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Grenada Lifts Heng Sheng Suspension But Removes 25 Sub-Agents · IMI Podcasts

• 0:00
  SPEAKER_00: Grenada's Investment Migration Agency, also known as the IMA, has resumed processing citizenship applications for the Grenada National Resort Project after a three-month investigation found no evidence of direct financing, but discovered some financial inconsistencies and irregularities.
• 0:18
  SPEAKER_00: The agency's latest circular shows a partial lifting of enforcement action that began in March when the Caribbean nation suspended all applications linked to Singapore Heng Sheng development and its flagship resort project.
• 0:31
  SPEAKER_00: The investigation turned up a more complex picture than the initial allegations suggested.
• 0:36
  SPEAKER_00: The IMA noted that, quote, interim-enhanced due diligence assessments have not found evidence of direct overfinancing, end quote, clearing the project of systematic price discounting.
• 0:47
  SPEAKER_00: The IMA, however, discovered that it observed post-approval owner financing issues, and some applicants' bank records showed financial inconsistencies and irregularities.
• 0:58
  SPEAKER_00: The agency will resume processing applications that its staff handles directly while maintaining restrictions on those that Hung Sheng's subagents submit.
• 1:07
  SPEAKER_00: This setup allows the Citizenship by Investment Program to keep running, while the IMA keeps a closer watch on the marketing network that caused the compliance problems.
• 1:17
  SPEAKER_00: The IMA will refund applications with identified financial irregularities at local agents' risk, though the agency requires that refunds will only proceed with credible, independent, verifiable documentation, proving that refunds happen at the applicant's discretion rather than as disguised third-party reimbursements.
• 1:38
  SPEAKER_00: The circular describes these actions as measures that uphold the integrity of Grenada's citizenship by investment program while adopting a proportionate, fair, and risk-based regulatory approach.
• 1:49
  SPEAKER_00: The case has prompted new paperwork requirements that go well beyond Hing Shing.
• 1:54
  SPEAKER_00: Grenada National Resort applicants must now submit attestation forms confirming that investment funds are derived from the applicant's own verifiable resources, plus bank credit advice proving direct transfers from personal accounts to the developer's offshore account.
• 2:10
  SPEAKER_00: These requirements represent the biggest program changes to emerge from the investigation.
• 2:16
  SPEAKER_00: The IMA notes that a formal, circular, outlining full implementation will follow.
• 2:22
  SPEAKER_00: The IMA plans to extend these stricter documentation standards to all CBI applicants, regardless of their chosen project or marketing agent, fundamentally changing how the program verifies fund sources.
• 2:35
  SPEAKER_00: The agency's enforcement actions targeted problematic actors while keeping the PRIMARI project license active, but maintaining restrictions on improper marketing channels.
• 2:47
  SPEAKER_00: The IMA removed 25 subagents using deceptive marketing practices from Hang Sheng's distribution channels, and one marketing agent faces license suspension pending formal revocation proceedings.
• 2:59
  SPEAKER_00: The IMA opted against suspending Hang Sheng's PRIMRI license, although it has revoked the licenses of sub-agents involved in the matter.
• 3:09
  SPEAKER_00: Applicants flagged by due diligence providers for wealth source concerns or unexplained financial activity will undergo mandatory Tier II interviews.
• 3:18
  SPEAKER_00: This process lets individuals address inconsistencies that enhanced background checks uncover, balancing program security against fair treatment.
• 3:26
  SPEAKER_00: The Internal Audit, Risk and Compliance Department continues coordinating with investigation providers and has influenced the CBI Committee's decision-making process throughout the review period.
• 3:37
  SPEAKER_00: The circular notes that their findings have informed the CBI Committee's decisions on disciplinary measures.
• 3:44
  SPEAKER_00: The Grenada case represents another enforcement action in the Caribbean investment migration sector, following sustained pressure from the European Union on citizenship programs.
• 3:54
  SPEAKER_00: Grenada had already revoked eight CBI applications in March due to clear and incontrovertible evidence of owner loan financing and resultant price discounting.
• 4:04
  SPEAKER_00: The outcome shows how Caribbean jurisdictions are adapting to heightened international scrutiny while trying to preserve program viability.
• 4:13
  SPEAKER_00: This episode first appeared as an article by Ahmad Abbas on imidail.com.
• 4:20
  SPEAKER_00: Subscribe for free to the IMI newsletter for breaking news and updates from the investment migration industry, and upgrade your membership to IMI Pro to get access to our exclusive professional community, citizenship catalog, investment migration company Rolodex, private briefings, and more members only content.