The ‘Caribbean Five’ has agreed to the implementation of Six Principles to safeguard and regulate their CBI programmes.
The Caribbean Programmes have retained their position atop the 2023 CBI Index. While the steady crescendo of international regulatory pressure on the industry reached its zenith in 2023, the performance of Caribbean programmes across the nine pillars of the CBI Index continues to reflect their affordability, simplicity, and efficiency.
Yet, there has been considerable nuance in how the different programmes have responded to this regulatory scrutiny. Having already introduced a raft of measures including mandatory interviews, higher investment thresholds, and partnering with external due diligence providers, St Kitts and Nevis stands out for taking immediate and decisive action based on the ‘6 Principles’ framework – a significant factor behind achieving the top spot in this year’s CBI Index with a score of 77 points. Moreover, it underscores a political will to take a leadership role in the long-term sustainability of the industry through good governance, enhanced due diligence, and regional harmonisation with international partners.
Despite falling to second place with a score of 75 points, Dominica is also making efforts to comply with international demands to enhance its vetting, due diligence, and transparency levels while simultaneously ensuring the long-term health of the programme. For example, Dominica has introduced additional enhanced due diligence procedures for certain jurisdictions instead of issuing outright bans which would impact programme revenue.
Saint Lucia maintains its top-three ranking despite a drop of six points from the previous year. While a lower Due Diligence score resulted in Saint Lucia ranking behind all but one of its regional peers, it has made positive changes such as the introduction of National Action Bonds replacing the Covid bond option. Now ranking joint third with Saint Lucia,
Grenada’s ascent to a top three position spotlights improved scores for Due Diligence, Standard of Living, and Certainty of Product. Grenada has also been fast to implement specific ‘Six Principles’ measures, as demonstrated by the introduction of mandatory interview requirements on 1 September 2023.
Although Antigua and Barbuda has maintained its fifth overall position for the CBI Index 2023, a poorer performance for Due Diligence and Ease of Processing Pillars in particular have seen it drop three points since last year. Malta, too, has retained its sixth ranking, despite considerably less interest and news around its MEIN’ (Maltese Exceptional Investor Naturalisation) programme. A sustained push to introduce new due diligence enhancements designed to assuage the EC’s concerns would go some way to help Malta climb its way back up the rankings.
Ascribing Vanuatu’s improved ranking from eighth to seventh to the demise of Montenegro would be to overlook the efforts that are being made on the ground to stabilise the programme and introduce tighter vetting procedures for applicants. The fact that the EU has given a further 18 months’ extension to allow time for the Vanuatu Government to engage in reforming its CBI programme further reflects this.
Türkiye has leapfrogged Egypt in this year’s rankings and is now in eighth position with a score of 55 points. The combined efforts to improve the perception of its programme by raising its investment threshold in the face of high demand and the subsiding of political pressure to kill off the programme have brought it greater stability.
Despite moving to tenth in the rankings from 12th in 2020, Austria continues to be weighed down due to having the highest minimum investment outlay of all CBI programmes, a long citizenship timeline and a lack of transparent mechanisms to ensure the ease of processing applications. In addition, its due diligence standards fall short in comparison to a number of other programmes, and, due to the EU Parliament criticisms, the programme is under threat on the basis of its EU member status.
Rounding out the overall rankings are Cambodia and Jordan in 11th and 12th position respectively. Both of these jurisdictions still need to make large strides with respect to tightening due diligence processes in order to raise their profile in the market.
|Country||Standard of Living||Freedom of Movement||Min. Investment Outlay||Mandatory Travel/Residence||Citizenship Timeline||Ease of Processing||Due Diligence||Family||Certainty of Product||TOTAL POINTS (90)||PERCENTAGE %|
|Antigua & Barbuda||7||7||10||6||6||8||6||10||6||66||73|
|St Kitts & Nevis||6||7||9||10||8||10||10||7||10||77||80|
- Antigua & Barbuda
- Saint Lucia
- St Kitts & Nevis
FREEDOM OF MOVEMENT RANKINGS
As the only two countries that are both Schengen and EU member states, Austria and Malta head the rankings under the Freedom of Movement Pillar by virtue of affording citizenship holders powerful global mobility as well as the right to to live and work in all EU member states, resulting in a perfect score of 10.
