The Government of Saint Kitts & Nevis has made important changes to CBI regulations in 2023, replacing the 2022 version. We have compiled the questions and answers below regarding the citizenship by investment of Saint Kitts and Nevis – Regulation No.4 of 2023, pursuant to Section 15 of Citizenship Act, Cap. 1.05.
1.What is Accelerated CBI application?
An “Accelerated CBI application” means an application for Citizenship by Investment that is processed within sixty calendar days of the acknowledgment of the application by the Citizenship by Investment Unit
2. What are Approved private homes?
“Approved Private Home” means land with a private dwelling home that has been approved by Cabinet as a qualified private home for sale for Citizenship by Investment pursuant to regulation 31;
An Approved Private Home shall qualify for Citizenship by Investment if a minimum investment sum of US$400,000 shall be paid to the owner of the Approved Private Home by the main applicant. Two or more CBI applicants may apply together by purchasing one Approved Private Home, provided that each main applicant contributes the minimum investment of US$400,000 towards the investment.
3. What is CBI application?
“CBI application” means an application for Citizenship by Investment submitted to the Citizenship by Investment Unit
4. What is Non-accelerated CBI application?
“non-accelerated CBI application” means an application for Citizenship by Investment that is processed within ninety calendar days of the date of acknowledgment of the application by the Citizenship by Investment Unit, unless delayed for cause;
5. What are the Post Approval-in-Principle CBI Application Fees applicable to SGF fund?.
The following application fees shall be paid to the Unit on every non-accelerated CBI application after approval-in-principle is granted by the Unit, except with respect to Part VI Sustainable Growth Fund contributions, and in addition to the due diligence fees prescribed in regulation 33—
(a) US$25,000 (Twenty-Five Thousand United States Dollars) for the main applicant;
(b) US$15,000 (Fifteen Thousand United States Dollars) for the spouse of the main applicant;
(c) US$10,000 (Ten Thousand United States Dollars) for each dependant child of the main applicant or other qualified dependant under eighteen years of age, including each dependant child born after the CBI application is submitted to
the Unit and before the date the Certificate of Citizenship is issued to the main applicant;
(d) US$15,000 (Fifteen Thousand United States Dollars) for each dependant child of the main applicant or other qualified dependant aged eighteen years or older; and
(e) US$30,000 (Thirty Thousand United States Dollars) for addition of spouse or other qualified dependant after approval-in-principle of the main applicant.
6.What is Public benefit option?
“Approved Public Benefit” means a benefit for the public good in Saint Christopher and Nevis that has been designated by Cabinet.. A public benefit unit in an Approved Public Benefit Project shall qualify for Citizenship by Investment, if a minimum donation of US$175,000 shall be paid to the Approved Public Benefactor by the main applicant.
Where any person or entity wishes to—
(a) develop an industry;
(b) finance the construction of a real estate development project on State land;
(c) construct a real estate development project on State land; or
(d) otherwise bring some substantial benefit to the people of Saint Christopher and Nevis; that person or entity shall apply to the Board of Governors to be designated as an Approved Public Benefactor.
The project must also
(b) maximise local employment;
(c) embark upon programmes including transfer of technology and local capacity building;
(d) if the investment results in a real estate development project on State land, agree to transfer all real estate to the State on substantial completion; and
(e) assume all financial risks involved with the project
7.What is an Authenticated translation?
An “authenticated translation” means a translation—
(a) prepared by a professional translator who is officially accredited by a court of law, a government agency, an international organisation, or similar official institution; or
(b) if done in a country where there are no official accredited translators, a translation done by a company whose role or business is preparing professional translations into the English language;
8.Who is an authorised agent?
An “authorised agent” means a person licenced by the Financial Services Regulatory Commission to conduct corporate or trust services in Saint Christopher and Nevis, who has paid the authorised agent’s fees pursuant to regulation 38 and
is authorised to act on behalf of the main applicant in relation to a CBI application;
9.Can St Kitts citizenship acquired through investments be revoked?
If a person found to have provided false or incorrect information, the applicant may be deprived of Citizenship of Saint Christopher and Nevis pursuant to Section 8(a) of the Saint Christopher and Nevis Citizenship Act, Cap. 1.05 titled “Deprivation of citizenship obtained by registration”
10.How do i get certified copies of document?
A notary public certifies a document to be a true copy of the original, that document must be authenticated by—
an Apostille in accordance with the provisions of the Hague Convention of 5th October 1961 Abolishing the Requirement of Legislation for Foreign Public Documents, in the case of countries that are parties to that Convention; or proof of the expiry date of the commission for that notary public in the case of certification made by notaries public in the United States of America, Canada, and in countries which are not party to the Hague Apostille Convention.
