Dominica’s Affordable Passport Plan Under Scrutiny By Organized Crime Investigation Group.

Photo by Anita Denunzio on Unsplash. The island of Dominica has a small population, but many passport holders.
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Foreigners have been able to buy passports from the Caribbean island nation of Dominica since 1993. Dominica has allowed foreigners to buy citizenship so as to boost its foreign currency revenues, which, since the decline of the banana export industry,  depend mainly on tourism.

The price for a passport is just $100,000 invested in a government fund or $200,000 in a government-approved real estate development—a cheap proposition for billionaires and wealthy investors seeking a better travel document or a way out of their home countries.

Dominican passports allow visa-free, visa-on-arrival or electronic visa access to 132 countries, including China, the European Union and Singapore, although not to Britain, which says that Dominica has given passports to individuals that Britain regards as ‘dangerous to Britain”.

Key findings of the investigation by the Organized Crime and Corruption Project are that:

  • Comparing published lists of citizenship buyers with figures from Dominica’s national budget reveals serious discrepancies: More than 10,000 names appear to be undisclosed.
  • On the other hand, revenues from the program appear to be lower than expected.
  • The budgets raise other red flags, like identical revenue numbers published two years in a row.

Dominica authorities call the program the “fastest, longest-running and most affordable” citizenship by investment scheme in the world. They also claim to run “due diligence checks” on all investors.

But a new cross-border investigation, named Dominica: Passports of the Caribbean, found that the country has given passports to at least three Russian oligarchs who have since been sanctioned and a controversial crypto investor now wanted in Singapore.

The joint investigation is a collaborative cross-border effort by the Organized Crime and Corruption Reporting Project, the Washington D.C.-based nonprofit the Government Accountability Project, and more than a dozen media partners including Forbes.

It began after the Government Accountability Project obtained the names of roughly 7,700 people who have bought Dominica passports in recent years. These names were compiled from official documents published by the government of Dominica and supplemented via certain leaked documents and corporate filings. They were then sifted through by reporters from more than 20 countries.

Dominican officials did not respond to multiple requests from Forbes for comment. But in a press conference held on September 18, the country’s prime minister Roosevelt Skerrit denounced what he called “an attempt by some in [Dominica] to destroy the [citizenship by investment program]” by “colluding in with international journalists and some regional journalists to propagate a lot of mischief, misinformation about [the program] all in an effort to destroy it.”

Dominica isn’t alone in offering citizenship by investment. At least four other Caribbean islands offer similar programs, as do several countries in Europe and the Middle East, including Turkey.

But what sets Dominica apart is that it has long faced criticism from Western governments for its lax attitude towards ensuring that suspected criminals and politically exposed people don’t get passports from the country.

In a 2019 report, the U.S. State Department called Dominica’s due diligence “lax” and stated that the country “does not always deny citizenship to those who are red flagged.”

A follow-up report published in 2022 said that “Dominica sometimes issues passports despite adverse information uncovered during vetting.”

The U.K., which previously allowed visa-free access to Dominican citizens, introduced a visa requirement on July 19.

In a statement, the U.K.’s home secretary Suella Braverman said that Dominica’s citizenship investment program had “shown clear and evident abuse of the scheme, including the granting of citizenship to individuals known to pose a risk to the U.K.”

“[Dominica doesn’t] have any other resources besides tourism. So that’s why they do this,” says Reaz Jafri, a private client and tax attorney at law firm Withersworldwide who focuses on immigration. “They’re relatively inexpensive. People do it primarily to have a good travel document. The due diligence, with 10 being very rigorous…I think these Caribbean countries are maybe around 5 or 6.”

Despite the controversy, the program has been a massive revenue generator for the Dominican government since it was first established in 1993.

Skerrit, who has served as prime minister since 2004, announced in 2020 that the country had raised $1.2 billion from the program in the previous three years alone. In the 2021-22 financial year, the most recent year where full records are available, Dominica received 459 million East Caribbean dollars ($170 million) from the citizenship by investment program—54% of total revenues.

And interest in the program is rising: according to London-based law firm Henley & Partners, which assists clients in getting residence and citizenship by investment, enquiries regarding Dominican citizenship by investment rose 729% in 2020, 131% in 2021 and 13% in 2022.

Even without access to the U.K., Dominican citizenship provides a key benefit for nefarious individuals facing sanctions or seeking to flee their home countries: a “clean” travel document.

Dominican passports allow visa-free, visa-on-arrival or electronic visa access to 132 countries, including China, the European Union and Singapore.

Forbes found that three sanctioned Russian oligarchs acquired Dominican passports, including the wealthy real estate moguls God Nisanov and Zarakh Iliev, who obtained citizenship in 2017—five years before they were sanctioned by the U.K. in 2022. (Nisanov’s wife and children also acquired Dominican passports, and Nisanov was also sanctioned by the U.S. last year.)

Steel magnate Alexander Abramov got a passport for himself, his wife and his children in 1996, more than a decade before he was hit by U.K. sanctions in 2022. Representatives for Nisanov, Iliev and Abramov did not respond to detailed requests for comment.

For Nisanov, the Dominican passport was another addition to a collection of citizenships he already held. According to sanctions designations in the U.S. and U.K., Nisanov is also a citizen of Azerbaijan, Cyprus and Russia.

Last year, Lisbon-based newspaper Público reported that Nisanov had also been seeking Portuguese citizenship, citing a source in the country’s ministry of justice. Cyprus started revoking the passports of several sanctioned Russian oligarchs after Russia’s invasion of Ukraine last year, but it’s unclear whether they’ve removed Nisanov’s.

Another oligarch, the real estate billionaire and former president of the Russian Judo Federation, Vasily Anisimov, obtained Dominican citizenship in 2000. A source close to Anisimov confirmed to Forbes that he holds a Dominican passport, but stated that he has not used it since the early 2000s, when he became a Croatian citizen as well.

The source also said that Anisimov renounced his Russian citizenship in 2022 but did not provide proof for the claim.

Meanwhile, Giannis Vardinogiannis, the son of Greek oil & gas billionaire Vardis Vardinogiannis, obtained Dominican citizenship alongside his wife and children in 2013. Representatives for Vardinoyannis did not respond to a detailed request for comment.

Several more controversial figures have used the scheme to get a second passport. One of them is Kyle Livingston Davies, the cofounder of former cryptocurrency hedge fund Three Arrows Capital, which filed for bankruptcy in July 2022. Davies received Dominican citizenship in 2009, three years before launching Three Arrows.

With a small population of 75,000 people, the ranks of naturalized Dominican citizens could soon outnumber the residents on the island.

The government doesn’t regularly publish the number of approved citizenship applications, but Skerrit, the prime minister, revealed in 2020 that 5,814 applications were approved between 2017 and 2020.

That doesn’t seem to match with the fees brought in by the program: Dominica’s opposition leader recently cited a figure of 46,615 naturalizations between 2016 and 2023 in a document shared with a media partner in the investigation, based on official revenue data provided by the Dominican government.

That number would represent more than half of the total population on the island.

There are few limits on who can get Dominican citizenship. Prior to last year, the country only banned applicants from northern Iraq. North Koreans and Sudanese citizens are also barred, with exceptions for those that have lived outside of their home countries for at least 10 years, have no “substantial assets” there and haven’t “performed any business or similar activity.”

After facing criticism in the aftermath of Russia’s invasion of Ukraine, Dominica also banned applicants from Russia and Belarus in March 2022. That may have been too late, given that the sanctioned Russian oligarchs had already become Dominican citizens years earlier.

Sources;, Forbes, The Guardian.
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