Since Henley lost its position as the primary agent for marketing Dominica and Saint Kitts passports, another London-based citizenship firm called CS Global Partners has risen in its place. Founded and led by a former attorney at Henley and Partners, CS Global is said to have been financed in part by a British-Indian investor named Dev Bath. Bath, who served as a director at the firm for over a year, remains a consultant to the company. His LinkedIn profile doesn’t mention CS Global Partners and describes him only by his title, “Special Representative of St. Kitts and Nevis,” which furnishes him with a diplomatic passport to the country.
Bath has also hired Lanny J. Davis, the longtime D.C. lobbyist and former special counsel to President Bill Clinton, to help promote Saint Kitts and Dominica passports. In one 2013 advertorial extolling the benefits of investor citizenship, Davis quotes his client, who “became a resident of Saint Kitts many years ago and has become a well-known global business leader.”
In 2017 Davis’s lobbying work on behalf of Saint Kitts raised eyebrows in Parliament, particularly around the question of who paid him and his law firm more than $96,000. His services—lobbying U.S. and Canadian authorities to lift their restrictions on the country’s passports—” comes at no cost to our government,” Prime Minister Harris told the National Assembly in 2015. Indeed, as public filings indicate, Davis’s fees were paid by CS Global Partners.
In a preliminary judgment, the UK’s National Crime Agency stated that “the claimants were ready and willing to pay bribes, and had given at least one gift to a Caribbean politician.” Virdee, who was arrested in January 2017 at Heathrow Airport on separate charges of a plot to evade millions of dollars in carbon credit taxes, has denied any wrongdoing.
Bath and CS Global Partners have not been linked to the allegations surrounding Virdee. But when asked about Virdee’s association with Bath and Saint Kitts, a spokesperson for the Prime Minister’s office said that “a historical business relationship that involves CS Global and the country’s CBI program” was “under review.”
The governments of the Caribbean and the passport firms insist they have stepped up their reviews of applicants and closed loopholes. (In one notorious instance, Saint Kitts had to recall 5,000 passports, because for years the documents did not include the owner’s place of birth.) Continuing reforms, the Prime Minister’s office said in an email, showed that “we are moving in the right direction.” The new vetting process for prospective Saint Kitts citizens, a CS Global spokesperson said, “is among the most strict in the world.” In May the European Union removed the country from an economic black list, citing the government’s commitment to reforming its passport program. (As of March, Dominica remains on a so-called gray list.)
Still, some worry that recent discounts for some passports and a growing applicant pool will drive CBI programs to cut corners. David Jessop, former head president of the London-based nonprofit Caribbean Council, wrote in November 2017 that growing competition among the citizenship-by-investment programs risked “becoming a dangerous race to the bottom.” He cited “the sometimes-questionable comments and defensive public relations exercises undertaken by some agents selling CBI programs” and “the questions that remain about the due diligence processes some governments pursue.”
In 2017, as part of efforts to raise money to rebuild infrastructure heavily damaged by Hurricane Maria, some Caribbean nations began to drastically cut their passport fees. In Dominica, Antigua, Barbuda, and Grenada, an investor passport can now be obtained through a $100,000 donation to a national fund. And investors seeking to obtain citizenship from Dominica, Saint Kitts, Antigua, or Grenada also have a new option: For an investment of at least $200,000 into a government-approved real estate project, a customer can obtain a passport for about $50,000, half the typical price.
Paolo Zampolli, a businessman who holds an honorary ambassadorship to the United Nation from Dominica has also claimed some credit for kickstarting this newer passport option: He introduced Dominica’s ambassador to the US to the head of Dubai-based Range Developments, a property firm that now markets the real estate investment program in Dominica and Saint Kitts.
The new fund has brought in record numbers of applicants: Over a five-month period, according to rough statistics released by Prime Minister Roosevelt Skerrit, the island of 50,000 people attracted 1,200 investor passport applications. In April, the head of Dominica’s CIU program said that the country had seen between 1,500 and 2,000 applications over the course of 2017.
Opposition parties in Dominica and Saint Kitts continue to raise questions about the programs, including about how much revenue they have earned and where that money is. As of 2014, Saint Kitts’ Sugar Industry Diversification Fund, to which most aspiring citizens had donated, had reached $1.5 billion in Eastern Caribbean dollars, or about U.S. $550 million. However, according to an estimate by Dwyer Astaphan, former minister of national security and tourism, the total donations to the fund should have amounted to a number closer to around $611 million. The discrepancy is due to the passport agents’ override commissions, he alleges, estimating that passport consultants have pocketed some $61 million.
In Dominica, opposition leaders have also cited a gross discrepancy between the passport revenues publicly reported to the Treasury—around $9 million between 2014 and 2015—and likely estimated revenues of $30 million that year. Representatives for Dominica’s passport program did not respond to requests for comment, but a spokesperson for CS Global said that all funds received under the program are “regularly outlined and reviewed by Parliament for distribution in the national budget.”
Dominica and Saint Kitts also do not disclose comprehensive data about their normal or diplomatic passport holders. For instance, Dominica’s January 2017 Official Gazette listed the 2011 passport recipients: 288, compared with a total island population of around 80,000. In February 2017, as revelations emerged that the government had sold diplomatic passports to alleged criminals, public frustration over the passport sales boiled over into violence.
Prime Minister Roosevelt Skerrit accused “irresponsible politicians” with the opposition of conducting a “concerted and orchestrated campaign against the citizenship by investment program.” Skerrit also promised reforms to the way the country reviews prospective citizens, and expressed regret, he said, “at the unfortunate turn of events with respect to a few persons holding diplomatic passports becoming persons of interest to foreign countries and external security organizations.”
Meanwhile, Dominica’s passport programs continue to flourish, thanks to tight relationships with industry partners. In April, Dominica appointed Nuri Katz as its ambassador to the Russian Federation, whom a government press release identifies as “a founding member of a number of businesses in Canada, Russia, and Ukraine.” (Katz holds a number of passports.) The government’s announcement about his appointment, however, does not mention his occupation, which suggests a conflict of interest: Katz is also president of Apex Capital, another prominent passport firm. The company is currently offering several real estate investment options in Dominica.