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.  

What is Due Diligence? 

Due diligence is a sequence of investigative practices that identify and verify information about an investor.  

Why is Due Diligence Important? 

Due diligence is critical to maintaining the integrity and transparency of Dominica’s CBI Programme. Stringent processes include verifying an investor’s identity, criminal background, source of funds, and public reputation amongst other checks.  

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’s Due Diligence Process 

Dominica is world-renowned for being one of the world’s most 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.  

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. 

Entities that scrutinise an application 

  • 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. 

All applicants sixteen years of age or over will be required to attend a mandatory interview. During this time, a third-party due diligence agency will perform stringent background checks on the information you have provided. Interviews will be held virtually, via a secure platform. Applicants will be contacted directly by authorised interviewers for scheduling interviews.

Thereafter, applicants and their dependants will attend virtual interviews; Authorised Agents/Licenced Promoters cannot attend interviews on their behalf. All applicants must hold identification documents, and supporting documents deemed necessary for the interview.

Interviews will be conducted in the applicant’s native language or a language of his/her choosing. All applicants 16 years and over are expected to attend interviews; applicants who are unable to join with the rest of their family must pay for additional interviews. Documents requested via the interview will be routed via the Authorised Agent.

  • 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.  
  • 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. 
  • 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. 
  • Partner governments 
    External checks are also performed with or by partner governments, including the Governments of Canada, the United Kingdom, and the United States.  
  •  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.  

How long does the due diligence processes take? 

The average processing time of a CBI application which includes a complete due diligence is approximately three months. This includes internal due diligence by the CBI Unit and external due diligence by international firms

How much does it cost? 

  • Main applicant: US$7,500
  • Spouse: US$4,000
  • Per dependant aged 16+: US$4,000

Enhanced due diligence checks and fees may sometimes be required, depending on the applicant’s current citizenship status and other personal circumstances.

There is a mandatory interview fee of US$1,000 per interview.

Effective 17 July 2023, all Iranian applicants are required to pay the following enhanced due diligence fees:

  • Main Applicant: US$25,000
  • Spouse: US$15,000
  • Each dependant sixteen years of age or over: US$15,000
  • Each dependant twelve to fifteen years of age: US$10,000

The enhanced due diligence fees above are inclusive of interview fee of US$1,000 and the standard due diligence fees of US$7,500 for the main applicant and US$4,000 for each dependant sixteen years of age or over. As such, all Iranian applicants are not required to additionally pay the standard due diligence fees on top of the aforesaid enhanced due diligence fees.

What happens next? 

Once due diligence reports are issued to Dominica’s CBI Unit, the relevant Committee determines the decision on whether to grant or deny citizenship to an applicant. Official notification is then delivered to the applicant’s Authorised Agent. 

Emmanuel Nanthan, former 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.”

CBI Index

The Commonwealth of Dominica has come out on top for 6 consecutive years in the ranking for best CBI programme in the  CBI Index. Dominica’s thorough vetting procedures often earn top scores in the Index , a consistent outcome for the nation since the inception of the Index in 2017. 

Published by the Financial Times’ Professional Wealth Management magazine, the CBI Index is a comprehensive ranking system that compares operational CBI programmes. The in-depth report examines and evaluates CBI programmes offered by various countries in the Caribbean, Europe, Asia, Oceania, and Africa.