While their visa-free status has been under the spotlight recently due to continued pressure from US, EU and UK authorities, the five Caribbean nations of Dominica, Grenada, St Kitts and Nevis, and Saint Lucia still afford powerful travel freedom and maintain a score of seven. Within this group, St Kitts and Nevis has visa-free/visa-on-arrival access to the highest number of countries (155), followed closely by Antigua and Barbuda and Saint Lucia with scores of 150 and 146 respectively. With more limited travel freedom are the programmes of Turkey with a score of three points, and Cambodia and Vanuatu both score two points. Egypt and Jordan round up the rankings with a score of one.
|Antigua & Barbuda||7|
|St Kitts & Nevis||7|
|Antigua & Barbuda||7|
|St Kitts & Nevis||6|
STANDARD OF LIVING RANKINGS
Living with nine points, a fact that reflects the comparatively high standard of the Eurozone overall. While Austria outperforms Malta in the Gross National Income measure, the latter’s slightly higher life expectancy and expected years of schooling level out the scores.
Antigua and Barbuda and Grenada follow in second position with seven points, with Turkey also joining this group. Although the two Caribbean nations outperform Turkey in relation to the societal freedoms and openness their countries provide, Turkey scores more highly in relation to gross national income.
Third position is occupied by the other Caribbean nations of St Kitts and Nevis, Dominica, and Saint Lucia, all of which score six points. Saint Lucia (15.4 per cent) and St Kitts (9.1 per cent) outperformed in the GDP growth measure which reflects a strong post-pandemic recovery as well as the successful economic diversification initiatives. On the other hand, Dominica achieves a higher score than its regional partners for Human Security.
Although Vanuatu, Jordan, and Egypt all achieve a score of five, there are significant differences in their performances across the Standard of Living measures. For example, while all three of these countries score highly for Human Security, citizens of Vanuatu enjoy greater civil and political freedoms than those residing in either Jordan or Egypt. Rounding off the rankings is Cambodia, which is let down by its comparatively poor educational endpoints, low GNI, as well as the government’s failure to extend greater societal freedoms to its citizens.
MINIMUM INVESTMENT OUTLAY RANKINGS
Antigua and Barbuda, Dominica, Grenada, Saint Lucia, and Vanuatu all achieve a score of ten points in the Minimum Investment Outlay Pillar. Within that group, Dominica and Saint Lucia maintain the industry’s lowest threshold with US$100,000. Antigua and Barbuda’s programme is priced slightly higher by virtue of its substantial government fee of US$30,000, with Vanuatu’s Development Support Programme (DSP) also again remaining at US$130,000. At US$150,000, Grenada’s National Transformation Fund (NTF) programme sits just within the maximum threshold to be awarded a full score.
In second position are Cambodia, Egypt and St Kitts and Nevis with a score of nine points. While no nominal change has been made to the donation options for Egypt and Cambodia for some time despite currency fluctuations, St Kitts and Nevis doubled its minimum threshold in July to US$250,000 as part of the rapid restructuring of its programme in response to international demands for tighter regulatory compliance.
Turkey places in third position with a score of seven. Turkey’s minimum investment threshold has undergone no further changes since it was increased from US$250,000 to US$400,000 in 2022.
Following Turkey are Jordan and Malta with a score of four points with a minimum investment of US$750,000 and US$769,000 (€705,000) respectively. As the most expensive option with a minimum investment of €3 million, Austria takes the final spot with a single point.
It is important to note that although the nominal value of most of the CBI programmes has remained unchanged, the 2023 CBI Index has adjusted the minimum threshold scoring to account for the current persistently high inflation that has inevitably impacted the value of the amounts invested.
|Antigua & Barbuda||10|
|St Kitts & Nevis||9|
|Antigua & Barbuda||6|
|St Kitts & Nevis||10|
MANDATORY TRAVEL OR RESIDENCE RANKINGS
There are no changes from the 2022 CBI Index to scores under the Mandatory Travel or Residence Pillar. The Caribbean jurisdictions of Dominica, Grenada, St Kitts and Nevis, Saint Lucia and Jordan, have no travel or residency requirements from applicants and all achieve the maximum score.
Austria, Cambodia, Montenegro, Turkey, and Vanuatu follow with a score of eight. These countries require an applicant to make a single trip to their new country of citizenship, often to obtain a National ID card or to swear an oath of allegiance.
