Five Caribbean Countries, Five Different Routes to Citizenship
Five countries currently offer Caribbean Citizenship by Investment programmes: Antigua and Barbuda, Dominica, Grenada, St. Kitts and Nevis, and Saint Lucia.
Each programme provides a legal route to citizenship for applicants who make a qualifying investment and successfully complete the required due diligence process. Depending on the country selected, eligible investments may involve a contribution to a government fund, an investment in approved real estate or another qualifying investment.
Although the five programmes share certain features, there are important differences in their investment requirements, family eligibility, available investment options and application procedures.
Understanding these differences is important when deciding which programme is appropriate for an individual applicant or family.
What is Caribbean Citizenship by Investment?
Citizenship by Investment allows a foreign national to apply for citizenship on the basis of making a qualifying investment in the country. Unlike residence by investment programmes, successful applicants obtain citizenship rather than a temporary or permanent residence permit.
The Caribbean has some of the world's longest-running Citizenship by Investment programmes. St. Kitts and Nevis introduced its programme in 1984, followed by Dominica in 1993. Antigua and Barbuda, Grenada and Saint Lucia subsequently introduced their own programmes.
Applicants are not granted citizenship simply because they make an investment. Each programme requires the applicant to satisfy eligibility requirements, provide detailed supporting documentation, establish the source of the funds being invested and successfully complete due diligence.
Applications must generally be submitted through an authorised agent rather than directly by the applicant.
What are the benefits of Caribbean citizenship?
The reasons for obtaining Caribbean citizenship will differ between applicants.
For some, the principal consideration is international mobility. For others, it may be the ability to establish a second nationality for themselves and eligible family members, create greater flexibility over where they live and travel, or reduce reliance on a single country of citizenship.
A second citizenship
Successful applicants become citizens of the country rather than simply obtaining a residence permit.
Citizenship is granted for life and may also be passed to future generations, subject to the nationality laws of the country concerned.
The Caribbean programmes also permit dual citizenship. Applicants are therefore generally not required to renounce their existing nationality, although they should confirm whether their current country of citizenship permits dual or multiple nationality.
International travel
Caribbean passports provide visa-free or simplified access to a range of international destinations. The exact countries available depend on the passport held, and visa policies can change.
For this reason, applicants should consider where they actually need to travel rather than selecting a programme solely on the basis of the total number of visa-free destinations advertised.
Family inclusion
All five programmes allow qualifying family members to be included, although the definition of a dependent differs between countries.
Depending on the programme and the family's circumstances, this may include a spouse, children and, in some cases, parents, grandparents or other qualifying dependents.
Family composition can have a significant effect on both programme eligibility and overall cost.
No requirement to relocate permanently
The Caribbean programmes do not generally require applicants to relocate permanently to the country before citizenship can be granted.
This can make them suitable for applicants who want to obtain an additional citizenship without changing their principal country of residence.
Individual programmes may nevertheless have specific requirements after citizenship is granted. These should be considered before applying.
Long-term planning
A second citizenship can form part of a wider international planning strategy, particularly for families with personal, educational or business interests in several countries.
Tax residence, existing citizenships, business interests, family circumstances and future residence plans should all be considered before deciding whether a Citizenship by Investment programme is appropriate.
Who may consider Caribbean citizenship by investment?
There is no single profile of a Caribbean Citizenship by Investment applicant. The programmes may be relevant to individuals and families looking for:
- an additional citizenship;
- greater flexibility for international travel;
- a citizenship that can include eligible family members;
- an alternative to residence-based immigration programmes;
- a long-term option that does not require permanent relocation; or
- greater flexibility as part of their international business, residence or family planning.
Citizenship by Investment is not necessarily the appropriate solution for everyone.
An applicant primarily interested in relocating to Europe, for example, may find that a European residence programme (also known as a Golden Visa) better meets their objectives. Similarly, applicants focused on access to a particular country should first determine whether the Caribbean passport they are considering provides the access they actually require.
The programme should therefore be selected around the applicant's objectives rather than the passport alone.
Which Caribbean countries offer Citizenship by Investment?
There are currently five established Citizenship by Investment programmes in the Caribbean.
Antigua and Barbuda Citizenship by Investment
Antigua and Barbuda introduced its Citizenship by Investment Programme in 2013.
The programme offers several qualifying routes, including a contribution to the National Development Fund, investment in approved real estate, investment in an approved business and a contribution to the University of the West Indies Fund for qualifying families.
