024, the five countries signed a Memorandum of understanding providing a framework for cooperation to strengthen the security of their schemes.” The Commission concludes that it will “continue to work in close cooperation with the five Eastern Caribbean countries and assess the implementation of the above-mentioned reforms, under the current legal framework of Article 8(2)(d) of the Visa Regulation that provides for the triggering of the visa suspension mechanism in cases of an increased risk or imminent threat to the public policy or internal security of Member States.”
Finally, the Eastern Caribbean Central Bank recently committed to continue to work with “the Citizenship by Investment Programmes (CIP/CBI) Technical Group and stakeholders to advance the cause of the Programmes in the ECCU …. given the significance of the Programmes to the survival of the economies of the ECCU.”
To date, several high-level meetings have been held. For example, the Inaugural US-Caribbean Roundtable resulted in the signing of an agreement on six principles between the USA and the five CBI countries in February 2023 in St. Kitts and Nevis. These principles are as follows:
1) Shared denial records: the countries will exchange information about rejected applicants and refuse to process anyone previously denied citizenship by another participating country.
2) Mandatory interviews: all citizenship applicants must participate in either face-to-face or video interviews as part of the application process.
3) Financial intelligence screening: every application will undergo mandatory screening by the country’s Financial Intelligence Unit to detect money laundering or financial crimes.
4) Regular program reviews: each CBI program must undergo independent audits meeting international standards at least once every two years.
5) Passport Recovery Protocol: countries will work with law enforcement agencies to physically recover citizenship documents that have been cancelled or revoked.
6) Russian/Belarusian suspension: all participating nations agreed to stop accepting new applications from Russian and Belarusian nationals, with Grenada implementing this suspension by March 31, 2023.
A subsequent meeting with US officials was held in October 2023, followed by a meeting with EU officials in January 2024; another roundtable with the USA, UK and EU in August 2024; and another roundtable with the UK, USA and EU in January 2025.
Emanating from these meetings have been commitments to introduce a minimum price of US$200,000 per applicant for all CBI programmes, as well as the establishment and funding of the Regional CBI Regulator. A draft Bill has since been produced. Each country will now enact the Bill in their domestic laws as an Act of their respective parliaments,paving the way for a harmonised approach to assessing CBI applications. The Bill provides for the following:
• The Eastern Caribbean Citizenship by Investment Regulatory Authority (EC CIRA) will be established for the purpose of regulating and maintaining public confidence in the CBI programmes in the participating states. Among other things, it will develop international standards and best practices, regulate authorised agents, and take action to deter deceptive, fraudulent and unethical conduct.
• The Minister responsible for CBI of each of the participating states will be required to present a copy of an annual report in their respective Parliaments to enable public scrutiny of CBI activities during the preceding fiscal year.
• The Regulator will have the power to issue aprequalification certificate that would authorise agents to apply to the CBI programmes. None of the participating states will be able to accept an application made by an unauthorised agent.
• There will be a standardised approach across all participating states with respect to minimum eligibility criteria for applicants; prohibited categories of applicants, including persons under national, regional and international sanctions or watchlists; disqualifying circumstances, including prior convictions, or incomplete disclosure; certified identification and travel documents; police clearance certificates from all relevant jurisdictions; financial statements and verifiable proof of the lawful source and transfer of funds; declaration of tax residence, tax status and compliance statement; and medical certificates and declarations of dependants.
• There will be a maximum number of applicants who may be granted citizenship by investment in each participating state in any financial year, based on an annual assessment of global demand, economic impact, national absorptive capacity and reputational risk.
• An in-person interview will be conducted with all applicants.
• An applicant to whom citizenship is to be granted will be required to commit to establishing a genuine and effective link to the participating state through the fulfilment of residency and integration obligations. For example, being physically present within the territory of the participating state for an aggregate of at least thirty days during or up to any of the first five calendar years after the date of the grant of the certificate of citizenship or naturalisation; participating in mandatory integration programmes (civic education, including knowledge of the laws, history and constitutional principles of the participating state); and cultural orientation or community service engagement.
• The CBI Unit of each participating state will ensure that a comprehensive due diligence review and risk-based screening is conducted in respect of each applicant and each dependant. In conducting the background checks, the Unit will consult with national, regional and international law enforcement agencies; relevant national, regional and international regulatory and intelligence bodies; national Financial Intelligence Unit;CARICOM Implementation Agency for Crime and Security (CARICOM IMPACS) and The Joint Regional Communications Centre (JRCC); and international databases and watchlists.
To conclude, Eastern Caribbean CBI programs have proven to be significant economic drivers, contributing between 6.5% to 37% of GDP across the five Eastern Caribbean countries, and funding critical infrastructure, climate resilience projects, and social programmes. The programme attracts a globally diverse applicant base, including increasing (and substantial) interest from Western democracies such as the United States (10-11%), Canada, and European nations, demonstrating that their appeal extends far beyond Russia and China. International partners, including the US, UK, and EU, while maintaining scrutiny, have engaged constructively rather than demanding the elimination of CBI programmes. Their focus has been on working collaboratively to strengthen due diligence and security protocols. The establishment of the Eastern Caribbean Citizenship by Investment Regulatory Authority (EC CIRA), the draft legislation, and implementation of standardized vetting procedures, mandatory interviews, and enhanced transparency measures address integrity concerns while preserving program viability. As St Vincent and the Grenadines remains the only independent Eastern Caribbean nation without a CBI program, the evidence suggests a well-regulated scheme could provide essential economic diversification while meeting international security standards.
Dr *Jason Haynes is a barrister-at-law and solicitor and associate professor of law, University of Birmingham, UK. He is a national scholar, British Chevening Scholar, and Commonwealth scholar. He is author of the forthcoming textbook with Routledge, UK, International Investment Law in the Commonwealth Caribbean.
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