The CBI Programe – A Cessation Demand
Dear Mr. President,
Now more than ever since 1979, the potential for far-reaching social and political upheaval has never been greater. The ruling political establishment of Dominica has become so entangled in the international web of intrigue and obscure dealing, that it is even hard for them to deny any links now. The People’s Party of Dominica (PPOD)
wishes to address the issue of passport selling. We are completely opposed to the outright sale of Dominican passports for cash or kind. We fundamentally denounce any such program that bestows citizenship of any country on any person, whereby that citizenship is granted for a simultaneous exchange of cash or barter.
We realize that the economic citizenship program, a.k.a the Citizen-By-Investment (CBI) program, is not a Labour Party brainchild. The scheme was initiated by the Dominica Freedom Party which witnessed its fair share of scandals. Under the United Workers’ Party, the CBI program continued and also contributed to questions about
management posed by the then opposition Labour Party. The common thread running here is the destabilization of political ethics due to a greed-inciting factor, a factor which at the same time causes us to lose the worth of our identity as a people. A passport represents the most sacrosanct of identification documents. It is that piece
of evidence that the international realm uses in order to assimilate persons who share inherent traits, common characteristics, and a common pride.
Therefore, it is much more likely that born citizens of a country will share similar political and social experiences, some disfavourable and others not. A major factor for this is long-term proximity, often combined with communal trust and family ties. Among other variables, the political and social expressions of a country’s people contribute to how the world identifies that country. An outsider who is automatically granted citizenship unfairly usurps the characteristics and reputation of that granting country. The CBI program under the current Dominica Labour Party (DLP) exponentially accelerated to become the revenue pillar. The DLP will not deny that it accounts for
over 85 percent of GDP revenue and that without it the ability to meet financial obligations and all forms of expenditure would cease to exist. We should have never ever arrived at that point! Not only are we helplessly addicted to the CBI program, but we are also sometimes at the mercy of agents who charge extortionary fees and commissions, thus robbing both the buyer and seller of a meaningful profit.
To compound matters further, strong allegations of corruption have surfaced involving the Prime Minister regarding the accountability and transparency of the program. While accusations are hurled at the DLP regarding dubious characters and supposed misappropriated amounts, we can just go off from facts. The below points we
consider as facts because they have never been disputed or denied by the Labour Party:
Fact # 1: An unsolved discrepancy exists in the 2015/2016 budget, whereby for that budget year, CBI Inflows amounted to EC $279,800,000. From this amount, actual expenditure came to $99,047,300, which was accounted
for by the Consolidated Fund in that sum. Fees and other miscellaneous expenses in the amount of $33,975,136.80 were further deducted. The balance or some EC $146.7 million is not accounted for.
Fact # 2: While on the books, Opposition Leader Lennox Linton is chairman of the Public Accounts Committee with Oversight on CBI matters, he is powerless to call for and effectuate an on-the-spot audit. He has not seen,
nor is he privy to obtaining a complete list of all financial transactions since the inception of two accounts, one at the National Bank of Dominica (NBD) and the other at the Royal Bank of Canada (RBC), where deposits from the CBI programme are maintained.
Fact # 3: There is no clear or public awareness procedure as to when CBI monies are received, who acknowledges their receipt, who are the custodians of the two acknowledged bank accounts, and who decides the amount of
disbursements according to discretion and/or external requests.
Fact # 4: Along with the peddling of passports for common citizenships, another program exists which confers diplomatic status on individuals, a lot of them of ill-repute, or on some individuals where the due diligence
process has failed. The majority of clients who purchase a second or multiple passports are people who
want to minimize expenses, be it personal and/or corporate, and/or who want to expand their international travel capability.
The minimization of expenses may mean tax avoidance or evasion; the acquisition of a cheaper lifestyle where their original home currency can stretch further; or the avoidance of prison/confinement. For those who solely desire the ability to be able to travel to more destinations, it is because their original passports do not allow them to do so. However, due diligence does not differentiate between someone who is of sound morale character and desires to
genuinely start a new life and a tax-evading rogue who skirts the law.