The National Development Fund contribution currently starts at US$230,000, with additional government processing and due diligence fees.
Antigua and Barbuda can be particularly relevant for larger families because of the way certain investment options and government fees are structured.
Applicants should also take account of the programme's requirements for citizens following approval, including its physical presence requirements.
Dominica Citizenship by Investment
Dominica has operated its Citizenship by Investment Programme since 1993.
Applicants can currently qualify through one of two principal routes:
- a contribution to the Economic Diversification Fund; or
- an investment in government-approved real estate.
The Economic Diversification Fund contribution starts at US$200,000 for a single applicant and US$250,000 for a main applicant with up to three qualifying dependants.
Approved real estate requires a minimum investment of US$200,000, in addition to the applicable government fees.
Dominica's programme has a relatively straightforward investment structure, but applicants are still subject to detailed due diligence and must satisfy the programme's eligibility requirements.
Grenada Citizenship by Investment
Grenada introduced its current Citizenship by Investment Programme in 2013.
Applicants may qualify through a contribution to the National Transformation Fund or through an investment in an approved project.
The National Transformation Fund contribution currently starts at US$235,000 for a single applicant or a family of up to four, subject to the rules applicable to particular categories of dependants.
The approved project route generally requires an investment starting from US$270,000, together with the applicable government contribution and other fees.
Grenada is also notable because Grenadian nationals may potentially qualify to apply for an E-2 Treaty Investor Visa to the United States, provided they independently satisfy the requirements of the US E-2 visa. Grenadian citizenship does not itself guarantee an E-2 visa.
St. Kitts and Nevis Citizenship by Investment
Established in 1984, the St. Kitts and Nevis Citizenship by Investment Programme is the longest-running programme of its kind.
Several investment routes are currently available, including the Sustainable Island State Contribution, Public Benefit Option, Developer's Real Estate Investment and qualifying private real estate.
The Sustainable Island State Contribution currently starts at US$250,000 for a main applicant or a family of up to four.
Approved Developer's Real Estate starts at US$325,000, while qualifying private real estate is subject to separate minimum thresholds depending on the type of property.
The main applicant is also required to complete an interview as part of the application process. Dependants aged 16 or over may also be interviewed where considered necessary.
Saint Lucia Citizenship by Investment
Saint Lucia introduced its Citizenship by Investment Programme in 2016.
The programme provides several investment routes, including the National Economic Fund and approved real estate.
A contribution to the National Economic Fund currently starts at US$240,000 for an applicant with up to three qualifying dependents.
Approved real estate currently requires a minimum investment of US$300,000, in addition to applicable fees.
As with the other Caribbean programmes, applicants must successfully complete the required due diligence before citizenship can be approved.
Caribbean Citizenship by Investment programmes compared
The five programmes share the same basic principle: the applicant makes a qualifying investment and undergoes due diligence before citizenship can be granted.
They are not, however, interchangeable.
| Programme | Contribution route from | Real estate route from | Particular consideration |
|---|---|---|---|
| Antigua and Barbuda | US$230,000 | US$300,000* | Can be attractive for certain larger family applications |
| Dominica | US$200,000 | US$200,000* | Two principal investment routes |
| Grenada | US$235,000 | US$270,000* | Grenadian nationals may potentially qualify for the US E-2 visa |
| St. Kitts and Nevis | US$250,000 | US$325,000* | Longest-established Caribbean CBI programme |
| Saint Lucia | US$240,000 | US$300,000* | Several qualifying investment options |
*Additional government contributions and fees apply to all approved real estate project route.
These figures represent minimum qualifying amounts rather than the total cost of obtaining citizenship.
Due diligence fees, government processing fees, passport fees, legal fees and other programme-specific costs may apply. The final amount will also depend on the number, age and relationship of the dependants included in the application.
What are the requirements for Caribbean citizenship by investment?
The exact eligibility requirements vary between programmes. As a general rule, the main applicant must:
- be at least 18 years old;
- make the required qualifying investment;
- provide evidence of the lawful source of the funds used for the application;
- successfully complete the required due diligence;
- provide the required identity, civil status, financial and other supporting documents; and
- satisfy the character and other eligibility requirements imposed by the country concerned.
The applicant's personal and financial history will form an important part of the assessment. Applicants will also be asked to prove where the funds originated.
