Dominica CBI Program

Dominica CBI program sold 34,500+ passports (EU data) vs 7,700 disclosed in gazettes; massive revenue discrepancies in budget records

Dominica's CBI program (est. 1993) offers citizenship via Economic Diversification Fund (K single applicant) or real estate investment (K min). EU Commission revealed 34,500 passports sold, vs ~7,700 names in public gazettes 2007-2022. PM Skerrit claimed 2,000 citizenships sold June 2018-July 2019 generating M, but national budget recorded only M and gazettes showed ~4,000 applicants. Official gazette stopped publishing new citizen names in March 2019. CBI revenue was 37% of GDP in 2022/23. OCCRP identified 30+ passport holders later investigated, charged, or convicted of crimes.

Dominica CBI real estate option escrow held at National Commercial Bank of Dominica — funds for real estate projects NOT publicly accounted in national budget

CBI real estate investments use escrow accounts at the National Commercial Bank of Dominica, with funds released only after compliance verification. However, PM Skerrit confirmed in a 2019 radio interview that monies collected under the Real Estate option are NOT revealed in the national budget — unlike the Economic Diversification Fund which enters the government's main account. This creates an opaque channel where hundreds of millions in CBI real estate funds flow from passport purchasers through government-adjacent escrow to developers like Range Developments without public accounting. The structure is: passport applicant pays K+ -> government fees extracted -> remainder held in escrow -> released to developer upon project milestones. The 'Where De Money Gone' opposition campaign demanded accounting of .2B in CBI revenue for 2018-2019.

EU data reveals Dominica sold 34,500 CBI passports vs 7,700 names published — massive disclosure gap suggests thousands of undisclosed citizenship grants

OCCRP's 'Passports of the Caribbean' investigation (2023) found Dominica published only 7,700 CBI recipient names (2007-2022) while budget data suggested 19,000 naturalizations (mid-2016 to mid-2022 alone). The EU subsequently revealed 34,500 total passports had been issued — over 4x the publicly disclosed figure. Key anomalies: (1) 2017-2018 naturalization fees implied ~4,000 naturalizations but gazettes listed only 1,664 names; (2) 2011 and 2012 showed identical passport revenues 'just over $6 million' to the dollar — statistically implausible; (3) PM Skerrit claimed ~2,000 citizenships sold June 2018-July 2019 generating '$170 million' but the national budget recorded only $80 million; (4) Dominica ceased publishing citizenship names in March 2019 through at least December 2022. The bulk of passport purchasers came from Iraq, Iran, Syria, Jordan, and Yemen.

FinCEN Advisory FIN-2014-A004 warned of CBI passport abuse for sanctions evasion (targeting St Kitts); rescinded Feb 2026 after reforms — Dominica was never directly named but same risks apply

In 2014, FinCEN issued Advisory FIN-2014-A004 warning US financial institutions about abuse of St Kitts & Nevis CBI passports by illicit actors seeking to mask identities and evade sanctions. While targeting SKN specifically, the advisory implicitly covered all Caribbean CBI programs. It was rescinded February 24, 2026 after SKN implemented reforms (biometric data, mandatory interviews, external audits). Dominica was not directly named but shares identical program structure and has since proven vulnerable to the exact abuse FinCEN warned about (Shamkhani case). FATF separately published a report on 'Misuse of Citizenship and Residency by Investment Programmes' identifying money laundering risks. No specific FinCEN advisory has been issued for Dominica's program.

Dominica suspended CBI applications from Iranian nationals effective March 24, 2026 — triggered by Shamkhani passport scandal and US pressure including Trump travel ban and visa restrictions

Dominica's CBI Unit issued memorandum March 23, 2026, suspending all Iranian applications immediately. Exceptions only for applicants with no Iran residence for 10+ years, no Iran assets, and no Iran business activity (all three cumulative). This followed: (1) July 2025 OFAC sanctions on Hossein Shamkhani who used Dominica 'Hugo Hayek' passport, (2) Trump Dec 2025 proclamation imposing travel restrictions on Dominica nationals citing CBI, (3) State Dept cutting US visa validity for Dominica nationals from 10 years to 3 months. Dominica had been the most permissive CBI option for Iranians since 2022. The ban came approximately one month after Ali Shamkhani was killed in the Feb 28, 2026 strikes.

