CBI Due Diligence and Licensed Agents in the Caribbean: 2026 Guide

Citizenship by investment (CBI) due diligence is the background investigation a Caribbean government runs on every applicant and adult family member before granting citizenship, covering identity, criminal history, sanctions exposure, source of funds and source of wealth. In 2026 due diligence fees run from USD 5,000 per adult in Grenada to USD 10,000 for the main applicant in St Kitts and Nevis, and every application must be filed by a government-licensed agent.

This guide from Mirabello Consultancy replaces a long series of shorter articles on due diligence, agent licensing and the proposed regional regulator. It is written for families who want to understand the vetting process before committing capital, and for anyone who wants to check that their adviser is legitimate. For programme-by-programme rules beyond vetting, see our companion guide to the Caribbean CBI rules in force in 2026.

What is citizenship by investment due diligence?

Citizenship by investment due diligence is the government's structured check that an applicant is who they claim to be, has a clean legal record, is not sanctioned or under investigation, and acquired the investment funds lawfully. Each Caribbean Citizenship by Investment Unit (CIU) requires it for the main applicant and older dependants before any approval is issued.

Due diligence is not a formality bolted onto the investment. It is the reason the programmes exist in their current form: the passports carry visa-free access negotiated on the understanding that the issuing state knows exactly who it naturalises. A government that approves the wrong person puts the travel privileges of every citizen at risk, so units have every incentive to refuse an application that leaves questions unanswered. For an applicant with a clean history and well-documented wealth, rigorous vetting is a protection: it is what keeps the passport valuable after you hold it.

In practice, due diligence has three layers. The first is the file itself: certified documents, police certificates, bank references and a written account of how your wealth was built. The second is independent verification: screening against sanctions and watch lists, adverse media and public records, with background investigations commissioned by the unit. The third is the human layer: an interview, now a standard part of the process in several programmes, in which the applicant explains their background and the purpose of the application.

Who carries out due diligence on Caribbean CBI applicants?

Caribbean CBI due diligence is carried out by each country's own Citizenship by Investment Unit, which commissions independent background checks and reviews the results before a decision. In 2026 the five units are Antigua and Barbuda's CIU, the St Kitts and Nevis CIU, Dominica's CBIU, Grenada's Investment Migration Agency and St Lucia's Citizenship by Investment Unit.

The licensed agent also has a duty of its own. Before an agent lodges a file, it is expected to know its client: to verify identity, review the documents and satisfy itself that the application is credible. A good agent refuses weak or unexplained files rather than passing the risk on to the government, because an agent whose applications are repeatedly refused damages its standing with the unit that licenses it. This is why the quality of your adviser matters as much as the choice of programme.

The banks that receive your contribution add a further check. Funds move through regulated financial institutions, which apply their own anti-money-laundering controls to large incoming transfers, so the documentation you prepare for the government should also satisfy a compliance officer at a correspondent bank.

How much are due diligence fees in each Caribbean CBI programme?

Caribbean CBI due diligence fees in 2026 range from USD 5,000 for the main applicant in Grenada to USD 10,000 in St Kitts and Nevis, with Dominica at USD 7,500, St Lucia at USD 8,000 and Antigua and Barbuda at USD 8,500. Dependant fees vary by programme and by age, and are charged on top of the minimum contribution.

Due diligence is only one of the government charges. Antigua and Barbuda adds a government processing fee of USD 10,000 for a single applicant or USD 20,000 for a family of up to four, published on the official Antigua and Barbuda schedule of fees. Dominica adds a processing fee of USD 1,000 per application, an interview fee of USD 1,000 and a USD 500 certificate fee per person, published by the Dominica CBIU. Licensed agents also charge professional fees, which are not set by the governments and vary by firm, so ask for a written, itemised quote before you sign.

What does the due diligence process actually check?

CBI due diligence checks five things: identity, criminal and legal history, sanctions and political exposure, source of funds and source of wealth, and reputation. Each Caribbean unit expects every adult on the application to pass, so a single unexplained issue for a spouse or adult child can delay or block the whole family's file.

• Identity and civil status. Passports, national identity cards, birth and marriage certificates and any change-of-name documents must be certified and consistent with one another. Inconsistent spellings across documents are one of the most common causes of avoidable queries.
• Criminal and legal history. Police certificates are required from your country of citizenship and from countries where you have lived. Pending proceedings, not only convictions, are relevant.
• Sanctions and political exposure. Applicants are screened against international sanctions lists. Politically exposed persons are not automatically excluded, but their files receive enhanced scrutiny and need especially clear documentation.
• Source of funds and source of wealth. Source of funds is the specific money used for the investment; source of wealth is how your overall fortune was built. Units expect both to be documented, for example through company accounts, sale agreements, inheritance documents, tax returns and bank statements.
• Reputation and media. Adverse media is reviewed. An old, resolved dispute is rarely a problem if you disclose and explain it; an undisclosed one that the investigators find is a much larger problem.

