The Future of CBI Programs: US-Caribbean Roundtable Agrees on 6 Key Principles
On February 25, 2023, a momentous event took place in Saint Christopher (St. Kitts) and Nevis. The US-Caribbean Roundtable on Citizenship by Investment brought together representatives from the five Eastern Caribbean states with Citizenship by Investment (CBI) Programs, including their Prime Ministers, and a delegation from the United States led by the Deputy Assistant Secretary of the US Department of the Treasury.
The Governor of the Eastern Caribbean Central Bank and the Director General of the Organisation of Eastern Caribbean States were also in attendance. The roundtable was a highly productive and mutually beneficial engagement, where both parties engaged in a candid discussion about the challenges and threats facing these programs and the important contribution they have made to national development in these small states.
In this blog post, we’ll take a closer look at this historic event and explore the outcomes of the roundtable discussion.
Acknowledgement of the Importance of CBI Programmes
During the event, the importance of CBI Programmes was recognized by the United States.
The programmes were acknowledged for providing a legitimate service and for aiding in the survival of the participating economies, particularly considering the existential threat posed by the climate emergency and the recent adverse external shocks.
The revenue generated by the CBI Programmes is crucial in funding major infrastructural and development projects and building resilience. The dismantling of these programmes was deemed as potentially triggering negative social consequences domestically and leading to an upsurge in criminality, among other pathologies.
Agreement on Six CBI Principles
The five governments collectively committed to six CBI principles proposed by the United States.
Several of these principles had already been adopted proactively by the Organisation of Eastern Caribbean States (OECS) states as part of their risk management framework to strengthen and safeguard the integrity of their CBI Programmes.
The six principles agreed to are as follows:
- Collective Agreement on treatment of denials: Not to process applications from persons whose applications have been denied in another CBI jurisdiction, by proactively sharing information on denials.
- Interviews: Conduct interviews with applicants, whether virtual or in-person.
- Additional Checks: Each jurisdiction will run checks on each application with the Financial Intelligence Unit of its respective country.
- Audits: Audit the Programme annually or every two years in accordance with internationally accepted standards.
- Retrieval of Passports: Request law enforcement assistance to retrieve revoked/recalled passports.
- Treatment of Russians and Belarusians: Suspend processing applications from Russians and Belarusians. Four jurisdictions have already suspended applications and Grenada, which processes applications from Russians and Belarusians with enhanced due diligence, will suspend processing new applications from Russia and Belarus from March 31, 2023.
It was recognized and accepted that the implementation of the sixth principle would have a significant adverse revenue impact on the CBI states.
Therefore, both parties agreed to convene a technical discussion within the next four to six months to assess the status of the implementation of the agreed six principles.
Further Requests and Commitments
At the next engagement, the OECS States requested further discussion on the US Government’s risk management framework for the EB-5 Immigrant Investor Program as it relates to the processing of applications from Russians.
Given these agreements, the CBI states requested that the United States Government facilitate a similar engagement with the European and United Kingdom Governments based on the six agreed principles.
Both parties reiterated their commitment to ongoing constructive engagement that takes into account the special circumstances of small states and their needs.
Final Thoughts
In conclusion, the US-Caribbean Roundtable on Citizenship by Investment was a significant event that highlighted the importance of CBI Programs in the development of small states in the Eastern Caribbean.
The agreed-upon six CBI principles will undoubtedly affect the programs and investors. The increased checks and audits will provide greater security and transparency. However, the suspension of applications from Russians and Belarusians will have a significant adverse revenue impact on CBI states.
Nevertheless, the commitment of both parties to ongoing constructive engagement is a positive step towards ensuring that these programs continue to benefit small states while safeguarding the integrity of the programs.