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Gregor Nassief. File photo

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September 9th, 2019

Dear Lennox,



On September 3rd, 2019 on the Hot Seat, you declared in advertence to affairs apropos to the Range/Kempinski Project: “when you appraise those elements carefully you seeing the outline of an busy adjustment to bluff and steal.”  You afresh accepted the achievability of bounded developers, including myself & Secret Bay who you alleged directly, actuality circuitous in such an busy scheme: “These arrange that bodies like those amenable for Jungle Bay and those amenable for the villas at Secret Bay, Residences at Secret Bay and the Anichi, Mr. Alick Lawrence and others are benefitting from.  So we accept been able to accept a window into the operations of the Kempinski by Range, these are two adopted people. But we accept locals as well. Accompany of the Government.  Who are benefiting from the absolute acreage arrange that are allotment of the Citizenship by Advance program.  And you can accept now why is it that these agents and these bodies who are benefitting , these locals are befitting their aperture shut. Nobody is speaking up for the candor of the scheme.  Nobody is speaking up for operating it appropriately in the accessible interest.  Because it appears from what we are seeing with Kempinski that there is a lot of money for these people, these locals, these accompany of Skerrit, the Sam Raphaels, the Gregor Nassiefs, the Alick Lawrences and so on. To make… There is lots of money for them to accomplish over and aloft what is bare for the auberge development. What is bare for the architecture of the hotel. There is a lot of money for them to be fabricated accustomed this Kempinski model, this Range Kempinski model.”

While the acknowledged implications of these statements are actuality pursued, I have, at your allurement absitively to “unshut” my mouth, and acknowledge to what I accede to be at best bookish artifice and at affliction bookish incompetence.  My response, afresh at your invitation, is advised to additionally accommodate anyone accommodating to read, an insider’s appearance of the CBI affairs and how it works.  Admitting the affairs is about complex, it continues to astonish me the abundant belief and fallacies that abound about the CBI program, and how few bodies absolutely accept how the affairs works, and added alarming is how anyone could absolutely booty actively an accusation that ec$1.2b could “go missing” in an abridgement the admeasurement of ours.

My response, as independent herein, will be in three parts: Allotment I: The Business of CBI, Allotment II: The Business of Absolute Acreage (aka “where de money gone”) and Allotment III: The Good, The Bad & The Ugly. Forgive the continued windedness of my acknowledgment but based on the contempo statements you made, I accept to accept the charge to go aback to basics.


Part I: The Business of CBI

Residence and citizenship by advance programs are now offered by over 80 countries and the all-around industry is conservatively estimated to be a US$21.4 billion bazaar that’s growing by 23% a year.  A address aftermost anniversary from IMI Insider declared that “57,000 Chinese spent added than US$44 Billion on in the aftermost decade.” Back a country enters the CBI bazaar they are not accomplishing so for altruistic reasons, they are accomplishing it to accomplish acquirement and investment.  It’s a awful aggressive bazaar with minimum investments alignment from us$100,000 to Euro $2 million.  And those of us with adventurous ethics (myself included) of acute our Bread-and-butter Citizens to appear to Dominica in adjustment to access Citizenship or to ambitious that they pay abundant college prices for Citizenship are blank aggressive armament and accident armpit of the actuality that the day we move in this administration is the day we adjudge to avenue the industry.  One can altercate as to whether one cast or dislikes the abstraction of “selling passports” as it is frequently termed, but so continued as our Government stays in the CBI bold – as anniversary alternating one has done for the accomplished 26 years – afresh it is a business in which we charge abide competitive.  The accepted Government’s restructuring of the affairs in 2014 has led to Dominica acceptable a bazaar baton aural the Caribbean arena and breeding to date billions of dollars in bread-and-butter activity for Dominica.

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So why would bodies be spending us$24b a year on abode and citizenship by advance programs offered by over 80 countries?  There are abounding factors, but the prevailing one is “an allowance activity adjoin approaching uncertainty”.  One of the fastest arising antecedent markets for added citizenship is South Africa.  The bill is in a bottomward spiral, abomination is out of ascendancy and the country’s authorization is added ambiguous for travel, so South Africans who can acquiesce it are advance in added Citizenship.  Anticipate of Yemen, Egypt, Hong Kong, Taiwan.  Think of restrictions on abandon in China or Russia or Saudi Arabia.  We all appetite to be able to travel, with our family, for our children’s education, for business, and in a affliction case book if our country collapses, we charge advancement options.

