Dominica’s government announced some changes to its Citizenship by Investment Programme in July. These changes affect the applicant’s dependants, costs, post-citizenship additions and documentary requirements.
Natasha Jones, a legal assistant
at CS Global Partners walks us through all the details of the changes to Dominica’s CBI Programme affecting families.
AM: Can you tell us how the definition of “dependant” has expanded with the new changes to Dominica’s CBI Programme?
NJ: Dominica expanded its definition of “dependant” quite significantly. A ‘dependant’ is a family member who is eligible to be included in an application for citizenship.
Firstly, dependent adult children aged 18 – 30, parents and grandparents must now only show that they are ‘substantially’ supported, and this can be by either the main applicant or the main applicant’s spouse.
Previously, for example, adult children had to show that they were ‘fully’ supported, but by the main applicant only, and they had to be in attendance at an institution of higher learning. Similarly, parents and grandparents were required to be both living with and fully supported by the main applicant only. So, allowing for dependants to be ‘substantially’ rather than ‘fully’ supported, by either the main applicant or the main applicant’s spouse, and removing additional education or cohabitation requirements, is therefore a lot less restrictive.
Secondly, Dominica removed the minimum age threshold for dependent parents and grandparents. Before the changes, only parents and grandparents above the age of 55 were eligible, now parents and grandparents of any age may be included, as long as they meet the requirement of being ‘substantially’ supported.
Finally, Dominica now allows the inclusion of a biological or legally adopted sibling of the main applicant or of the main applicant’s spouse, as long as that sibling is (1) aged 25 or under, (2) single, (3) childless, and (4) ‘substantially’ supported by the main applicant or the main applicant’s spouse. Importantly, if the sibling is under 18, that sibling must have received consent to make an application from all individuals with parental responsibility for the sibling.
“Family eligibility is … a significant consideration for prospective investors, as it is now more important than ever to ensure that one’s whole family has a place they can call home should a crisis occur.”
AM: One of the things investors can appreciate about CBI in the Caribbean is that it is inclusive in many ways. Not only are family members of the main applicant given the opportunity to be included in the initial application, but applicants can also apply for the post-citizenship addition of family members. Can you tell us about the changes to post-citizenship additions under Dominica’s CBI Programme?
NJ: Post-citizenship additions only apply to family members of applicants who have received citizenship through the Programme. Under the new changes, children born or adopted after citizenship was obtained are now eligible to be added at any time after birth or adoption. Spouses married after the original application was made may also be added but at a cost of US$75,000.
Importantly, applications for the post-citizenship addition of new children and spouses can be made by all persons who obtained citizenship through the Programme, not just by the main applicant.
Finally, any dependant who would have qualified as a dependant at the time the original application was made can be added, but by the original main applicant only. The cost of such an addition differs according to how much time has passed since the grant of citizenship, however. For applications made more than one year after the grant of citizenship, the cost increases.
Processing Fees, Due Diligence Fees, and Certificate of Naturalisation Fees also apply, and additional Due Diligence Fees of US$7,500 must be paid by the original applicant if the post-citizenship application is submitted more than one year after the date the original application was submitted. However, this additional fee does not apply to the addition of children born or adopted after citizenship was obtained.
AM: Can you give us an example of a type of family that might be better catered to with the new changes to the definition of “dependant? Perhaps by using a TV family?
NJ: Of course. Take for example a family consisting of (1) William, the main applicant, (2) Kate, the main applicant’s spouse, (3) their child, George, who is aged 25, not in education, but still living with them, (4) William’s mother, Elizabeth, who is aged 50 and who is living in accommodation paid for by the main applicant, and (5) Kate’s sibling Pippa, who is aged 20 and attending a University paid for by Kate.
Under the new changes to Dominica’s CBI Programme, William would be able to include all of these family members in an application for citizenship. Previously, George would not have been eligible as he is not in education, Elizabeth would not have been eligible as she is under the age of 55 and not living with William, and Pippa would not have been eligible as no provision was made for siblings to be included in an application.
AM: Why has the government now decided to make these changes?
NJ: Part of the reason Dominica remains at the forefront of the investor immigration industry, having been voted the best CBI Programme in the world for three consecutive years in the CBI Index, is because it is always monitoring the direction of the industry in order to adapt and improve its Programme.
One central trend in recent times has been to expand the definition of “dependant” and decrease prices for large families, we saw this in May when Antigua and Barbuda priced its University of the West Indies Fund more competitively for families, and when St Lucia permitted the inclusion of siblings in June. Most recently, St Kitts and Nevis implemented a Limited Time Offer that reduced the contribution amount for families.
Therefore, keep pace with the industry, Dominica’s recent changes prioritise families.
AM: You mentioned that the country is prioritizing families when it comes to attracting investors, why is importance placed on this?
NJ: Since the onset of Covid-19, we have seen a shift in investor priorities. Now, many investors are seeking a second citizenship as a means to ensure they are able to settle indefinitely in a welcoming, safe location with their families should the need arise. Family eligibility is therefore a significant consideration for prospective investors, as it is now more important than ever to ensure that one’s whole family has a place they can call home should a crisis occur.
Countries like Dominica are recognising the importance of family reunification for investors. By implementing family-friendly changes, Dominica ultimately seeks to encourage investors and their family members to choose Dominica as their country of second citizenship.
This interview has been edited and condensed for length and clarity. 
