Post-MOA: Comprehensive Update on the Caribbean CBIs

After more than a week since the start of the MOA validity, we now have a clearer and more comprehensive image of the changes and their impacts. Five Caribbean nations—Dominica, Antigua and Barbuda, Grenada, St. Kitts and Nevis, and St. Lucia—signed a Memorandum of Agreement (MOA) in March 2024. This MOA, which set a deadline of June 30, 2024, for the implementation of new regulations, has led to a series of announcements from the participating countries in the past week, each detailing their commitment to the agreed-upon changes.

New regulations and investment requirements

St. Kitts and Nevis

St. Kitts and Nevis was the first to act, implementing new regulations in July of 2023, ahead of the curve. Now in the attempt to equalize prices with other Caribbean jurisdictions they have issued a revised amounts for the donation route, keeping it the same for one applicant and a family of four. The updated investment amounts are:

  • Donation to the government fund:

    1. Single applicant: US$ 250,000
    2. Family of up to four members: US$ 250,000
  • Donation to an Approved Public Benefit Project

    3. Minimum investment in a unit: US$ 250,000
  • Government-approved Real Estate: US$ 400,000
  • Government-approved Private Home:
    • Condominium: US$ 400,000
    • Single-family home: US$800,000

Grenada

Following St. Kitts and Nevis, Grenada declared the commencement of its changes with notable updates:

Investment requirements effective from July 1, 2024, are:

  • National Transformation Fund

    1. Single applicant + three additional family members: US$ 235,000
  • Real estate option: US$ 350,000

Additionally, due to the impact of Hurricane Beryl, Grenada has requested a postponement, accepting applications under old investment amounts until July 12, 2024, with all processes to be completed by July 31, 2024.

St. Lucia

St. Lucia’s new regulations, effective from July 1, 2024, set the following investment requirements:

  • National Economic Fund:

    4. Single applicant + three additional family members: US$ 240,000
  • Real estate option: US$ 300,000
  • National action bond: US$ 300,000 (unchanged amount)
  • Approved enterprise project option III. Infrastructure project: US$ 250,000 for a single applicant + three additional family members

    *(the rest of the Approved enterprise project options kept the same prices:
    I. Single applicant: US$ 3,500,000
    II. Joint venture: US$ 6,000,000 (each applicant contributing at least US$ 1,000,000)) *

St. Lucia has granted a one-month grace period, allowing ongoing applications to be processed under the old regulations until July 31, 2024.

Dominica

Dominica released its new regulations with the following investment amounts effective from July 1, 2024:

  • Economic diversification fund:

    5. Single applicant: US$ 200,000
    6. Family of up to four members: US$ 250,000
  • Real estate option: US$ 200,000

Antigua and Barbuda

Antigua and Barbuda affirmed their commitment to the MOA’s stipulations with changes effective from August 1, 2024, with recommended amounts of:

  • Donation route:
  1. Single applicant + three additional family members: US$ 230,000
  • Real estate option: US$ 235,000

Update: Please check this article about the final prices since 1st August: https://ntltrust.com/news/second-citizenship/antigua-and-barbuda-announces-changes-to-citizenship-by-investment-regulations/

Transition period for ongoing applications

The changes have raised questions about the fate of applications currently in process. Antigua and Barbuda will implement the new regulations starting August 1, 2024, providing a short buffer for applicants. St. Lucia has granted a one-month grace period, allowing ongoing applications to be processed under the old regulations until July 31, 2024.

Grenada reported on July 3rd, they will be giving a grace period, asking for a postponement of new rules to July 12, 2024, following an emergency lockdown due to Hurricane Beryl. They are accepting applications under the old investment amounts until July 12, 2024, with the necessity to receive funds and cleared documentation for the application by July 31, 2024.

Implications for the Citizenship by Investment industry

The collective action of these nations underscores a unified effort to strengthen due diligence processes, preserving the privilege of citizenship and safeguarding against illegal activities that could undermine the programs, the countries, or other applicants. Alongside the increased investment amounts, the introduction of higher government fees aims to bolster the programs’ financial contributions to the respective economies.

Stay tuned for more updates as we closely monitor changes in the Caribbean programs so we can advise you to our fullest potential when you decide to start your citizenship journey. As a trusted partner, NTL Trust is here to help you navigate all dilemmas and guide you to the best solution for you.

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