The Caribbean countries which offer Citizenship By Investment Programmes are moving with alacrity to implement the Memorandum of Agreement (MOA). The purpose of the Memorandum of Agreement is to provide a framework for mutual assistance and cooperation in vetting to ensure only legitimate and qualified applicants are admitted and information sharing among the five OECS Member States in relation to their CBIPs.
Signatories
The signatories of the MOA are:
- Antigua and Barbuda,
- Commonwealth of Dominica,
- Grenada,
- St. Kitts and Nevis and
- Saint Lucia.
The MOA which was published in March 2024 aims to ensure mutual cooperation, information sharing and adherence to common standards of best practice, and regulatory oversight.
Investment Threshold
With effect from July 01, 2024, all countries have agreed that the minimum price for any CBI options shall be US$200,000. This means the minimum sum that will be paid into any government fund, government project or private development project of, or in participating countries shall be US$200,000.
Common Framework
The MoA will empower five caribbean nations to implement harmonized framework.
- share information on CBIP applicants;
- implement enhanced transparency measures such as the disclosure of funds received by CBIPs, the use of the proceeds of CBIs and to conduct independent financial and operational audits to assess CBIs compliance with best practice standards;
- assign or establish a regional competent authority to set standards in accordance with international requirements and best practices and to regulate the CBIPs;
- establish common standards to manage the communications and promotion of the CBIPs;
- establish common standards for the regulation of agents operating in the CBIPs; and
- facilitate joint training programs and capacity-building initiatives for their respective officials and agencies involved in the administration of CBIPs.
Discounting
The signatories to the MOA make it abundantly clear that discounting of the agreed minimum price is illegal.
Agents
Market actors, Marketing Agents, Local Agents and or Developers who have evidence of any attempt at, or instances of discounting should report same promptly to the CBI Unit, Investment Migration Agency or Financial Intelligence Units of the participating countries.
Regional Regulator
In respect of a regional regulatory body, participating Governments will soon appoint an Interim Regulatory Commission pending the enactment of enabling legislation for the regional regulator. The 7-member Interim Regulatory Commission will be drawn from each of the participating countries (5), the OECS Commission and the Eastern Caribbean Central Bank. The functions of the regional regulator will include to:
- Develop, issue and enforce regional standards for CBI Programmes.
- Monitor compliance of legislation, regulations and standards.
- Monitor compliance with international agreements.
- Investigate complaints.
- Facilitate information sharing and engagements with regional and international stakeholders.
Work streams have been developed and assigned for all articles of the MOA. The CBI countries will provide periodic updates on the implementation of the MOA.
Download
Memorandum of Agreement – Download pdf
