Regarding St Kitts and Nevis Citizenship by Investment Programme changings, the Citizenship by Investment Unit Headed by Michael Martin introduced new regulations called St Kitts and Nevis Citizenship by Substantial Investment Regulations, (CSI Regs) at noon Atlantic Standard Time on July 27, 2023.

These new regulations replace the existing St Kitts and Nevis Citizenship by Investment Regulations 2023 and its amendments (Current Regs). 

The CSI Regs bring about significant changes to eligibility criteria, investment options, due diligence fees, application processing times, and the process of obtaining St Kitts and Nevis Citizenship by Investment. The regulations also include advertising restrictions and revised requirements for Authorized Agents and International Marketing Agents. These new rules are in effect immediately.

What changes have occurred in the regulations of St Kitts and Nevis Citizenship by Investment?

– The term “dependant” is defined in St Kitts and Nevis Citizenship Regulation of the CSI Regs as follows:

• •  a child under the age of eighteen;
  • a child between the ages of eighteen and twenty-five, who is attending a recognized secondary or tertiary level institution full-time and financially supported by the main applicant;
  • a child aged eighteen years or older with physical or mental challenges; or
  • a parent of the main applicant, or the spouse of the main applicant, who is sixty-five years or older and living with and financially supported by the main applicant.

– The key changes to dependant eligibility are as follows:

• • Siblings are no longer eligible to be included as dependants.
  • Grandparents are no longer eligible to be included as dependants.
  • The minimum age for parents to be eligible as dependants is increased to 65.

– The new conditions of the St Kitts and Nevis Citizenship by Investment Options:

• • Sustainable Island State Contribution (SISC) Option:

The Sustainable Growth Fund (SGF) option is replaced immediately by SISC.

The SGF option’s Limited Time Offer, which was available until January 31, 2024, is closed.

To apply for St Kitts and Nevis Citizenship through donation, applicants need to make minimum contributions to the Federal Consolidated Fund based on the number of dependents they have.

The contributions start from:

• Main applicant only: US$250,000
• Main applicant and a spouse: US$300,000
• Main applicant and one dependant: US$300,000
• (Family up to 4) Main applicant, a spouse and one or two dependants; US$350,000 
• (Family up to 4 ) Main applicant and two or three dependants: US$350,000
• Each additional dependant under 18: US$50,000
• Each additional dependant aged 18 or over US$75,000

• • Real Estate Investment Option:

To qualify under this option, applicants need to invest at least US$400,000 in a real estate unit in an Approved Development.

The investment must be held for 7 years, and the unit can be resold once by the original purchaser.

• • Private Home Sale Investment Option:

For this option, applicants can invest in an Approved Private Home.

The minimum investments are US$400,000 for a condominium unit (an apartment) or US$800,000 for a single-family private dwelling (house).

The investment must be held for 7 years, and joint investments with other CBI applicants are not allowed.

If the Approved Private Home is to be sold to another purchaser for CBI purposes, the Federal Cabinet must be satisfied that substantial further investment was made in the property.

• • Public Benefit Option:

Under this option, applicants can contribute a minimum of US$250,000 to an Approved Public Benefits Project to get St Kitts and Nevis Citizenship.

– The new conditions of the Due Diligence:

• • The New Due Diligence Fees:

For each St Kitts and Nevis Citizenship by Investment (CBI) application, there are non-refundable due diligence fees that must be paid to the Unit:

• 1. The main applicant pays US$10,000.
  2. Each dependant aged 16 years or over, pays US$7,500.

• • Mandatory Interviews:

As per an agreement made between the 5 Caribbean CBI Countries and the US, the CIU is now implementing mandatory interviews.

Here are the interview requirements:

• Main applicant in the process must attend an interview conducted by an independent professional firm commissioned by the Unit or by Unit officials.
• Main applicant who has not received his Certificate of Registration and has not been interviewed yet must also attend an interview.
• Dependants aged 16 years or over may need to attend an interview if deemed necessary.

– The interviews could be virtual, in person in St Kitts and Nevis, or other approved locations by the Board of Governors.

– During the interview, the person being interviewed must attend alone and answer questions directly without any legal representative or support person.

– The CIU will provide a certified translator if needed for those who don’t speak English as their first language.

– The increased due diligence fees cover the cost of these mandatory interview requirements.

– Application Processing Time:

For all four CBI Options, within 120 days (4 months) from the date the Unit receives a CBI application, the Unit will inform the main applicant’s Authorized Agent about the application’s status:

• It could be approved in principle.
• It could be denied.
• It could be delayed for a specific reason and still under processing.

Previously, clients had the option to expedite their CBI application by paying additional fees for premium due diligence or post-approval services. However, this option is no longer available.

– Transition Requirements for Discontinued Investment Options:

• • Private Alternative Investment Option (AIO):

Main applicants who applied under the private AIO must pay the following post-approval CBI application fees within 90 days of receiving approval-in-principle notification from CIU:

• Main applicant: US$50,000
• Spouse: US$25,000
• Each dependent under 18: US$10,000
• Each dependent aged 18 or over: US$50,000

The developer of the approved infrastructural project or other development project must provide proof of receiving a US$200,000 investment from the main applicant before issuing Certificates of Registration.

• • Public Alternative Investment Option (AIO) :

Main applicants who applied under the public AIO must pay the following post-approval CBI application fees within 90 days of receiving approval-in-principle notification from CIU:

• Main applicant: US$20,000
• Spouse: US$10,000
• Each dependent (regardless of age): US$10,000

The developer of the Public Good Infrastructural Project or other approved Public Good Development Project must deposit US$175,000 into an escrow account at a licensed financial institution in St Kitts and Nevis, specified by the Board of Governors, before issuing Certificates of Registration.

• • Previous Real Estate Option:

If a main applicant applied under the previous St Kitts and Nevis Citizenship through Real Estate Option (2011 CBI Regs), he needs to pay certain fees after receiving approval-in-principle notification from CIU. These fees must be paid within 90 days and are as follows:

• Main applicant: US$50,000
• Spouse: US$25,000
• Each dependent under 18: US$10,000
• Each dependent aged 18 or over: US$50,000

The developer of the Approved Project must also show that they received a US$200,000 investment from the main applicant before issuing Certificates of Registration.

– And Finally, Changes in receiving Collecting Certificates of Registration:

After St Kitts and Nevis Citizenship by Investment application is approved, the main applicant will receive a Certificate of Registration once the investment is made and all checks are completed. The main applicant must collect the Certificate of Registration in person either in St Kitts and Nevis or at an Embassy or Consulate specified by the Citizenship by Investment Unit and approved by the Board of Governors.

In another announcement issued on the same date 7/27/2023, holders of the following nationalities were excluded from applying for St Kitts and Nevis Citizenship by investment program, and the decision includes:

Russia, Belarus, North Korea, Afghanistan, Iran, and Iraq.

The Prime Minister of St. Kitts and Nevis, Dr. Terrance Drew, stressed the need for new changes to St Kitts and Nevis Citizenship by investment program to ensure an upscale investment environment and prevent illegal practices to obtain citizenship.

We at NTL are ready to answer all your questions and inquiries related to the new modifications.