Antigua and Barbuda maintains its score of six as it requires applicants to spend a minimum of five days in the country every five years and to travel to the country (or one of its embassies) to swear the oath of allegiance.
Malta retains its place at the bottom of the rankings with a score of two. This is due to the 12–36 month minimum residency requirement (depending on the investment outlay) before acquiring citizenship. Applicants must also make two subsequent trips to provide biometric information for their residence card and to take the oath of allegiance.
CITIZENSHIP TIMELINE RANKINGS
For 2023, a diverse range of countries rank in first position for Citizenship Timeline Pillar, including Dominica, Jordan, Saint Lucia, and Vanuatu, all of which have programme applications that can be completed in under four months.
Cambodia, Egypt, St Kitts and Nevis, and Turkey follow in second position with a score of eight points, with all aforementioned programmes quoting end-to-end processing times of under five months. While St Kitts and Nevis had previously attained a top score for its timeline ranking in previous editions of the CBI Index, the country’s CIU increased processing times from 90 days to 120 days and rescinded its ‘accelerated CBI application’ option in July 2023, again in response to international pressure which has impacted its Citizenship Timeline score.
Antigua and Barbuda maintains its third position with six points with an estimated processing time of between six and seven months. Despite dropping a point since the 2022 CBI Index due to widespread processing delays, Grenada has moved up in the rankings from fifth to fourth with a score of four points.
Malta maintains its score of three due to its best-case scenario minimum timeline for obtaining citizenship of
13 months. Austria rounds out the list with a score of two with a timeframe of 12–36 months.
|Antigua & Barbuda||6|
|St Kitts & Nevis||8|
|Antigua & Barbuda||8|
|St Kitts & Nevis||10|
EASE OF PROCESSING RANKINGS
The two Caribbean jurisdictions of Dominica and St Kitts and Nevis share the top rank with Malta for the Ease of Processing Pillar. This reflects these programmes’ ability to balance the administrate demands of the application process with quick and efficient processing.
The six countries of Antigua and Barbuda, Egypt, Grenada, Saint Lucia, Turkey, and Vanuatu all share the second rank with a score of eight points. The most significant differentiating factor between the first two rankings is passport validity, with Turkey and Vanuatu being the only two countries issuing passports of ten-year validity vs five-year validity for the other jurisdictions.
Austria and Jordan follow in third position, both with a score of seven points. Austria’s score is due to the requirement to demonstrate a minimum level of business experience, and Jordan’s performance is weighed down by its poor passport validity and lack of a dedicated government CBI unit or programme website.
Rounding out the rankings is Cambodia, where language and culture and history tests prevent the programme from attaining a higher score for Ease of Processing.
DUE DILIGENCE RANKING
St Kitts and Nevis retains its position from the previous year due to the CIU’s changes made as part of a rapid implementation of the ‘Six Principles’, which include mandatory interviews and measures to stop financial irregularities in the real estate option to protect the programme’s integrity and reputation.
Dominica and Grenada follow with nine points. While neither Caribbean country has yet made sweeping changes in response to the recent regulatory pressures, they do already have a broad range of measures in place including robust external due diligence procedures, on-the-ground checks with assistance from international agencies, and banned nationalities.
Malta and Saint Lucia place in third with a score of seven points. While Malta does have a four-tier due diligence process in place, the ongoing lawsuit by the EC suggests that mandatory interviews and additional investor protections may be necessary to secure the programme’s future. Saint Lucia’s introduction of mandatory interviews will help to address the irregularities around its real estate programme and strengthen other requirements that are already in place. In fourth and fifth positions are Antigua and Barbuda and Austria respectively. While the former’s score reflects the need to tighten its police certificate requirements and introduce mandatory interviews, Austria’s score would benefit from extra due diligence checks on applicants from sanctioned countries supported by independent agencies.