OCCRP Passports of Caribbean screening: 20+ named notable Dominica CBI holders include: Saddam Hussein's top nuclear scientist (2014, Jafar Dhia Jafar candidate), Libyan Gaddafi-era colonel (2015), Asadullah Khalid (Afghan intel chief, 2017 PEP), Samir Rifai (Jordan ex-PM via Range, 2018), God Nisanov + Zarakh Iliev (OFAC-sanctioned Russian/Azeri oligarchs, 2017), Omar Murtuzaliev (Russia, not yet sanctioned), Yildirim Demiroren (Turkey, 2018), Anthony Haiden (US/Dominica airport contractor, 2017), Ali Reza Monfared (Iran oil theft, 2009), Mehdi Monfared (now CBI broker), Mehdi Ebrahimi Eshratabadi (Iran, Interpol 2019), Hassan Jaffar al-Lami (Iraq Noor Bank), Namir el-Akabi (Iraq, 2010), Oday Nadir al-Quraishi (Iraq), Ehsan Azarnekou (Iran), Pedro Fort Berbel (Spain SEC Ponzi, 2015), Gursamarjit Singh (India/UK Tory donor, 2013), Faouri father/son (Jordan fraud, 2010), Pai-Hung Wang + Ching-Yi Hsieh (Taiwan fraud, 2017), Rakesh Wadhwa (India/Nepal casino tax fugitive, 2016), Prateek Gupta (India bank fraud, 2018), Aman Lohia (India Interpol, 2018), Preeti+Sanjay Chandra (India money laundering), Roman Vasilenko (Russia fraud, 2018), Glory Oseidebame + Muyiwa Folorunso (Nigeria Ponzi, 2017), Bassem Awadallah (Jordan royal court / Jordan 2021 coup attempt)

Dominica pattern of selling ambassadorships alongside CBI passports: Monfared paid K+ for diplomatic passport, Nanthan laundered proceeds, Skerrit had 'no memory'

Iranian businessman Alireza Monfared obtained Dominica citizenship Sept 2014 (~-300K), then secured diplomatic passport through payments channeled via My Dominica Trade House. Documented payments: Oct 29 2014 two invoices totaling K for Skerrit election campaign (manifesto printing K, billboards/sound/fireworks K); Nov 2014 additional K to service station owned by Emmanuel Nanthan family in Portsmouth. Skerrit personally met Monfared Aug 2014, handed him diplomatic passport March 2015 at lavish reception. CBI head Nanthan expressed frustration at delayed transfers. Monfared arrested by Iran 2017, convicted Nov 2019 of embezzlement (.3B fine, 20-year sentence). Nanthan later terminated after US filed money laundering demands. Skerrit claimed 'no memory' of meeting.

Swiss Leaks (2015): 28 Dominican passport holders held $40.9M in 78 HSBC Swiss private bank accounts in Geneva — establishes historical Dominican-Swiss banking channel

The ICIJ Swiss Leaks investigation (2015, based on data stolen from HSBC Private Bank Suisse SA in Geneva by Herve Falciani in 2007) revealed that 41 client accounts associated with Dominica held approximately US$40.9 million in 78 HSBC Swiss accounts, with 28 (14%) owned by Dominican nationals or passport holders. All accounts were 'beyond the reach of government authorities.' This establishes that a significant Dominican-Geneva banking channel existed through HSBC Private Bank well before the Cabrits project. The Zampolli allegation of a 'Bank of Dominica account in Geneva' could refer to: (1) a National Bank of Dominica nostro/vostro account at HSBC Geneva or another Swiss correspondent, (2) a Range-controlled account at a Swiss bank established for CBI fund management, or (3) a government-designated escrow or operating account. The Swiss Leaks data covers 1988-2005, predating the peak CBI era.