Previous visa refusals, criminal matters, regulatory issues, sanctions exposure, politically exposed person status, discrepancies in source-of-funds documentation or other matters identified during due diligence may require further explanation and, depending on the circumstances, may affect eligibility.
For this reason, a proper assessment should take place before an application is submitted and before significant financial commitments are made.
Can family members be included?
Yes. All five programmes allow eligible dependents to be included in an application.
A spouse and minor children will generally be eligible, while the treatment of adult children, parents, grandparents and other relatives varies between programmes.
Age alone does not determine whether an adult family member qualifies.
Some programmes require adult children to be financially dependent on the main applicant or enrolled in higher education. Minimum ages and dependency requirements may also apply to parents and grandparents.
Where several generations of a family are applying together, family eligibility should therefore be reviewed programme by programme.
Investment options for Caribbean citizenship
The investment route is one of the most important decisions in a Caribbean Citizenship by Investment application.
Government contribution
All five programmes provide a contribution-based route in some form. The applicant makes a non-refundable payment to a designated government fund or programme.
For applicants whose objective is simply to obtain citizenship and who do not want to hold an investment asset in the country, this is often the simplest route to evaluate.
It is important to note that the contribution is not recoverable.
Real estate
Certain programmes also provide, or have provisions for, qualifying investments in approved real estate.
Applicants cannot normally purchase any property they choose and use it to qualify for citizenship. The property or development must meet the requirements of the relevant programme.
Minimum holding periods, resale restrictions and other conditions may apply.
Applicants considering this route should therefore assess the property as an investment in its own right rather than assuming that its inclusion within a Citizenship by Investment programme makes it commercially attractive.
The purchase price is also only one part of the cost. Government fees, legal fees, property-related charges and eventual resale costs should be taken into account.
Other qualifying investments
Certain programmes provide additional routes.
For example, Antigua and Barbuda provides options involving approved businesses and the University of the West Indies Fund, while St. Kitts and Nevis provides a Public Benefit Option.
The availability and suitability of these routes will depend on the applicant's circumstances and the rules in force when the application is made.
What documents are required?
The exact documents depend on the programme, applicant and family members included. A Caribbean Citizenship by Investment application will generally require documents relating to:
- passports and identification;
- birth and marriage records;
- residential address;
- education and employment history;
- business ownership and professional activities;
- police clearance or criminal record certificates;
- medical examinations;
- bank and financial records;
- source of funds and source of wealth;
- the qualifying investment; and
- eligible family relationships and dependency.
Documents issued overseas may need to be notarised, certified, apostilled or otherwise legalised depending on where they were issued and the requirements of the programme.
One of the more demanding parts of an application can be establishing source of funds and source of wealth.
The evidence required will depend on how the applicant accumulated their wealth and where the investment funds originate. A business owner, salaried executive, investor and individual who recently sold a company or property will therefore require different supporting evidence.
How to obtain Caribbean citizenship by investment
Although procedures vary between countries, an application will generally follow several stages.
1. Initial eligibility assessment
The applicant's nationality, family composition, background, objectives and source of funds should be reviewed before selecting a programme.
Potential due diligence issues should also be identified at this stage.
2. Select the programme and investment route
The five programmes should then be compared according to the applicant's priorities.
The lowest headline investment is not always the lowest overall cost or the most appropriate option for a particular family.
3. Prepare the application
The applicant gathers the required personal, financial and supporting documentation.
Application forms must be completed consistently with the supporting evidence, and the source of the investment funds must be documented.
4. Submit the application and complete due diligence
The application is submitted through the appropriate authorised channel.
The relevant Citizenship by Investment Unit or agency then reviews the application and carries out the required due diligence.
Applicants may also be required to attend an interview, depending on the programme.
All programmes now require applicants to complete an interview (online) as part of the due diligence process.
5. Receive a decision
If the application is approved in principle, the applicant is instructed to complete the qualifying investment and any remaining programme requirements.
The investment should generally not be completed prematurely unless the programme or chosen investment route requires it.
6. Complete the investment
The applicant makes the required contribution, completes the qualifying real estate transaction or fulfils the conditions of the selected investment route.
Evidence of completion is then submitted to the relevant authority.
7. Citizenship and passport
Once all requirements have been satisfied, the applicant is granted citizenship and can proceed with the required citizenship and passport formalities.
The exact procedure differs between countries.
How long does Caribbean citizenship by investment take?
Processing times vary according to the programme and individual application. Applicants should be careful about treating advertised processing periods as guaranteed completion dates.
