Due diligence on your passport application: what the state checks and how to stay calm

Citizenship by investment is not a purchase contract, it is naturalisation. At the end you hold an official certificate you can rely on for the rest of your life, and that is exactly why the state wants to know beforehand whom it is taking in. The thorough review is not an obstacle on your way; it is the reason your passport is worth something later. A passport is a right, not a permission, and that right only holds if it was acquired properly. How the programmes work as a whole is set out in the overview Buying citizenship.

What does due diligence mean in citizenship by investment?

Due diligence literally means the care that is due. In a passport application, the term refers to the background check the state runs on every applicant before deciding on naturalisation. It is not a chat between acquaintances but a formal procedure with deadlines, fees and fixed grounds for refusal.

The timing is well chosen. In St Kitts and Nevis, the regulations require the check to take place after the application is submitted and before approval in principle. Only after that approval do you pay your contribution or complete the purchase of your property. That protects you: the large sum only moves once it is certain that you have passed the review. The steps before and after are described in the route to your passport.

Important for your family: the main applicant is not the only one checked. In St Kitts and Nevis and Dominica, every applicant aged 16 and over goes through the background check, in Saint Lucia everyone over 16, and in Antigua and Barbuda due diligence fees already apply to children from the age of twelve. Sierra Leone checks all applicants aged 18 and over.

Who checks you: authorities, financial investigators and international due diligence firms

The review is not in the hands of a single caseworker. The programmes spread it across several bodies so that no single pair of eyes decides on your application.

St Kitts and Nevis sets this out in the most detail. The Citizenship by Investment Unit engages independent due diligence firms according to the rules of its Board of Governors. The data of the main applicant, the spouse and every dependant over 15 goes to four places: the country's Financial Intelligence Unit, the government's Continuing International Due Diligence Unit, the Joint Regional Communications Centre, a sub-agency of CARICOM IMPACS, and at least one reputable international due diligence firm. Biometric data may be collected as well, such as fingerprints and a check of your passport.

Dominica puts the review in the hands of its Financial Intelligence Unit. It engages approved due diligence agencies and reads every report and every application itself. One detail with real consequences: every month, the Financial Intelligence Unit reports the names and details of all refused applicants to the Joint Regional Communications Centre, which may pass them on to every other Caribbean state with an investment programme. A refusal on one island therefore does not stay on that island.

Vanuatu charges a separate Financial Intelligence Unit due diligence fee for every applicant. Sierra Leone has an independent due diligence provider check the identity, sanctions lists and criminal record of every applicant aged 18 and over. In São Tomé and Príncipe, every main applicant must pass comprehensive due diligence according to the authority's criteria.

What the state checks, point by point

The grounds for refusal are written into the regulations. The list from St Kitts and Nevis is the most complete and gives you a good picture of what lands on the table everywhere. An application there is not approved if the applicant

• makes false statements or withholds required information in the application,
• has a criminal record or is under criminal investigation,
• is a potential security risk to St Kitts and Nevis or another country,
• does not sufficiently document the source of the funds for the investment,
• has been declared bankrupt,
• is involved in activities that could damage the country's reputation,
• has been refused citizenship by another country,
• has been refused an entry visa by a country to which citizens of St Kitts and Nevis can travel visa-free.

Refused visas

This point surprises many people. Dominica goes further still and explicitly names a refused visa for the European Union or the United Kingdom. A refused visa for another country that the programme state's citizens can visit visa-free does not count against you in Dominica or in Antigua and Barbuda if you later did obtain a visa for that country. In Dominica, a residence permit is also enough. If you have never applied for a visa, there is nothing to explain here. If you were refused one at some point, it belongs in the application, together with what happened afterwards.

Source of funds

The state wants to know that your money is clean. São Tomé and Príncipe requires you to prove the legitimate source of the funds that go into the National Transformation Fund. Saint Lucia requires a sworn declaration of a net worth of at least USD 350,000. In Sierra Leone, depending on the payment agreement, proof of the source of funds and a CV are part of the documents. Banks now ask you the same questions every time you open an account, as the article on the new EU customer due diligence for account opening shows. Once your paperwork is in order, you can use it for both.

Health

Health comes into it too. Dominica requires a form completed, signed and stamped by a licensed doctor. Antigua and Barbuda lists as a ground for refusal that a doctor finds a contagious disease or a serious health problem in a family member.

Naturalisation with a criminal record: where the line is drawn

More people ask themselves about a criminal record than talk about it openly. The honest answer: it depends on the programme and on the offence. The rules differ considerably.

Two things follow from this. First, a minor offence need not stand in the way of approval in Dominica, while St Kitts and Nevis leaves no room at all. If you have a small entry on your record, choose your programme accordingly; the comparison of all programmes helps. Second, the review does not end with the certificate. Dominica revokes citizenship if someone is sentenced in any country to at least twelve months in prison after naturalisation.

What works in no programme: concealing an entry. That is precisely what the due diligence firms and authorities look for, and concealment turns a point that might have been resolvable into a certain ground for refusal.

The interview: what to expect

Almost all Caribbean programmes want to get to know you in person. This is not a test with trick questions but a conversation about your life, your work and your funds.

• St Kitts and Nevis: the main applicant and every dependant aged 16 and over have an interview, either virtually, in person in the country or at another approved location. It is conducted by staff of the Unit or by the appointed due diligence firm.
• Dominica: every applicant has an interview, virtually or in person. The minister can set up a panel that includes, for example, the Attorney General, the head of the Financial Intelligence Unit and a police representative. If you do not attend the interview, your application is refused.
• Grenada: the interview takes place online and is part of due diligence.
• Saint Lucia: for applications received since 4 September 2023, the main applicant has an interview with an identity check.

