As per the Memorandum of Agreement (MOA) signed earlier this March, the Caribbean region is set to announce the formation of an Interim Regulatory Commission. This Commission will be responsible for establishing standards, regulating, and overseeing Citizenship by Investment (CBI) programmes, and will implement corrective actions when necessary.
3rd US-Caribbean Roundtable in Grenada, September 6, 2024
During the recent 3rd US-Caribbean Roundtable, representatives from Caribbean nations with CBI programmes indicated that they will soon introduce the interim Regulatory Commission. This body will play a crucial role in establishing a regional regulatory framework.
The US delegation expressed appreciation for the progress made by Caribbean CBI jurisdictions in the establishment of an independent regional regulator to oversee standards and enforce regulatory measures.
The roundtable, held in Grenada, facilitated productive discussions among five Eastern Caribbean countries that offer CBI programmes alongside officials from the United States Department of the Treasury. The meeting took place on August 29, 2024, focusing on the implementation status of six key CBI principles.
Co-chaired by U.S. Treasury Acting Deputy Assistant Secretary Warren Ryan and Governor Antoine, this roundtable marked the third such meeting on CBI matters. Delegates reviewed the overall advancements and challenges related to the six CBI principles first introduced by Caribbean Heads of Government in February 2023.
Participation from CBI Countries and Regional Organisations
Delegations from the participating island nations included Chairs, technical staff, and Chief Executive Officers from their CBI units, representing Antigua and Barbuda, Commonwealth of Dominica, Grenada, St. Kitts and Nevis, and Saint Lucia. The meeting also included attendees from the Eastern Caribbean Central Bank, led by Governor Timothy N.J. Antoine, and the Organisation of Eastern Caribbean States (OECS) Commission, represented by Director General Dr. Didacus Jules.
The 6 CBI Principles Include:
- Collective Agreement on Denial Treatments
- Interviews
- Additional Checks
- Audits
- Retrieval of Revoked Passports
- Treatment of Russian and Belarusian Nationals
Delegates acknowledged the region’s commitment to implementing these principles as quickly as possible.
Emphasis on Implementing the 6 CBI Principles
This roundtable was pivotal in discussing the progress made regarding the six principles. The initial meeting took place in St. Kitts and Nevis in February 2023, followed by a second in Miami in October 2023. These principles aim to enhance governance of CBI programmes while mitigating risks associated with money laundering and terrorist financing across the region.
During the discussions, it was revealed that the participating countries have collectively agreed on the treatment of application denials and have begun executing these denials bilaterally. They are working towards a more sustainable and efficient mechanism for sharing and coordinating on denials through CARICOM’s Joint Regional Communications Centre.
Furthermore, all CBI countries have collaborated to actively implement four of the six principles, which include:
- Collective Agreement on Denial Treatments: This principle ensures that CBI units will not process applications from individuals whose applications have been denied in any of the five Caribbean CBI jurisdictions.
- Interviews: This principle mandates that all applicants undergo interviews prior to the processing of their applications.
- Additional Checks: CBI units are required to conduct thorough checks on each applicant in collaboration with the Financial Intelligence Unit of the respective country.
- Treatment of Russians and Belarusians: This stipulation requires that all CBI jurisdictions halt the processing of applications from individuals from Russia and Belarus.
While the Citizenship by Investment nations have successfully implemented these four principles, they are actively working to fully integrate the remaining two principles as well.
These focused efforts by Caribbean nations offering CBI programmes align seamlessly with the regional initiatives outlined in the Memorandum of Agreement, which has now been ratified by all participating countries.
Additionally, the decision to establish the Interim Regulatory Commission to create a regional regulatory body reflects the goals set forth in the MOA and has been positively received by the US delegation. These significant actions demonstrate the commitment of CBI nations to enhance risk management and mitigation for their programs while expressing gratitude for the ongoing support from the United States Treasury.
