Dominica introduces mandatory interviews to CBI applicants

By Moustafa Daly

Dominica, a Caribbean commonwealth island nation with a popular citizenship-by-investment program, has just announced that applicants to the program will now have to undergo mandatory personal interviews – effective immediately.

The move comes as part of a set of measures that aim to increase the program’s due diligence process.

“We are serious and committed to the collective fight to safeguard our respective financial systems. We understand that this step will add another layer to our due diligence process and is a risk management framework to strengthen and safeguard the integrity of our CBI Programme,” stated Dominica’s Prime Minister Roosevelt Skerrit following the announcement.

“The implementation of the mandatory interview of applicants for citizenship of the Commonwealth of Dominica is mainly to verify and authenticate the applicants' documents, photocopies against originals, filed in support of the applications and presented at the interview,” explains Stephen Isidore, attorney and partner at Caribbean Commercial & IP Law Practitioners. 

Dominica is the first Caribbean nation to introduce the personal interview measure, which applicants can conduct in-person or virtually, but other countries are soon expected to follow suit.

“All Caribbean programs will be doing this,” said Christos Vardikos, a Greek lawyer and consul of the Commonwealth of Dominica to Greece.

“The interview is part of the requirement from the US to increase due diligence,” he adds, referring to an agreement established in February 2023 between the US and the presidents of five Caribbean nations, including Antigua & Barbuda, Dominica, Grenada, Saint Lucia, and St. Kitts and Nevis.

The agreement, which was reached in St Kitts in attendance of the Anna Morris, U.S. deputy assistant secretary of treasury for global affairs, introduces a collaborative risk management framework for the islands’ popular citizenship-by-investment programs, stipulating six CBI rules to increase the Caribbean programs’ due diligence and security.

What are the six CBI rules agreed upon between the US and Caribbean nations?

In addition to conducting personal interviews with applicants, all five Caribbean nations have also agreed to start running extensive financial intelligence checks on applicants; rejecting applicants who were denied from other CBI programs; introducing regular auditing practices; working with international law enforcement to retrieve revoked passports.

Finally, Caribbean nations agreed to enforce a ban on Russian and Belarusians applicants to their CBI program starting March 31, 2023. Moreover, the five nations also agreed to convene within six months to assess the status of implementation of the new rules.

The US has since made it clear that it doesn’t intend to end the programs altogether for the negative impact that would have on those nations’ economies and lead to unforeseen negative consequences – deciding instead to work collaboratively to introduce tighter security and regulations that make the programs safer for all parties.

The new rules expected to add to the Caribbean’s CBI attractiveness 

The implementation of the new rules is expected to increase the appeal of the region’s CBI programs, which are already some of the most popular in the world.

In particular, the programs of Dominica and St Kitts and Nevis have been named as the two best programs in 2022 by CBI Index published by the Financial Times, based on a set of criteria that includes certainty of product, standard of living, and due diligence, among others.

According to Bloomberg, the due diligence process in Dominica is particularly praised for adopting a multi-layered approach, and for being conducted by globally-renowned risk agencies mostly based in the US and UK. Thus, the introduction of the new measures is seen by industry experts as further cementing the program’s popularity and reputation.

“Dominica has always had a vigorous due diligence process but since people are becoming [cleverer] as time passes on, you always have to improve your processes to be ahead of the game to counteract and be able to identify fraudulent misrepresentation through whichever means that is being employed to gain unfair advantage,” explains Isidore.

“Therefore, it is expected that Dominica will do more in depth investigation including making use of more sophisticated intel and cyber investigators to ascertain the integrity of the information and documentation being presented to it in support of one's application,” he adds.

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