An application for Grenadian citizenship by investment passes through more hands than most applicants realise. A marketing agent in Dubai or Hong Kong may make the first contact; a law firm in St George's lodges the file; international investigators run the background checks; a government agency weighs the results; and, increasingly, a regional authority watches over the whole process. Each has a defined role and none of them can promise the outcome.
Understanding who does what helps in two practical ways. It tells you whom to ask when something stalls, and it helps you spot claims that do not fit the structure, such as an adviser who says they can "speak to the minister" or guarantee a date. Institutional names and arrangements have changed over the years, so check current details with the Investment Migration Agency before relying on them.
The Investment Migration Agency: the decision-making body
Applications are administered by the Investment Migration Agency (IMA), the body that succeeded the original Citizenship by Investment Unit. Many agents and older guides still say "the CBI Unit"; in current practice they mean the IMA. It receives files from licensed agents, checks them for completeness, commissions due diligence, conducts or arranges interviews, assesses the results and issues decisions.
The IMA also licenses and supervises local agents, keeps the list of approved real estate projects under review, issues circulars on procedure and handles post-approval matters such as confirming that an investment has been made. It is the body to which questions about status, missing documents or rule changes should ultimately be directed, normally through your agent rather than by approaching it yourself.
The agency does not deal directly with members of the public who want to apply. Contacting it to check that an agent is licensed, or to verify an official notice, is a different matter and a sensible precaution.
The minister and the political layer
The programme sits under a minister responsible for it, and portfolio arrangements have varied between governments. The minister answers to Parliament for the programme, makes or amends regulations, approves certain categories of decision under the Act and carries policy proposals such as the 2026 amendment bill.
Political oversight matters because CBI revenue has become significant for public finances, and the programme is a recurring subject of parliamentary questions and public debate in Grenada. Changes of government have brought changes of emphasis, though the programme itself has continued across administrations since 2013.
For an individual applicant, the political layer should be invisible. Decisions on files are meant to follow the process set out in law and guidance. Anyone who claims to be able to influence a decision through political contacts is describing something improper, and in most cases simply untrue. Treat such claims as a reason to walk away.
The agents: two very different roles
Authorised local agents. Only a Grenadian firm or individual licensed by the IMA may submit an application. Most are law firms or licensed consultancies in St George's. They prepare and lodge the file, pay government fees on the applicant's behalf, receive the agency's queries and bear regulatory responsibility for the submission. A local agent can lose its licence for misconduct.
International marketing agents. Many applicants first deal with an adviser in their own country who has an arrangement with the programme or with a local agent. These firms market the programme, collect documents and manage the client relationship, but they cannot lodge an application themselves.
Why the distinction matters. Your engagement letter should name the local agent that will sign and submit. If an international adviser will not disclose that name, or the firm named is not on the IMA list, do not transfer money.
Fees follow roles. Each layer charges for its work. Ask for a schedule showing which payments go to the government, which to the local agent, which to the international adviser and which to third parties such as translators.
Due diligence firms and other checks
Background checks are not carried out by the IMA alone. The agency engages specialist international due diligence providers to investigate applicants and adult dependants: verifying identity, education and employment, searching court records, sanctions and watch lists, examining media coverage and testing the explanation given for the source of funds. Checks may also be made through regional and international law enforcement channels.
These firms report to the agency, not to the applicant or the agent. Their reports are confidential, and applicants do not normally see them. If a report raises questions, the agency may ask for more information or an interview before deciding.
Banks are another layer of scrutiny. The bank receiving an NTF contribution or a property payment applies its own anti-money-laundering checks, which can delay a transfer even after the government side has approved a file. Building time for bank compliance into your plans avoids a missed payment deadline.
The regional layer: ECCIRA and common standards
Grenada is one of five Eastern Caribbean states with citizenship by investment programmes, alongside Antigua and Barbuda, Dominica, St Kitts and Nevis, and St Lucia. After years of criticism that competition between them led to discounting and uneven vetting, the five agreed a common minimum investment in 2024 and, in 2025, an agreement establishing the Eastern Caribbean Citizenship by Investment Regulatory Authority (ECCIRA). Grenada passed legislation giving that agreement effect.
ECCIRA is intended to set shared standards, oversee the national agencies and coordinate checks such as information sharing on refused applicants. At the time of writing it was still being set up, and Grenada had tied the start of its new presence requirement to the authority becoming operational.
For applicants this means the IMA's decisions will increasingly sit inside a regional framework. A refusal in one programme is more likely to be known to the others, and changes to fees or procedures may be announced collectively rather than by Grenada alone.
How to check who you are dealing with
Before signing anything, run through a short verification list. Most problems in this market involve intermediaries, not the government itself:
- Ask for the full legal name of the Grenadian authorised agent and check it against the IMA's published list.
- Confirm that payments to the government, including the NTF contribution, go to official accounts specified by the programme, not to an adviser's own account.
- Ask whether the adviser is paid a commission by a real estate developer; this affects the neutrality of any project recommendation.
- Get the engagement terms in writing, including what happens to fees if the application is refused or withdrawn.
- Be suspicious of guaranteed approval, guaranteed timelines, "special" discounts or claims of personal access to decision-makers.
- If a notice claiming to come from the IMA asks for money, verify it independently before paying.
When something goes wrong: who to approach
Delays and disputes are common enough that it helps to know the escalation path in advance. If a file seems stuck, the first call is to the authorised local agent, who is the IMA's point of contact and should be able to say whether the agency is waiting for documents, due diligence results or an interview. Ask for any request from the agency in writing.
If the problem is with the agent itself, such as unexplained fees, missed deadlines or silence, the IMA licenses agents and can receive concerns about their conduct. Complaints about lawyers can also be raised with the professional bodies that regulate legal practice in Grenada.
Disputes with a real estate developer are usually contractual and belong with a Grenadian attorney acting for you rather than for the developer or the agent who sold the unit. Keeping these roles separate from the start, with your own lawyer reviewing the purchase, makes any later dispute far easier to resolve.
Frequently asked questions
Is the CBI Unit the same as the Investment Migration Agency?
In practice, yes. The Investment Migration Agency has succeeded the original Citizenship by Investment Unit as the body administering the programme. Older guides and some agents still use the old name, but current applications are handled by the IMA.
Can an individual apply directly to the IMA without an agent?
No. Applications must be submitted through an authorised local agent licensed by the IMA. You can, however, contact the agency to confirm that a particular agent holds a licence, which is a sensible step before engaging anyone.
Does the minister decide each application personally?
Files are assessed through the process set out in the Act, regulations and agency procedures, with ministerial roles defined by law. Applicants should not seek, and nobody legitimate will offer, personal intervention in a decision.
Who sees the due diligence report on an applicant?
The report goes to the IMA. It is confidential, and applicants and agents do not normally receive a copy. If concerns arise, the agency may ask for further information or an interview before reaching a decision.
What is ECCIRA and does it decide applications?
ECCIRA is the regional regulatory authority agreed by the five Eastern Caribbean CBI states in 2025. It is meant to set common standards and oversee national agencies. Individual decisions remain with each country, including Grenada.
How can fraud by an intermediary be avoided?
Verify the local agent on the IMA list, pay government amounts only to official accounts, get engagement terms in writing and refuse anyone promising guaranteed approval or political access. Independent legal advice in Grenada adds a further check.