The best preparation is your own story. If you can explain without notes how you built your wealth, why you want a second passport and who is on the application with you, the interview is the easiest part of the process.

The documents you need for the review

The reviewers work with what you submit. The usual set is your passport, birth and marriage certificates, police certificates, proof of the source of funds, photos and, for some programmes, a medical form. A few rules deserve particular attention.

Police certificates

Antigua and Barbuda requires every applicant over 18 to provide a certificate from the national police authority for every country in which you have lived for six consecutive months or more since your 18th birthday. So if you spent a few years in Spain or Dubai, you need a certificate from there as well.

You apply for the German police certificate (Führungszeugnis) at the Federal Office of Justice (Bundesamt für Justiz), also online using the online ID function of your identity card, an NFC-enabled smartphone and the AusweisApp. For a programme abroad you need the certificate on paper: no apostille can be attached to the digital certificate. You can apply for the authentication at the Federal Office of Justice together with the certificate itself; the apostille is then issued by the Federal Office for Foreign Affairs (Bundesamt für Auswärtige Angelegenheiten). If you apply from abroad, processing takes longer according to the Federal Office, so allow time for it.

Translations and certifications

St Kitts and Nevis requires all forms in English and every document in another language with a certified translation by an officially recognised translator. Copies certified by a notary outside the country need an apostille in states party to the Hague Convention. Dominica requires translations of birth, marriage and police certificates and of the passport data page to be confirmed by the competent authority, embassy or consulate of the country of origin.

Declarations for your family

In St Kitts and Nevis and in Dominica, you sign a sworn declaration for every adult dependant other than your spouse confirming that you support them. Children in higher education prove their enrolment with a letter from their university. Which family members can be included in which programme is shown on the family page.

What the review costs

Due diligence has its own price, set by the state. It comes on top of the contribution or investment and is included in the total cost of every programme, which you will find under costs.

Do not count on getting the due diligence fee back. St Kitts and Nevis calls it expressly non-refundable in its regulations, Dominica does not refund the fees if an application is refused, Saint Lucia describes due diligence and processing fees as non-refundable, and Grenada declares all fees non-refundable. Sierra Leone takes a different approach: the programme fee sits in an escrow account until naturalisation and is refunded 100 % if naturalisation cannot be completed, minus submission and processing costs such as due diligence.

The logic behind it is simple: the review takes place whatever its outcome. That is why it pays to be honest with yourself before you submit, rather than staking a fee on a programme whose grounds for refusal apply to you.

How long the review takes

A thorough review takes its time, and no programme can be hurried here. Grenada approves applications within 60 working days of submission, provided the due diligence is satisfactory and the funds have been received, and explicitly offers no express service because the checks are thorough and take time. Dominica gets back to the authorised agent within three months of submission with the status of the application.

The biggest lever is in your own hands: complete documents spare you follow-up questions, and every follow-up question costs time. St Kitts and Nevis only accepts an application when all forms are fully completed, dated and signed and all documents and fees are in. The timelines of every programme side by side are under processing times.

False statements: why honesty is your best strategy

The only mistake in due diligence that cannot be repaired is a false statement. The regulations leave no doubt on this.

In St Kitts and Nevis, an application can be refused if you make a false statement or leave out required information. If this only comes to light after naturalisation, your citizenship can be revoked, and prosecution under the Perjury Act is possible. Dominica has the same rule and adds: anyone who loses citizenship for this reason must return the passport, and neither fees nor investments are refunded.

That goes to the heart of what a second passport is meant to do. You want a citizenship that still stands in twenty years, even when a programme has long since been reformed or closed. What happens to people whose naturalisation is reviewed later is shown in Citizenship revoked. A thorough review at the time you acquire it is your best insurance against that.

How to stay calm: seven points before you apply

The good news: if your record is clean and you can document your wealth, due diligence is mostly paperwork. Settle these seven points beforehand and the review holds no surprises.

1. A CV without gaps. Write down your positions, companies and places of residence so that they match your documents. Contradictions between your CV and your paperwork trigger follow-up questions.
2. Document the source of funds. Gather the papers that show how you built your wealth: contracts for a company sale, certificates of inheritance, salary statements, tax assessments, bank statements.
3. Disclose old refusals. A refused visa or a rejected naturalisation belongs in the application, with the date and what happened afterwards.
4. Request police certificates early. For Germany on paper with an apostille, and for every country where you lived for a longer period, from the authority there.
5. Think of your family. In St Kitts and Nevis and Dominica, every family member aged 16 and over is checked, and for adult dependants other than your spouse you need the declaration of support there. Clarify their history too.
6. Choose the programme that fits your situation. A small entry on your record, a visa refused in the past or a nationality all help decide which programme suits you. St Kitts and Nevis, for example, accepts no nationals or residents of Russia, Belarus, North Korea, Afghanistan, Iraq or Iran. What legitimate programmes look like is shown in Buying a passport, but legally.
7. Be yourself in the interview. Nobody expects a rehearsed speech. Tell your story as it is.

And think long term. Citizenship by investment buys you time; naturalisation through genuine residence remains the free route, but it takes years. The two are not mutually exclusive, quite the opposite: how to combine both routes is shown in CBI and naturalisation.

Frequently asked questions