By Salman Siddiqui
Caribbean nations are joining the chorus of Western sanctions on anti-Ukraine countries as Grenada, St. Kitts and Nevis, Commonwealth of Dominica, and Antigua and Barbuda all announce that they too will no longer allow wealthy Russians and Belarussians to apply for their CBI programs. Some Caribbean migration industry professionals expect to be hit hard since the region is popular among Russians, but they are hoping the setbacks would only be temporary.
St. Kitts and Nevis CBI agent Stacey Ann Aberdeen, who is the founder of Aberdeen Law, said she expects to see a decline in clients from Russia and Belarus because of the suspension, but she hopes things would turn around eventually.
“I believe that the St. Kitts government will adhere to this ban for a short period but will eventually revert to allowing such applicants as they contribute significantly to the economy,” Aberdeen said.
In a statement released to the media on March 8, the Citizenship by Investment Unit of St. Kitts and Nevis called the suspension of CBI applications to Russians and Belarusians “a pause”, which gave hope to migration professionals that this could change in the future.
“In solidarity with US and European efforts to isolate the Russian government for its military invasion, the CBI has implemented a pause on citizenship application files from all applicants from Russia and Belarus irrespective of whether or not they are on the sanctioned list. This pause is effective immediately,” the government statement said.
“The CBI Unit will continue to work closely with its due diligence companies to ensure that Russian and Belarussian names are continually being monitored against these sanctioned lists and to note any changes that may occur in the future,” it added.
Aberdeen said she did not think the government was in the wrong in taking a decision that would surely hit her industry.
“I don’t think they made the wrong decision; it’s just a matter of maintaining their international relationship with the rest of the world,” she said.
“Initially we will see a decline with the number of potential applicants but I’m hopeful that business will return to good business.”
Impact on Caribbean migration firms
Antigua and Barbuda CBI agent Kaline Kennard, who is a founding partner at Citizens International, said the move to suspend citizenship by investment application from people in Russia and Belarus would hurt many investment immigration firms in the Caribbean, especially in her country.
“We have had to pause work on a number of Russian applications that were not yet submitted. Russia is not a primary source market for us; however, I know that some immigration specialists are being very heavily affected by this ban,” Kennard said.
The CBI unit of Antigua and Barbuda paused all CBI applications from Russians and Belarusians, citing the fact that due diligence providers could not conduct proper investigations in the countries involved in Ukraine war, according to local Caribbean media reports. Due diligence professionals need to verify an applicant’s birth and residency details apart from scrutinizing the money trail of the funds being used for investment, which becomes impossible if the entire banking systems remain inaccessible due to sanctions.
Kennard also said the due diligence challenges would be huge due to the ongoing Ukraine war.
“I expect the other Caribbean citizenship jurisdiction will follow in the footsteps of Antigua and Barbuda, and Dominica quite soon. It may be very challenging for the Caribbean governments and their third-party diligence companies (who are US based) to carry out the required diligence under the current situation, so I believe it’s the right move. I am only sorry that many innocent Russian families will be affected,” she added.
Russians to miss Dominica’s CBI program
Dominica CBI agent S.K.M. Isidore, who is the principal and managing partner at Caribbean Commercial & IP Law Practitioners, said Russia's participation in Dominica's investment immigration program had always been sizable, particularly by Russian elites and businessmen, and the suspension would hurt business.
“Certainly, with the temporary suspension of Russia's participation in Dominica's Citizenship by Investment Program, there will be a decrease in the overall number of applications. The Russian community has been participating in Dominica's program for decades even at a time when the citizenship program was virtually unknown to the wider world,” Isidore said.
“The temporary suspension of Russian and Belarusian's participation in Dominica's citizenship by investment program will certainly lead to less participants which ultimately will decrease the total investment the programs generate in any given year,” he said.
In its official letter to migration agents in Dominica released on March 4, the Dominica’s Citizenship by Investment Unit said the suspension of applications “is geared at safeguarding the global community and the integrity of Dominica’s citizenship by investment program.”
CBI agents are nonetheless putting up a brave face and hoping to weather the storm, which they hope would only be temporary.
“Taking into consideration the undisputed fact that Dominica's program is widely known and has been enjoying such a great reputation and acceptance in the citizenship industry for over two decades, we believe that the lessened participation mainly from the Russians and Belarusians will surely have an impact on the program on the investment income side but certainly not one that will be of any immense measure to have a negative adverse effect that will be troubling for the country,” Isidore added.
Grenada becomes fourth Caribbean country to impose ban
In a statement released on its official website on March 10, Grenada’s Citizenship by Investment Unit announced that the government has also decided to “temporarily suspend the acceptance of new applications from Russians and Belarussians for the citizenship by investment program with immediate effect.”
It added that the government was closely following the situation in Ukraine, and all efforts would be made to “preserve the integrity and reputation of the Grenada CBI program.”
Investment immigration firms in Grenada are feeling the heat from the ban already, with many expecting to lose business, even though many anticipated the new restrictions, especially after Dominica, Grenada and Antigua and Barbuda announced similar suspensions.
“It was inevitable that sanctions would eventually be applicable throughout the Caribbean jurisdictions especially with Grenada and our close relationship to the United States and our E2 Visa waiver program,” said CBI agent Richard Hallam.
Hallam said he was expecting to lose potential clients following the suspension.
“Yes, regrettably, we had a very strong presence in the Russian market prior to the current situation and these clients will now have to look elsewhere.”
Before the Russian invasion of Ukraine, “we had a 20% market share from Russian clientele,” he said.
Giving his personal opinion on the merits of the temporary ban, Hallam said: “I think it is unfortunate that the actions of one have repercussions over all the citizens of the entire country but I understand the desire to leverage political weight and impose sanctions to pressure a government through its people as opposed to engaging in a war.”
Another CBI agent from Grenada, who did not want to be named, said she had received several inquiries from people who were trying to get into Grenada before the letter announcing the ban was issued in the morning.
St. Lucia decides not to ban all Russians
Unlike other Caribbean nations, St. Lucia has decided it would not ban all Russians and Belarusians from its CBI program, but would only prohibit those individuals from the two countries who are on the international sanctions list.
In an official statement released on March 18, the government of Saint Lucia said the eastern Caribbean island nation does not discriminate against any individual based on just their nationality.
It said the government "supports the call to restrict the access of any Russian national to use the CIP to avoid sanctions and mask their affiliation to the Russian regime.
"However, some individuals have applied who have lived outside Russia for many years and themselves have been persecuted or needed to flee the actions of the regime. It was felt that these people should not be abandoned and disregarded once they pass due diligence."
The government promised to review the citizenship and passports of all Russians who benefited from the CBI program but clarified that it would revoke the credentials of only those individuals who had been placed in the international sanctions list.
"Citizens who are not on the sanctions list will continue to enjoy citizenship," the statement said.
It added that while the country was suspending CBI applications from Russians and Belarusians, the government "will continue to make representation for persons who are special cases suffering from persecution and discrimination from the Russian regime and are in need of support in these difficult circumstances."
Other countries who have imposed a total RCBI ban on Russians and Belarusians include Portugal, Greece and Malta. The move came on February 26 after the European Commission issued a joint statement with several Western countries, among them the non-EU states of the UK, Canada and the US, which outlined a host of sanctions against Russia following its invasion of Ukraine.
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