Disclosure is the guiding principle. Due diligence firms are paid to find what an applicant leaves out, and an omission that comes to light during the investigation is far more damaging than the underlying fact would have been. If anything in your history needs explaining, raise it with your adviser at the start, before a fee is paid to the government.

Do family members go through due diligence separately?

Family members do go through due diligence separately in every Caribbean CBI programme: each adult dependant is vetted in their own right, and fees are charged per person above an age threshold. In St Kitts and Nevis, for example, every dependant aged 16 or over carries a USD 7,500 due diligence fee in addition to the main applicant's USD 10,000.

The age thresholds differ. Dominica charges USD 4,000 for each dependant aged 16 or over, while Antigua and Barbuda charges by band, from no fee for children under 12 to USD 4,000 for dependants aged 18 and over. For a family with adult children or dependent parents, the due diligence line can therefore become a meaningful part of the budget, and a weak profile for one adult member affects everyone on the file. If one family member has a complicated history, it may be wiser to discuss whether that person should be included in the main application or considered separately later.

Adding a dependant after citizenship is granted triggers fresh vetting. St Kitts and Nevis, for instance, requires the citizen and qualifying dependants to undergo due diligence again when a spouse or child is added after citizenship, so it is usually more efficient to include every eligible family member from the start.

What is a licensed or authorised CBI agent?

A licensed or authorised CBI agent is a firm or individual approved by a Caribbean government to submit citizenship by investment applications and communicate with the unit on the applicant's behalf. In 2026 none of the five Caribbean programmes accepts applications directly from investors: every file must be lodged by an agent the government has approved.

The terminology differs by country, but the principle is the same:

• Antigua and Barbuda uses "Licensed Agents". The official Antigua and Barbuda caution notice states that applicants may only submit their application through a Licensed Agent, and that advertising the programme is prohibited without authorisation from the unit.
• St Kitts and Nevis makes "Select an Authorised Agent" the first step of the application on the official St Kitts and Nevis CIU contribution page.
• Dominica asks applicants to choose an Authorised Agent or official promoter listed on the CBIU website.
• Grenada uses a two-tier system: an Authorised International Marketing Agent works with an Authorised Local Agent, and the Grenada Investment Migration Agency states that applications may not be submitted directly to the Citizenship by Investment Committee.
• St Lucia requires applications to be submitted by an authorised agent under its Citizenship by Investment Act, and the Government of St Lucia publishes the agents it has authorised.

Many advisers, including international firms, do not lodge files themselves: they prepare and review the application and then work with a locally licensed agent who submits it. That arrangement is normal and legitimate, provided you know which licensed agent will file your application and can confirm that agent on the official list.

How do you verify that a CBI agent is genuinely licensed?

You verify a CBI agent by finding the firm's name on the official list published by the relevant government unit, then confirming that the contact details on that list match the people you are dealing with. Each Caribbean programme publishes its own list, and a licence in one country does not authorise an agent to file in another.

A practical verification routine takes less than an hour:

1. Ask in writing which licensed or authorised agent will submit your application, in which country, and under what licence or registration name.
2. Open the official site yourself by typing the government address rather than following a link you were sent, then find the list of licensed or authorised agents.
3. Match the details: the legal name, the address and the email domain should correspond to the official list. A similar-sounding name is not a match.
4. Check where your money goes. The investment contribution is paid to a government account or a government-approved escrow arrangement, never to a personal account, and you should receive documentation that traces the payment.
5. Keep the paper trail: engagement letter, fee schedule, receipts and copies of everything submitted in your name.

Antigua and Barbuda's caution notice puts the point plainly: investors must ensure that they work only with properly approved agents and service providers, to protect their personal and financial information. The same advice applies in every programme.

What are the warning signs of an unlicensed or unreliable CBI adviser?

The clearest warning signs of an unreliable CBI adviser are a price below the published government minimum, a promise of certain approval, a request to pay the contribution to a private account, and reluctance to name the licensed agent who will file the application. Any one of these is reason to pause before paying anything.

• Prices below the official minimum. Each government publishes its minimum contribution: USD 230,000 for Antigua and Barbuda, USD 250,000 for St Kitts and Nevis, USD 200,000 for Dominica, USD 235,000 for Grenada and USD 240,000 for St Lucia. An offer that undercuts these figures is either not what it claims or relies on an arrangement the government does not recognise. Antigua and Barbuda's official site states that discounts are not supported.
• Promised approval. No adviser can promise the outcome of a government's due diligence. A reputable firm can tell you whether your profile is strong and what risks it sees; it cannot promise a decision that belongs to the state.
• Unusual payment instructions. Requests to pay government contributions through personal accounts, cryptocurrency or third-party intermediaries that you cannot trace to the government are serious red flags.
• Claims of special status. Any claim of exclusive standing with a government, or of being a "designated benefactor", should be checked against the official unit. St Kitts and Nevis, for example, designates approved projects and public benefactors itself; an agent's marketing does not confer that status.
• Pressure and artificial deadlines. Urgent warnings that "the rules change next month" were used widely in 2026 around regional reforms that had not taken effect. Treat any deadline that is not published by the government with scepticism.

