Dominica: Passports of the Caribbean
Dominica: Passports of the Caribbean, a collaborative cross-border investigation into Dominica’s citizenship-by-investment program, is a joint effort by OCCRP, the Washington D.C.-based nonprofit the Government Accountability Project, and more than a dozen media partners. It began after the Government Accountability Project obtained the names of roughly 7,700 people who have bought Dominica passports between 2007 and 2022. These names were compiled from official documents published by the government of Dominica and supplemented via leaked documents and corporate filings.
PARTNERS: The Government Accountability Project, Paper Trail Media, Der Standard, Le Monde, Forbes, the Guardian, Daraj, Follow the Money, Zamaneh Media, InfoLibre, Lighthouse Reports, the Reporter, Heidi.news, Proekt, Context.ro
What is “Dominica: Passports of the Caribbean”?
“Dominica: Passports of the Caribbean” is a cross-border investigation into the fugitives, alleged criminals, and politically connected people who have purchased citizenship and passports from the Caribbean island nation of Dominica.
It is a joint effort by OCCRP, the Washington D.C.-based nonprofit the Government Accountability Project, and more than a dozen media partners.
Where is Dominica?
Not to be mistaken for the nearby Dominican Republic, the Commonwealth of Dominica is a small island country in the Lesser Antilles volcanic chain in the eastern Caribbean Sea. Often referred to as “Nature Island,” Dominica is largely covered with tropical rainforest.
Dominica gained independence from Britain in 1978, and its capital Roseau is known for its 18th-century French architecture. The country is home to over 70,000 people, largely the descendents of Africans trafficked as slaves.
What is Dominica’s “citizenship-by-investment” program?
Since 1993, the Dominican government has sold citizenship to foreigners. The application requires either a roughly $100,000 contribution to a government fund, or the purchase of at least $200,000 worth of real estate in a government-approved development.
Aspiring Dominican citizens must also pay “processing” and “due diligence” fees, which can total to as much as 16 percent of the costs, depending on the type of investment. Additional family members cost between $25,000 and $50,000 per person. Documents seen by OCCRP show that passport brokers might also charge tens of thousands of dollars in fees.
If they pass the screening process, investors might be approved within three months of paying these fees — without even being required to set foot on the island. Until July 2023, interviews were not even mandatory.
Successful applicants are then eligible for a Dominican passport, which allows travel to more than 130 countries or territories without a visa or with a visa on arrival, including China, Singapore, and member states of the European Union. Investors are not required to pay taxes if they don’t live on the island.
How are applicants vetted?
Dominica’s citizenship-by-investment regulations rule out granting citizenship to people who have “a criminal record other than in respect to a minor offense,” are subject to “a criminal investigation of which he was aware or ought to have been aware,” who pose “a potential security risk to Dominica or to any other country,” or have been involved in “any activity likely to bring disrepute to Dominica.”
Citizenship purchases are handled through government-selected brokers who are supposed to vet applicants along these lines before government officials make the final decision. Over 70 companies are authorized to participate in the program.
Dominica’s government did not respond to requests for comment about how it screens applicants. But over the years, officials have repeatedly claimed the process is thorough. In 2016, Vince Henderson, then Dominica’s representative to the United Nations, told HuffPost that the government’s due diligence “digs deep” into the “personal lives and business dealings” of applicants.
“Those who have something to hide don’t apply in the first place,” he said.
Yet a 2019 U.S. State Department report on Dominica’s citizenship-by-investment program described due diligence as “lax.” The country “does not consistently use available regional mechanisms … to properly vet candidates,” the report said, adding that it “does not always deny citizenship to those who are red flagged.”
Dominica has recently imposed some reforms. In July this year, the island nation started requiring applicants over 16 years old to undergo interviews.
Why is this a problem?
OCCRP spoke with half a dozen experts who highlighted how so-called “golden passports,” such as those offered by Dominica, can be powerful tools for misconduct — especially in tandem with financial tools such as anonymous shell companies or secret bank accounts.