The threshold for due diligence investigators not to recommend an individual or family for citizenship is if he/they are involved in glaring terrorist-related activities, or if he/they are in legal trouble, the consequences being incarceration or something similar. Otherwise, all due diligence does is to report and give “grey area” advice.
Diplomatic passports should never, ever be sold for cash or exchanged for kind. This is sovereign prostitution to the highest degree. This not only cheapens a country’s diplomatic status but places all bona fide diplomats at risk. Over 90 percent of persons who purchase diplomatic passports without having representational intent for that selling countries are crooks and scoundrels, known fact.
We share a dim view on those who wish to evade taxes. Flip it, and how would you like it if top Dominican businessmen were to travel abroad, their intention to evade local taxes? Would not treasury receipts be affected?
What gravely concerns us is the real possibility of terrorists and individuals of renowned disrepute travelling under our passports to conduct their nefarious deeds. For one, while due diligence does recommend on who to grant or not grant citizenship status, it is really up to the government to make that decision. For another, due diligence only goes so far.
For example, if a well-intended man from the Middle East with a decent reputation with two sons, both under the age of sixteen, applies for a family passport, background investigations will approve him. Say one of his sons has
links with terror groups, that most likely will not affect the due diligence decision in recommending that the family get a second, in that case, a Dominican passport. Due diligence cannot detect a massive conspiracy to cover up one’s background by state and other society officials.
The penalties for the fear of passports falling into the wrong hands are too well known. For instance just three years ago, Canada imposed visa restrictions on St. Kitts for fears that terrorists and other shady characters were acquiring St. Kitts passports for the purposes of avoiding immigration screening and entry denial. These restrictions have since been lifted with St. Kitts promising tighter scrutiny and more regulations. The competition among OECS countries for a slice of the passport selling market has never been fiercer.
Not only Dominica but also countries like St. Lucia continue to lower the bar for entry requirements, thus raising the risks. Our Dominican passport grants us access to 91 countries, thereby making it the 41st most valuable travel document. Envisage for a moment, especially under the new Trump administration, that a massive terror network with links to Dominica was uncovered by US authorities. There is no doubt that there would be a US response, especially given their confirmation that they are concerned about the program. As to what the response may be, one could take a guess from passport restrictions until we cease the program to outright aid sanctions, to heaven forbid, military intervention (worst case scenario).
As a result of the potential, undesirable outcomes listed above and because we are ethically perturbed, we hereby demand that the Citizen-By-Investment program, in its current form, wind down and cease operations within nine (9) months from the date of this letter. Just to reiterate, we are firmly opposed to the selling of automatic citizenship. The Government of Dominica had five good years of CBI returns to invest in alternative streams of revenue. Prudent investing over that time period would have yielded returns equivalent to, or maybe more than what the CBI scheme
reportedly earns. If a dearth of good ideas for lucrative alternative investments exists, we strongly recommend that the government consult our Economic Message webpage which lists a plethora of sound ideas. In lieu of the CBI current structure, we recommend:
1. A resident-to-citizenship program, whereby foreigners can acquire Dominican citizenship after spending a certain amount of time per year, and a total of a given number of years in Dominica. For example, an individual or family could attain citizenship after spending three years in Dominica. Those years could be consecutive or could be broken into a mandatory number of consecutive weeks/months per year for three years.
2. A measurable, rationale option whereby investors can obtain citizenship after say, their investments show early signs of fruition. Such sustainable and viable investments should be made in economically pertinent areas.
3. A refugee-resident program, as outlined in our economic message. It is estimated that the average refugee costs the US government some US $35,000 per annum. We could host refugees at three-quarters of that cost, all expenses being met by NGOs and UN programmes, plus still get a financial incentive for doing so. Our demands can also be viewed as us doing the government a favour.
In light of the recent news stories of the arrests of Ali Reza Monfared and Diezani Alison-Madueke, it is only logical to conclude that the eyes of the international law enforcement community are more focused on Dominica. Regardless of whether their passports were canceled or revoked prior to legal troubles, the facts remain that they once held
diplomatic status thanks to a scheme that should have never been. We are calling on the Skerrit-led Labour Party government to do the right thing, and restore the pride and worth in our passport, a prominent yardstick by which the world measures us.
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