Now on the affairs ancillary of this equation, in China abandoned there are 27,000 “immigration agents”.  Add the added aloft markets of the Middle East and Africa, Russia, South East Asia and India (these “immigration agents” bazaar and advance Citizenship or Residency options to their clients, not to be abashed with accountant “authorized agents” that activity Citizenship applications).

In summary, there are 80 countries alms one blazon or accession of Citizenship or Residency options, of which 5 are in the Caribbean, and there are tens of bags of agents advance above the globe, and you should activate to get a faculty of the legitimacy, size, complication and competitiveness of this all-around industry for 2nd Citizenship and Residency.


Part II: The Business of Real Estate

If afterwards attractive at the array of programs accessible worldwide, a abeyant bread-and-butter aborigine looks at the Dominica program, they are faced with two options tabled below: the Bread-and-butter Diversification Fund option, additionally accepted as the “Donation” option. The added option, alleged the “Real Estate” option, requires a minimum us$200,000 advance into the Real Estate project and an added minimum of us$25,000 into the Bread-and-butter Diversification Fund.  The bulk activity into the Absolute Acreage activity is a minimum of us$200,000 behindhand of the admeasurement of the family, while the associated bulk for Absolute Acreage activity into the Bread-and-butter Diversification Fund is a minimum of us$25,000 which increases according to the admeasurement of the family:

Before I get into the statements you fabricated surrounding Absolute Estate, it is important to ask the simple question:  Why would a abeyant bread-and-butter aborigine baddest the added big-ticket Absolute Acreage advantage over the Donation option?  A distinct Applicant about won’t anticipate alert because the Donation advantage is us$100,000 while the Absolute Acreage advantage (investment additional EDF) starts at $225,000.  But as the ancestors admeasurement grows, say a ancestors of 4, the Donation advantage is $200,000 vs. the Absolute Acreage advantage at us$235,000.  So at a ancestors admeasurement of 4 or more, the abeyant broker may accede Absolute Acreage for the simple acumen that they are advance in article tangible, an asset that they can potentially get a cyberbanking acknowledgment on and potentially resell in the future, while the Donation advantage is a absolute accession to the Government EDF which does not aftereffect in the affairs of an asset.  This basal point of the Absolute Acreage advance carrying a actual asset to the broker seems to escape you as you accept acclimated the appellation “free money” time and time again, afresh advertence for archetype “the handing over of the passport, in barter for monies that end up as chargeless money in the easily of developers to do assignment in Dominica”.

There is annihilation “free” about the advance monies that developers attract.  It is not, as you or others may believe, CBI money that the Government has that they duke over to the Developer.  It is adamantine won advance monies in a awful aggressive bazaar becoming by the developer.  As you should be aware, that there are about 100 CBI absolute acreage projects in St. Kitts, over 40 in Antigua, about 20 in Grenada and currently 6 in Dominica additional endless developments in European programs additional the currently quota-restricted EB5 in the US.  Why would an broker accept Jungle Bay in Dominica vs. Kimpton Kawana in Grenada vs. Christophe Harbor in St. Kitts vs. Canelles in St. Lucia or a development in Greece or Malta or Cyprus?  It’s a adamantine won activity that agents and developers fight, with actual cogent sales commissions in the mix, and anniversary advance is scrutinized by the investor, because afterwards all, they can absorb beneath money and artlessly go with the Donation/EDF option.  So there is no “free money” actuality handed over here.

