By Caribbean News Global 
GENEVA, Switzerland – The International Migration Council (IMC) the worldwide forum for investment migration, bringing together the leading stakeholders in the field, sent a memo to members on May 6, 2024, citing complaints at “prices that fall under the full legislated amounts set out by governments” and counselled “whether members or not, to re-familiarise yourselves with our various codes of conduct.”
In the memo, IMC said it “has received, a number of complaints citing that it is common practice for agents, particularly in the Middle East and some Caribbean countries, to promote investment migration pathways at prices that fall under the full legislated amounts set out by governments. This practice contravenes the IMC’s Codes of Conduct and Guidelines on Advertising and Marketing. IMC members are reminded to act in a manner that aligns with the fundamental values we promote at the IMC: ethics, transparency, and openness and to abide by the contents of the codes,” the memo added.
‘Some Caribbean countries’
Antigua and Barbuda, Dominica, Grenada and Saint Kitts and Nevis, on March 20, 2024, signed a Memorandum of Agreement (MOA) Memorandum-of-Agreement-CBIP-20-March-2024.
This follows European Union officials‘ visit to Dominica on 24 January 2024 with the OECS countries to discuss the Caribbean CBIPs.
The MOA supplements the six principles agreed upon between Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia on 25 February 2023, at the US-Caribbean roundtable deliberating the challenges faced by Caribbean CBI programmes and discussed opportunities that would enable the programmes to thrive among OECS Member States.
However, as of May 7, 2024, Saint Lucia has not signed the MOA, citing – “On the matter of pricing, we have contractual arrangements in place which will have to be observed or government will face potential legal action. We hope to sign the Memorandum of Agreement once it becomes possible.” Prime Minister Philip J Pierre. And at Monday, May 7, 2024, pre-cabinet press briefing commented: “If you can get your roads built without increasing your national debt, you are against that?”
The prime minister’s deliberations in Belgium last month concerned the Citizenship by Investment (CBI) investment marketplace engaged in discussions with the European Commission and European Parliament regarding international migration matters.
The 2024/2025 budget address of Prime Minister Pierre, states:
“The government has taken the decision to leverage the Citizens by Investment Programme (CIP) to bring more direct benefit to the people of Saint Lucia. This year, we intend to construct houses under the CIP programme, as has been done in other islands.”
“The minister has skilfully used our CIP programme started in 2016, when the people of Saint Lucia made up their minds that same year to change the government of the day. In 2016, Saint Lucia was not actively engaged in the CIP programme. Between 2016 and 2021, the rules governing our CIP had changed.
“In December 2023, this government introduced an infrastructure option to complement the other funding options. The new infrastructure option requires developers to raise the financing needed to undertake approved projects in a number of selected areas and recover their expenses through CIP.
“The islands that have signed the agreement (MOA) have been able to build roads, houses, community centres and reduce their public debts from their CIP. And, I am pleased that they were able to do so. But we are the last to have adopted the programme and have benefited the least.
“Our CIP programme is anchored by robust due diligence processes at every stage and complemented by robust due diligence processes by the financial institutions involved in facilitating the CIP.
“There has not been one issue with our CIP programme. No one has raised any negatives regarding the due diligence of our programme. Our programme is now well poised to deliver infrastructure in the form of roads, community centres, and hotels to our people without increasing the national debt.”
Building resilience and sustainability in the immigration investment industry: The perspective of St Lucia
“The importance of the industry underscores the need for accurate information. This must be the basis for any resilient and sustainable industry. This industry has become notorious for salacious stories about countries, individuals and companies. I have learnt that in public life, you must ride the waves but remain unflinching in your focus and determination.
“So let us move forward focusing on the challenges we face with pricing, commissions, due diligence processes, branding and perception, quotas, transparency and accountability of promoters and agents. We are at a historic moment, let us make it count,” Dr Ernest Hilaire.
Returning to the IMC memo, it reads:
“Any unchecked and insufficiently regulated investment migration programme is potentially open to abuse, and without oversight and a rigid code of ethics, it leaves itself vulnerable. As an industry representative body, it is our responsibility on behalf of all our members to protect the reputation of the industry, and the contribution of investment migration for the economic and social development of countries, that we helped to pioneer by upholding the highest standards and thus avoid the opacity that sours at times the discourse around investment migration.
“Moreover, please be reminded that the IMC code of ethics is binding on members, and please remind colleagues that unprofessional and unethical behaviour undermines the industry and the economic development of IM recipient countries and will put their own careers at risk, especially when it brings companies and the wider IM sector unfairly into disrepute.
“Furthermore, we remind members that unless you are a licensed arranger of financing you should refrain from doing so. Unlicensed financial arrangement activities are inconsistent with the IMC’s code of conduct and strongly recommend minimum contributions that entitle access to investment migration status are observed at all times.”
The IMC memo concluded: “It is our professional duty and organisational responsibility to act in the best interests of the industry and ensure that we continue to adhere to the highest professional standards.”
CNG Insights
Taken together, “to promote investment migration pathways at prices that fall under the full legislated amounts set out by governments.” And/or to engage in practices that “contravenes the IMC’s Codes of Conduct and Guidelines,” hitherto, simply means that credibly, “financing schemes are illegal.”
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