Marketing materials often describe Grenada's Citizenship by Investment (CBI) programe's due diligence as "robust" or "thorough".
In actuality, the descriptions are merely superficial.
Today, international pressure and domestic law shape Grenada's multi-layered security, financial, and intelligence process of due diligence.
Applications are screened not only by Grenadian authorities but also through regional intelligence networks, international sanctions databases, private investigative firms, and, since 2023, mandatory applicant interviews.
This is no longer a paperwork exercise. Every application is treated as a potential national-security risk until proven otherwise. Sources of wealth are dissected, personal histories are reconstructed across borders, and inconsistencies, no matter how small, can lead to rejection or even future revocation.
This article explains what actually happens during due diligence for Grenada CBI: who is involved, how decisions are made, why applications fail, and how recent crackdowns have permanently changed the program.
If you're thinking of Grenada citizenship, this is the process you'll follow—not the simplified version you've heard.
Why Grenada’s Due Diligence Is Different
Grenada’s Citizenship by Investment program operates under far stricter scrutiny than most applicants expect. Its due diligence process is shaped not only by domestic law but also by international security expectations, regional intelligence sharing, and direct pressure from major visa-waiver partners.
What sets Grenada apart is not volume or speed, but how seriously citizenship is treated as a security asset.
A Security-First Reboot After 9/11
Grenada had previously suspended its citizenship program entirely after 9/11 due to international concerns. When the CBI program was reintroduced in 2013, it was rebuilt with a clear, security-first mandate.
Citizenship was no longer viewed as a commercial product. Every application would be assessed with visa-free access, banking relationships, and geopolitical risk in mind.
International Pressure Drives Standards
External stakeholders, particularly the United States, the European Union, and international financial regulators, heavily influence Grenada's due diligence rules.
This pressure intensified in 2023 with the US–Caribbean Six Principles agreement, which expanded due diligence beyond criminal records to include reputational risk, financial transparency, and intelligence cooperation.
Shared Denials Ended “Forum Shopping”
One major change applicants rarely see is shared denial data across Caribbean CBI programs.
If one participating jurisdiction rejects an applicant for security or integrity reasons, other countries may automatically reject the same applicant. This effectively ended the practice of applying country by country until one approves.
Due Diligence Doesn’t End at Approval
Approval does not close the file.
Grenada retains the right to re-examine approved cases and revoke citizenship if fraud, misrepresentation, or illegal financing later comes to light.
This became visible during the 2024–2025 enforcement actions tied to illegal discounting.
In Grenada, due diligence is ongoing.
Enforcement Now Comes First
Grenada has shifted away from growth-driven approvals toward strict enforcement.
Mandatory interviews, enhanced source-of-wealth checks, regional intelligence screening, and aggressive action against non-compliant agents all reflect the same priority: protecting the credibility of the passport itself, even if that means approving fewer applicants.
Who Actually Conducts Due Diligence for Grenada CBI
Due diligence in Grenada is not handled by a single office or checklist. It is a layered system, where responsibility is deliberately spread across multiple actors to reduce conflicts of interest and prevent weak points.
Each layer looks at the applicant from a different angle—administrative, security, financial, and regional intelligence.
The Investment Migration Agency (IMA)
The Investment Migration Agency (IMA) is the operational hub for Grenada’s CBI program. It receives applications, commissions due diligence reports, coordinates interviews, and manages the overall review process.
The IMA does not approve citizenship on its own.
Its role is to assemble the full risk profile of each applicant and present a recommendation based on verified findings. In recent years, the agency has taken a far stricter enforcement stance, issuing circulars that mandate interviews, prohibit discounting, and discipline non-compliant agents.
In practice, this is where most applications slow down—or stop.
The Citizenship by Investment Committee (CBIC)
The Citizenship by Investment Committee (CBIC) acts as a review and oversight body.
It evaluates the due diligence findings prepared under the IMA’s supervision and decides whether an application should move forward. The committee is intentionally multi-disciplinary, creating a buffer between raw investigative work and political decision-making.
Final approval authority rests with the Minister, but the CBIC’s recommendation carries decisive weight.
