Due diligence is a sequence of investigative practices that identify and verify information about an investor. Due diligence is critical to maintaining the integrity and transparency of Dominica’s CBI Programme. Stringent processes include verifying an investor’s identity, criminal background, source of funds, and public reputation amongst other checks.
Dominica’s Vetting Process
Dominica is world-renowned for being one of the world’s most efficient and reliable CBI programmes, with its strict, multi-layered measures. Dominica also favours a collaborative approach with the other Caribbean CBI jurisdictions, with similar due diligence mechanisms being adopted across the region.
Dominica’s CBI Programme focuses on the overall description of its candidates, rejecting the applications of individuals that do not comply to the set conditions and criteria. Comprehensive checks are performed on all applicants older than 16 years of age, and additional safeguards are present to monitor compliance with international sanctions and security.
List of Entities that scrutinise an application
The following entities scrutinise the applications in each phase (6 layers of checks).
1.Authorised agents
Authorised agents perform Know-Your-Client (KYC) checks and ensure that applications are only received by the Citizenship by Investment Unit (CBIU) if they contain all, complete application forms and supporting documents, accompanied by the required fees. KYC checks include using the WorldCheck database and desktop controls, which allow agents to do an initial background screening.
All applicants sixteen years of age or over will be required to attend a mandatory interview. During this time, a third-party due diligence agency will perform stringent background checks on the information you have provided. Interviews will be held virtually, via a secure platform. Applicants will be contacted directly by authorised interviewers for scheduling interviews.
Thereafter, applicants and their dependants will attend virtual interviews; Authorised Agents/Licenced Promoters cannot attend interviews on their behalf. All applicants must hold identification documents, and supporting documents deemed necessary for the interview.
Interviews will be conducted in the applicant’s native language or a language of his/her choosing. All applicants 16 years and over are expected to attend interviews; applicants who are unable to join with the rest of their family must pay for additional interviews. Documents requested via the interview will be routed via the Authorised Agent.
2. Citizenship By Investment Unit
The Dominica CBI Unit is responsible for ensuring that both internal and external checks are performed on each application. Internal due diligence is conducted by the staff of the CBIU, made up of experts in document review, anti-money laundering, and counter-terrorism financing. They perform open-source checks on all applicants and ensure that all documents are consistent and adhere to the Unit’s requirements.
The CBIU has upheld its Rigorous due diligence standards, reinforcing trust in the Programme
The Citizenship by Investment Unit (CBIU), led by Ms. Marie-Therese Johnson, is responsible for overseeing the Programme. The CBIU ensures efficient processing, transparent management, and rigorous due diligence while exploring opportunities for continuous improvement.
3. Expert international DD Firms
External due diligence mandated by the CBIU, requires independent firms to conduct online and on-the-ground checks to verify the information provided in the application forms and supporting documents. They then produce a report that is returned to the CBIU, establishing the applicant’s identity, familial ties, criminal background, employment history, source of funds, press and media profile and political exposure.
4. Crime prevention and detection agencies
The Joint Regional Communications Centre (JRCC), an arm of the CARICOM Agency for Crime and Security, cross-references all applicants against regional watchlist and Interpol databases as part of the external due diligence process.
5. Partner governments
External checks are also performed with or by partner governments, including the Governments of Canada, the United Kingdom, and the United States.
6. The National Bank of Dominica
The bank that receives the Citizenship by Investment funds from the applicant, the National Bank of Dominica, performs additional, independent due diligence checks. It charges its own due diligence fees, requests supporting documents, and only accepts funds of which clean origin can be established.
Processing Times
The average processing time of a CBI application which includes a complete due diligence is approximately three months. Over 90% of the time consumed in vetting of application. This includes internal due diligence by the CBI Unit and external due diligence by international firms.