Another absurd annual from you (with Matt in the accomplishments adage “Why do you appetite a cut”): “I’m asking, if you are authoritative your fees as a abettor of passports, you putting the Government’s money in the treasury, you putting the advance now into the absolute acreage project, why are you still demography a agency on the investor’s money, what is declared to be the investor’s money.”  You are implying actuality that developers are agents “selling passports”.  A antic statement.  Secret Bay is not a CBI agent, we do not “sell passports” and as such we cannot and do not aggregate fees from anyone for “selling” or “processing” passports.  We are in the business of announcement our absolute estate, our villas, and alluring investments into those assets.  Your advertence to “taking a agency on the investor’s money” is additionally apperception boggling. You are application the appellation “commission” to alarm a developer’s profit, and implying that developer’s should not be advantaged to a “profit” from affairs their auberge or villas or absolute acreage artefact because they are “making fees as a abettor of passports”.  So application Secret Bay as an example, I absorb 20 years purchasing 33 acreage of acreage in over 10 abstracted transactions, I advance tens of millions of dollars, additional borrow money from the bank, our absurd Secret Bay aggregation runs a auberge for eight years with all of their blood, diaphoresis and tears, we accretion unparalleled all-embracing acceptance with our “local brand” activity global, we advance added and commence on architecture abounding added villas, and our villas are actuality awash to both Citizenship and Non Citizenship investors, and every advance dollar we get is adamantine fought and won, and you, Lennox, are cogent me that we are not advantaged to a profit?  And you affirmation to be a acquaintance of the clandestine sector?

It is time that you brainwash yourself on Absolute Acreage development.  Outside of the CBI program, absolute acreage developers will aim for annihilation amid a 16% and a 20% return, which we can appellation a “development profit”.  And aural the CBI program, due to the college risks involved, the targeted margins can be higher.  Abounding developments go broke afore they are completed, usually because sales lag and/or due to cogent architecture costs overruns, and the boilerplate accumulation absolutely accomplished in the end for those that do not go broke is generally essentially lower.

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You added stated: “There is lots of money for them to accomplish over and aloft what is bare for the auberge development. What is bare for the architecture of the hotel”.  Accept you fabricated any accomplishment Lennox to accept how absolute acreage development works?  Are you acquainted for archetype that architecture costs about annual for amid 50% and 60% of the absolute absolute acreage development costs in a CBI scenario, with sales and business expenses, decidedly commissions to all-embracing business agents, abacus cogent costs, in accession to abounding added band items including pre-operating costs.  As you acutely charge to do some research, I advance you apprehend 2018 HVS All-around Hospitality abstraction and the 2018 BCQS Architecture Bazaar Trend Address for the Caribbean& Latin America.  You will agenda that costs for Luxury Resorts can and generally do beat us$600,000 per key/room (this is not what it amount to body the room, it is the absolute architecture costs disconnected by the cardinal of rooms).  You will additionally apprehension architecture prices per Sq. Ft. alignment amid us$250 to us$550, and you should apperceive that currently, in Dominica, to body a aloft auberge requires adopted contractors and aggregation at decidedly college costs due to abridgement of accessible bounded resources.  And finally, you cannot actively allocution about accumulation afterwards compassionate risk.  So bisected way through a aloft CBI project, the basal avalanche out of the CBI market, no added sales, aggregate area to a halt.  What happens afresh to the developer’s investment, the loans, the debt and the half-built project?  Bankruptcy happens.

Secret Bay’s example.  Afterwards 8 years of operations and assorted expansions, and afresh a battering by Hurricane Maria in 2017, and an absurd accomplishment to re-open in November 2018, we are continuing to aggrandize and body out our resort, and CBI is but one approach of disinterestedness financing: there is my own equity, the disinterestedness of added shareholders, coffer loans, disinterestedness investments from non-Citizenship buyers and disinterestedness investments from Citizenship buyers.  Afore we akin activated to the Government for approval beneath the CBI program, about ec$20m had been spent, for the land, the resort construction, adept planning, architecture and engineering casework of every kind, aloft basement works, and the annual goes on.  We activated for CBI approval in 2015 – continued afterwards we began operating – and it took an absurd (and in my assessment shameful) 3.5 continued years for Government approval which came in February 2019.  We accept back opened offices in Dubai, affianced Sales Directors in Dubai and Mainland China (for Citizenship sales) and in the Caribbean (for non-Citizenship sales) and invested untold hundreds of bags of dollars in sales and business to advance our villas, and we accept already began architecture works on the expansion.  We accept apparent no “free money” advancing in yet, as you alarm it, but we are committed to our vision, and accommodating to booty the risk.

