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.
As one of the world’s longest-established CBI Programmes, Dominica has continually strengthened its due diligence framework to meet evolving international standards. Today, the Programme incorporates comprehensive background screening, mandatory interviews, financial verification, and independent third-party investigations to ensure every application undergoes rigorous review.
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What is Due Diligence?
Due diligence is a sequence of investigative practices that identify and verify information about an investor.
In the context of Citizenship by Investment, due diligence extends well beyond identity verification. It involves assessing an applicant’s background, financial history, business activities, source of wealth, source of funds, reputation, and potential security risks before citizenship is granted.
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. The process serves to protect the population of Dominica and its international partners from illicit actors.
A rigorous due diligence process benefits both Dominica and genuine applicants. It helps preserve the international credibility of Dominican citizenship while giving successful applicants confidence that they are joining a Programme recognised for its integrity and responsible governance.
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 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 with the set conditions and criteria. Comprehensive 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 provides a detailed budget of the allocation of CBI funds.
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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 (CBIU) 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 CBIU, 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.
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Expert international firms
External due diligence mandated by the CBIU, requires independent 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 CBIU, 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.
What does Dominica’s Due Diligence Process Include?
The due diligence process may include:
- Identity verification
- Criminal background screening
- Financial due diligence
- Source of wealth verification
- Source of funds verification
- Anti-money laundering (AML) screening
- Counter-terrorism financing checks
- International sanctions screening
- Politically Exposed Person (PEP) assessments
- Adverse media checks
- Verification of supporting documentation
Every application is assessed individually based on the applicant’s profile and supporting documentation. Additional information may be requested where necessary to ensure a thorough review.
Mandatory Interviews Strengthen Programme Integrity
Applicants aged 16 and over are required to complete a mandatory interview as part of the application process.
Conducted by an independent professional due diligence firm, the interview provides an additional layer of verification by allowing applicants to clarify information contained within their application and supporting documentation.
The interview complements existing background investigations and demonstrates Dominica’s ongoing commitment to maintaining one of the Caribbean’s most robust due diligence frameworks.
Source of Wealth vs Source of Funds
Many applicants confuse these two concepts.
Source of Wealth explains how an applicant accumulated their overall wealth over time, such as through employment, business ownership, investments, inheritance, or property sales.
Source of Funds refers specifically to the money being used for the qualifying investment under the Citizenship by Investment Programme.
Applicants must provide supporting documentation demonstrating that both are lawful and verifiable.
How Long Does the Due Diligence Process 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.
What can Delay Due Diligence?
- Incomplete documentation
- Inconsistent information
- Missing financial records
- Complex business structures
- Additional verification requests
- Documents requiring authentication or translation
How much does it cost?
Main applicant: US$7,500
Each dependant aged 16 years or above: US$4,000
Enhanced 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.
Why Strict Due Diligence Benefits Applicants
While rigorous due diligence can make the application process more detailed, it ultimately benefits successful applicants.
Strong screening procedures help preserve the international reputation of Dominica’s Citizenship by Investment Programme, strengthen confidence among international partners, and ensure that citizenship is granted only to individuals who meet the Programme’s high standards.
This commitment to integrity has contributed significantly to Dominica’s reputation as one of the Caribbean’s most respected Citizenship by Investment Programmes.
CBI Index
Dominica has come out on top many years in the ranking for best CBI programme in the CBI Index. Dominica’s thorough vetting procedures often earn top scores in the Index . This has been a consistent outcome for the nation since the inception of the Index in 2017.
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.
Frequently Asked Questions
What is Due Diligence in Dominica’s Citizenship by Investment Programme?
Due diligence is a comprehensive background investigation that assesses an applicant’s identity, financial history, source of wealth, source of funds, reputation, and security profile before citizenship can be approved.
Who Conducts Due Diligence?
The Citizenship by Investment Unit works alongside internationally recognised independent due diligence firms that conduct detailed background investigations using multiple trusted data sources.
Does Every Applicant Undergo Due Diligence?
Yes. Every applicant is subject to rigorous due diligence before citizenship can be granted.
Are Interviews Mandatory?
Yes. Applicants aged 16 years and older are required to complete a mandatory interview as part of the due diligence process.
What Documents are Reviewed?
Depending on the applicant’s circumstances, documents relating to identity, finances, employment, business ownership, source of wealth, source of funds, and supporting legal documentation may all be reviewed.
Why is Due Diligence Important?
Due diligence protects the integrity of the Programme, safeguards Dominica’s international reputation, and ensures citizenship is granted only to qualified applicants.