- Report from the Commission to the European Parliament and the Council Seventh report under the visa suspension mechanism – Brussels, 6.12.2024 COM (2024) 571 final.
- Eastern Caribbean (Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia).
BRUSSELS / EASTERN CARIBBEAN – Since 2020, the Commission has been engaging with the five visa-free Eastern Caribbean countries operating investor citizenship schemes (Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia) to obtain relevant information and data on those schemes.
All five countries operate different investor citizenship schemes, which consist mainly in either direct contributions to the state budget or investments in large infrastructure, utilities or real estate projects. The first option is normally cheaper, while the real estate option is normally more expensive. The process to apply for citizenship and the due diligence and security screening used are similar across the five countries, with five main steps:
1) Licensed marketing agents are trusted to find interested investors in third countries.
2) Interested investors file their applications through authorised local agents, who submit the applications and supporting documents to the Citizenship-by-investment (CBI) unit.
3) A three-layer vetting process is conducted on the origin of the funds (by the banks), on the identity, security and reputational profile of the applicants (by international due diligence firms) and on the security and immigration risks (by the CARICOM Implementation Agency for Crime and Security’s Joint Regional Communications Centre – JRCC).
4) Based on the above-mentioned checks, the CBI unit approves or rejects the application.
5) For approved applications, the final decision on the granting of citizenship is taken by competent minister.
As presented in the Sixth Visa suspension mechanism report of October 2023, there are several elements emerging from the Commission’s assessment, suggesting that the five countries’ screening and vetting procedures may not be sufficiently thorough to ensure the rejection of applications from individuals who could be a potential security risk for the EU once acquiring the citizenship of those countries and consequently visa-free access to the EU.
None of the five countries require residence or even physical presence in the country before citizenship is granted. This implies that the biometrics of successful applicants are not registered. Also, to various extents, all five countries allow successful applicants for the possibility to change their name after having obtained citizenship by investment. In Antigua and Barbuda and Dominica, it is allowed as of five years after obtaining citizenship; in Grenada after one year. However, the old name is kept in the passport under the heading ‘observations’.
Since the publication of the sixth report, for all countries’ schemes the number of successful applicants has continued to increase, while the number of rejections remain relatively low, despite some increasing trends for some countries. The table below includes the data provided to the Commission by the five countries.
The successful applicants continue to include mostly nationals that would otherwise require a visa to enter the EU. The main successful applicants’ nationalities in 2023-2024, according to the information received, include Iran (1 918), China (1 099), Syria (747), Iraq (425), Nigeria (308) and Lebanon (149), among others.
Following the Russian aggression against Ukraine, all five countries have suspended the examination of applications from Russian and Belarusian nationals. However, in 2023 Grenada still had a considerable number (around 2 300) of pending applications from Russian nationals which have been processed in 2024.
Following the publication of the sixth report, the Commission has continued the engagement with the five countries, at both political and technical level. On 12 January 2024, the Commission held a high-level meeting with the Prime Ministers of the five countries, which was followed by a technical fact-finding mission of the Commission services to the region in January 2024 and exchanges of information in writing.
The mission and the updated information received confirmed most of the main concerns presented in the sixth report, i.e., that the investor citizenship schemes cannot be zero-security-risk, as well as the economic and political importance of those schemes for the five countries.
At the same time, over the past months all five countries have showed an increased awareness of the need to strengthen their due diligence and security screening systems, and openness to substantial improvements with the support of their international partners. In particular, in the first months of 2024, the five countries signed a Memorandum of understanding providing a framework for cooperation to strengthen the security of their schemes. In accordance with the memorandum, the five countries decided to harmonise the minimum investment fee to 200 000 USD.
For Antigua and Barbuda, Dominica, Grenada and Saint Lucia this constituted an increase of 100 percent (from a previous threshold of 100 000 USD). The memorandum also included a commitment to share information on applicants, implement enhanced transparency measures, establish a regional regulation authority, strengthen their security screening frameworks, and establish common standards on agents, marketing and promotion of schemes.
The Commission will continue to work in close cooperation with the five Eastern Caribbean countries and assess the implementation of the above-mentioned reforms, under the current legal framework of Article 8(2)(d) of the Visa Regulation that provides for the triggering of the visa suspension mechanism in cases of an increased risk or imminent threat to the public policy or internal security of Member States. Once the revised visa suspension mechanism will be adopted, the Commission will adapt its assessment on the basis of the new rules. In any circumstances, the Commission’s assessment will continue to take due account of the overall relations between the EU and the third countries concerned as well as the overall political context.
- Report from the Commission to the European Parliament and the Council Seventh report under the visa suspension mechanism – Brussels, 6.12.2024 COM (2024) 571 final.
