EU and US issue guidelines for CBI Programs

The US and EU authorities have made specific recommendations to Caribbean nations that have CBI programmes, to further strengthen high levels of background checks, prevent money laundering and tax evasion. High levels meeting were held by caribbean governments with US and EU authorities this year.

US Guidelines

The following recommendations were put forth by US authorities at round table conference held this year.

The six agreed upon principles were:

1. Treatment of denials: Not to process applications from persons whose applications have been denied in another CBI jurisdiction, by proactively sharing information on denials;
2. Interviews: Conduct interviews with applicants, whether virtual or in-person;
3. Additional checks: Each jurisdiction will run checks on each application with the Financial Intelligence Unit of its respective country;
4. Audits: Audit the Programme annually or every two years in accordance with internationally accepted standards;
5. Retrieval of passports: Request law enforcement assistance to retrieve revoked/recalled passports; and
6. Treatment of Russians and Belarusians: Suspend processing applications from Russians and Belarusians.

EU Guidelines

The following guidelines would be suggested to countries offering CBI Programmes by EU authorities at a recent meeting held in Brussels.

1. Enhance due diligence – Introduce enhanced due diligence on all applicants and to be conducted by reputable international due diligence firms based in the EU, US, and UK. The firms must be a third parties of high repute.
2. Interviews – Implementation of mandatory interviews for all CBI applicants. These interviews can be conducted either in person or virtual if necessary
3. Document collection – No official citizenship documents or passports should be sent to new citizens via mail after the granting of citizenship. Citizenship certificates and passports must be received only from government authorities (eg. consulate or embassy abroad)
4. Increase Investments – Minimum investment thresholds should be increased, with a minimum of US $200,000 (per single applicant) for applications under the donation option and a minimum of US $400,000 for real estate investments.
5. Flow of funds – Flow of investment funds must be properly monitored and verified against strict money laundering processes. The funds should to be transferred directly to the host country without any diversion into accounts in other countries. This step is to stem money laundering or tax evasion.
6. Promotions – Refrain of all promotional material of passports from these third countries that shows the benefit of visa-free access to the EU.