Citizenship-by-Investment (CBI) programs operate under increasing global scrutiny. Governments must balance economic development objectives with international compliance expectations, reputational safeguards, and diplomatic considerations.
Superficial background checks are no longer sufficient.
A robust CBI due diligence process typically includes:
- Multi-jurisdictional adverse media screening
- Politically Exposed Person (PEP) checks
- Sanctions screening (OFAC, UN, EU, UK, and other relevant lists)
- Litigation and regulatory review
- Corporate and beneficial ownership analysis
- Source-of-wealth and business activity assessment
- On-ground verification, where necessary
In many cases, relevant intelligence may exist only in local-language media or through reputational inquiries that are not captured by automated databases.
For CBI destination jurisdictions, including Caribbean programs such as Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia, defensible, well-documented due diligence is critical to meeting regulatory expectations and maintaining program integrity.
The objective is not merely risk identification, but defensible decision-making.
