This recent Letter to the Editor, appearing in Dominica media, says it all; the Revenue Dependence Dominica has on CBI funds is a direct Conflict of Interest, interfering with the proper operation of the program, especially the DUE DILIGENCE requirement. It is worth a read:
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"The recent letter seeking to absolve Dominica’s Citizenship by Investment (CBI) programme of responsibility by shifting blame almost entirely to the United States deserves careful scrutiny, not passive acceptance.
The central flaw in the writer’s argument is not technical—it is structural. The letter attempts to frame weaknesses in the CBI programme as unavoidable by-products of U.S. information-sharing policies, rather than as consequences of how the programme itself is designed, incentivized, and administered.
While it is true that no vetting system can uncover crimes that have never been recorded, this reality does not excuse weak or rushed due diligence. On the contrary, uncertainty demands greater scrutiny, not complacency. In international compliance, gaps in information are a risk factor that must be mitigated through conservative approval standards, extended investigations, and higher rejection thresholds—not explained away after the fact.
More importantly, the letter avoids the most critical issue entirely: revenue dependence.
Dominica’s CBI programme is not a marginal economic policy. It is a dominant fiscal pillar, accounting for a substantial share—often a majority—of government revenue. This fact alone creates a structural conflict of interest. When passport issuance becomes the primary income stream of the state, speed, volume, and approval rates inevitably come under pressure. No amount of rhetorical defense can change that reality.
This is not conjecture. It is basic governance logic. No country can credibly argue that citizenship decisions remain insulated from financial incentives when the programme funding the national budget depends on approvals continuing uninterrupted. In such an environment, the risk is not “accidental” approvals of unsuitable applicants—it is systemic tolerance of risk.
The letter also minimizes the significance of identity complexity, legal name changes, and thin personal histories by portraying them as issues only the United States can resolve. This is misleading. International AML/CFT standards explicitly require heightened scrutiny where identity continuity is weak or fragmented. These are not U.S. demands; they are global compliance norms. Ignoring them does not make the programme compliant—it makes it vulnerable.
Furthermore, the repeated assertion that the United States should simply “fix its databases” misses the point entirely. Border security does not begin at the airport. It begins with the sovereign act of granting citizenship. When a passport is issued, the issuing country is vouching for the holder’s identity, background, and trustworthiness. That responsibility cannot be outsourced, deflected, or diluted.
Finally, describing legitimate security concerns as punishment of “innocent applicants” is a mischaracterization. Visa-free access is a privilege, not an entitlement. When a programme introduces elevated risk into international travel systems, partner states are entitled—indeed obligated—to reassess that risk.
This debate will not be resolved by pretending that all failures originate abroad. If Dominica wishes to defend its CBI programme credibly, it must confront uncomfortable facts: over-reliance on passport revenue, structural conflicts of interest, and the reality that citizenship has been treated less as a sovereign trust and more as a transactional product.
Accountability cannot be demanded of others while being avoided at home."