The Dominica Citizenship by Investment (CBI) Programme mandates strict due diligence processes and robust vetting of potential investors. Reputable international due diligence agencies are engaged by Governments to ensure that only reputable individuals can successfully receive the economic citizenship of Dominica.
The correct functioning of Dominica’s CBI Programme depends on the proper performance of thorough due diligence, as it serves to protect the population of Dominica and its international partners from illicit actors.
Dominica is world-renowned for being one of the world’s most affordable, efficient and reliable CBI programmes, with its strict, multi-layered due diligence measures. Dominica also favours a collaborative approach with the other Caribbean CBI jurisdictions, with similar due diligence mechanisms being adopted across the region.
Dominica’s CBI Programme focuses on the overall description of its candidates, rejecting the applications of individuals that do not comply to the set conditions and criteria. Comprehensive due diligence checks are performed on all applicants older than 16 years of age, and additional safeguards are present to monitor compliance with international sanctions and security.
Emmanuel Nanthan, the Head of Dominica’s CBI Unit, highlights the importance of implementing a stringent due diligence framework:
“We strive to remain at the forefront of the global migration industry. We do so by enforcing a robust due diligence process. We have engaged some of the best companies in the world to do our due diligence for us. We use the best due diligence firms to ensure that we have excellently vetted investors. We use our due diligence regional partners as well, such as the JRCC, and the international intelligence community. We try to ensure that the backbone and the cornerstone of our programme is due diligence.”
Dominica applies the following six layers in vetting an application for high risk applicants.
Entities that scrutinise an application
1. Authorised agents
Authorised agents perform Know-Your-Client (KYC) checks and ensure that applications are only received by the Citizenship by Investment Unit (CBI Unit) if they contain all, complete application forms and supporting documents, accompanied by the required fees. KYC checks include using the WorldCheck database and desktop controls, which allow agents to do an initial background screening.
2. Citizenship By Investment Unit
The Dominica CBI Unit is responsible for ensuring that both internal and external checks are performed on each application. Internal due diligence is conducted by the staff of the CBI Unit, made up of experts in document review, anti-money laundering, and counter-terrorism financing. They perform open-source checks on all applicants and ensure that all documents are consistent and adhere to the Unit’s requirements.
3. Expert international firms
External due diligence mandated by the CBI Unit, requires independent due diligence firms to conduct online and on-the-ground checks to verify the information provided in the application forms and supporting documents. They then produce a report that is returned to the CBI Unit, establishing the applicant’s identity, familial ties, criminal background, employment history, source of funds, press and media profile and political exposure.
4.Crime prevention and detection agencies
The Joint Regional Communications Centre (JRCC), an arm of the CARICOM Agency for Crime and Security, cross-references all applicants against regional watchlist and Interpol databases as part of the external due diligence process.
5. Partner governments
External checks are also performed with or by partner governments, including the Governments of Canada, the United Kingdom, and the United States.
6. The National Bank of Dominica
The bank that receives the citizenship by investment funds from the applicant, the National Bank of Dominica, performs additional, independent due diligence checks. It charges its own due diligence fees, requests supporting documents, and only accepts funds of which clean origin can be established.
PEP’s
The Politically exposed or high risk persons are subjected to enhanced due diligence checks
Publication of Names
Furthermore, Dominica’s CBI Unit publishes its economic citizens’ names in the Official Quarterly Gazette and provides a detailed budget of the allocation of CBI funds.
Visa refusals
The CBIU checks for visa refusals, with countries where visa waiver agreements apply (eg. UK, Schengen etc)
Blacklists
Certain country nationals such as Iran, Russia, Belarus, North Korea etc cannot apply for Dominica CBI programme.
The average time to complete due diligence is approximately three months. This includes internal due diligence by the CBI Unit and external due diligence by international firms.
