By Bayat Group
BASSETERRE, St Kitts – St Kitts and Nevis is committed to maintaining the integrity of its Citizenship by Investment (CBI) program by taking decisive action against illegal discounting and unauthorized financial schemes. In an official circular dated March 19, 2025, the chairman of the board of governors of the Citizenship by Investment Unit (CIU), H.E. Calvin St. Juste, underscored that any developers, agents, or marketing firms found to be engaging in such practices would face serious penalties, including blacklisting, revocation of approvals, and even loss of citizenship for applicants involved in fraudulent transactions.
Since transitioning into a statutory corporation, the CIU has intensified its regulatory oversight, implementing reforms aligned with the 6 Principles Agreement agreed during the US-Caribbean roundtable talks of 2023 and the Memorandum of Agreement signed in March 2024 by five Caribbean nations with CBI offerings. These measures aim to enhance transparency and uphold the St Kitts & Nevis CBI program’s reputation as “The First. The Finest.”
Criminalizing underselling: A regional first
Last November, prime minister Dr Terrance Drew made remarkable statements, underscoring the government’s zero-tolerance stance on illegal practices like underselling and owner financing. He announced a groundbreaking move during a roundtable discussion, revealing that underselling—offering CBI options below the legally mandated minimum investment thresholds—has been criminalized. “We are the only government in the region to make underselling a criminal offense,” he stated, emphasizing that this empowers the director of public prosecutions to pursue legal action against violators.
The latest circular reiterates the minimum investment thresholds under St Kitts and Nevis Citizenship by Substantial Investment Regulations, 2024 (CSI Regulations), making it clear that any deviation from these legally mandated amounts constitutes a violation.
The prescribed minimum investment amounts include:
- $325,000 for a real estate unit in an Approved Development.
- $250,000 for the Sustainable Island State Contribution for a single applicant or family of up to four persons.
- $325,000 for a condominium unit or share in Approved Private Real Estate.
- $600,000 for a single-family private dwelling home under Approved Private Real Estate.
- $250,000 contribution to an Approved Public Benefit Project for a family of four.
Any deviation through discounting or unauthorized financing is deemed a breach of the regulations and may cause consequences.
Consequences of non-compliance
The CSI regulations provide robust enforcement mechanisms to address breaches. Penalties range from fines of up to EC$10,000 to severe administrative actions, including:
- Suspension or revocation of Approved Development status for developers.
- Revocation of Approved Private Real Estate or Public Benefactor status.
- Removal and permanent ineligibility of Authorised Agents and International Marketing Agents.
- Blacklisting on the CIU website, barring individuals or entities from participating in the program.
- Revocation of citizenship and disqualification from future CBI applications.
The CIU has already taken action against violators, revoking licenses, canceling development approvals, and reclaiming passports where illegal practices—such as underselling or underpayment—have been detected.
Chairman St Juste underscored that preserving the program’s integrity remains the CIU’s top priority. “Illegal discounting and financial options will not be tolerated,” the circular stated, warning that the board of governors will act decisively against any developer or agent found breaching the rules.
The CIU also assured stakeholders of its ongoing monitoring efforts and encouraged those with questions or concerns to reach out directly. “We are here to support a transparent and lawful process,” St Juste added, inviting partners to contact his office or the CIU for clarification.
A vision for sustainability
These reforms align with St Kitts and Nevis’ Sustainable Island State Agenda, aiming to build a resilient economy while protecting the CBI program’s credibility. A key component of these reforms is the introduction of continuous due diligence, which requires ongoing assessments of both applicants and real estate projects associated with the CBI program. This measure ensures that any irregularities or potential risks are swiftly identified and addressed, reinforcing the government’s goal of maintaining high standards of compliance and accountability.
The CIU has already taken action against those violating the rules, revoking the licenses of promoters and authorized agents involved in illegal activities. Additionally, the government has revoked citizenships and reclaimed passports issued under fraudulent circumstances.
“Our standards dictate that we ensure robust due diligence and that no questionable actors exploit our program,” stated the prime minister last November.
As St Kitts and Nevis continues to refine its CBI Program, the message is clear: compliance is not optional. With its rigorous standards and proactive enforcement, the CIU aims to maintain the program’s status as a global leader, offering investors a secure and prestigious pathway to citizenship.
St Kitts and Nevis’ firm stance against illegal discounting follows a broader trend of tightening regulations within Caribbean CBI programs. In recent months, Grenada has also introduced stricter enforcement mechanisms to combat similar issues in its own CBI program. The coordinated efforts by regional governments indicate a strong commitment to eliminating unethical practices that threaten the credibility of these programs on an international scale.
As detailed in Circular No. 2 of 2025 from Grenada Investment Migration Agency (IMA) on March 5, 2025, authorities in Grenada are also taking decisive actions: the IMA rejected eight applications and began revoking one citizenship after uncovering illegal discounting, including $100,000 loans from a developer.
Minimum investments for the Grenada’s Citizenship by Investment program are set at:
- $270,000 (plus $50,000 to the government) for real estate;
- $350,000 for non-tourism projects;
- $235,000 for the National Transformation Fund for a family of four.
Offending agents face license revocation, and projects risk decertification. These measures align with a regional Memorandum of Agreement (MOA) signed by five Caribbean nations, including St Kitts and Nevis and Grenada, to harmonize CBI standards and eliminate underselling. The MOA’s $200,000 minimum threshold and planned regulatory body reinforce this collective effort.
Fighting illegal discounting in the CBI programs will be one of the key topics discussed during the Caribbean Investment Summit 2025 (CIS25) scheduled to take place in Antigua and Barbuda from April 22 to 26.
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