IF YOU READ ANYTHING THIS WEEK, REGARDING CITIZENSHIP BY INVESTMENT IN THE EASTERN CARIBBEAN, READ THIS:
Dear Hon. Prime Minister and Hon. Leader of the Opposition
Re: A CBI Programme Completely out of Control
I write with profound regret to state that, despite all efforts on my part and, I am sure, on the part of others, the current state of the country's CBI programme and related development projects is untenable.
ILLICIT MONEY
Although it lies squarely within the Prime Minister's power and purview to stop it, and despite my thirteen letters over seven years enclosing hundreds of pages of evidence, our major CBI projects continue to be funded by illicit money. Our principal developers, led by MMC, are breaking Dominica's laws daily by offering illegal discounts on citizenship. My last letter of 21 October 2024 contained over forty pages of evidence, demonstrating that approximately 80% of the CBI transactions surveyed were illegal. More recently, through my investigative channels, I have again surveyed the market and, of the developers and service providers reviewed, 100% demonstrated illegal pricing, averaging a 55% discount on the legal price. In previous letters I shared the relevant evidence of illegal pricing with the Prime Minister, hoping and expecting that he would act. I do so again, attaching previous letters along with the most recent evidence referenced above, in the expectation that it will now be acted upon.
DETRIMENTAL ARRANGEMENTS
The developer of the cable car project, ABL Holdings Ltd., has been allocated over 400 citizenships to finance the project and granted a 999-year lease over lands in our Morne Trois Pitons National Park, a UNESCO World Heritage Site, with no defined annual lease rent, concession fee, revenue share, or other recurring benefit to the Government. In other words, the State is effectively providing financing through citizenship, while the developer receives, in substance, freehold ownership of strategic national assets for the next 35-40 generations, even though ABL Holdings Ltd. is majority-owned by a BVI company with undisclosed shareholders.
ILLEGAL CONSTRUCTION
he Prime Minister is aware, as we all are, that the airport, cable car and marina projects do not have formal and final planning approval. This has been confirmed to me in writing by Physical Planning as at 26 January 2026 for the cable car and marina projects, and as at 5 March 2026 for the international airpor project, and these projects have all been under construction for between two and three years. Our major infrastructure projects are being funded through illicit transactions, structured through opaque and detrimental arrangements, and are being constructed in violation of our planning laws.
DELIBERATE OPACITY
t appears that few, if any, members of Cabinet, far less Parliament, have had the opportunity to review debate and provide feedback on contractual arrangements with MMC, ABL and Range, the country's primary CBI infrastructure development partners. None of these developers and related projects-worth billions of dollars- has gone through a competitive bidding or tender process. There is no periodic project-level public information on citizenships sold, monies raised, monies deployed, or the payment of monies due to the Government. These issues are closely connected to the misuse of CBI revenues and, in my view, warrant separate, detailed examination in their own right at the appropriate time.
CONSEQUENCES
Passport volumes surged after Maria, driven in large part by illegal discounting that undercut Dominica':s official CBI programme. EU-derived data indicate that Dominica granted about 34,596 CBI passports in just ive years (2018-2022), followed by another 9,539 in 2023 and 5,484 in the first half of 2024. Taker together, this amounts to at least 49,619 passports from 2018 to mid-2024-more than in all prior programme history combined-- on the back of a high-volume, heavily discounted model that systematically drained lawful revenue from the Treasury, channelled billions into the hands of third-party developers, and left Government's EDF (Economic Diversification Fund, or direct investment) optior uncompetitive. The effects are visible in the Treasury's chronic inability to meet Parliament-approvec budgets for basic services, from solid waste and tourism to health and education. The loss of UK visa-free access and the heightened risk of EU visa-free suspension reflect, in no small measure, the unprecedented flow of economic citizens relying on CBI passports and arriving at UK and EU borders expecting visa-free entry. The tightening of US visa rules for Dominicans is part of the same pattern of international concerr about the integrity of CBI programme.
A MEANS TO AN END?
It is neither reasonable nor acceptable that, to develop Dominica--to build an airport, a cable car, a marina and other infrastructure assets --we must break our own laws and hand over our future to interests that are not aligned with Dominica's, under a veil of secrecy and opacity. Development anc integrity are not, and must never be, mutually exclusive. If this reckless, lawless course is seen as a means to an end, are we, as a nation, to feel proud that the island's critical infrastructure has been built on a foundation of ilicit money, illegal construction and opaque, detrimental arrangements? Or will we, in the, words of Matthew 7:24-27, be remembered as the foolish who built our house on sand?
NOWHERE ELSE TO TURN
The Prime Minister knows that my efforts over the past seven years have been sincere, made in good faith and with only the best interests of the country at heart. After a dozen letters and several meetings, I hope vou will both agree that I have fullv exhausted my--now clearlv naïve--optimism and hope that the Prime Minister would act to reform our hijacked CBI programme and, in so doing, steer our country onto the right development path.
At the 25 March 2026 press conference, in response to a journalist's question regarding discounting, the Prime Minister stated: "With regards to the CBI and the allegations of underselling, the reality is anybody who violates the provisions of the CBI law, the CBI regulations, will be taken to task and if we have evidence of that taking place, then those persons who would have gotten citizenship, that means that their citizenship would be immediately revoked, simple as that. And those who engaged in it, their icences would be revoked, and the law makes provision for fines. We've heard those things, it's a matte for us to get the evidence and to have this thing prosecuted properly.
The evidence has been in front of the Prime Minister since 2019, yet he has not lifted a finger to stop it and his inaction has been the wind in the sails of the serial violation of our laws and the steady depletior of our Treasury. While I acknowledge that there has been a tightening of the laws, this is futile if nc decisive action is taken under those laws Let us be clear, and those who have managed the CBIU for years can attest to this: at any time, the Prime Minister could have brought this to a halt within 48 hours--if he had wanted to.
IN CLOSING
I am therefore formally requesting a hearing with Parliamentarians to look at and discuss the issue: raised. I propose that this could be done either through the setting up of a Special Committee of the whole House for the purpose of looking at the issues, or a formal meeting otherwise at another suitable venue. I wish to have in attendance up to six concerned citizens, including the President of the Bar Association, Mrs Noelize Knight-Didier, Deacon Val Cuffy, trade unionist Mr. Thomas Letang, and three additional representatives from the private sector of my choosing. The presence of all members of Cabinet and Parliament is requested, including the heads of the FIU and CBIU. Should this request for a hearing be refused, or the outcome yield no restorative results, 1 will pursue all available legal options, including judicial review and the petitioning of a commission of inquiry and, through one or both, an independent forensic financial audit of the CBI programme over the last ten years. Should I not receive a response within three (3) weeks of the date of this letter, this will be taken as a refusal of my request. This letter, including my request for a hearing, is copied to Cabinet, Parliament, the FIU and the CBIU, in the hope that others will now act where the Prime Minister has chosen not to.
