Due Diligence Checks for Caribbean Citizenship by Investment

Importance of Due Diligence Checks in Citizenship by Investment

The aim of an applicant is to become a citizen of the relevant Citizenship by Investment Country. As such, the government of the country has an obligation to its citizens to ensure that the applicant is appropriate and does not represent a threat to the country’s safety and security and won’t represent a burden on state resources (in particular the health care system). 

To ensure these objectives are met, the relevant government will seek to:

• verify the applicant’s identity;
• assess the applicant’s financial background and stability;
• assess the applicant’s state of health;
• determine any criminal history;
• prevent fraud and money laundering; and
• ensure compliance with legal and regulatory standards.

Given that one of the main attractions of a second citizenship is visa-free access to other countries, the Citizenship by Investment Country also has an obligation to such countries to ensure that the applicant is suitable. 

The process is necessarily rigorous for these reasons. If the process is found to be flawed and unsuitable applicants are granted citizenship, this will impact the credibility of and support for the programmes: 

• locally in the relevant Citizenship by Investment Country;
• from the countries that grant visa-free access to holders of that passport, which may then be revoked; and
• from future applicants and the global community in general.

All five Citizenship by Investment Countries have strengthened their due diligence check in recent years and they are largely aligned in terms of the details required. 

Of course, as you will also become a citizen of the chosen Citizenship by Investment Country, you also have an interest in ensuring that other applicants are suitably vetted.

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What is Due Diligence? Key Components

In the context of citizenship by investment, due diligence is the process of interrogating an applicant’s status and background to ensure that the applicant meets the requirements for security and safety as set out in the relevant CBI programme, won’t represent a burden to the country (hence the health check), and is suitable to become a citizen.

Each programme is slightly different, but it is common to all programmes that the due diligence process is extremely thorough.

The due diligence check will analyse the following areas with examples of the types of checks that will likely be carried out:

• Security: background and criminal record checks and a risk assessment;
• Financial: source of funds, bankruptcy, anti-money laundering (AML) compliance, sanctions, terrorism financing;
• Political: any relationship to politically exposed persons (PEPS), political affiliations and other connections to political interests.

The Due Diligence Process for Applicants

The due diligence check is similar across the Caribbean CBI programmes, as they are similar and the objectives are common.

The Caribbean Citizenship by Investment Countries implemented enhanced due diligence procedures in their US and EU agreements. This process included potential interviews.

To carry out the due diligence check, the Citizenship by Investment Country government will request information from the applicant. Such information will include:

• proof of identity;
• proof of residential address;
• police certificate from the home country;
• bank statements and letters and other source of funds information;
• tax returns;
• confirmation of health status,

and any other documentation that the government deems necessary to determine the applicant's suitability. An applicant may be called to interview (remotely) to further explain any matters not fully covered by the documentary due diligence.

The government will review the provided documents, utilize local sources such as intelligence agencies and local law enforcement, and seek information from non-local sources such as foreign banks and foreign law enforcement and intelligence agencies.

Many applicants will have carried out similar procedures in their lives, such as opening a bank account or making an investment. The due diligence check for citizenship by investment will be similar to such processes but considerably more extensive.

Providing comprehensive and accurate documentation in support of your application is essential:

• to complete the process and become approved for citizenship; 
• to smooth the path to a timely completion of the process; and
• as citizenship is granted based on due diligence, if an applicant does not complete the process correctly (for example, by providing false or misleading information), this failure can lead to subsequent revocation of citizenship and potential legal (including criminal) action against the applicant.

This last comment is particularly pertinent as citizenship has been revoked on the basis of incorrect or misleading due diligence provided in at least three countries (Malta (5), Bulgaria (17) and Cyprus (over 200)), showing that this is a real likelihood and not just an empty threat. 

If an applicant has any concerns that the due diligence check may uncover something that may affect their application, it is vital that he/she does not seek to hide this. Your agent will be able to discuss this with you and determine whether it is in fact an issue of relevance and help you deal with it accordingly. For example, a speeding ticket is highly unlikely to affect your application.

Once appropriate documentation has been provided, the government agency responsible for the process will carry out its own research, as explained above, and either approve or reject your application.

Caribbean Citizenship by Investment Due Diligence Requirements

The documentary requirements for the five citizenship by investment countries are very similar, not least as a result of an agreement between them to harmonise the process across the region. However, they do vary slightly. Below are lists of the documentary requirements for each, although the relevant CBI unit may ask for further or more detailed information as it sees fit to determine eligibility. 

The five Caribbean Citizenship by Investment Countries have strengthened their due diligence checks in recent years and they are largely aligned in terms of the details required. The five countries also have agreed not to accept applicants who have been denied citizenship of any of any of them. They have agreed to share information on denials to ensure that this objective is met and applicants do not seek to exploit any differences in the due diligence checks carried out in each country.

