IM Yearbook 2020/21

FROM THE GROUND UP:
ST. LUCIA’S EVER-EVOLVING CIP PRE AND POST COVID-19
The Caribbean CBI industry will experience a surge in demand, but it will also become
more competitive as a result of the coronavirus pandemic, write Brenda Floissac
Fleming and Keith Isaac of Polaris Citizenship & Investment Consultancy Services.
One may argue that Citizenship by
Investment is intrinsically Caribbean.
This once micro-industry kickstarted
by St. Kitts & Nevis in 1984 is now established
in 13 countries worldwide; five of which
are Caribbean. St. Lucia is the latest isle in
the region to have made that metaphoric
plunge, having established its citizenship-byinvestment
programme in 2016. Unlike most
regional CIPs, Parliament’s clear intention
was to offer a niche programme to the world’s
billionaire club, with starting investments
double that of the most competitively priced
programmes in the region. This proved
unpopular, and the island had limited success
in attracting economic citizens to its shores.
Emphasis Change
By 2017, St. Lucia aligned its approach with
that of its regional counterparts. Starting
investments were reviewed to create parity with
the region’s most competitive programmes, while
net worth requirements and other arbitrary
hindrances to citizenship were removed. This
shift was vindicated with an almost 1,000%
increase in applications for the year 2017.
Legislation has been complimented
by a focused marketing mix. This has
involved strategic partnerships with
global stakeholders in key markets in an
attempt to boost the programme’s visibility.
The selling point of St Lucia’s CIP has
transcended the cliché visa-free rhetoric
and has been multifaceted; incorporating
the island’s culture, a focus on foreign direct
investment and ease of doing business. This
has allowed St. Lucia, unlike similar thirdworld
CBI destinations, to be viewed by
many HNWIs as a viable second home.
These shifts, along with streamlining of
the application process and a focus on top-tier
due diligence, helped the programme gain
the investment migration industry’s respect.
Covid-19 Emergence
St. Lucia, like most Caribbean CBI offerings,
has been acutely affected by Covid-19. As a
nation largely dependent on tourism, shortterm
economic loss due to the pandemic
has been reported in several industries.
Quite uniquely, whilst causing ruin to
global economies, the coronavirus pandemic
has simultaneously accelerated growth in the
investment migration industry. The expected
long-term recession and the likeliness of tax
hikes in several first-world jurisdictions, coupled
with nationalist and protectionist policy trends,
have seen interest in Caribbean citizenship
surge from both traditional and non-traditional
markets such as South Africa and Europe.
Response to Date
Eager to make best use of this incidental
opportunity, Caribbean governments
have taken swift action to attract HNWIs
to their programmes. This has included
price reductions and fee waivers from
the likes of St. Kitts and Dominica.
Refusing to be outdone, St. Lucia’s
Parliament has approved amendments to the
country’s CIP. Those included a reduction of
the qualifying donation from US$190,000.00
to US$150,000.00 for a family of four and the
introduction of a limited time Covid-19 noninterest-bearing
bond starting at US$250,000.00
with a five-year maturity period. Most notably,
the definition of ‘qualifying dependent’ has
widened significantly to include children aged
30 and parents aged 55, provided that they are
fully supported by the primary applicant.
Whilst critics may argue that such actions
diminish an offering’s value and contribute
to a philosophical ‘race to the bottom’ by
third-world CIPs, these shifts are signs of
the times – nations with limited resources
are waging war against each other in a
competitive CBI industry. The opportunity to
earn foreign exchange amidst global financial
crises simply cannot be disregarded by newly
independent states still attempting to secure
post-independence economic utopia.
Meanwhile, improvements to the scope of
‘qualifying dependent’ should be welcomed as
it points towards greater opportunity for nontraditional
family structures to benefit from CBI.
We anticipate the legislative acceptance of nonheterosexual
family structures by regional CIPs.
Future Outlook
Whilst the verdict is still out on these initiatives,
one should expect sustained incentivising of
HNWIs in a post-Covid-19 St. Lucia, which will
likely continue to rely heavily on its CIP in the
wake of an impacted tourism sector. Externally,
demand for RCBI should continue to intensify
with prolonged economic, social and political
uncertainty forecasted in major markets. The
challenge for St. Lucia’s, and other regional
CIPs, post Covid-19 will be balancing the need to
attract economic citizens with the requirement to
maintain ‘programme integrity’ in an increasingly
regulated RCBI sector, shadow governed by global
superpowers, often far removed from, and with
little understanding of, Caribbean realities.
BIO
Brenda Floissac
Fleming is a Senior
Partner at the
firm Floissac Fleming &
Associates and Managing
Director of Polaris
Citizenship & Investment
Consultancy Services in
St. Lucia. Brenda has over
30 years experience as
an attorney and advises
primarily on commercial
and transactional matters.
She is St. Lucia’s Honorary
Counsel to Chile and a
Director of the island’s
largest indigenous bank.
Keith Isaac is an attorneyat-law
at the firm Floissac
Fleming & Associates and
General Manager of Polaris
Citizenship & Investment
Consultancy Services in
St. Lucia. Keith holds a
master’s degree in Law and
Certification in Investment
Migration. He is a five time
former St. Lucia National
Youth Parliamentarian and
a former St. Lucia Junior
Minister for Tourism.
Investment Migration Yearbook 2O2O/2O21 59