Authorised Local Agents: The First Filter
Applicants cannot submit directly to the government. Every Grenada CBI application must go through an Authorised Local Agent.
Agents are legally required to conduct initial Know Your Customer (KYC) checks, verify documents, and assess obvious risk factors before submission. A reputable agent will decline high-risk cases early to protect their licence.
Agents who facilitate misrepresentation, fake financing, or illegal discounting risk suspension or permanent revocation—something Grenada has enforced aggressively since 2024.
Regional Intelligence: CARICOM IMPACS and the JRCC
One of Grenada’s strongest and least visible due diligence layers operates at the regional level.
All applications are screened through CARICOM’s Joint Regional Communications Centre (JRCC), which cross-checks applicants against:
- Regional law enforcement databases
- INTERPOL alerts
- Border and travel intelligence across Caribbean states
This layer often identifies risks that do not appear in standard criminal records, particularly involving regional financial crime or trafficking networks.
Private Due Diligence Firms
Grenada also contracts independent international investigative firms to conduct enhanced background checks.
These firms:
- Verify business operations on the ground
- Interview local sources discreetly
- Examine litigation history and reputational risk
- Perform deep financial analysis
Their findings often determine whether an application proceeds smoothly, triggers enhanced due diligence, or is rejected outright.
The Due Diligence Process: How Grenada CBI Applications Are Actually Reviewed
The Four Pillars of Grenada CBI Due Diligence
Every Grenada CBI application is assessed through four parallel lines of investigation.
An applicant must pass all four. A failure in any one pillar is usually enough to trigger rejection or enhanced scrutiny.
These checks do not happen strictly in sequence. Most run simultaneously, which is why applications can feel unpredictable from the outside.
Pillar 1: Open-Source & Database Screening
The first pillar focuses on the applicant’s digital and institutional footprint.
Authorities and contracted investigators screen applicants against:
- International sanctions lists (US, UN, EU, UK)
- Politically Exposed Person (PEP) databases
- Criminal and enforcement databases
- Adverse media in multiple languages
This step often uncovers issues that never appear on police certificates, such as unresolved allegations, regulatory investigations, or reputational risks reported by credible media.
Even without a conviction, adverse findings can be enough to halt an application.
Pillar 2: Mandatory Interview
Introduced in 2023, the mandatory interview added a human layer to the process.
Applicants aged 17 and over must complete a paid interview, typically conducted remotely.
The goal is not formality—it is verification. Interviewers assess whether the applicant:
- Understands their own application
- Can clearly explain their background and wealth
- Presents information consistent with submitted documents
Inconsistencies, hesitation, or unfamiliarity with financial details often lead to more profound investigation.
Pillar 3: On-the-Ground Intelligence
This pillar involves examining real-world processes and systems.
Independent investigative firms may conduct physical verification in the applicant’s home country.
These tasks can include:
- Confirming business operations exist and function as claimed
- Reviewing court records not available online
- Speaking discreetly with local sources
This phase is where shell companies, inflated business claims, or hidden disputes are most often exposed.
Pillar 4: Financial Forensics (Source of Wealth & Source of Funds)
Grenada draws a strict distinction between where the investment money comes from and how the applicant became wealthy in the first place.
Investigators analyse:
- Long-term income history
- Business ownership and dividends
- Tax records where available
- Bank statements and transaction patterns
Complex structures, unexplained transfers, or implausible wealth accumulation can trigger enhanced due diligence or rejection.
Applicants using crypto assets face even more profound scrutiny, particularly around traceability and conversion to fiat currency.
Why These Pillars Matter
No single document guarantees approval. Grenada’s approach is designed so that weaknesses in one area cannot be concealed by strengths in another.
Together, these four pillars form a risk profile, not a checklist.
Grenada CBI Due Diligence: Process Overview
Source of Wealth vs. Source of Funds: Where Applications Succeed or Fail
One of the most common misunderstandings about Grenada CBI is the belief that proving where the investment money comes from is enough. It isn’t.
Grenada treats Source of Wealth and Source of Funds as two separate questions, and both must make sense.
What “Source of Wealth” Means
Source of Wealth looks at the big picture.
Authorities want to understand how an applicant accumulated their total net worth over time.