“Free money”, and an “elaborate adjustment to bluff and steal”?  I animate you Lennox, or any of the “Friends of Lennox Linton” – DO IT!  Buy land, aftermath architectural and engineering concepts, alpha building, advance everything, borrow money, adapt your budgets and cyberbanking forecasts across-the-board of your “developers profit”, go through an all-embracing Government approval process, appoint a all-around sales and business team, advance in and advance your brand, go out into a all-around bazaar as a newcomer, biking non-stop, booty on the absolute titans, and accumulate activity abnormally back there is no momentum, and all you accept on your amateur is advance and debt, but accumulate the faith, accumulate committed, assignment 24×7 because now you accept to acknowledgment abettor buzz calls at 10pm from Dubai and 2am from China, and accumulate going, persevere my friend, accompany that ambiguous profit!  Afterwards you accept done that, afresh appear at us with your consecutive belief and casuistic inferences.

Now “Housing”, the 3rd advantage afresh fabricated accessible to investors.  Apartment is like Absolute Acreage in that there is a clandestine developer circuitous but it is additionally like EDF/donation in that the broker gets no asset in return.  So it’s a amalgam product, a “mix” of the two (and agenda that no developer or abettor is blessed with it because it provides for best bazaar appraisement to reflect the Government’s antecedence on housing).  So the accurate developer finds audience on their own for this “hybrid” CBI offering: the broker invests their money, the developer uses these funds to body out Apartment projects and the State, accepting taken aught risk, gets the Apartment assets in return, and the developer reaps a profit.

This accompany us to the actual important point of how money is accounted for and who “owns” what money, aka “where de money gone”.  Agenda that if the Government was to accommodate in its accessible accounts, based on how developer affairs are structured, the declared “missing” money, it would be counterfeit because that money does not accord to Government, it belongs to the developers.  This is the accepted in all the OECS CBI Programs. In fact, the one bearings area a bounded Government dared to aperture that adjustment and to use the appointed funds, they were auspiciously litigated adjoin by a developer. In added words, if an broker invests us$200,000 in purchasing a Villa, and the developer transfers abounding appellation of that Alcazar to that investor, how can the $200,000 be appear as Government revenue?  No, ONLY the $25,000 that the broker pays to Government (refer to table above) is what goes into the Treasury and this is what is appear in the Government’s accessible accounts.  Incredibly, you accept not grasped this and prefer, as is acceptable for you, to seek circuit rather than gluttonous a added compassionate and truth.

Now Secret Bay, like all developers, has an Escrow annual to which the Government is a signatory.  The monies from investors affairs villas at Secret Bay that gets accomplished due activity are deposited in this annual – this is Secret Bay’s money, not the Governments, because it is money acclimated to acquirement a cyberbanking absorption in a absolute acreage asset at Secret Bay, it is NOT money actuality acclimated to “purchase a passport”.  Actuality is the affair you do not assume to understand: the actuality that they accept fabricated the advance in Secret Bay “qualifies” them for Dominica Citizenship, and afresh they charge additionally pay the minimum us$25,000 (using the archetype above) to the Government to access Citizenship, but their $200,000 has becoming them a absolute actual cyberbanking absorption in a Secret Bay villa.

Why is the Government accomplishing this: because the Government wants its CBI affairs to accomplish money a) into its Treasury for absolute Government investments, b) into its tourism area to ensure the country’s auberge bulb rapidly expands and c) into its apartment area to bear a actual cogent cardinal of homes to the citizenry afterwards two aloft accustomed disasters.

You may catechism the Government’s activity for alignment the agreements and escrow accounts in this way, but Dominica’s Absolute Acreage affairs is, in accepted terms, no altered than St. Kitts or Antigua or Grenada, in that the monies that go into those developments are not reflected in Government accounts.  The affairs has apparent the re-launch of Jungle Bay, the anon to be aperture of Kempinski, and both Anichi and the Hilton are in their architecture phases.  You may adopt to “eliminate” the clandestine developer from the equation, let the Government do the adamantine assignment and let the Government booty the abounding accident of marketing, sales, architecture and delivery.  I can acceding you that this would crop a adversity in ailing managed architecture projects (aka The Morocco Hotel), massive amount overruns, deadlines activity years above what they should and half-built or unbuilt hotels.  That is why no added Government in the arena has structured absolute acreage any altered from Dominica.

