CBI Due Diligence: What Actually Happens at Each Tier

Introduction: Why Due Diligence Is the Heart of CBI

The sustainability of citizenship by investment programmes depends entirely on the integrity of the due diligence process. A CBI programme that issues passports to sanctioned individuals, criminals, or money launderers becomes unusable — visa-free access agreements are suspended, the programme's reputations is destroyed, and existing passportholders find themselves carrying a document that attracts heightened suspicion.

Caribbean CBI jurisdictions have collectively invested heavily in due diligence infrastructure since approximately 2015, when significant scrutiny from FATF, the US State Department, and the EU exposed weaknesses in some programmes. Today, the major Caribbean CBI programmes (St Kitts, Dominica, Antigua, Grenada, St Lucia) operate structured multi-tier due diligence processes that are described below.

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The Four-Tier Due Diligence Framework

Tier 1: The Authorised Agent's Initial Review

Who does it: the government-licensed Authorised Agent (AA) in the applicant's country of residence or the AA's office.

What it involves:

• Review of all submitted documents for completeness and internal consistency
• Basic identity verification: passport authenticity check, facial recognition against provided photos
• Initial adverse media screen (Google, LexisNexis, World-Check)
• Assessment of whether the application raises any immediate red flags

Outcome: the AA either proceeds with submission to the CBIU, requests additional documents from the applicant, or — in rare cases — declines to represent the applicant where the AA identifies clear disqualifying factors.

Timeframe: typically completed before submission; the AA's review is part of the application preparation process.

Applicant interaction: the applicant interacts primarily at this stage — gathering documents, answering the AA's questions, providing source of wealth documentation.

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Tier 2: The CBIU Initial Review

Who does it: the Citizenship by Investment Unit (CBIU) — the government department responsible for the CBI programme in each jurisdiction.

What it involves:

• Confirmation that the application is complete (all required documents received, all fees paid)
• Eligibility assessment: confirms the applicant meets formal eligibility criteria (nationality, age, no prior CBI refusal in the jurisdiction or CARICOM region)
• Initial internal database checks: the CBIU maintains records of previous applicants, refused applicants, and flagged individuals

The CARICOM Exclusion List: Caribbean jurisdictions share information through the CARICOM (Caribbean Community) security framework. An applicant refused by any member jurisdiction is typically flagged on this list and will be refused by all other member jurisdictions as well. This cross-jurisdiction information sharing has significantly strengthened the Caribbean CBI ecosystem.

Outcome: the CBIU either accepts the application for further processing, returns it for completion, or refuses at the initial stage (rare at this stage; usually requires an obvious disqualifying factor).

Timeframe: 2–4 weeks.

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Tier 3: Independent Due Diligence by Licensed Investigators

Who does it: the CBIU commissions independent due diligence from licensed specialist investigation firms. The firms engaged vary by jurisdiction and over time, but include internationally recognised names:

Firm	Specialisation
Control Risks	Risk consulting; geopolitical and corporate investigation
Mintz Group	Corporate investigation; background checks
Kroll	Corporate investigation; forensic accounting; due diligence
Thomson Reuters Acuity (Refinitiv)	Data services; World-Check PEP/sanctions database
LexisNexis Risk Solutions	Data aggregation; identity verification; adverse media
Exiger	AML/sanctions screening; supply chain risk

What they check:

Check Category	Detail
Criminal record verification	Requests official criminal record certificates from all countries of citizenship and significant past residence
INTERPOL screening	Red Notice (wanted); Yellow Notice (missing persons); and Blue Notice (information requests)
OFAC screening	US Treasury Office of Foreign Assets Control — SDN (Specially Designated Nationals) list
UN Security Council sanctions	Consolidated UN sanctions list
EU sanctions list	EU restrictive measures list
PEP screening	World-Check and other PEP databases; identifies current and former political figures and their close associates/family
Adverse media	Comprehensive global media searches in multiple languages; past 5–10 years
Business ownership verification	Confirms declared business interests; checks for undisclosed associations with controversial entities
Litigation database	Court records search for significant civil litigation, judgments, and insolvency

Timeframe: 2–6 weeks (standard); can be longer for complex backgrounds, multiple countries of residence, or applicants from jurisdictions with difficult records-access.

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Tier 4: Government and International Intelligence Checks

Who does it: the CBIU, in cooperation with national intelligence services and international partners.

What it involves:

• The CBIU submits applicant details to the host country's national security/intelligence service for checking
• Information is shared with CARICOM security intelligence framework (for regional checks)
• Bilateral checks with partner countries: the US, UK, Canada, and sometimes the EU are partners in intelligence-sharing with Caribbean CBIUs

US Intelligence Sharing: Several Caribbean CBIUs have formal or informal intelligence-sharing arrangements with the US Department of State and US intelligence community. This means that applicants' details are reviewed against US intelligence databases. This is one reason why Grenada's CBIU can represent to the US Embassy that its due diligence meets US standards (supporting the E-2 pathway).