This includes:
- Business ownership and profits
- Employment history and career progression
- Dividends, asset sales, or inheritances
- Long-term income patterns
The key test here is plausibility. Even if documents are technically valid, an application may be escalated if the wealth story does not align with the applicant’s age, industry, or economic context.
What “Source of Funds” Means
Source of Funds focuses on the specific money used for the Grenada investment.
Investigators trace:
- The exact account the funds came from
- How long the funds have been held
- Whether they moved through multiple accounts
- Whether loans, gifts, or third parties are involved
This step is designed to prevent money laundering, hidden financing, and illegal discounting arrangements.
Why Grenada Separates the Two
An applicant might be genuinely wealthy but still use problematic funds for the investment, or the reverse.
For example:
- A successful entrepreneur using undeclared cash triggers concerns
- A family gift may be legitimate but still requires full documentation
- Sudden transfers shortly before application raise red flags
Grenada separates these analyses to ensure both the origin of wealth and the path of money are clean.
Common Red Flags That Trigger Enhanced Due Diligence
Applications are often escalated when investigators see:
- Complex layering of transactions without clear explanation
- Recently opened accounts holding large balances
- Inconsistent income versus declared net worth
- Loans or “developer financing”, tied to the investment
- Missing tax logic for jurisdictions where records should exist
Enhanced due diligence does not mean rejection—but it does mean deeper scrutiny, longer timelines, and higher costs.
Crypto Assets: A Special Case
Grenada accepts applicants with crypto wealth, but the standard is higher.
Applicants must show:
- How fiat funds were used to acquire crypto
- A transparent transaction history
- Conversion into fiat currency before investment
- No use of mixers, tumblers, or anonymous wallets
Untraceable crypto assets typically lead to rejection.
Why This Step Matters Most
Many applications fail quietly at this stage. There may be no headline rejection, just prolonged review until the case becomes unviable.
For Grenada, financial transparency is not negotiable. If the numbers don’t add up, the application doesn’t move forward.
Why Grenada CBI Applications Get Delayed, Escalated, or Rejected
Illegal Discounting & Financing Schemes: Why Grenada Is Cracking Down
Illegal discounting occurs when an applicant pays less than the legal minimum investment, often through hidden loans, side agreements, or undeclared incentives offered by agents or developers.
Grenada says this is misrepresentation and fraud, not a technical violation.
Since 2024, authorities have suspended projects, revoked agent licences, rejected applications, and even initiated citizenship revocation where discounting was discovered after approval.
The key takeaway is simple: if the full legal amount is not genuinely paid and traceable, the application is at risk—now or years later.
Can Grenada Citizenship Be Revoked After Approval?
Yes. Approval does not end due diligence.
Grenada retains the legal authority to revoke citizenship if it later discovers fraud, misrepresentation, undisclosed financing, or false declarations made during the application process.
This includes information that surfaces after naturalisation.
Recent enforcement actions have confirmed that revocation is no longer theoretical. Due diligence is effectively ongoing, and citizenship obtained under false pretences is not considered permanent.
What This Means for Applicants Today
Grenada's CBI program now prioritises integrity over speed.
Well-prepared applicants with transparent finances, consistent documentation, and legitimate investment structures generally move through the process without issue. Poorly prepared or aggressively “optimised” applications do not.
For applicants, the practical lesson is clear: there are no shortcuts.
A slower, more intrusive process is the price of maintaining the value and credibility of Grenadian citizenship.
FAQs
Final Thoughts
Due diligence for Grenada CBI is no longer a background screening. It is a comprehensive risk assessment that reflects how seriously citizenship is now treated on the global stage.
The process is slower, more intrusive, and less forgiving than it was just a few years ago.
Interviews, financial forensics, regional intelligence sharing, and active enforcement have reshaped the program into one that prioritises credibility over convenience.
For applicants with transparent finances, consistent documentation, and a legitimate investment structure, this rigour is not a disadvantage. It is what protects the long-term value of Grenadian citizenship itself.
The message is clear: there are no shortcuts, and there is no “light” version of due diligence anymore.
But for those who approach the process correctly, Grenada remains one of the most respected and resilient citizenship programs available today.
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