The time required can be affected by the complexity of the applicant's background, the number of dependants, the countries from which documents must be obtained, due diligence, requests for additional information and the investment route selected.
An application involving complex corporate structures or several sources of wealth may also require considerably more preparation before it is ready to submit.
Applicants with a particular deadline should therefore build sufficient time into their planning rather than relying solely on a programme's minimum or indicative processing period.
Which Caribbean Citizenship by Investment programme should you choose?
There is no single Caribbean programme that is best for every applicant.
For a single applicant, overall cost may be an important consideration. A family may place greater emphasis on dependent eligibility and the cost of including several family members.
An entrepreneur interested in future access to the United States may want to consider Grenada because of its E-2 treaty relationship with the US, while an applicant interested in real estate will need to compare not only the minimum investment but also the approved projects, holding requirements and likely exit options.
The questions to consider include:
- Which family members need to be included?
- Where does the applicant need to travel?
- Is a contribution or investment asset preferred?
- What is the total cost for the family rather than the advertised minimum?
- Are there any existing nationality or dual-citizenship restrictions?
- Is US E-2 eligibility relevant?
- Are there potential due diligence issues that need to be addressed before applying?
- How does citizenship fit with the applicant's existing residence, tax and estate planning?
The answer may also be that Caribbean citizenship is not the appropriate route.
Comparing Citizenship by Investment with residence programmes and other immigration options before committing to an application can prevent an applicant from obtaining a citizenship that does not actually address their objectives.
Tax considerations for Caribbean citizenship
Obtaining Caribbean citizenship does not automatically make an applicant a tax resident of that country, nor does obtaining a second passport automatically change their existing tax obligations.
Citizenship and tax residence are separate issues.
The tax consequences will depend on factors including where the individual lives, how much time they spend in particular countries, where their income arises, the location of their assets and businesses, and the tax residence rules of the countries concerned.
Applicants considering a Citizenship by Investment programme as part of wider tax or wealth planning should therefore obtain appropriate tax advice based on their individual circumstances.
Why work with Harvey Law Group?
Harvey Law Group has advised individuals and families on investment immigration matters since 1992.
Choosing a Citizenship by Investment programme involves more than comparing passport rankings or minimum investment amounts. The applicant's nationality, family structure, source of funds, business interests, travel requirements and long-term plans can all affect which programme is appropriate.
Our lawyers can assess the available options, identify potential eligibility or due diligence issues and manage the legal aspects of the application from the initial assessment through to the final decision.
Where an applicant is considering several jurisdictions, we can also compare Caribbean citizenship with other residence and citizenship options to determine which route best fits their wider objectives.
Frequently asked questions
Which Caribbean countries offer Citizenship by Investment?
Five Caribbean countries currently operate established Citizenship by Investment programmes: Antigua and Barbuda, Dominica, Grenada, St. Kitts and Nevis, and Saint Lucia.
What is the cheapest Caribbean Citizenship by Investment programme?
The answer depends on the number and type of applicants included.
For a single applicant, Dominica currently has a government contribution starting at US$200,000. However, the minimum contribution is not the total application cost. Due diligence, processing and other government fees must also be considered.
For families, the relative cost can change significantly because each programme treats dependants differently.
Can I include my family?
Yes. All five programmes allow qualifying family members to be included.
Eligibility depends on the programme and may extend to a spouse, children, parents, grandparents and certain other dependants. Age, financial dependency and education requirements may apply.
Do I have to live in the Caribbean?
The programmes do not generally require applicants to relocate permanently before citizenship can be obtained.
However, individual programmes may impose particular presence or other requirements, so these should be checked before applying.
Can I keep my existing citizenship?
The five Caribbean Citizenship by Investment countries permit dual citizenship.
Whether an applicant can retain their existing nationality will also depend on the nationality laws of their current country or countries of citizenship.
Can I buy any property and qualify for citizenship?
No.
Where citizenship is sought through real estate, the investment must comply with the requirements of the relevant programme. This generally means investing in a property or project approved or otherwise qualifying under that programme.
Is Caribbean citizenship permanent?
Citizenship granted under the programmes is intended to be citizenship for life and may generally be passed to future generations in accordance with the country's nationality laws.
Citizenship can nevertheless be revoked in circumstances provided by law, including where it was obtained through fraud, false representation or concealment of material information.
Does Caribbean citizenship make me tax resident?
Not by itself.