A purchased passport can allow people wanted by law enforcement to travel more freely. It can also help sanctions evaders, money launderers, and other financial criminals get around compliance checks.
“If you’re a government official embezzling public funds or a businessperson making dodgy deals, chances are you’re worried about future prosecution,” Eka Rostomashvili of Transparency International, said. “New citizenship — and potentially a new identity — comes in handy if you want to evade law enforcement and prosecution efforts.”
A Dominican passport can also facilitate tax evasion. Under global tax treaties, banks have to report the assets of their clients to authorities based on where these clients live, or where they are taxed. But if someone who bought a Dominica passport falsely tells their bank they are a tax resident of Dominica — which doesn’t tax citizens who don’t live there — they could avoid paying any taxes at all.
A 2021 paper by the Center for Economic Studies, a Munich-based think tank, found evidence this was in fact happening. After countries introduced citizenship-by-investment programs, bank deposits in tax havens originating from those countries jumped by about $9 billion, it said.
“Acquiring a new citizenship without moving to the respective country does not affect the tax legally owed to an individual’s true country of residence,” the report said. “It does, however, facilitate tax evasion by providing the individual with the means to circumvent tax information exchange.”
What countries are represented?
OCCRP and partners obtained a list of about 7,700 people who purchased Dominican citizenship. They found individuals from more than 60 countries on six continents in the data. But the bulk of the passport purchasers came from countries in North Africa, Central Asia, and the Middle East — especially Iraq, Iran, Syria, Jordan, and Yemen.
“We issue passports to people, not to countries,” Henderson, the then U.N. representative, said in his 2016 interview. “There are good people in bad countries who want to get away, just as there are bad people in good countries.” (Henderson declined to comment when contacted by OCCRP.)
But applicants from certain countries have faced restrictions, including North Korea, Sudan — and, following Russia’s full-scale invasion of Ukraine last year — Russia and Belarus. The move against Russian and Belarusian applicants was welcomed by the U.S. State Department. A spokesperson told reporters the department is “pleased with Dominica’s efforts to increase security and due diligence” surrounding the passport program.
Who is in the data?
People who bought Dominica passports included a former Afghan defense minister accused of human rights violations, Saddam Hussein’s top nuclear scientist, and an Iranian middleman who created a company that funneled money to Spain’s national football league.
Reporters also identified at least 30 people who obtained Dominica passports and were later investigated by authorities, charged with crimes, or convicted. On nearly a dozen occasions, they ended up as fugitives from the law, fleeing criminal investigations or prosecutions in their home countries.
In these cases, Dominica cannot be accused of knowingly selling passports to criminals. But the country’s officials did not respond to reporters’ questions about whether any of these citizenships have been revoked.
OCCRP decided to publish only those names that could be verified beyond doubt and which were clearly in the public interest, such as people with high-level political connections or who were investigated, indicted, or convicted for misconduct.
How did you get this data?
In theory, the names of people who have purchased Dominica citizenship should be in the public record and published in the country’s official gazette, which covers major legal news, including new laws, court cases, and public auctions.
But getting a hold of back issues of the gazette can be challenging. Last year, the Government Accountability Project, a U.S.-based whistleblower and advocacy group, procured dozens of Dominican gazettes from libraries, private collections, and Dominica’s National Archives in Roseau. Many were obtained from the University of the West Indies Mona in Kingston, Jamaica.
In addition, names are published inconsistently, and the lists that are released often only cover a few months of a year. Some years have been skipped entirely.
Dated from 2007 to 2022, the gazettes included the names of roughly 7,700 people who purchased Dominican citizenship. These names were then provided to OCCRP and partners.
The last of these issues to publish names of applicants was from March 2019. That year, controversy erupted when the government published nearly 4,000 names, which appeared to suggest state income from the program should have been much higher than reported. The disclosure raised “red flags,” Linton later said. Since then, authorities have not published a single new name.
