As an Authorised Agent, you will assist the main applicant with their application by helping them obtain all the required documentation and submitting the application on the main applicant’s behalf to the Citizenship by Investment Unit (CBIU).  

Here are five common mistakes that can be made while processing a Citizenship by Investment application and how you can avoid them. 

1. Not conducting thorough know-your-client checks 

The first step of the robust due diligence process begins with the Authorised Agent’s know-your-client checks.  
 
It is essential to run internal due diligence processes to pre-screen the applicant. The information found will indicate whether they are a suitable candidate for citizenship.  
 
The Dominica Citizenship by Investment (CBI) Programme mandates strict due diligence processes and robust vetting of potential investors.  

2. Missing important documents or information 

Authorised Agents assist applicants through the process of preparing all the paperwork before submitting it to the CBIU. This detailed procedure includes the completion of both forms and all supporting documents. All colour copies of documents must be notarised and legalised before they are submitted, and any documents in a foreign language must be translated, notarised, and legalised prior to submission.  

If any of these documents are not translated, notarised and legalised correctly, there could be a delay in the processing times of the application.  

3. Failing to provide the required police clearance certificates 

A Police Clearance Certificate is a document provided by a law enforcement agency confirming the absence of a criminal record. These certificates are usually required for each applicant and dependant aged sixteen years and over.  

The document is needed from the country of birth, country of citizenship, and should it be different, the country of residence. A police clearance certificate is also required from any country the applicant has resided in for more than six months in the past ten years.  

For children aged twelve to fifteen, a sworn affidavit by the parent confirming that a child does not have a criminal record is required.  

4. Lack of proof of origin or insufficient funds

When the process reaches the stage of evidencing the origin of the applicant’s funds, and its complexity depends on the circumstances specific to each case. If an applicant claims that their source of funds is from the sale of real estate, then a sale and purchase agreement in support must be provided.

If an applicant is an entrepreneur or self-employed and own their own companies, then their source of funds is commonly linked/derived from the profits of their business. The applicant will need to provide a copy of the shareholder’s certificate, memorandum of association, or company incorporation documents.  
 
If applicants have derived their source of wealth from cryptocurrency, an increasingly popular instance as the world of virtual assets continues to advance, then an applicant must show the origin of the funds they invested in a sworn affidavit. Here, the applicant explains how they purchased cryptocurrencies, the value of the cryptocurrencies in US dollars, how they made a profit, and confirm that they will be liquidated in the amount required for payment of the investment. In such cases, applicants must also show a copy of their crypto portfolio showing purchases and sales.  

Applicants need to be able to commit to the required investment. They can prove this by showing presence of enough funds in their bank account to make the required investment. Authorised Agents can attest to this commitment by checking bank statements before submitting the application to the CBIU.  
 
For example, a single applicant should have an amount of US $100,000 on their bank statements to prove that they can make the investment. 

5. Outdated documents

Gathering the required documents should be done in a timeous manner that ensures that they will not expire. For example, reference letters and proof of address must be dated within the past three months at the time of submission.

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