Due Diligence in the Investment Migration Industry

A common challenge for citizenship by investment programme (CBI) administrators is verifying information and claims about an investor’s background quickly and efficiently. This is where due diligence in the Investment Migration Industry (IMI) comes in.

What is Citizenship by Investment Due Diligence?
CBI programmes are an effective method of raising capital investment and attracting talent and experience that help to boost regional economic growth. However, any significant inflow of funds brings a risk of money laundering or financial impropriety if not carefully vetted.  Effective enhanced due diligence processes are imperative to ensure that only reputable and honest investors are allowed to obtain citizenship. Therefore, each investor application requires a thorough and careful audit to mitigate any security, financial crime, and reputational risks. This is known as due diligence. 

Average Time

Average time to complete due diligence, including internal due diligence by the Unit and external due diligence by international, expert firms: three months.  
Due Diligence in the Caribbean
The Caribbean is a region leading the way in due diligence because of its multi-layered approach to the process. There are many entities involved in the due diligence process: Authorised Agents, Citizenship by Investment Units, independent due diligence firms, law enforcement and intelligence agencies, and partner governments. Due Diligence in the caribbean infographic
Due Diligence Fees
The due diligence fees levied in the Caribbean as part of a citizenship by investment application are: 

Antigua and Barbuda 

Main applicant  US$7,500 
Spouse  US$7,500 
Other family member aged 12-17  US$2,000 
Other family member aged 18+  US$4,000 

Dominica 

Main applicant  US$7,500 
Per family member aged 16+  US$4,000 

Grenada 

Main applicant  US$5,000 
Per family member aged 17+  US$5,000 

St Kitts and Nevis 

Main applicant  US$7,500 
Per family member aged 16+  US$4,000 

* Note: due diligence fees must also be paid for family members who will turn 16 within three months of submitting the citizenship application 

Saint Lucia 

Main applicant  US$7,500 
Per family member aged 16+  US$5,000 
 
Due Diligence Firms Used
All Caribbean countries that offer CBI require applicants to undergo vetting by a number of entities, including independent due diligence firms. These due diligence firms are highly respected and have the ability to perform checks that cover sanctions lists, open-source checks, and on-the-ground assessments. Some of the due diligence firms that have been mandated by Caribbean jurisdictions include S-RM, Thompson Reuters, Exiger, and Fact. 
Entities That Will Scrutinise an Applicant for Citizenship by Investment

Authorised Agents

In the Caribbean, CBI regulations requires all applications to be directed through an Authorised Agent, a person or entity licensed by the government to act on applicants’ behalf when they apply for citizenship by investment. These agents are monitored and listed on the official website of the relevant Citizenship by Investment Unit. They are specialised experts who have the skills and experience needed to assist applicants through the application process and help prepare and submit applicant’s files and documents to the Unit.

Citizenship by Investment Unit

Internal checks are conducted by the Unit staff, who have expertise in document review, anti-money laundering, and counter-terrorism financing. They make sure all documents adhere to the Unit’s requirements and perform open-source checks on all applicants and dependants.

Independent Due Diligence Firms

Caribbean CBI nations mandate independent, qualified due diligence firms to conduct further checks on applicants. These firms perform on-the-ground checks to verify information provided in the forms and supporting documents, check sanction lists, and produce a report on the applicants’ identity, source of funds and political exposure, which is then handed to the Unit.

Law Enforcement and Intelligence Agencies

The Joint Regional Communications Centre (JRCC) arm of the CARICOM Agency for Crime and Security provides an additional layer of security that is unique to the Caribbean. Applications forwarded to the JRCC are cross-referenced with watchlist databases, Interpol, and partners governments, including Canada, the UK, and the US.
About CS Global Partners
Headquartered in the heart of London, with offices across the Middle East, Africa and Asia, CS Global Partners comprises of a passionate team of reputable specialists and lawyers. As authorised agents, we provide expert advice to investors looking to apply for second citizenship and advise you on which option is best for you and your family. To get a free consultation, contact us