Diligence Top Priority Says First C.E.O. of C.I.P.

CHIEF Executive Officer of the Citizenship by Investment Programme (CIP) Unit, Cindy Emmanuel-McLean, says the terms “due diligence” and “professionalism” will be key parts of the standard procedures at her recently-formed unit.

The CIP Unit, which started its work last October, is the administrative arm of the Citizenship by Investment Programme, which officially began receiving applications on January 1.

Among the unit’s key roles are accepting all applications from people interested in being associated with the CIP: authorized agents, promoters, marketing agents and applicants. The other role is reviewing and processing those applications, following which a recommendation will be made by the five-member CIP Board, the latter of which provides oversight.

Emmanuel-McLean told the media at a press briefing yesterday that she was “absolutely confident” that the CIP Unit will do its part in a professional manner to ensure the controversial new measure implemented by government to attract foreign direct investment (FDI) is successful. She said her nine staff members are cognizant of the investment being made, as well as the serious implications should the programme fail to deliver as promised.

“We know that doing something wrong is essentially a make-or-break for the programme,” Emmanuel-McLean said. “We are 100% committed to it not being a break and it being a make. So we’re going to take every precaution possible to ensure that we do things the right way and in the way that has been legislated and mandated.”

The global announcement of the CIP came in Monaco where Prime Minister Dr. Kenny Anthony addressed the Global Citizens Forum on October 8 last year. The Citizenship by Investment Act (No. 14 of 2015) was passed in the House prior to that.

Five licensed Saint Lucian-based authorized agents have since been announced. They are Mark D. Maragh (Century Capital Inc.), Diana Thomas (Citizenship Services [Saint Lucia Inc]), Peter I. Foster (Citizenship Investment Services), Jonathan McNamara (McNamara Citizenship Services Inc.), and Thaddeus Antoine (TM Antoine Partners Advisory Inc.

These agents, Emmanuel-McLean said, “act as a buffer between the Unit and the prospective applicants” and do due diligence on the applicants. Only the authorized agents can submit applications on behalf of an applicant since the CIP Unit is not responsible for liaising directly with the applicants.

Emmanuel-McLean said two global marketing firms have been selected to assist in coming up with a global marketing programme that can appeal to the various target markets, as well as throughout the globe. They are Arton Capital and CS Global Partners.

Applicants seeking citizenship by investment can do so via one of the following four means: indicate that they want to make a donation to the National Economic Fund, investing in an approved real estate project, an approved enterprise project or purchase non-interest bearing government bonds.

All applications received by the CIP Unit, Emmanuel-McLean said, will be vetted to ensure that they are compliant. Compliance means that everything asked for forms part of the submission and is in the appropriate format.

A compliant files then goes through the due diligence process by a chosen “due diligence firm” that will conduct a full background check on the applicant. After that, the file is then returned to the CIP Unit which, in turn, determines what recommendations it makes to the CIP Board, which is headed by Dr. Ernest Hilaire.

The due diligence firms listed on the CIP’s website are BDO Consulting, IPSA International, Thomson Reuters and Wealth X.

The CIP Board can, however, deny, grant or delay the applicant’s request to become a citizen by investment. Should the applicant be recommended for the programme, the Board then recommends that to the Prime Minister who may then issue a certificate of citizenship to that applicant.

Principal applicants need to be 18 years and older and must have a minimum net worth of US$3 million. However, the main applicant can also apply on behalf of his/her dependents, namely spouse, children and parents over 65 years old.

Successful applicants are required to hold their investments for a minimum period of five years, meaning they cannot dispose of such investments within that time frame.

Applicants are required to pay the costs associated with the due diligence process and also pay the authorized agent for making their application.

The Prime Minister, who is the minister responsible for the Citizenship by Investment Programme, has set a limit of no more than 500 applications being approved per year. By March month-end, the CIP Unit is expected to present him with a full report that will include the number of applications received, recommended for granting citizenship, and denied.

Ever since the plans to introduce the programme was announced in the Throne Speech in May, 2014, the debate has been raging as to whether the requisite due diligence will be followed to prevent abuse.

While the opposition United Workers Party (UWP) supported the bill in Parliament, its leader, Allen Chastanet, expressed concerns in a January 12, 2016 press release in which he stated the following:

“The United Workers’ Party lent its critical support to the Citizen by Investment Programme (CIP) in Parliament, but we are still not happy that best practice in governance, transparency, and accountability (has) been applied within the legal framework of the CIP.”

Meanwhile, Emmanuel-McLean said calls have been coming in from many people requesting more information on the programme. She believes that with the right amount of marketing and efficiency, the programme can be a success.

“We’re anticipating a very slow start and we have projected a gradual build-up to where we want to be,” McLean-Emmanuel said.