Is ECCIRA licensing CBI agents in 2026?

ECCIRA, the Eastern Caribbean Citizenship by Investment Regulatory Authority, does not license CBI agents in 2026. The agreement creating it was signed in September 2025 and the Authority was established in December 2025 with an office in Grenada, but it is not yet operating; agent licensing remains the responsibility of each national unit.

The Eastern Caribbean Central Bank expects ECCIRA to begin operating later in 2026, and no start date has been announced; the original target of April 2026 passed. Proposals discussed for the regional framework include 30 days of presence in the first five years after citizenship (with at least five days in the first year), an initial five-year passport that would be upgraded to ten years, and mandatory regional biometrics. None of these proposals is law. Common standards for agents have also been part of the regional discussion, but until ECCIRA operates and its rules are published, the list that matters is the national one. Our dedicated guide, ECCIRA explained, tracks the Authority's status in detail.

The practical lesson for applicants is not to time a decision around a regulator that has not started work. Plan on the rules that apply today, choose a programme on its merits, and make sure your file would satisfy a stricter regime anyway. A well-prepared, fully disclosed application is the best protection against any future tightening.

Which post-approval rules are actually in force in 2026?

Three national rules are in force in 2026: Antigua and Barbuda requires citizens by investment to spend 5 days in the country within the first 5 years, St Kitts and Nevis requires biometric enrolment, and the UK requires a visit visa from Dominica and St Lucia passport holders. Grenada, Dominica and St Lucia set no presence requirement.

• Antigua and Barbuda: 5 days within the first 5 years after citizenship is the law today; a bill proposing 30 days has been tabled but is not law.
• St Kitts and Nevis: national biometric enrolment launched on 14 April 2026, and existing citizens by investment must enrol by 31 July 2027. Details are on the official St Kitts and Nevis biometrics page.
• United Kingdom visits: holders of Dominica passports need a UK visit visa (since 19 July 2023), as do holders of St Lucia passports (since 5 March 2026). Antigua and Barbuda, St Kitts and Nevis and Grenada passport holders visit the UK visa-free with an Electronic Travel Authorisation.

These obligations matter for due diligence planning because they show what the governments now expect of citizens: a genuine, verifiable connection and a clean record that continues after approval. For renewals and biometric appointments, see our CBI passport renewal guide.

How long does due diligence take?

Due diligence is the longest single stage of a Caribbean CBI application, and its length depends far more on the quality of the file than on the programme. St Kitts and Nevis publishes a decision window of 120 to 180 days from acknowledgement of the application, within which the unit advises whether a file is approved in principle, denied or delayed.

The fastest files share the same characteristics: complete certified documents on submission, a clear and evidenced source of wealth, consistent personal details across every document and prompt answers to any query from the unit. The slowest share the opposite: missing police certificates, translations that do not match originals, and wealth narratives that rely on assertion rather than evidence. A complex profile, such as several business interests across jurisdictions, is not a problem in itself; it simply needs more preparation before the file is lodged.

What happens if a CBI application fails due diligence?

A CBI application that fails due diligence is refused, and the investor normally loses the due diligence fees already paid, because those fees fund the investigation itself. Antigua and Barbuda, for example, states that its due diligence fee is payable on submission and non-refundable, and that 10% of its government processing fee is also payable, and non-refundable, on submission, with the balance due after an approval letter.

Units do not always explain a refusal, and a refusal in one programme is relevant to applications elsewhere: application forms ask whether you have previously been refused citizenship or a visa, and a false answer is itself a ground for refusal. This is the strongest argument for honest pre-screening. A good adviser will tell you before you apply if your profile is unlikely to pass, or which programme's requirements suit your circumstances better, rather than collecting fees on an application it expects to fail.

Several programmes also restrict or suspend applications from certain nationalities, and those lists change. Restrictions are set by each government and are not always published in full, so confirm your eligibility with the unit, through the licensed agent, before you prepare any documents.

How does Mirabello Consultancy approach due diligence?

Mirabello Consultancy approaches due diligence as a pre-screening discipline: we review your profile, source of wealth and family composition before any government fee is paid, and we recommend a programme only when we expect the file to pass. Our team holds ACAMS anti-money-laundering certification and is a member of the Investment Migration Council.

From our offices in Zurich, Dubai and Hong Kong SAR, we have handled more than 250 citizenship by investment cases with a 99% approval rate. That record comes from refusing to lodge weak files, not from any special access: decisions belong to the governments alone. We tell every client which licensed or authorised agent will submit the application, we never accept government contributions into our own accounts, and we work in 11 languages so that families can understand every document they sign. To compare the five programmes side by side, see our Caribbean citizenship by investment comparison for 2026 or our guide to the best citizenship by investment programmes.

For background on the international standards that shape CBI vetting, the OECD guidance on residence and citizenship by investment explains how tax authorities treat investment migration documents, and the Financial Action Task Force sets the anti-money-laundering standards that underpin source-of-funds checks.