Dominica’s sweeping CBI reforms aim to restore the program’s integrity

By Stephen Isidore

Dominica has made sweeping changes to its Citizenship by Investment (CBI) program, all geared to increase the propriety and integrity of the program and attract investors of good standing as participants.

One of the most significant changes is the ineligibility of applicants who have received either European Union (EU), United Kingdom (UK), U.S., and Canada visa rejections and thereafter have not gotten a visa or residence permit to travel or reside in those countries. Also, individuals who received visa rejections from those countries and from any other country with whom Dominica has enjoyed a Visa Free arrangement are also ineligible. Those applicants are barred from being successful applicants for Dominica’s citizenship.

This requirement keeps the number of potential candidates down, but on the other side of things, it improves the program's integrity and sends Dominica citizens out there with whom those countries have no concerns or reservations about entering their ports and pose no risks to them.   

However, all is not lost for candidates interested in Dominica’s CBI option. It is said that in difficulties lies opportunities.

Candidates who haven’t applied for a visa to enter any of the Visa-Free Countries with which Dominica has this relationship may find it worthwhile to test the waters by applying for Dominican citizenship in the first instance. Once successful, it will clear the way or enhance their chances of success with the Visa-Free countries. Dominica will be seen and taken as a first screening test for potential globe-trotting investors.

CBI program increases scrutiny on agents and promoters to improve candidate quality

Dominica has also implemented an over 100% increase in the application and renewal license fees for authorized agents and promoters. Promoters must now have a contractual engagement with an authorized agent to be licensed as a promoter.  External authorized agents not residing in Dominica must lodge their application to become one in person, maintain an established place of business in Dominica with a minimum of three staff members, and prove bi-annual visits to the country to be qualified for a new license and renewal of existing license.

Authorized agents must also not encourage unlicensed promoters by the Government of Dominica to promote the program outside the country’s promotional guidelines.

It has been stated in the past that external authorized agents may not generally be working in the interests of the program but theirs only; a reason is that they have no connection with the country and cannot appreciate the immense importance of the program. Some have never visited Dominica and don’t intend to, but to process applications for a fee.  These new conditions aim to address those issues and for external agents not to be moved primarily for a fee but also to develop an affinity to the country and its program.

By these requirements, the country hopes to see an attitude change; external agents would implement an initial screening process to guide them in selecting applicants to sign up as potential candidates for the program, which would be underpinned by credibility, good standing and less than questionable character.

Another reason for these added requirements on authorized agents and licensed promoters is to weed out non-productive agents and promoters who clog the list.

Dominica enforces due diligence for CBI candidates from red flagged-countries

Dominica has also implemented mandatory interviews for all applicants 16 years and above and an enhanced due diligence process for applicants from certain countries, termed specific countries or regions.  These specific countries are troubled countries with security risks concerning Dominica and other friendly countries. The enhanced due diligence will attract additional fees above the normal due diligence as it is more involved and demands deeper research, investigation, and background checks.

The mandatory interviews confirm the applicants' identity and all the facts and circumstances they have declared in their application. The primary language for the interview is English but applicants can be facilitated with their native language if they don’t speak English. 

These additional requirements and layers to the program are necessary to strengthen and safeguard the propriety, respectability, and integrity of Dominica’s over 30-year-old CBI Program.

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About the Author

S.K.M. Isidore
S.K.M. Isidore

S.K.M. Isidore is a Dominica local agent. He is currently the principal and managing partner of Caribbean Commercial & IP Law Practitioners, based on Roseau, Dominica.

Caribbean Commercial & IP Law employs solicitors, barristers and attorneys to help with immigration, citizenship, litigation, real estate, international business and intellectual property law.

Isidore is experienced in Dominica’s citizenship-by-investment program, as well as takeovers and mergers, syndicated loan transactions, cross-border transactions and securitization of long-term loans. He has also practiced as an attorney in Trinidad and Tobago and as a solicitor and barrister of the Eastern Caribbean Supreme Court.

Isidore is a former director of the National Bank of Dominica. He has also worked as a commercial officer at the National Cooperative Credit Union in Dominica and the Bank of Nova Scotia.

Isidore serves on the board for Dominica Social Security and National Telecommunications Regulatory Commission for Dominica.

He received his bachelor’s degree from the University of the West Indies and a legal education certificate from the Hugh Wooding Law School in Trinidad and Tobago.

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