St Kitts Doubles Investment Requirement

The government of St Kitts has announced significant increases in its investment limits for applications to its Citizenship by Investment programme. The move comes as St Kitts looks to be the first island to fall into line with EU guidelines for CBI programmes. In a press release dated 27^th July the government announced that the Sustainable Growth Fund (SGF) option is immediately replaced by the Sustainable Island State Contribution (SISC) option. The Limited Time Offer for the SGF option originally extended to 31 January 2024 has been closed with immediate effect.

Investment amounts are now as follows:

• Main applicant only: US$250,000
• Main applicant and a spouse: US$300,000
• Main applicant and one dependant: US$300,000
• Main applicant, a spouse and one or two dependants: US$350,000
• Main applicant and two or three dependants: US$350,000

The new amounts represent a 100% increase for single or family applications.

While the increase only affects St Kitts we expect the remaining Caribbean countries operating CBI programmes, that is, Antigua, Grenada, Dominica and St Lucia to fall in line with similar price increases in the coming six months.

The move by St Kitts followed guidelines issued by the EU. The European Union has laid down several new guidelines for countries offering citizenship by investment programmes following a recent meeting held between leaders of Caribbean countries and EU officials in Brussels. The guidelines are as follows:

1. Implement robust due diligence: Due diligence must be conducted on each applicant by reputed and legal international due diligence firms based in top-tier countries such as the EU, US and UK.
2. Implement mandatory interviews: Mandatory interviews of all CBI applicants must be conducted. These interviews could be held through a trusted online digital platform or in person (if possible).
3. Enhancing security measures: No official documents related to alternative citizenship or passports should be sent to the investors/new citizens through postbox (mail) after the citizenship is granted.
4. Increase of investment thresholds: Investment amounts must be increased up to US $200,000 (minimum) for a single applicant under the donation option and US $400,000 (minimum) for real estate investment options.
5. Investment must reach host country: The countries offering CBI programmes must properly monitor the flow of funds and verify it against stringent money laundering processes. This will include the provision that the funds must be directly transferred to the host nation under any situation and must not be diverted into accounts in any other country.
6. Abolition of promotional material of passports: All promotional material of passports must be repealed from these third nations showing the benefits of visa-free access to the European Union or other visa free country.

The guidelines have been laid down by the EU with the primary focus of ensuring that nations execute exceptional standards in their CBI programmes. The EU stated that the minimum amount of investing through donation on such programmes must be raised to at least US $200,000 for single applicant, while for applications made through the real estate option, the minimum investment must be US$400,000. The St Kitts new investment limits are exactly in line with these guidelines. The new requirements are to ensure that CBI programmes attract only those high net worth individuals with a significant capacity to contribute economically to the host nation.

The European Commissioner for Home Affairs, Ylva Johansson, is set to lead an oversight committee to monitor the overall operations of Caribbean programmes over the coming six months.

While the EU holds no jurisdiction over the Caribbean countries each of the five countries offering CBI programmes has visa-free access to the EU Schengen Zone and governments are no doubt keen to preserve that access for their citizens. Apart from specifying investment limits the guidelines are similar to those issued by the USA some months back.

Both the US and EU moves are positive in the sense of recognising the programmes have a legitimate role to play in global mobility subject to minimum standards being maintained.