Recent Policy & Legal Developments

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Over the past 24 months, Antigua and Barbuda’s Citizenship by Investment Programme (CIP) has undergone a suite of legal reforms in response to increased international scrutiny, regional harmonization efforts, and domestic economic planning. As a member of the Organisation of Eastern Caribbean States (OECS), Antigua has aligned many of its regulatory changes with counterparts like St. Kitts & Nevis and Dominica, particularly in the areas of due diligence, pricing standardization, and fund transparency.

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Investment Threshold Revisions (Effective July 2024)

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In response to the OECS-wide initiative to curb the "race to the bottom" on donation pricing, Antigua increased its minimum National Development Fund (NDF) contribution from USD $100,000 to USD $200,000 for a family of four. This change, announced in March 2024 and implemented in July, was not retroactive. A 90-day grace period allowed in-process applicants to finalize submissions under the previous rate. The move seeks to restore value perception, increase program sustainability, and avoid European Union blacklisting concerns.

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Family Inclusion and Due Diligence Enhancements (2025)

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A suite of regulatory updates came into effect in January 2025, amending who may be included as dependents and reinforcing the program’s due diligence framework. Notably:

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• Siblings are no longer eligible under the main applicant’s file.
  
• Adult children aged 18–30 must demonstrate enrollment in higher education and financial dependency.
  
• Parental dependents must be over 55 years old and fully financially supported by the main applicant.

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The legislation also introduced tiered due diligence fees for applicants from jurisdictions flagged by the OECD or FATF, with additional documentation required for crypto-derived wealth and complex offshore structures.

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Institutional Reforms and Oversight

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In 2023, the Citizenship by Investment Unit (CIU) underwent structural reform to enhance oversight. This included:

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• Creation of a Program Compliance Directorate, tasked with post-citizenship audits.
  
• Enhanced cooperation with Interpol, CARICOM IMPACS, and international financial intelligence units.
  
• Integration of blockchain-based tracking tools for application integrity and fund transparency (pilot launched in late 2024).
  
  

Collectively, these reforms reflect Antigua’s efforts to secure the long-term credibility of its CIP in a tightening global regulatory environment.

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