Iranian Families of 4 Now Subject to Enhanced DD Fees of Up to $70,000 in Dominica: Other Nationalities Next?

A week ago, Dominica’s CIU issued a circular informing agents that, as of this Monday 17th, interviews will be mandatory for all applicants above the age of 16 and that, furthermore, Iranian applicants will henceforth be subject to enhanced due diligence, which comes with much higher fees.

While the imposition of an interview requirement has been expected since the advent of the pan-Caribbean agreement with the United States Treasury on the “6 CBI Principles” in March, Dominica’s CIP has now become the first in the Caribbean to put the policy into practice.

The enhanced due diligence fees, on the other hand, appear to have been entirely unexpected and saw RCBI advisories with Iranian clients working overtime throughout last week to file as many Iran-sourced applications as possible within the five-day window granted by the CIU before the higher fees became applicable.

The difference in cost for Iranian families after July 17th is considerable:

A family of four qualifying under the EDF contribution option would, under ordinary circumstances, pay

• US$175,000 for the contribution itself;
• US$1,000 in processing fees;
• US$7,500 in due diligence fees for the main applicant;
• US$12,000 in due diligence fees for the spouse and two children;
• US$1,000 in Certificate of Naturalization fees; and
• US$4,800 in expedited passport issuance fees

– altogether amounting to an outlay of US$201,300.

As of Monday, however, an Iranian family of four qualifying under the same option would pay

• US$175,000 for the contribution itself;
• US$1,000 in processing fees;
• US$25,000 in due diligence fees for the main applicant;
• US$45,000 in due diligence fees for the spouse and two children over 16 years old (less if under 16);
• US$1,000 in Certificate of Naturalization fees; and
• US$4,800 in expedited passport issuance fees

– altogether amounting to an outlay of US$251,800

One executive of a large investment migration company who declined to be named due to the topic’s sensitive nature expressed concerns about the new policy’s impact. He highlighted that, considering the widespread practice of unauthorized-yet-tacitly-permitted discounting – which has the effect of bringing the qualifying amounts down to under US$100,000 in many cases – the enhanced due diligence fees in practice amount to a near doubling of the total cost for Iranian applicants.

He also questioned whether Dominica would stop at Iranians:

“What if Dominica extends this enhance due diligence requirements to applicants from other, similarly challenging jurisdictions, like Iraq or China? This is going to really hurt the program. The top applicant nationalities in most of these programs [Chinese, Nigerians, Syrians, Libyans, Lebanese, etc.] are typically viewed with skepticism by Western governments.”

Separately, several Caribbean news outlets are reporting today that the UK is planning to remove Dominica’s visa waiver this week. This was first reported by The Associates Times, which cited an unnamed “trusted source within the Home Office.” IMI has not been able to verify these claims independently but is closely monitoring the situation.