All of that actuality said, I am 100% in favor of added cellophane accountability so the accessible has a abundant bigger compassionate of how the industry is structured and how monies are allocated, but to serially appoint in the cool belief of $1.2b “missing”, and to infer that developers like myself may be circuitous in an “elaborate adjustment to bluff and steal” and to advance that this is the acumen that we are “keeping our aperture shut”, is, as I accept said earlier, at best bookish artifice and at affliction bookish incompetence.


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Part III: The Good, The Bad & The Ugly

The Good.  Back Dominica instituted the Real Estate option in 2014, if differentiated itself in a cardinal of ways.  First, the approval activity is arduous.  Second, it requires that all investment monies destined to a real estate project are deposited into a developer’s escrow annual which the Government has ascendancy over as a signatory, and akin admitting that money belongs to the developer, it is alone appear to the developer if there is correlating advance in the project.  In added words, if the developer sells and receives 20% of the absolute investment, the Government does not acquiesce the absolution of those funds until the developer shows 20% advance on construction.  This requires the broker to financially front-load the advance – acceptation to accommodate their own costs advanced of accepting any funds from escrow such that architecture advances.  I accept heard developers acutely on the bend of a afraid breakdown because the Cyberbanking Secretary will not assurance off on absolution their money to their project.  But this prevents a developer from accepting money and not putting it into construction, article that has happened again in accession jurisdictions.  Also, the Government has advisedly kept the carry of CBI real estate projects “tight” (so alone a few projects at a time) appropriately accretion the anticipation of anniversary activity completing.  Look at Dominica’s activity of projects vs. added Media It’s acute activity and increases anniversary developer’s anticipation of success.  And lastly, but absolutely not least, Agents and Applicants akin acclaim Dominica’s CBI unit for its ability and acceleration of processing while advancement actual aerial due activity standards.

The Bad & The Ugly.  The regional CBI programs are acutely accessible and one aloft abortion in due activity could activate to derail it.  This requires an bound accomplishment to ensure the best and best absolute due activity process, and to added enhance that, Dominica needs to apparatus biometric passports, a move that is, in my opinion, continued overdue.  The industry additionally needs abundant tighter regulations – there are arrant agents and developers authoritative a blend of things for anybody abroad alms what are accepted as “special deals”, absolutely undercutting the bazaar and abrasive the absolute affairs and the corresponding Governments are not arise down.  The appropriate amalgam Apartment offering, while benign to Dominica, creates a austere claiming for the affairs to the point that some agents are now abnegation to activity Dominica because they cannot attempt with the Apartment option.  The cyberbanking activity of accepting funds from bread-and-butter citizens is arresting at best, and added needs to be done to access ability and chump account while applying the all-important due activity requirements.  In summary, the bristles accommodating Caribbean CBI countries charge to authorize compatible regulations and guidelines, across-the-board of astringent penalties for those developers and agents affianced in bent and actionable practices.  Such regulations should additionally accommodate minimum accuracy and accountability requirements for the programs.   And as a final note, we are architecture many, abounding hotels, but these projects will not bear on the affiance of a acceptable bread-and-butter appulse if we are clumsy to ample the apartment and allure abounding added visitors to the island, an approaching claiming that requires a lot added focus and action.


In Closing 

CBI Real Estate projects do not receive Government CBI monies, Bread-and-butter Citizens allotment the absolute acreage advantage are actual investors and become owners of the real estate projects, Government cannot address developer’s money as their own, “total architecture cost” does not according “total absolute acreage development cost” and developers should be advantaged to a accumulation for authoritative cogent investments and demography cogent risks in the marketing, sales and development of absolute acreage projects.

Finally, while it is accessible you accept no austere ability or compassionate of the apparatus of the absolute acreage option, or the acceding of my agreement, I charge allure you to about apologize for what I accede to be your insidious and bottomless inferences or innuendoes fabricated adjoin me as the developer of Secret Bay on September 3rd, during your altercation with Mr. Matthias Peltier on the Hot Seat on Q95.

Time is of aspect on this one as this will not be taken agilely because I charge assure my acceptability and that of Secret Bay.



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Gregor Nassief

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