The requirements other than the financial checks generally apply to the main applicant and all family members applying alongside the main applicant unless otherwise stated.

Antigua and Barbuda Due Diligence Requirements

Antigua and Barbuda Citizenship by Investment programme imposes fees of US$ 7,500 for the main applicant and spouse, US$ 2,000 for dependents aged 12-17 and US$ 4,000 for dependents aged 18+ and requires an online interview at a cost of US$ 1,500. Nationals of Afghanistan, Iran, North Korea, Somalia, Sudan, or Yemen must have left these countries before the age of majority and/or permanently resided elsewhere for at least 10 years and have no economic connections with these countries.

The documents required are:

• Certified colour copy of current passport(s).
• Certified colour copy of national ID card.
• Birth certificate: Original or certified copy.
• Marriage or divorce certificates: As applicable.
• Proof of address: Utility bill or other document showing residential address.
• Police certificate: Original police certificate for the applicant’s home country and countries where the applicant has lived for more than six months over the last 10 years.
• Medical certificate: Including original results of an HIV test dated within the last three months for all applicants.
• Bank statements: Covering the last 12 months.
• Source of funds documents: Employment letters, pay slips and or tax returns verifying occupation and earnings.

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Dominica Due Diligence Requirements

Dominica Citizenship by Investment programme imposes fees of US$ 7,500 for the main applicant and US$ 4,000 for any spouse and dependents applying alongside the main applicant and requires an online interview at a cost of US$ 1,000. If you’ve been denied citizenship in any country or been refused a visa to the EU, UK, USA or Canada, or anywhere Dominica has a visa-free arrangement with, you are ineligible as an applicant. Applicants from Belarus, Northern Iraq, Russia, and Yemen are not eligible and if you come from either North Korea or Sudan, you must not: have lived there for 10 years; done business there; or retain assets there. Although Iranian applicants (by citizenship or domicile) may apply, they will be subject to enhanced due diligence at an increased cost.

The documents required are:

• Certified colour copy of current passport(s).
• Colour copies of all IDs.
• Certified copy of birth certificate.
• Marriage or divorce certificates: As applicable.
• Colour copy of driving licence: As applicable. 
• Proof of address: Document such as a utility bill proving the applicant's residential address.
• Bank statements: Covering the last 12 months.
• Source of funds documents: Employment letters, pay slips, or tax returns verifying occupation and earnings.
• Police certificate: From country of birth, country of citizenship, country of residence, and any country where the applicant and dependants (16 and above) have lived for longer than 6 months in the past 10 years.
• Medical health certificate.
• HIV test results: For main applicant and dependants aged 12+.

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Grenada Due Diligence Requirements

Grenada Citizenship by Investment due diligence fees are US$ 6,000 (including an online interview fee of US$ 1,000) for each applicant over the age of 17. Nationals of Belarus, Iran, North Korea are not eligible for citizenship and applications will not be processed.

The documents required are:

• Certified colour copy of passport(s).
• Colour copy of national ID or social security card: If applicable.
• Birth certificate: Certified copy including parents’ details.
• Proof of name change: Certified copy if applicable.
• Marriage or divorce certificates: As applicable.
• Proof of address: Utility bill or other document proving residential address.
• Source of funds documents: Employment letters, pay slips, or tax returns verifying occupation and earnings.
• Bank statements: covering the last 12 months.
• Military service card: Copy if applicable.
• Education certificates and transcripts.
• CV: Detailed curriculum vitae.
• Professional reference letter: Recent and relevant.
• Bank reference letter: Recent and from a recognised institution.
• Police Certificate: From the applicant’s home country and any country where the applicant resided for more than six months in the last decade.
• Medical health certificate.

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St. Kitts and Nevis Due Diligence Requirements

Due diligence fees in St Kitts and Nevis Citizenship by Investment Programme are US$ 7,500 for the main applicant and US$ 4,000 for any spouse and dependent applying alongside the main applicant and require an online interview at a cost of US$ 1,000. If you’ve been denied citizenship in any country or been refused entry or a visa to any country that St Kitts and Nevis has a visa-free arrangement with, you are ineligible as an applicant. Applicants from Afghanistan, Belarus, Iran, North Korea, Northern Iraq or Russia are not accepted.

• Certified colour copy of passport(s): Current passport for all applicants.
• Proof of name change: Certified copy if applicable.
• Certified colour copy of ID Card: If applicable.
• Marriage or divorce certificates: As applicable.
• Birth certificate: Certified copy.
• Police certificate: Original from country of citizenship, country of residence, and any country where applicant and dependants (16 and above) have lived for longer than 6 months in the past 10 years.
• Military records: Certified copy or exemption from military service, if applicable.
• Proof of address: Utility bill or other document proving residential address. 
• Source of funds documents: Employment letters, pay slips, or tax returns verifying occupation and earnings.
• Bank statement: Recent bank statement 
• Bank reference letter: Original, not older than six months.
• Professional reference letter: Original, not older than six months.
• Education certificates and transcripts.
• Medical Health Certificate.

