The Commonwealth of Dominica is one of five countries in the Eastern Caribbean that allows persons born outside of the state to obtain a passport for a one-time fee or real estate investment through its Citizenship by Investment (CBI) programme.
The programme began in 1991 to support areas like tourism, manufacturing, low-cost housing, infrastructure, agriculture, and healthcare.
The Caribbean Investigative Journalist Network (CIJN) found that Dominica is heavily dependent on the CBI programme and that more than half of the government’s projected growth in revenue for the fiscal year 2021/2022 is expected to be financed by the CBI.
Prime Minister Roosevelt Skerrit in his latest budget address declared that CBI will contribute 58% percent of Dominica’s capital budget for the Public Sector Investment Programme.
The Public gets a glimpse of some of the CBI earnings during Dominica’s annual National Budget presentation.
This table depicts the reported contributions for CBI’s Economic Diversification Fund (EDF) over the last five years:
CBI Total Yearly Revenue for the Period 2017-2022
| Year | CBI Revenue in USD |
|---|---|
| 2017-2018 | $148,146,776 |
| 2018-2019 | $83,086,517 |
| 2019-2020 | $67,538,902 |
| 2020-2021 | $109,841,909 |
| 2021-2022 | $171,612,697 |
Between 2017 to 2022, the country collected more than USD$580M from CBI applications and investments from its Economic Diversification Fund – one of two options to gain citizenship via the programme.
The majority of these funds have historically been used to pay down national debt and to finance capital projects such as road infrastructure and healthcare centers.
Dominica’s Citizenship by Investment Appeal
- Dominica’s is one of the cheapest second passports in the world
- An individual can purchase citizenship by making a non-refundable contribution of USD$100,000 plus processing due diligence fees totaling USD$8,750
- Passport holders get visa-free access to more than 140 countries including the 26 European nations in the Schengen region
- CBI citizens pay no wealth, gift, inheritance, or capital gains tax
- Applicants can obtain a passport within three to six months of approval without ever visiting Dominica
- Successful applicants are allowed to hold dual citizenship which lasts a lifetime for the main applicant and qualified family members
- CBI passport holders are not required to be resident in Dominica even after obtaining the passport
That combination of features earned Dominica a top spot on the Financial Times 2021 CBI Global Index.
Transparency & Accountability
CIJN found transparency and accountability lacking in Dominica’s CBI programme.
While the CBI Unit reveals the number of passports issued, it is only by paid subscription to the official Government Gazette. Few ordinary citizens pay the USD$40 annual fee to access that information.
There is no information released about the original nationality of the buyers.
While monies contributed to the Economic Diversification Fund are placed in the government’s main account, there is no public accounting of monies raised and spent through its Real Estate option.
Millions of US dollars collected under the Real Estate Investment option are set aside in an escrow account. Prime Minister Skerrit confirmed that during a radio interview in 2019 and admitted that the monies collected are not revealed in his national budget.
Since 2014, authorized CBI agents and promoters who actually sell the passports are banned by law from disclosing anything about the citizenship programme without explicit approval.
Only two people are authorized to speak, Prime Minister and Finance Minister Roosevelt Skerrit and Emmanuel Nanthan, the head of the country’s CBI programme.
The problem is that neither of them have responded to repeated requests by CIJN to clarify the many questions about the transparency and accountability of the programme.
The Prime Minister’s Secretary requested a list of questions to facilitate an interview. Those questions were provided, but up to the time of this report she never answered any further calls or emails.
The office of the head of the CBI never responded to any interview requests.
How Much Money is in the Real Estate Escrow Account?
Dominica’s Real Estate escrow account remains wrapped in mystery as no details are released.
While government officials are silent, its critics are not.
Opposition Leader of the United Workers Party (UWP) Lennox Linton says he calculates that there is about XCD$4.2B in that escrow account which is equivalent to about USD$1.6B.
“So, $5.4 billion is collected, and $1.2 billion comes into the revenues (in the NDF) which leaves us with $4.2 billion outside. Under whose control?”
Linton says he’s been deducing his own numbers because the government refuses to divulge any of its own.
“I’ve been sitting in the parliament the past year and the government is not responding to say, “No, this is not correct. Here are the numbers instead”.
