CBI Agents and Promoters are licensed by citizenship by investment units. Each of them have different roles and it is important to understand the difference between local agents and authorized service providers.
It is important to note that International marketing agents work with local agents to submit file of the applicant to CBI unit. The rule is marketing agents cannot submit file directly to the government CBI unit without involving the local agent. CIP regulations require full list of agents and service providers are published in the official websites CBI units for easy access for investors.
We have compiled the role of authorized agents, promoters and marketing agents specific to each country to see the picture clearly.
St Lucia
Authorized Agent
An Authorised Agent is licensed by the Citizenship by Investment Board and is authorised to act on behalf of the applicant in relation to an application. Authorised Agents have close ties with the Citizenship by Investment Units. Only Authorised Agent can check on the status of your application.
Promoter
A Promoter is licensed by the Saint Lucia Citizenship by Investment Board to market the Programme globally, thereby driving applications.
Marketing Agent
A Marketing Agent is licensed by the Citizenship by Investment Board and has direct obligation to market the Programme by way of roadshows, conferences and other marketing efforts which may contribute to the enhancement of the Programme globally.
Grenada
Authorized International Marketing Agents
Authorised International Marketing Agents are trusted global marketers who are permitted to promote, market, and disseminate information about Grenada’s Citizenship by Investment Programme. Authorised International Marketing Agents can assist you, along with an Authorised Local Agent, in obtaining your citizenship.
Authorized Local Agents
Authorised Local Agents are specialist CBI lawyers have the skills and experience to assist you every step of the way as you apply for citizenship by investment in Grenada. Importantly, your application for citizenship by investment will only be accepted if you use an Authorised Local Agent.
Escrow Agents
The Grenada Citizenship by Investment (Approved Projects) Regulations, 2017 which govern the CBI approved projects make provision for the setting up of a project escrow account by a developer with a licensed financial institution in Grenada and the signing of an escrow agreement between the developer of an approved project and the Committee. The regulations also mandate strict monitoring and oversight of approved projects by the
Committee.
To assist in the strict monitoring and oversight of approved projects, the escrow agreement makes provision for the management of escrow accounts by escrow agents who shall facilitate the draw-down of funds from the escrow account in keeping with stipulations and criteria set out in the agreement.
Dominica
Authorized Agents
Authorised CBIU Agents have a great deal of experience in assisting with citizenship by investment programs, with the skills required to assist you through every step of your application. They provide professional advice and assistance with preparing and submitting your application for citizenship by investment in Dominica.
Promoters
Promoters and sub-agents must be registered by an Authorised Agent and are responsible to the Authorised Agent for all their promotional and marketing activity. They provide invaluable assistance to applicants from all corners of the globe both in familiarising them with the Dominica Citizenship by Investment Programme and in providing tailored advice on how to obtain supporting documents, complete forms, and keep in touch with Authorised Agents.
St Kitts and Nevis
Authorized persons
An authorised person is an individual or entity approved by the Financial Services Regulatory Commission (FRSC) of St. Kitts and Nevis licensed to conduct corporate or trust services in St Kitts and Nevis. Authorised persons must be appointed by a main applicant by way of Limited Power of Attorney to act on their behalf in relation to all matters regarding their Citizenship by Investment application. They are required to provide professional advice, assist and give details regarding the application process and help with the preparation and submission of an application for Citizenship by investment and its supporting documents. Your authorised person will engage the Citizenship by Investment Unit and maintain a point of contact to review all matters surrounding the application, make payments and submit and collect all important correspondences.
Authorised persons are required to renew annually both their FSRC and CBI authorisations.
International Marketing Agents
Effective January 1, 2017 the Government of St. Kitts and Nevis approved the promotion of the Sugar Industry Diversification Fund (SIDF) by registered International Marketing Agents. They are trusted global entities authorized to market and distribute promotional information about the St. Kitts and Nevis Citizenship by Investment Program.
International Marketing Agents are required to renew annually their authorization and are further required to list their sub agents and their websites, show evidence of documented AML/KYC policies and identify their marketing areas.
Applications generated by International Marketing Agents are to be submitted to the Citizenship by Investment Unit through the Authorised Persons
Escrow Agents
An escrow account is a bank account opened with an escrow agent in the escrow agent’s name for the benefit of the parties to a principal agreement such as a real estate purchase contract. The escrow agent oversees the management of an escrow account subject to certain conditions based on the principal agreement and the escrow agreement. The escrow agent – who is a neutral third party – temporarily holds the purchase money and supervises the payments (the timing and amounts of disbursements).
Antigua and Barbuda
Licensed agents
Agents who are issued license by the Government are authorized to act on behalf of the main applicant in relation to the CBI application. Agents license may only be issued to natural person who is resident of Antigua and Barbuda
Authorized Service Providers
Authorized representatives are appointed from time to time to contract representatives and service providers to promote, advertise, and disseminate information on the citizenship by investment program.
Turkey
Turkey does not publish official list of agents and service providers.
Montenegro
The Investment Agency of Montenegro officially maintains list of licensed agents and due diligence firms responsible for the special citizenship by investment program (expires on Dec 31, 2021).
Malta
Malta appoints Licensed Agents who are approved and licensed by Community Malta Agency (the Agency) thereby authorising them to guide them through the whole application process and submit prospective applications under the Granting of Citizenship for Exceptional Services Regulations (S.L. 188.06) and the Agents (Licences) Regulations (S.L. 188.05).
These Agents may be public accountants or auditors, lawyers, or financial advisors duly licensed by a competent Authority, after attending training organised by the Agency and satisfying such other conditions and requirements as may be set out in the guidelines issued by the Agency from time to time.
Bulgaria
Bulgaria does not appoint any agent or service provider for the purpose of the citizenship by investment program.
Vanuatu
The Vanuatu citizenship commission has appointed local DSP agents (35+) and VCP Agent (1) for its two citizenship programs. These agents are nationals of Vanuatu assigned the task of submitting applications with citizenship commission
No marketing agents are appointed.
Due diligence Firms
Due diligence companies that do vetting are an important cog in the CBI programs. These third party companies are responsible for doing background check from behind the scenes which takes about 90 days. Investigative reports are directly submitted to CBI units calculating the risk. Applicants are required to bear due diligence fees from their side. You can find full list of due diligence firms in the CBI industry.
