I INTRODUCTION TO THE IMMIGRATION FRAMEWORK
The territory of Grenada consists of three islands; Grenada, Carriacou and Petite Martinique, situated in the southernmost part of the Caribbean region between the Caribbean Sea and the Atlantic Ocean with a year-round average climate of 23 degrees Celsius. Grenada is 133 square miles with a population that ranges from 90,000 to 110,000.
Grenada immigration is governed by legislation, policy, treaties and practice.
i Types of visas
Persons entering Grenada from specified states may require the issuance of a visa prior to or upon entry.
The entry visa types are as follows:
- multiple-entry visa: valid for one year; and
- single-entry visas.
In the case of a single entry visa, a single entry applicant must arrive in the state within three months of the issuance.
- single-entry visa: 100 Eastern Caribbean dollars; and
- multiple-entry visa: 250 Eastern Caribbean dollars.
Application can be made online or by contacting the Immigration Department of Grenada.
Countries requiring a visa to enter Grenada include Thailand, Saudi Arabia, Vietnam, Syria, Indonesia, El Salvador, Bolivia, Guatemala, Honduras, Rwanda and Turkey.
ii Legislation and policy
The Grenada immigration framework is governed mainly by the following laws of Grenada:
- Aliens (Land Holding Regulation) Act, Chapter 13 of the 2010 Edition of the Continuous Revised Laws of Grenada (the Aliens Land Holding Act);
- Citizenship Act, Chapter 54 of the 2010 Edition of the Continuous Revised Laws of Grenada (the Citizenship Act);
- Employment Act, Chapter 89 of the 2010 Edition of the Continuous Revised Laws of Grenada (the Employment Act);
- Foreign Nationals and Commonwealth Citizens (Employment) Act, Chapter 115 of the 2010 Edition of the Continuous Revised Laws of Grenada (the Foreign Nationals and Commonwealth Citizens Act);
- Immigration Act, Chapter 145 of the 2010 Edition of the Continuous Revised Laws of Grenada (the Immigration Act);
- Passports Act, Chapter 226 of the 2010 Edition of the Continuous Revised Laws of Grenada (the Passports Act);
- Citizenship by Investment Act No. 15 of 2013 of the 2010 Edition of the Continuous Revised Laws of Grenada (the Citizenship by Investment Act); and
- the Constitution of Grenada 1973.
The Immigration Act
Entry via any port in Grenada (whether airport or seaport) is regulated by the Immigration Act. A person entering Grenada must produce a valid passport. Sections 5(1), 5(2), 5(3) and 5(3A) of the Immigration Act stipulate the following.
A person entering Grenada without a passport shall be deemed to be a prohibited alien unless and until he or she establishes his or her identity and nationality to the satisfaction of an immigration officer.
In this section, the word ‘passport’ means a passport furnished with a photograph and duly issued not more than five years before the date of arrival, or some other document establishing identity and nationality to the satisfaction of an immigration officer:
Provided that the Minister may by regulations order that the passport of a national of all or any foreign countries shall not be accepted unless it bears the visa of a diplomatic or consular officer of Grenada or, where Grenada is not represented by such an officer, by a diplomatic or consular officer of the country that acts on behalf of Grenada in the country of issue.
A visa shall show the purposes for which the holder of the passport seeks to enter Grenada.
A person who is a citizen of any Member State of the Organisation of Eastern Caribbean States may establish his or her identity and nationality by producing an identity card, in the form of a driver’s licence or national identification card of the Member State with a photograph, which has been duly issued or renewed and is valid for the period of the person’s intended stay in Grenada.2
Section 9 of the Immigration Act outlines the duties of persons at ports of entry in Grenada as follows:
- No person shall enter Grenada except at a port of entry.
- A person entering Grenada by sea shall not disembark without the consent of an immigration officer, and the master of a ship shall not allow any person to disembark without such consent.
- Every person entering Grenada by air shall forthwith present himself or herself in person to the nearest immigration officer.