Certainly, some of that money has been used in development projects for low-cost housing, hurricane shelters and medical units. But detailed records of the amount of funds remaining in the escrow account is unknown.
Questioning the Deal with MMCE
Montreal Management Consultants Establishment (MMCE), a Dubai-based development company headed by Dr. Anthony Haiden has exclusive authority to construct many of Dominica’s infrastructure projects like housing, healthcare centers, schools and medical facilities.
MMCE also has control of Dominica’s much vaunted International Airport project, often described as being worth an estimated USD$370M (XCD$1B).
According to Linton it was a no-bid contract on a project that Montreal Management boasts is the region’s largest ever.
The Dominica International Airport Project is the biggest contracted project not only in the history of Dominica but also in the history of the Eastern Caribbean region, to date.
(Source: MMC Development)
Critics argue a deal this size deserves transparency and the public deserves to know every detail of its terms and see an accounting of how the funds are being spent. Such information is difficult to obtain given the absence of Freedom of Information Laws.
Haiden spoke about their connection during the dedication of the airport facility on June 9, 2021.
“The long-standing relationship between the MMCE and the Commonwealth of Dominica establishes an example of trust, dedication and, for the most part, friendship.”
“I credit our healthy relationship,” said Dr. Haiden, “to the mutual trust we have developed over the years.”
“Ladies and gentlemen,” said Dr Haiden at the airport dedication ceremony, “MMCE is privileged and honored to contribute to this history-making initiative as we embark on a legendary project.”
While MMCE’s company website lavishes praise on PM Skerrit, UWP Opposition Leader Lennox Linton questions the no-bid contracts.
For years, Dr. Haiden has told reporters he’s “contractually unable to disclose the particulars” about his exclusive deals with Dominica’s government.
Montreal Management Consultants Est. sells passports with Dominican government authorization as a Citizenship by Investment Programme service provider in the UAE. The company has another arm, Montreal Management Consultants Development, that has control over how that CBI money is spent on projects.
There is no public record of this exclusive agreement made between the government and MMCE and no record of how much money the company is earning. It would appear to be a conflict of interest.
CIJN made several attempts to secure an interview with Prime Minister Skerritt but up to the time of the publication, he has not responded.
Linton says skipping the open tender process may have cost the people of Dominica as much as USD$30M (XCD$80M): “We’re saying that this is totally and absolutely unacceptable.”
The View is Better from a Luxury Spa
CBI agent Sam Raphael feels differently about the lack of transparency of the CBI programme and has even complimented the Government of Dominica for its management of the programme over the years.
He is the owner of Jungle Bay Resort and Spa which was funded by CBI money.
As an agent authorized to sell Dominican passports, Raphael caters to high-net-worth individuals. It is those people willing and able to invest USD$200,000 or more for a second passport who have helped make Jungle Bay Resort a reality.
Raphael says keeping the names of applicants confidential is a sign of the times. He goes all the way back to the September 11 attacks on the United States to justify that point of view.
“It was a whole different era then,” he told us.
“…9/11 changed the world. Security for people has become paramount now and there’s a lot of concern with high-net-worth people.”
CIJN was unable to find a single incident where CBI applicants became victims of terrorism.
However, a troubling number of people who had acquired Dominican diplomatic passports have made international headlines for alleged involvement in economic crimes.
For example, Alireza Zibahalat Monfared, Chinese billionaire Ng Lap Seng, Nigeria’s former Petroleum Resources Minister Diezani Alison-Madueke have been sought-after for allegedly committing international crimes.
The former minister is alleged to have committed offenses bordering on abuse of office, bribery and money laundering between 2011 and 2015 while she was still Nigeria’s oil minister. She obtained Dominica citizenship in June 2015 and was appointed a Trade and Investment Commissioner for the island. She is believed to have fled to the United Kingdom. The Federal Court in Abuja issued another arrest warrant for the ex-minister as early as January 2022.
In November 2019, Alireza Zibahalat Monfared, an Iranian who secured a Dominican diplomatic passport in 2015, was sentenced to 20 years’ imprisonment for stealing over a billion dollars in oil revenues.