In sixth position, Egypt requires clean police certificates from an applicant’s country of residence and citizenship as well as corroborated evidence of employment or business ownership – but without external support. Sharing the sixth position, Vanuatu’s programme remains in flux, with changes being made on multiple fronts, including the launch of biometric passports and the securing of external third parties for enhanced vetting. Cambodia follows in seventh position, with Turkey and Jordan both rounding off the rankings with two points.
|Antigua & Barbuda||6|
|St Kitts & Nevis||10|
|Antigua & Barbuda||10|
|St Kitts & Nevis||7|
In the 2023 CBI Index, Antigua and Barbuda and Grenada were determined to have the most family-friendly programmes. In addition to a main applicant, they allow the applicant’s spouse, children under 18 and over 18 (in certain circumstances), siblings, parents, and grandparents of both the main applicant or their spouse to be included in an application.
In second position and maintaining a score of nine points are Saint Lucia and Malta in second position. Saint Lucia misses out on a perfect score due to not permitting grandparents to be included in the application, while Malta falls short of a perfect score due to its exclusion of the main applicant’s siblings.
Now with a score of eight points, Dominica has dropped two positions in the Family Pillar ranking due to a tightening of the documentary requirements for evidencing the degree of dependency of children over 18.
Having also previously attained a perfect score, ending both the sibling and grandparent eligibility means has seen St Kitts and Nevis drop to seven points and now ranks joint fourth with Vanuatu.
Egypt and Turkey retain a score of five. While Turkey allows a spouse to obtain citizenship with the main applicant, children over 18 can only be included based on a medical condition. Conversely, Egypt allows over 18s to be included with few restrictions, but a spouse only receives their citizenship a year after the main applicant.
Austria and Jordan remain on four, with stringent dependency requirements for the eligibility of certain family members to be included in an application. Cambodia remains at the bottom of the standings as it only allows the applicant’s spouse and children under 18 to be included in an application.
CERTAINTY OF PRODUCT RANKINGS
As the only country to attain a score of 10 for this year’s CBI Index, St Kitts and Nevis’ performance reflects a boldness of action in response to the recent unprecedented international pressure imposed on all Caribbean Citizenship by Investment programmes.
Occupying joint second position with seven points are Grenada, Turkey, and Dominica. With Grenada’s Citizenship by Investment programme now active over a decade and showing steadily rising application volumes, the country has increased its score by one point through a stronger performance in ‘Longevity’ and ‘Popularity and Renown.’ While Dominica has taken steps to improve investor vetting through, for example, the enhanced due diligence requirements imposed on particular jurisdictions, the absence hitherto of additional changes as undertaken by St Kitts and the recent loss of visa-free travel to the UK has impacted its performance under ‘Reputation’ and ‘Adaptability’. Turkey’s efforts to stabilise its programme by increasing minimum investment thresholds have been validated by consistently high application volumes, and combined with the ending of political pressure on the Citizenship by Investment programme, have seen its ‘Reputation’ and ‘Adaptability’ scores increase.
Ranking third are Saint Lucia and Antigua and Barbuda, with neither Caribbean country able to match its previous score. Despite Saint Lucia introducing measures to step up its due diligence framework, ongoing issues around illegal discounting suggests that more needs to adapt to the realities of a tighter regulatory environment as quickly as possible.
The six Citizenship by Investment jurisdictions of Malta, Cambodia, Jordan, Austria, Egypt, and Vanuatu, round out the rankings in fourth position all with a score of four points. Despite Malta’s efforts to stay out of the EC’s regulatory crosshairs with the introduction of the ‘MEIN’ (Maltese Exceptional Investor Naturalisation) back in 2020, the programme has yet to return to its prior popularity or reputation.
Cambodia’s score remains unchanged as the programme has seen no significant changes and remains relatively unknown despite having been in existence since 2013. Now in existence since 2018, Jordan benefits from an improved ‘Longevity’ score in 2023. However, a relatively low number of approvals since its inception and the cap of 500 passports annually still weigh on its overall score.
Austria’s score remains unchanged, as, while not explicitly targeted in the EU Parliament’s criticisms, will be directly affected by any legislative changes implemented on CBI programmes in EU Member states.
Despite a stable number of applications, Egypt retains its score of four points owing to an overall lack of changes to its programme to attract new investors or to adapt to the industry’s rapidly evolving compliance requirements.
Though Vanuatu’s programme remains in s state of flux due to the looming threat of a full suspension of the country from the Schengen area’s visa-free agreement, the current efforts being made to stabilise the programme through improved due diligence requirements in conjunction with economic diversification initiatives have muted prior calls to end the programme.
|Antigua & Barbuda||6|
|St Kitts & Nevis||10|