Citizenship by Investment: A Lifeline for St Kitts and Nevis says Les Khan

On 1 April 2020, Head of the St Kitts and Nevis Citizenship by Investment Unit (CIU), Mr Les Khan, participated in a webinar hosted by CS Global Partners, entitled “Safety and Security with Citizenship by Investment”. Addressing the online audience, Mr Khan discussed the St Kitts and Nevis Citizenship by Investment Programme, touching upon how it has maintained its status as the industry’s ‘Platinum Standard’, as well as the many benefits of obtaining citizenship of the country. Mr Khan also considered the future direction of the Programme in light of the current COVID-19 pandemic.

According to Mr Khan, all applicants to the Programme must be of good moral character, this means that they must possess a clean criminal record and pose no reputational risk or security threat to St Kitts and Nevis. Furthermore, Mr Khan emphasised the importance of establishing the financial background of applicants to ensure that they do not become a burden on the state. In order to determine an applicant’s suitability, applicants are therefore subject to a multi-tiered system of due diligence. Mr Khan, who is responsible for spearheading some of the investor immigration industry’s due diligence and processing developments, described the strict due diligence practices that underpin the Programme at great length.

Firstly, as part of a citizenship by investment application, applicants are required to obtain various documents evidencing their identity (including but not limited to: passports, ID cards, and birth certificates), moral character (including police certificates from an applicant’s country of birth, citizenship and residence), health (including HIV tests), and source of funds (including but not limited to bank statements, company incorporation documents, and professional reference letters). Each of these documents must either be submitted in original form or via a certified and legalised copy.

Applicants are then subject to initial scrutiny by the Programme’s Authorised Persons – individuals who have been approved by the Government to help applicants submit their application. The Authorised Persons are trained to perform know-your-client checks to determine the authenticity of the information provided in an application. Upon submission of an application to the CIU, applicants are then subject to internal scrutiny by CIU staff who are experts in document review and receive training in anti-money laundering and anti-terrorism financing.

The CIU then forwards applications to external due diligence firms and the Joint Regional Communications Centre (JRCC). The external due diligence firms, of which Mr Khan revealed as many as six work with the CIU, specialise in performing online and on-the-ground checks on every piece of information provided by applicants in their application forms and supporting documents. The JRCC are responsible for coordinating data from international partners such as the US, Canada, EU, and the UK, and check applications against databases entailing criminal records, anti-money laundering, and terrorist activity. Only when the CIU has liaised with its external partners, stated Mr Khan, will a decision be made in respect to approval or denial of an application for citizenship.

As well as the Programme’s steadfast commitment to due diligence, another factor contributing to its ‘Platinum Standard’ reputation is the efficiency with which applications are processed. The fastest, most straightforward route to citizenship of St Kitts and Nevis is via a one-time contribution to the Government’s Sustainable Growth Fund (SGF), introduced by Prime Minister Timothy Harris in 2018. Applicants obtaining citizenship via a one-time contribution to the Sustainable Growth Fund receive approvals in a mere three months, subject to a positive due diligence outcome.

The SGF route, as well as boasting efficient processing times, is more affordable than the alternative option of an investment in real estate. Families of four can apply under the SGF by making a minimum contribution of US$195,000 (plus US$10,000 for each additional dependant). The SGF is also an attractive option for single applicants, who are required to make a US$150,000 contribution.

Additionally, reflecting St Kitts and Nevis’ position as a thought-leader in the industry, Mr Les Khan acknowledged that the St Kitts and Nevis Citizenship by Investment Programme is the only Programme to offer a fast-track route to citizenship. Investors seeking to obtain even faster results may apply through the Programme’s 60-day Accelerated Application Process (AAP) for an additional fee. Mr Khan noted, however, that the AAP in no way compromises the Programme’s strong due diligence.

Inevitably, Mr Khan also touched upon the effects that COVID-19 will have on the country’s Citizenship by Investment Programme and the wider implications expected for St Kitts and Nevis and its people. Far from allowing COVID-19 to close the doors of the Citizenship by Investment Programme, Mr Khan has ensured that the CIU is in a position to remain open and accept applications remotely through its online submission platform; recognising the country’s need to facilitate foreign direct investment while also protecting the health of the CIU staff.

Although Mr Khan expects that the country’s tourism industry will take a hit and that it will take time for the economy to recover globally, Mr Khan underscored the important role that the Programme will play in the coming months in helping to mitigate the economic effects of the decline in tourism and support locals should the need arise.

Of course, COVID-19 is not the only challenge that citizenship by investment has helped St Kitts and Nevis to overcome. The country’s Citizenship by Investment Programme was instrumental in allowing St Kitts and Nevis to respond to the termination of the sugar industry in 2005 and the devastation wrought by Hurricanes Irma and Maria in 2017. St Kitts and Nevis is therefore fortunate to be in a position to respond to the virus in a way that protects its people while still ensuring economic growth.

This sentiment was echoed by Prime Minister Harris, in his appearance on WINN FM on Saturday 4 April. “Once upon a time, our country was challenged. Once upon a time when that challenge came in 2010/11, we had to go begging to the IMF for $225 million,” stated the Team Unity leader. Today, however, thanks largely to the country’s Citizenship by Investment Programme, St Kitts and Nevis is in a much better fiscal position to respond to COVID-19. Prime Minister Harris has made the Federation of St Kitts and Nevis proud with his response to the pandemic and has displayed excellent leadership in encouraging Kittitians and Nevisians to protect vulnerable groups and practise social and physical distancing.

To investors worldwide, Mr Khan has a message, in the uncertain times in which we find ourselves, obtaining citizenship of St Kitts and Nevis is an insurance policy – one that allows investors to safeguard the interests of their families while making a tangible difference in the economic development of a vulnerable small-island nation.