The 2019 CBI Index: Collaboration - present action and future opportunities

Over the years, increased collaboration between countries that run citizenship by investment programmes has proven fruitful, bringing positive outcomes for both applicants and the countries themselves. 

For example, the CARICOM’s Joint Regional Communications Centre (JRCC), established in 2006 by intergovernmental agreement, provides an additional and shared layer of due diligence for all five Caribbean programmes. 

This year, collaboration emerged as a priority for the international citizenship by investment community. In May, Cyprus introduced the requirement for all applicants to possess a valid visa to the Schengen Area, of which Cyprus is not part. In so doing, Cyprus incorporated the safety procedures set by the European Union for third-country nationals into its own. Malta too, acknowledges its responsibility to Europe in this way. Indeed, because they are required to visit Malta in person, applicants for Maltese citizenship must obtain a Schengen visa as a matter of course.

Even before 2019, the Caribbean protected international open borders by mandating the rejection of applicants who were denied a visa to any of its visa-free travel destinations, and who had not subsequently obtained a visa from that destination. Malta’s regulations are similar, but have additional flexibility that enables it to consider an applicant’s special circumstances.

In May 2019, Cyprus also tightened its eligibility criteria to exclude applicants who had been rejected for citizenship in any other EU member state, an innovative move among Europe’s citizenship by investment nations. Interestingly, the tightening of eligibility in this fashion has a precedent from 2017 in the Caribbean, where Grenada amended Section 8(3) of its Grenada Citizenship by Investment Act to reject applicants who were “denied citizenship by investment in another Caribbean jurisdiction.”

In addition to the specific developments to the legal structures around citizenship by investment programmes, there is reason to believe that cooperation between nations in the industry will grow. Attendees of the Caribbean Investment Summit 2019 discussed common regulations and harmonised relations with global intergovernmental organisations. At Malta’s second Citizenship by Investment Due Diligence Conference, speakers advocated for industry-wide standards. The 67th meeting of the Organisation of Eastern Caribbean States in June 2019 brought further commitment from the Caribbean, including the introduction of a supervisory board to oversee the programmes, standardised legislation, and consistent application forms.

Whilst collaboration is presently most prominent among nations whose neighbours have also adopted citizenship by investment, as the industry becomes more crowded and searches for ways to establish a strong, international voice, collaboration will likely have a bigger role to play across all continents.