Citizenship and tax residence are different legal concepts. Tax residence will depend on the relevant country's rules and the individual's personal circumstances.
Can Grenadian citizens apply for a US E-2 visa?
Grenada is an E-2 treaty country with the United States.
A Grenadian citizen may therefore be eligible to apply for an E-2 Treaty Investor Visa if they make a qualifying investment in a US business and satisfy the other E-2 requirements.
Obtaining Grenadian citizenship does not itself guarantee that an E-2 visa will be approved.
What is ECCIRA?
There’s a lot of talk lately about the new central authority in the Caribbean. The initials are ECCIRA, which should start their full operation in the coming days or week. This new authority is definitely good news again to legitimize the Caribbean citizenship by investment programs, and will help to standardize a lot of the approach.
It comes from minimum investment, minimum residency requirement, and of course the way to promote, how to promote, and how not to promote. The different programs, what to offer and what not to offer. This is definitely great news for the industry.
Does ECCIRA replace the five Caribbean Citizenship by Investment programmes?
No.
Each participating country continues to operate its own Citizenship by Investment programme and applicants continue to apply for citizenship of an individual country.
ECCIRA provides regional regulation and common standards across the five programmes rather than creating a single Caribbean citizenship.
Is Caribbean citizenship by investment coming to an end?
We often get the question as what is the future of the Caribbean program - programs, I should say.
Due to all the changes, the EU interest into the citizenship by investment, same for US, for Canada, and many other countries. Actually, without the changes, we can be sure that citizenship by investment is just getting stronger, especially in the Caribbean.
The level of due diligence and the professionalism now from the different citizenship units is definitely more robust than it used to be. And from that, I see a very bright future for it. The great thing about, also, the CBI – citizenship by investment industry- is that it used to be on the edgy side of things before, and now it’s fully legitimate.
I mean, the majority of the population understand this is a legitimate program, that there’s no funny game behind all this, and it’s a well-regulated way to acquire citizenship.
Can the EU, US, or UK take away my Caribbean citizenship?
We’ve got a lot of calls lately from existing clients, wondering because of the EU scrutiny and order, that if they can lose their citizenship, that they acquired from one of the Caribbean countries. This is totally wrong. There’s a wrong perception I should say. Citizenship by investment is the product of law of each of those countries, and it is a matter of sovereignty for each of those countries, to whom they offer such citizenship.
What EU is talking about in other countries, like the UK did with Dominica for example, and other countries is, they may want to impose a visa for people to travel from certain countries, like they always did and always will do. Canada, US, UK is doing that too. So, of course, there’s no chance that you may lose citizenship.
This is yours, it’s yours for your life, and for generations to come.
What may change is that you may have to have another step later on to go on the online and apply for ETA or apply for visitor visa like we all have to do at one point or the other. This is the worst case scenario: is that either ETA or visa would be required, but we had the experience with Dominica when UK imposed a visa, and most of our clients just went online, applied for a visa, get multiple entry visa, and that was not a problem.
So, again, it’s just one – maybe one step they will add to the process, but that’s about it.
Which Caribbean citizenship program is the best?
one of the questions that I often get, together with the team, is which CBI program is the best between the all the 5 programs that exist already. The answer to that is all of them and none of them. Why I say that is because it all depends on your goals, of your profile, what you’re looking for, what is the end result that you want by acquiring a citizenship by investment.
Some people is for tax reasons, some people is for protection, some people is for travel free. So, by example, Saint Kitts and Nevis doesn’t have diplomatic relations with China; they have diplomatic relations with Taiwan. So, of course, for some clients, this is a big plus, and they would choose Saint Kitts for that.
Other client like the fact that Saint Lucia offers a government bond in which they can invest, and they feel secure with this. If I take Grenada, Grenada is an E2 country, so for people who may wish to do business in the US later, Grenada is an obvious choice.
Then, if I look at Antigua, Antigua is a lot more inclusive in terms of the definition of a family, and who is part of the family or not. So, again, if you want to bring your grandparents, your brother or sister… Antigua is definitely more open in their definition.
Of course, we have Dominica. Dominica, for some people, they love the idea of the “organic” side of Dominica, but also about the fast processing. We have clients that want to acquire citizenship by investment as fast as possible for different reason. Not only for tax, they’re going for IPO later on, and things like that, so Dominica would be an obvious choice too.
So, there is no best program, there is no worst program. It all depends on what you need.
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