Alicia Nicholls
Citizenship by investment programmes (CIPs) are currently operated by five countries in the Caribbean. These are St. Kitts & Nevis, Dominica, Grenada, Antigua & Barbuda and St. Lucia. Caribbean CIPs face increasing threats stemming from reputational risks, increased regional and international competition and heightened international scrutiny. Despite these challenges, some Caribbean CIP-operating countries are utilising CBI revenues to finance climate change adaptation/mitigation initiatives in order to build climate resilience.
The Climate Change Challenge
June 1st of each year marks the official start of the Atlantic Hurricane Season. It is exemplified in the rhyme many Caribbean school children learn: “June – too soon, July – standby, August – you must prepare, September – remember, and October – it’s all over”.
Rhymes aside, Caribbean countries are no strangers to the human, economic, financial and social devastation inflicted by weather systems around this time of the year. 2017 was an unforgetable year as Hurricanes Maria and Irma caused significant damage to a number of Caribbean islands, most notably Dominica, the island of Barbuda (part of Antigua & Barbuda) and the US territories of Puerto Rico and the US Virgin Islands.
In a 2016 International Monetary Fund (IMF) study, Acevedo wrote that in the Caribbean, “storms cause on average 1.6 percent of GDP in damages every year, but that figure could be 1.6 to 3.6 times larger due to underreporting of disaster and damages.” One of the many adverse impacts of climate change is more intense weather systems. As such, the level of damage from hurricanes and tropical storms is expected to rise.
Whereas climate change mitigation focuses primarily on emissions reduction, adaptation recognizes the irreversibility of some climate change impacts and emphasizes resilience building through targeted programmes, initiatives, policies and projects. Caribbean countries’ domestic financing constraints necessitate their disproportionate reliance on international financing and support for their climate change adaptation efforts. High debt overhangs mean they often lack the fiscal space to respond quickly and adequately to climatic shocks. Rebuilding requires significant capital, which can be burdensome for small countries beset by narrow tax bases and limited ability to attract the large inflows of FDI required. In some cases, high gross national income (GNI) per capita restrict their access to most official development assistance and concessional funding from multilateral agencies.
Role of CBI Revenues
In light of these constraints, revenues from CIPs are increasingly attractive sources of inflows for funding development programmes and initiatives. In its Staff Concluding Statement of the 2019 Article IV Mission for Grenada published in May 2019, the IMF noted that “robust FDI flows, including from the citizenship-by-investment (CBI) program, are financing the external deficit while supporting economic growth.” It further noted that these inflows “have helped channel sizable resources to the contingency fund that could be used for mitigating the effects of natural disasters”.
In September 2017, St Kitts & Nevis introduced a temporary third investment option, the Hurricane Relief Fund, to prepare for future hurricanes, repair property damage and support Caribbean neighbours in need. The minimum contribution is US$150,000. The Fund was controversial because it was criticised as further evidence of a “race to the bottom” among Caribbean CIPs. Nonetheless, it was reported that over 900 persons benefited from the Hurricane Relief Fund. A reported 1200 applications were received under the Fund, but it is unclear how many were successful.
CBI assisting Dominica’s recovery
In September 2017, category five Hurricane Maria caused Dominica pervasive human, social and economic damage equivalent to 226% of its GDP (Post Disaster Needs Assessment 2017), resulting in 31 confirmed deaths and 34 missing. According to the Government of Dominica, CBI inflows have been pivotal in financing Dominica’s recovery. In its Article IV Report on Dominica, the International Monetary Fund (IMF) noted that “fiscal performance deteriorated sharply due to the fall in tax revenue after the hurricane, but was partially offset by a surge in grants and buoyant Citizenship-by-Investment (CBI) sales revenues.”
Following Hurricane Maria, Dominica has sought to become “the world’s first climate-resilient nation”. The island nation has emphasized resilience-focused rebuilding with the help of international donor funding coordinated through its Climate Resilience Executing Agency for Dominica (CREAD). This includes building climate-resilience structures.
In a recent article, the Dominica Citizenship by Investment Unit (CBIU) noted as follows:
After Hurricane Maria last year, Dominica’s CBI Programme was responsible for funding housing and hotel developments, as well as tourism and agriculture projects that cumulatively helped the island recover. The collected financial resources also enabled the Dominican authorities to make payments to affected home owners in the region of £26 million, whilst a government scheme to build 5,000 new homes is financed entirely by CBI income, according to Prime Minister Roosevelt Skerrit.
Moreover, it was announced that the Housing Revolution, which is providing climate resilient low income housing is “completely funded by Dominica’s Citizenship by Investment (CBI) Programme”.
Conclusion
CIPs have significant risks, but can also be tools for promoting sustainable development. The revenue inflows can assist cash-strapped governments in financing climate climate adaptation and mitigation programmes.
This is not to suggest, however, that CIP revenues are a panacea for financing resilience. Firstly, heavy dependence on these revenues is a real risk which must be guarded against due to the potential volatility of CBI revenue inflows. Fiscal discipline, including prudent management of these inflows, is important to ensure these countries have the fiscal space to respond to any shocks. Fiscal responsibility frameworks such as that adopted by Grenada are important.
Secondly, due diligence standards of CIPs must be maintained and should not be lowered or compromised just to attract greater inflows.
Thirdly, any special climate/disaster relief funds financed by CBI revenues should be situated within a coherent national policy framework for catalyzing and making optimum use of these and other resources for building climate resilience.
Fourthly, transparency is also important. This also includes timely data on the number of applications received under special funds, timely audits of the funds and reporting of the audits of these special funds. It also requires sensitizing the general public about the use to which the funds are being put.
Alicia Nicholls, B.Sc., M.Sc., LL.B., is an international trade and development consultant with a keen interest in sustainable development, international law and trade. You can also read more of her commentaries and follow her on Twitter @LicyLaw.
DISCLAIMER: All views expressed herein are her personal views and do not necessarily reflect the views of any institution or entity with which she may be affiliated from time to time.
Caribbean Trade Law and Development 
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