The Commonwealth of Dominica's Citizenship by Investment (CBI) program has undergone transformative changes throughout 2024, establishing itself as one of the Caribbean's most stringent yet accessible pathways to second citizenship. With 31 years of operation since its inception in 1993, the program has evolved into a sophisticated economic instrument that contributed 37% to the nation's GDP in fiscal year 2022/23, generating approximately USD 232 million in revenue.
The landscape of approved real estate projects
As of June 2025, Dominica maintains a selective portfolio of nine government-approved real estate projects for CBI investors. This deliberately limited number reflects the government's quality-over-quantity approach, ensuring each development meets stringent environmental and construction standards while contributing meaningfully to the island's economic development.
The flagship InterContinental Dominica Cabrits Resort & Spa stands as the program's most prominent success story. Developed by Range Developments and operational since October 2019, this 151-room luxury resort near Cabrits National Park demonstrates the caliber of projects attracting CBI investment. Originally branded as a Kempinski property before transitioning to InterContinental management in March 2023, the resort features four outdoor pools, an expansive spa, and 8,500 square feet of meeting space, earning recognition from Condé Nast Traveler as one of the "hottest new hotel openings" upon its debut.
Among the developments currently under construction, Jungle Bay Resort represents a significant eco-luxury investment opportunity. Located in Soufriere on a 20-acre plot overlooking Scott's Head and the Atlantic Ocean, the project encompasses 120 eco-villas, with 40 units already completed in phase one. Developer Sam Raphael's Ay Ay Holdings Caribbean Ltd has positioned the resort to feature two of the Caribbean's largest yoga studios while providing employment for over 100 Dominican citizens. The minimum investment of USD 255,000 for a Sea View Villa exceeds the program's USD 200,000 threshold, with expected completion targeted for early 2025.
The Sanctuary Rainforest Eco Resort and Spa, developed by Vital Developers Limited, exemplifies Dominica's commitment to climate-resilient construction. Situated within the Morne Trois Pitons National Park region in Laudat, this 72-unit luxury organic villa development spans 10 acres of pristine rainforest. The project's design specifications enable it to withstand Category 5 hurricanes and earthquakes, addressing critical infrastructure resilience concerns. Investors receive one preferred share for their USD 200,000 investment, with promised dividend income from year one and 7-14 days of complimentary accommodation annually.
Tranquility Beach Resort, a collaborative venture between Sunset Homes and Aries Capital, brings the Hilton Curio Collection brand to Dominica's Salisbury region. This 99-room resort spread across 15 buildings on a four-acre marine coastal property features cliff-hanging villas and access to two secluded beaches. With construction commencing in January 2019, the development promises to create 250-300 permanent jobs upon completion, significantly impacting local employment.
Additional approved projects include Anichi Resort & Spa in Roseau, positioned as a transformative eco-luxury development; Grande Anse Holdings' Timbo's Downtown, a luxury boutique hotel targeting business and leisure travelers in the capital; The Residences at Secret Bay, offering fractional ownership from USD 216,000; and Ocean Edge Development, described as a mixed-use project blending nature with comfort.
Investment pathways and financial requirements
Dominica's CBI program offers two distinct investment routes following the June 2024 regulatory overhaul. Notably absent is a government bonds option, distinguishing Dominica from neighboring St. Lucia, which remains the sole Caribbean program offering this investment category.
The Economic Diversification Fund (EDF) represents the most direct pathway to citizenship. Following a dramatic 100% increase implemented on June 8, 2024, single applicants must contribute USD 200,000, aligning with the Organisation of Eastern Caribbean States (OECS) Memorandum of Agreement signed in March 2024. Family applications require USD 250,000 for a main applicant with spouse, or USD 275,000 for a family of four. Additional dependents incur supplementary fees of USD 25,000 for those under 18 and USD 40,000 for adults.
These contributions directly fund national development initiatives spanning infrastructure, healthcare, education, and climate resilience. The new international airport project in Wesley, budgeted at USD 1 billion, represents the most ambitious infrastructure undertaking. Healthcare improvements include the 75-bed Marigot Hospital, which opened in September 2023, while housing initiatives target 5,000 climate-resilient homes. Educational investments encompass school construction and renovation projects, complemented by geothermal energy development and digital transformation initiatives.
Real estate investment maintains its USD 200,000 minimum threshold but carries additional government fees restructured as of July 1, 2024. Single applicants pay USD 75,000 in government fees, while families of up to four members pay USD 100,000. The mandatory holding period remains the Caribbean's shortest at three years for general market resale, extending to five years if selling to another CBI applicant.