Timeframe: 2–4 weeks (but can extend if specific intelligence queries arise).

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What Disqualifies Applicants

Automatic Disqualification

Disqualifying Factor	Basis
Criminal conviction in any jurisdiction	All Caribbean CBIUs; includes both serious crime and significant financial crime
Active INTERPOL Red Notice	Immediate refusal
OFAC/UN/EU sanctions listing	Immediate refusal
Previous refusal in any Caribbean CBI programme	CARICOM exclusion list
Application misrepresentation	Deliberate false or misleading information
Involvement in terrorism or terrorist financing	All programmes
National security threat to the issuing country	Broad ground; used sparingly
Citizenship of a country subject to blanket restrictions	Some programmes restrict certain nationalities — check current position

PEP Status: Complication, Not Automatic Refusal

Politically Exposed Person (PEP) status does not automatically disqualify an applicant, but it triggers significantly enhanced scrutiny:

• The PEP's source of wealth is more intensively examined
• Political positions held are assessed for corruption risk
• International exposure checks are extended
• Senior CBIU approval is required
• Some programmes apply a blanket policy against senior PEPs from certain jurisdictions

PEPs who are current heads of state, cabinet ministers, or senior officials in jurisdictions with significant corruption indices (Transparency International scores) face the greatest scrutiny.

Source of Funds: What Triggers Concerns

The due diligence firm assesses not just the applicant's identity but the legitimacy of the source of funds for the investment:

Source of Funds Risk	Due Diligence Response
Unexplained cash deposits in recent years	Requests explanation; may require detailed bank statement review
Business in a high-risk jurisdiction (FATF grey/black listed)	Enhanced scrutiny of business activities
Sudden large wealth increase without obvious explanation	Detailed documentation of windfall events (sale, inheritance, etc.)
Beneficial ownership of companies in multiple opaque jurisdictions	Full mapping of corporate structure required
Business activities in sanctioned sectors	May be disqualifying
Crypto source of funds without documentation	Requires blockchain analysis and exchange statements

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Typical Processing Timeline: Tier by Tier

Stage	Who	Typical Duration
Application preparation by AA	Authorised Agent + applicant	4–8 weeks
AA initial review and submission	Agent	1–2 weeks
CBIU completeness check	CBIU	1–2 weeks
Independent due diligence (Tier 3)	Investigation firms	3–6 weeks
Government/intelligence checks (Tier 4)	CBIU + security services	2–4 weeks
CBIU decision and notification	CBIU	1–2 weeks
Investment transfer (following approval)	Applicant	2–4 weeks
Citizenship certificate and passport	CBIU/Passport Office	2–4 weeks
Total (standard)		3–5 months

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Documents Required for Due Diligence

Document	Specification
Passport (all current and expired within last 10 years)	Certified copies
National ID card	Certified copy
Birth certificate	Official; apostilled if required
Marriage certificate (if applicable)	Official; apostilled
Police clearance certificate	From all countries of residence >6 months in past 10 years
Proof of address	Utility bill or bank statement; 3 months
Bank reference letter	From applicant's primary bank; confirming relationship and good standing
Source of wealth declaration	Narrative form
Source of wealth documentation	Supporting documents (see SOW guide)
CV/professional history	Comprehensive; 10 years minimum
Business documents (if self-employed)	Audited accounts; directorship proof
Medical certificate	Some programmes require health certificate
Photographs	Passport-standard; specific requirements per jurisdiction

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What Happens If Due Diligence Reveals an Issue

If the investigation reveals adverse information (e.g., minor criminal record, adverse media, undisclosed association), the CBIU may:

1. Request a detailed written explanation from the applicant (through the AA)
2. Request additional documents to clarify the issue
3. Issue a conditional approval pending satisfactory explanation
4. Refuse the application

Appeal process: Caribbean CBI programmes generally do not have a formal independent appeals process for refused applications. Refusals are discretionary government decisions. In some programmes, a second application may be submitted after a specified period with additional documentation.

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HPT Group and CBI Application Advisory

HPT Group provides comprehensive pre-application assessment to identify potential due diligence issues before submission, advising on the documentation strategy and explanation of any adverse factors. We work with authorised agents across all five Caribbean programmes to ensure that applications are correctly prepared and submitted with the strongest possible supporting documentation. Our experience with complex backgrounds — including PEPs, crypto wealth, multi-jurisdiction business structures, and prior adverse media — means we can advise on realistic prospects and appropriate programme selection before any commitments are made. Contact HPT Group for a confidential pre-application assessment.