How did we verify individuals in the data?
Until 2009, the gazette published nationalities and addresses of people obtaining Dominica citizenship. Since then, only names have been published.
Adding another layer of complication, the names were often English transliterations from other languages, such as Russian, Arabic, or Chinese, meaning spellings might vary from external documents. In one example, transliteration turned the name Ayman into Yman on Dominican documents. Some regions were especially challenging — only a few of the hundreds of names from China and Taiwan could be identified, for instance.
There were also spelling errors — for instance, Q’s substituted for G’s, or vice versa. Middle names or tribal names were often used inconsistently, even within families, or left off altogether.
To overcome these challenges, OCCRP identified individuals who had used their Dominica passports to register companies in jurisdictions that record the nationality of company owners, such as the U.K., Jordan, and Hong Kong. Reporters also used data from other sources, including the Panama, Paradise, and Pandora Papers, as well as a leak of data from Henley & Partners, a London-based law firm that helped run a citizenship-by-investment program in Saint Kitts and Nevis, to confirm people on the list held Dominica passports.
Reporters also drew on leaked wire transfer and emails from Reza Zarrab, an Iranian national who pled guilty in the U.S. in 2017 to money laundering, fraud, and other charges.
Over a dozen people also confirmed they had bought Dominica citizenship when contacted by OCCRP.
Relatives offered another clue. Frequently, people who purchased citizenship as a family were listed together in the data. Using social media and public documents, reporters identified people who had spouses and children with names matching those on the list.
Does Dominica sell other types of passports?
As well as selling citizenship, Dominica has also sold diplomatic passports. Sales of these passports — which can confer diplomatic immunity, streamlined airport entry, and other benefits — have often proven controversial.
Ng Lap Seng, a Chinese billionaire, obtained one such passport before he was later convicted of bribery in the U.S. Diezani Allison-Madueke, a former Nigerian oil minister who was arrested in the U.K. on bribery charges in August, also held a Dominican diplomatic passport. One of the most infamous cases, exposed by Al Jazeera, was Ali Reza Monfared, an Iranian man convicted for helping embezzle billions of dollars while working to evade Western sanctions on the country’s oil sales.
Some of those known to hold diplomatic passports appeared in the data, including Monfared, but others, such as Allison-Madueke, did not. (People can obtain Dominican diplomatic passports without buying citizenship.) In his 2016 interview, the U.N. envoy Henderson acknowledged that Alison-Madueke obtained a diplomatic passport, but denied that she had received citizenship.
Allison-Madueke and Seng did not respond to requests for comment. In an interview, Monfared’s son Mehdi said that the family “sought Dominican citizenship primarily to explore business opportunities in the Caribbean region.”
He said his father “was not involved in the direct sale of sanctioned Iranian oil or the alleged misappropriation of proceeds. His role was not in the sales aspect but rather in providing auxiliary services to companies within the oil industry.”
“It is crucial to clarify that my father was not involved in any efforts to evade or hide from authorities during his time as a diplomat or any other instance,” he said.
Are there other similar programs?
Several other Caribbean islands also sell citizenship, including Antigua and Barbuda, Grenada, St. Kitts and Nevis, and St. Lucia. The Pacific island nation of Vanuatu has a similar citizenship-by-investment program, as does the European Union member state of Malta.
A leak of data from the self-proclaimed “citizenship planning” company Henley & Partners showed that its clients included people with connections to financial crimes, sanctions evasion, political power, or unexplained wealth. This year, the Intercept reported that Harlan Crow, a billionaire real estate developer and benefactor of U.S. Supreme Court Justice Clarence Thomas, had obtained St. Kitts and Nevis citizenship.
If you’re a journalist who would like to access the data, please send in an application to join Aleph and request to join the Dominica: Passports of the Caribbean project.