11.What is the eligibility criteria for family members?
Please see the conditions for family members below.
- “child” means a biological or legally adopted child of a main applicant, or of the spouse of the main applicant.
- “spouse” means the partner of the opposite sex of the main applicant by marriage in accordance with the Marriage Act, Cap. 12.09, and the Marriage (Prohibited Degrees of Relationship) Act of Saint Christopher and Nevis
Dependant” means —
(a) a spouse of the main applicant;
(b) a child under eighteen years old;
(c) a child between eighteen and twenty-five years of age who is in full time attendance at a recognised secondary or tertiary level institution of learning and fully supported by the main applicant;
(d) parents or grandparents of the main applicant aged fifty-five years or older living with and fully supported by the main applicant;
(e) parents or grandparents of the spouse of the main applicant aged fifty-five years or older living with and fully supported by the main applicant or the spouse of the main applicant;
(f) a child aged eighteen years or older and physically or mentally challenged;
(g) a brother or sister of the main applicant or his or her spouse, who is—
(i.) unmarried;
(ii) childless;
(iii) twenty-five years of age or younger; and
(iv) is dependent on the main applicant or his or her spouse for financial
support.
12.Who should sign the forms for children?
for a child who is below the age of eighteen, both parents must sign the forms on behalf of the child as the child’s legal guardians; or in a case where one parent has sole custody of a child, or another person has legal guardianship of a child, the appropriate legal documentation shall be provided to demonstrate that sole custody or guardianship of that child was awarded by a court of law or other relevant authority.
13.What is an Escrow agreement?
Escrow agreement” means an agreement between an escrow agent and the parties to a binding agreement to purchase a real estate unit from the developer of an Approved Development , under which the escrow agent agrees to supervise the parties’ payments pursuant to the provisions of the Saint Christopher and Nevis Citizenship (CBI Escrow Accounts) Act,
14.Can i get financing for real estate investment?
You should provide a letter from a licenced financial institution stating that approval-in-principle for financing for the development has been granted,
15.What are the processing times for SGF fund applications?
From the 1st day of January, 2023 to the 30th day of June, 2023, within sixty days of the date of acknowledgment of a CBI application made under this regulation by the Unit, the Unit shall notify the authorised agent on behalf of the main applicant whether the application
has been—
(a) approved-in-principle;
(b) denied; or
(c) delayed for cause and still being processed.
16.What is the Limited time offer for SGF applications?
From the 1st day of January, 2023 to the 30th day of June, 2023, the minimum contribution to the Sustainable Growth Fund shall be as follows—
(a) for a main applicant only: US$125,000 (One Hundred and Twenty-Five Thousand United States Dollars);
(b) for a main applicant and a spouse: US$150,000 (One Hundred and Fifty Thousand United States Dollars);
(c) for a main applicant and up to three dependants: US$170,000 (One Hundred and Seventy Thousand United States Dollars);
(d) for each additional dependant under eighteen years of age: US$10,000 (Ten Thousand United States Dollars); and
(e) for each additional dependant eighteen years of age or over: US$25,000 (Twenty-Five Thousand United States Dollars)
NOTE: From the 1st day of January, 2023 to the 30th day of June, 2023, a decision is issued within sixty days of the date of acknowledgment of a CBI application under accelerated processing (no cost) .
After the 30th day of June, 2023 the minimum contribution to the Sustainable Growth Fund shall increase by USD 25,000 on all of above categories and processing times will be increased to non-accelerated 90 days
17.What is ‘CBI’ Unit?
“Unit” means the Government office within the Ministry having responsibility for citizenship known as the Citizenship by Investment Unit established to process all applications submitted for Citizenship by Investment specified in regulation 5
18.What is the role of Citizenship by Investment Technical Committee?
The Minister shall appoint a Technical Committee charged with the responsibility of—
(a) reviewing CBI applications submitted to the Unit;
(b) ensuring that all due diligence background checks are comprehensive and completed throughout the CBI application process;
(c) conducting spot checks of CBI applications; and
(d) providing information sufficient to justify any recommendation to the Minister to approve or deny CBI applications for Citizenship by Investment.
The Committee shall make recommendations to the Minister based on its findings in relation to CBI applications under review
19.What is the basic qualification to apply for SKN citizenship?
(1) Any person who —
(a) is at least eighteen years of age;
(b) has made an investment pursuant to these Regulations; and
(c) meets the CBI application requirements,
may apply as a main applicant to become a citizen of Saint Christopher and Nevis pursuant
to section 3(5) of the Saint Christopher and Nevis Citizenship Act, Cap. 1.05.