Processing fees apply uniformly across both investment routes. Due diligence costs USD 7,500 for the main applicant and USD 4,000 for each dependent aged 16 or older. The mandatory interview process, introduced in July 2023 as a pioneering requirement among Caribbean programs, adds USD 1,000 per applicant over 16. Additional fees include USD 1,000 for processing, USD 500 for the certificate of naturalization, and USD 500 for passport issuance. Iranian nationals face enhanced due diligence fees of USD 15,000 for main applicants and USD 10,000 for dependents.
The application journey from submission to citizenship
The path to Dominican citizenship follows a structured five-phase process typically completed within three to six months, maintaining the Caribbean's fastest processing timeline despite enhanced security measures.
The pre-application phase spans two to four weeks, beginning with mandatory selection of an authorized agent. Dominica uniquely requires all agents to hold Dominican citizenship and maintain registered offices with at least three staff members on the island. Agents conduct preliminary due diligence screening before guiding applicants through investment route selection and comprehensive document preparation.
Application submission requires one to two weeks for completion of Form 12 and supporting documentation. All documents must be apostilled or certified, with non-English materials requiring sworn translation. The application package, submitted exclusively through authorized agents, includes identity documents, financial records, police clearances, medical certificates, and detailed source of funds documentation.
The due diligence and review phase represents the most time-intensive component, lasting two to three months. The Citizenship by Investment Unit (CBIU) conducts internal reviews while engaging third-party international firms from the United States and United Kingdom for external investigations. Database checks encompass Interpol records, sanctions lists, and criminal databases. All applicants aged 16 and above must complete mandatory virtual interviews, available in multiple languages. The Financial Intelligence Unit, operational since October 2024, performs comprehensive source of funds verification.
Upon receiving approval in principle, applicants have 30 days to complete their investment. For EDF contributions, funds transfer directly to the government account. Real estate investments involve escrow arrangements through the National Commercial Bank of Dominica, with funds released only after compliance verification.
The final citizenship grant phase spans two to four weeks. Applicants sign the oath of allegiance before an authorized official, receive their certificate of naturalization, and apply for Dominican passports. Document delivery occurs via secure international courier services.
Regulatory evolution and program updates
The year 2024 marked a watershed moment for Dominica's CBI program, with the Commonwealth of Dominica Citizenship by Investment Regulations 2024 consolidating all previous amendments into a comprehensive framework. Published in the Official Gazette on June 28, 2024, these regulations introduced sweeping changes affecting every aspect of the program.
The establishment of an Independent Due Diligence Unit under Financial Intelligence Unit oversight in October 2024 significantly enhanced screening capabilities. This unit coordinates with the Joint Regional Communications Centre (JRCC) for cross-referencing applicants against regional watchlists while implementing monthly reporting requirements for denied applications.
Family inclusion criteria underwent substantial revision. Adult children must now be "fully supported" rather than "substantially supported," with mandatory full-time enrollment in recognized higher education institutions. Parents and grandparents must be over 65 years old, while siblings aged 18-25 lost eligibility entirely. Exceptions remain for mentally or physically challenged dependents and unmarried daughters under 25.
New restrictions explicitly prohibit name changes for CBI applicants, with citizenship subject to deprivation if names are changed within five years, except for marriage. Criminal convictions resulting in sentences of 12 months or more trigger automatic citizenship revocation without refund. This enforcement mechanism proved its effectiveness in June 2024 when 68 citizenships were revoked for fraud or misrepresentation, predominantly affecting Iraqi nationals.
Dominica's position in the Caribbean CBI marketplace
Within the competitive Caribbean CBI landscape, Dominica maintains its position as the second-ranked program globally according to the 2024 CBI Index, achieving perfect scores in six of nine evaluation pillars. The program's 80% overall score trails only St. Kitts & Nevis at 84%, while outperforming Grenada (77%), Antigua & Barbuda (74%), and St. Lucia (74%).
Dominica's competitive advantages center on affordability and processing efficiency. The USD 200,000 EDF contribution remains the most economical option for single applicants across all Caribbean programs. Processing times of three to six months significantly outpace competitors, with St. Kitts & Nevis requiring six to eight months and St. Lucia extending to six to ten months.
However, passport strength presents a persistent challenge. Dominican citizenship provides visa-free access to 145 countries, including unique privileges for China and Russia, yet falls short of St. Kitts & Nevis' 154 destinations. The July 2023 imposition of UK visa requirements, though under diplomatic negotiation, temporarily diminished the passport's appeal for some investors.
Market dynamics shifted dramatically in 2024, with competitors experiencing explosive growth. Antigua & Barbuda reported a 205% increase in applications during the first half of 2024, processing 739 applications. St. Lucia achieved an 85% increase, while Grenada cleared substantial backlogs, processing 1,314 applications to generate USD 186 million in revenue.