Ng Lap Seng was convicted in 2017 for bribery. Between 2010 and 2015, Ng paid the two UN officials approximately US$ 2 million in bribes. In return, they secured approval for the multibillion-dollar construction of a conference center in Ng’s native Macau intended to benefit developing countries. He was a diplomat of Dominica at the time of his arrest. Source: AP
There are no options that offer diplomatic passports to CBI applicants under the programme. The issuance of diplomatic passports would have had to be authorized by high level politicians.
Trying to prevent repeated scandals, in February 2017, Prime Minister Skerrit invoked the CBI rules on background checks for non-nationals obtaining diplomatic status.
“Effective immediately, all non-nationals under consideration for Diplomatic and Consular appointments will be subjected to the same due diligence requirements as persons applying for citizenship under the Citizenship by Investment Programme of Dominica. Persons would also have to be cleared by an internationally rated and recognized global security agency that would carry out the necessary due diligence exercise.”
– PM Roosevelt Skerrit
But the damage to Dominica’s reputation was already done. Much like the CBI programme, the issuance of those diplomatic passports was done in secret.
Approved CBI agent Samuel Raphael told CIJN that he has signed agreements not to disclose certain things about the Real Estate programme or share information about it.
“We need to be very mindful as a small player in the Caribbean region,” says Raphael “that we are in a fishbowl and we’re being watched by the international community. And whereas they may do things, and they may get away with it, it may not be the same for us, they’re going to be very harsh on us with respect to that.”
Raphael concedes the Dominica CBI programme needs more transparency.
“I do believe that there can be some balance,” he told CIJN. “So, this is something that can be discussed. There’s always a debate, what is the public’s right to know versus the privacy of someone?”
EU and US Warn Caribbean CBI Nations
On March 9, 2021, the European Parliament approved a report urging the EU to ban golden passport schemes by 2025.
EU lawmakers proposed the gradual phaseout of golden passport schemes and have submitted that rules for residence arrangements should be tighter, including much more rigorous checks on applicants.
US Congressmen Burgess Owens and Steve Cohen recently introduced the No Travel for Traffickers Act, a bipartisan legislation that would revoke a country’s eligibility for the U.S. Visa Waiver Programme if they participate in citizenship-by-investment.
The congressmen reasoned that “These schemes require little vetting and are notoriously abused by human traffickers, international criminals, and corrupt oligarchs.”
With so much of its development revenue at stake, at least at one turn the Government of Dominica has tried to show cooperation. It temporarily banned applications for all Russian and Belarusian citizens as a result of the conflict in Ukraine.
The Opposition Leader also wants to save the CBI in Dominica.
“The CBI definitely faces some existential threats based on the actions in the EU and the reaction in the US Congress where some moves are surfacing against what is called the Golden passport, which is something that we involved in second citizenship for people in different parts of the world where their passports don’t work as well as ours. But our passports work well, because of the goodness of other countries, countries that allow visa-free access to their countries with our passports, like in the Schengen area, “ he said.
The Citizenship by Investment Unit sent a letter in January, 2022 to its agents and promoters warning them to purge any language that underscored the EU’s concerns.
The letter to agents warned “It is prohibited to reference visa-free travel to specific countries, territories, and regions including the European Union and Great Britain with which a Dominican passport holder may travel to without needing to first apply for a visa, in any content used.”
The letter went on to require agents to stop using language like “sale of passport,” “citizenship sale,” “buying passport,” or “purchasing passports”.
The purely cosmetic changes are unlikely to have any effect on whatever action lawmakers in the EU and the US decide to take.
A report by Global Financial Integrity in October 2021 noted a lack of transparency.
“While the CBI programme brings important investment for the island—Dominica collected US$444 million over the three-year period 2017-2020—it still presents a vulnerability for the country as applicants whose back-ground checks return unfavorable information are reportedly not always rejected, applicants are not automatically disqualified for providing false information, nor is there much transparency about the programme save for its annual earnings and the number of passports issued.”
Small Island Developing States like Dominica do little to influence climate change and the world’s other major crises. They are left almost entirely on their own to come up with strategies to raise funds in order to remain safe and to protect their populations.
The Citizenship by Investment programme has helped Dominica do that.
In order to ensure the programmes’ validity and lifespan, improved transparency and accountability of its operations is vital.
This will help build understanding of the programme locally and increase confidence among international governments and agencies that threaten CBI’s future.