(2) A person who has—
(a) been denied a visa to a country to which citizens of Saint Christopher and Nevis have visa-free travel; and
(b) not subsequently obtained a visa to the country that issued the denial;
shall not be eligible to apply for Citizenship by Investment in Saint Christopher and Nevis
20.How do i provide proof of Enrollment in School?
A CBI applicant between the age of eighteen and twenty-five years who is applying as a dependant of a main applicant shall submit official transcripts from a recognised secondary or tertiary level institution of learning or a letter from the competent authority confirming the applicant’s enrolment at such institution of learning.
21.What is licensed surveyors report on property?
A licenced quantity surveyor’s report contains details about the following—
(i) the estimated or actual cost of construction of the entire development;
(ii) the estimated cost of construction of the remaining elements of the development, if construction has already begun but the development remains incomplete; and
(iii) the estimated cost of construction of each major phase of the development, if the development has not been substantially completed;
22.What is the criteria to invest in real estate for citizenship?
A person may submit a CBI application pursuant to this investment option on his or her behalf through an authorised agent only if—
(a) a designated real estate unit in an Approved Development pursuant to sub-regulation (6) is available; and
(b) the main applicant executes a binding agreement to purchase the real estate unit of an Approved Development from its developer.
23.Can i sell the property immediately after citizenship?
A real estate unit which is the subject of an application for Citizenship by Investment submitted to the Unit after the 10th day of March, 2023 shall—
(a) not be resold until a period of seven years has elapsed after the date of issuance of the formal legal document issued in favour of the main applicant to be the registered owner of the real estate unit; and
(b) not be sold to another purchaser who wishes to acquire Citizenship by Investment unless the Cabinet is satisfied that substantial further investment was injected into the real estate unit by way of further construction, renovation
or otherwise.
Those who sell or use real estate in contravention of sub-regulation (22), the following sanctions shall be applicable—
(a) that person shall be liable to have his or her citizenship revoked;
(b) that person shall be disqualified from any further application for Citizenship by Investment; and
(c) any transaction purporting to sell that real estate unit shall be null and void or if the transaction cannot be nullified or voided, damages shall be payable to the Government of Saint Christopher and Nevis by the offending person or
persons.
24.What fees are excluded from minimum investment?
The following sums shall be excluded from the minimum investment sum—
(a) International Marketing Agent commissions;
(b) authorised agent fees;
(c) advances to the main applicant or dependants of any nature;
(d) financial returns, guaranteed returns, advances or any type of payments to the main applicant or dependants of any nature;
(e) due diligence background check fees;
(f) Post approval-in-principle CBI application fees;
(g) CBI application processing fees;
(h) any other commissions of any nature; and
(i) any other related fees listed in regulation 35
25.Who is subjected to due diligence?
(1) A CBI applicant who is aged sixteen years or older shall undergo a due diligence background check after submitting a CBI application to the Unit and before approval-in- principle.
26.What are the reasons for rejection of CBI application?
Note well below. A CBI applicant who—
(a) has provided false information on his or her application form;
(b) has a criminal record;
(c) is the subject of a criminal investigation;
(d) is a potential national security risk to Saint Christopher and Nevis or to any other country;
(e) is involved in any activity likely to cause disrepute to Saint Christopher and Nevis; or
(f) has been denied an entry visa by a country to which citizens of Saint Christopher and Nevis have visa-free travel;
shall not be approved for Citizenship by Investment.
(3) Pursuant to sub-regulations (1) and (2), a due diligence background check may include the secure collection and processing of biometric and other data including fingerprints and passport verification
27.What if the documents submitted are not in english?
A CBI application form shall be completed in the English language and any document submitted with the application shall be in English, or, if the original language of the document is not in English, the document shall be accompanied by an authenticated translation.
28.Can i submit the applications myself to CBI unit?
CBI applications shall be submitted to the Unit only by an authorised agent on payment of the due diligence fees
29.Where can i get CBI application forms?
CBI application forms shall be available only from the Unit upon request by the main applicant or by an authorised agent on payment of the processing fee (US$ 250)
30.Who can be principal/main applicant?
A “main applicant” is the person who, either as a single applicant or as the head of a family, undertakes an investment for the purposes of these Regulations and signs the relevant agreements and undertakings on behalf of his or her dependants. The principal applicant can be family member above 18 years of age (spouse, parents, adult child) who fully support financially.
31. What is Real estate unit?
Under the CBI regulations 2023 specified in the act, a “real estate unit” means—
(a) a Certificate of Title to a condominium unit;
(b) a Certificate of Title to a villa;
(c) a share in a company registered solely to own a particular condominium or villa by Certificate of Title; or
(d) a time-share interest issued pursuant to the Saint Christopher and Nevis Vacation Plan and Time-Share Act,