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St. Lucia Due Diligence Requirements

Due diligence fees in St Lucia Citizenship by Investment Programme are US$ 7,500 for the main applicant and US$ 5,000 pre dependent with an interview fee of US$ 500 for the main applicant only. Applications from Belarusian or Russian national will not be accepted.

• Birth certificate: Certified copy, including parents’ details.
• Certified copy of passport(s): All pages of current passport for all applicants.
• Proof of name change: Certified copy if applicable.
• Permanent residence card: A certified copy is required if applicable.
• Military records: Certified copy if applicable.
• National identity card: Certified copy if applicable.
• Proof of address: Recent document (within 3 months) proving residential address.
• Source of funds documents: Employment letters, payslips, or tax returns verifying occupation and earnings.
• Bank Reference Letter: Recent and from a recognised institution.
• CV: Detailed curriculum vitae.
• Professional and Academic Certificates: Certified copies.
• Professional Reference Letter: Recent and relevant.
• Police Certificate: From the applicant’s home country and any country where the applicant resided for more than one year in the last decade.
• Medical Health Certificate.

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Common Challenges in Due Diligence Checks

The due diligence check is necessarily a lengthy and exhaustive process and issues can arise that increase complexity and cost further. Some common issues are:

• the document requirements are the same for all applicants and may not ‘fit’ with the documentation available in the applicant’s home country (e.g. identity cards are not issued in the UK) and so a ‘best fit’ approach needs to be taken and explained;
• documents not in the English language will need to be translated and certified;
• many of the documents require the input of third parties over whom the applicant has no control and so the timing of provision and quality of documents is uncertain;
• some documents (e.g. police certificates) must be dated within a certain time period prior to the application being submitted and so will need to be re-issued if the document’s validity expires prior to submission as the applicant waits for other documentation required.

Your agent will take you through the process and assist with managing the above factors to ensure that your application is complete. However, it is up to you to arrange all the documentation and deal with your local banks and authorities to collate the information. This can be time consuming and frustrating and, depending on the jurisdiction(s) involved, may require the expenditure of considerable time and expense on the part of the applicant.

Final Thoughts

The due diligence check is based on evidence, but the ultimate decision, whether to approve or otherwise an application, is a subjective one and seeks to determine whether the applicant(s) are suitable persons to become citizens. Compare it with people staying at your home. One night you might not be too careful about who the person is and their background. The longer they stay, the more you want to know about them. Obtaining citizenship is granting the right to stay forever so the level of checks is commensurately high. 

It might seem like a tortuous and intrusive process, and it is indeed a lengthy and deep dive into your (and potentially your family’s) personal circumstances. However, it is necessary to participate in the CBI programmes, and much of the work is done by the relevant government behind the scenes (hence the fees charged). With the right agent to guide you, the process can be smoother. 

Our specialists at Caribbean Golden Passport Advisers are here to assist with any questions this blog may raise and take you through your CBI journey. Feel free to contact us; we would love to hear from you.

FAQs on Due Diligence Checks

Does the due diligence check need to be carried out on all family members applying for citizenship?

Generally yes, although children under the age of 17 are typically not subject to the due diligence check.

Who conducts due diligence in citizenship by investment applications?

Due diligence in Citizenship by Investment applications involves a thorough, multi-step process. Initially, a licensed agent conducts a preliminary check to verify the completeness and accuracy of the applicant's information. The government then reviews the application, followed by an in-depth assessment by an independent third-party specialising in AML compliance and checks against global databases, ensuring a comprehensive evaluation of potential risks.

Will a previous refusal of entry to a country affect my application?

Prior refusals are a major red flag. If the refusal was to the relevant Citizenship by Investment Country or any country to which the passport grants vis-free access, the application will almost certainly be denied. If the refusal was to another country, this will also attract scrutiny but if it can be explained adequately, this may be viewed more leniently. All five Caribbean CBI countries reject applicants who have been denied a visa for the Schengen area and for the UK (and potentially other jurisdictions), and such denials are checked during the due diligence process.

Will a previous bankruptcy or criminal record affect my application?

The due diligence check ensures that the applicant is suitable for citizenship and previous bankruptcies will not be viewed favourably, not least as the applicant will be a long-term investor in the country. Criminal records likewise are not helpful but minor offences (usually defined as offences which carry a potential custodial sentence of less than 6 months may be accepted. Again, whether anything which becomes apparent from the due diligence check will prevent the success of the application is a subjective decision of the government.