Dominica: stricter due diligence on CBI applications

Every citizenship by investment programme relies on a due diligence procedure on the applicant, entrusted to specialist firms appointed by the state. It is this procedure that determines whether the application is accepted, not the payment itself.

The checks cover three areas: identity and civil status, the absence of a criminal record or restrictive measures, and the source of the funds invested. This last area is the one that has become most demanding.

The fees are charged separately and are not refundable if the application is refused. In Saint Kitts and Nevis, they amount to $10,000¹ for the main applicant and $7,500² per dependant aged sixteen and over.

Dominica, whose minimum contribution to the economic diversification fund stands at about $200,000³, applies a procedure of the same kind, with a mandatory interview of the applicant.

The cause lies outside the Caribbean. The European Union and the United States have publicly expressed reservations about these programmes, linking them to risks of sanctions evasion, money laundering and identity fraud.

What is at stake for these states is the visa exemption their nationals enjoy for the Schengen area and the United Kingdom. This exemption is what gives the passport its value; losing it would strip the programme of its purpose.

The precedent is well known and documented: Vanuatu lost the visa exemption it enjoyed with the European Union, and its passport now opens only about 95⁴ visa-free destinations. The Caribbean states have taken the measure of this example.

The tightening of checks is therefore a protective measure, and it goes hand in hand with higher thresholds: Dominica, Antigua and Barbuda at $230,000⁵ and Grenada at $235,000⁶ have all converged towards amounts above their historical entry tickets.

We do not publish rejection rates or statistics on refused applications: these data are not published by the authorities concerned, and we have found no official source that would allow them to be quantified.

1. Gather apostilled and translated civil status documents and criminal record certificates for each country of residence in recent years.
2. Document the source of funds continuously: sale of a business, inheritance, earned income, with the corresponding bank records.
3. Expect an interview with the authorities or their service provider, now the rule rather than the exception.
4. Treat the due diligence fees as lost in the event of refusal, and include them in the budget.
5. Go through a licensed agent: direct applications are not possible.

The second point is the one that holds up the most applications. Long-established wealth without a complete paper trail is harder to get accepted than recent, well-documented assets — which often surprises the strongest applicants.

The open question is not whether checks are carried out but whether they are sufficient. Nothing guarantees that the tightening under way will preserve the visa exemption in the long term: the decision lies with third countries, and it is as political as it is technical.

An applicant must therefore assess what they are buying with this revocability in mind. The citizenship itself is acquired; the mobility advantage that makes it attractive is not.

Finally, it should be remembered that the passport does not move tax residency. Saint Lucia applies a threshold of 183 days⁷ to establish tax residency, and Dominica taxes income at up to 35%⁸: the absence of taxation applies only to the foreign-source income of a genuine resident.

For a French national, moreover, the gain in mobility is nil. The only serious reason to embark on such a process is diversifying nationalities, and it should then be judged as insurance, not as an investment.