Due diligence framework and program integrity
Dominica's multi-layered due diligence approach represents one of the program's core strengths. Internal screening by CBIU staff with specialized training in anti-money laundering and counter-terrorism financing precedes external investigations by top-tier US and UK firms. The JRCC provides regional intelligence sharing, while the National Bank of Dominica conducts independent financial verification.
Background investigations encompass identity verification, criminal records across all jurisdictions of residence, employment history, source of funds analysis, media profile assessment, and political exposure evaluation. Due diligence firms employ both online and on-ground verification methods, including interviews with former business associates, law enforcement contacts, and employers.
The mandatory interview requirement, pioneered by Dominica in July 2023, adds a crucial human element to the screening process. Conducted virtually or in-person in the applicant's preferred language, these interviews involve all family members aged 16 and above, with identification documents required throughout the session.
Program integrity measures extend beyond initial screening. The June 2024 revocation of 68 citizenships demonstrated the government's commitment to retroactive enforcement when fraud is detected. Published citizenship deprivation orders included passport cancellations and potential legal action against violators.
International compliance remains paramount. The program adheres to the Six Principles Agreement established at the 2023 US-Caribbean Roundtable, implements FATF anti-money laundering standards, participates in the Common Reporting Standard for tax information exchange, and shares intelligence through the JRCC digital portal.
Economic impact and future outlook
The CBI program's contribution to Dominica's economy extends far beyond direct revenue generation. Infrastructure developments funded through CBI proceeds include a new international airport, geothermal energy facilities, climate-resilient housing for 2,000 families displaced by Hurricane Maria, twelve new healthcare centers, and modernized educational facilities with advanced laboratories.
These investments align with Dominica's ambition to become the world's first climate-resilient nation, addressing vulnerability to natural disasters while building sustainable economic foundations. The program's success in attracting over USD 200 million annually provides crucial foreign exchange reserves and employment opportunities across construction, hospitality, and professional services sectors.
Looking ahead, several factors will shape the program's trajectory. The anticipated establishment of an independent regional regulator in late 2025 promises standardized oversight across Caribbean programs. Continued engagement with US and EU partners aims to address security concerns while maintaining program accessibility. Digital transformation initiatives, including the mandatory E-APIS portal system effective June 30, 2025, will streamline processing while enhancing security.
Competition from regional programs, particularly rapidly growing options in St. Lucia and Antigua & Barbuda, necessitates continuous innovation. Dominica's strategy appears focused on maintaining quality standards while leveraging unique advantages including processing speed, program integrity, and exclusive visa-free access to major markets like China and Russia.
Strategic considerations for prospective investors
High-net-worth individuals evaluating Dominica's CBI program should weigh several critical factors. The program's established 31-year track record provides confidence in operational stability, while recent regulatory enhancements demonstrate responsiveness to international concerns. The limited number of approved real estate projects ensures quality control but may restrict choice compared to programs with larger portfolios.
Financial considerations favor single applicants and small families, with Dominica offering the Caribbean's most economical pathway to citizenship. However, larger families might find better value in programs with more generous dependent inclusion policies. The three-year real estate holding period provides superior liquidity compared to five-year requirements elsewhere, though the five-year restriction for CBI-to-CBI sales limits secondary market options.
Processing efficiency remains Dominica's standout advantage, particularly valuable for time-sensitive applications. The mandatory interview requirement, while adding complexity, signals commitment to program integrity that may facilitate future visa-free travel negotiations with countries that have imposed restrictions.
Investors must carefully evaluate their specific mobility needs against Dominica's visa-free destination list, considering both current access and potential future changes. The unique China and Russia visa-free privileges may prove particularly valuable for certain business profiles, offsetting limitations in other regions.
Conclusion
Dominica's Citizenship by Investment program stands at a critical juncture, balancing established strengths against evolving regional competition and international scrutiny. The comprehensive regulatory overhaul of 2024 positions the program for sustainable growth while addressing legitimate security concerns from international partners.
For prospective investors, Dominica offers a compelling combination of affordability, efficiency, and program integrity, particularly suited to single applicants and small families prioritizing quick processing and Chinese market access. The limited but high-quality real estate portfolio provides investment diversification opportunities, while the EDF option delivers the most direct path to citizenship.
Success in navigating the program requires careful selection of authorized agents, meticulous documentation preparation, and realistic expectations regarding due diligence requirements. The enhanced screening procedures, while extending processing times compared to historical standards, ultimately strengthen the program's international credibility and long-term value proposition.
As Caribbean CBI programs continue evolving in response to global security concerns and regional competition, Dominica's commitment to quality over quantity, demonstrated through limited project approvals and stringent due diligence, positions it as a reliable choice for discerning investors seeking legitimate second citizenship opportunities. The program's contribution to national development, from climate-resilient infrastructure to healthcare improvements, ensures that investment directly supports sustainable progress in this Caribbean nation.