- Every person entering Grenada shall, if required by an immigration officer –
- make and sign the prescribed declaration; and
- submit to examination by a medical practitioner.
- A person who contravenes, or fails or refuses to comply with, any of the provisions of the preceding subsections of this section, when entering Grenada, shall be deemed to be a prohibited alien and may be dealt with as such.
- An immigration officer may grant a permit for a person to disembark without prejudice to the question of whether he or she is a prohibited alien.3
Section 24 of the Immigration Act regulates the criteria for a person applying for permanent residence.
- Subject to the provisions of this Act, the Minister may grant a permit of permanent residence to any person who applies for the same in the prescribed manner and who –
- is of good character; and
- in his or her application, has stated his or her intention to reside permanently in Grenada.
- Where a permit of permanent residence is granted to a person under this section the Minister may then, or on subsequent application by the person, endorse the permit to relate also to any one or more of his or her dependants.4
The following are the requirements for obtaining permanent residence:
- one application for permanent residence form to be completed and signed;
- four passport-sized photographs certified by a justice of the peace or notary public;
- reference letter from a reputable person in country of birth or residence;
- reference letter from a reputable person in Grenada;
- police certificate of character from country of origin (must be dated within six months of application);
- police certificate of character from Grenada (must be dated within six months of application);
- original and one photocopy of birth certificate. If the name does not appear on the birth certificate and the original affidavit is required;
- letter stating date of arrival in Grenada, purpose of visit, the activities engaged in and reason why applicant would like to acquire permanent residence status;
- updated immunisation card; and
- security check fee of 275 Eastern Caribbean dollars applicable on submission of application.
If permanent residence is granted they are entitled to reside in Grenada but still require a work permit if they desire to work.
A person permitted to obtain permanent residence within the jurisdiction of Grenada must adhere to the legal requirements in order that permanent residence is not revoked by the minister of government with responsibility for granting the same. Pursuant to the provisions of the Immigration Act, the said minister of government has the discretion to revoke the permit of permanent residence.
Section 25 of the Immigration Act states:
- The Minister may, by order in writing, revoke a permit of permanent residence or any endorsement thereon on the grounds that the person to whom it relates –
- subsequent to the grant of such permit has been ordinarily resident outside Grenada continuously for a period of three years;
- has in any country been imprisoned for a criminal offence for one year or more;
- has so conducted himself or herself that in the opinion of the Minister it is not in the public interest that he or she should continue to enjoy the privileges conferred by the permit;
- or being the wife of the person to whom it was granted –
- has commenced to live apart from her husband under a decree of a competent court or under a deed of separation, or
- has ceased to be married to her husband by reason of dissolution or annulment of marriage.
- No order shall be made by the Minister in exercise of the power conferred by subsection 1 unless the person against whom the order is proposed to be made has first been given a notice in writing of the grounds on which it is proposed to be made and has been afforded an opportunity to be heard.5
Foreign Nationals and Commonwealth Citizens Act
A foreign national as defined in the Foreign Nationals and Commonwealth Citizens Act to mean a person who is neither a citizen of Grenada nor a commonwealth citizen. Section 3 of Foreign Nationals and Commonwealth Citizens Act dictates that individuals who enter the jurisdiction of Grenada through one of the ports of entry are not permitted to be employed without a valid work permit. Section 3 outlines the requirements as follows:
- Subject to this section and to the Caribbean Community Skilled Nationals Act, Chapter 39B, an individual who is a foreign national or a Commonwealth citizen shall not engage in any occupation for reward or profit, or engage in or be employed in Grenada in the manifestation or propagation of any religion or belief in religious worship, teaching, practice or observance, unless he or she has a valid work permit and unless he or she engages in or is employed in these activities in accordance with the conditions specified in his or her work permit.
- Subject to the Caribbean Community Skilled Nationals Act, Chapter 39B, no person shall have in his or her employment a foreign national or Commonwealth citizen unless he or she has a valid work permit or an order of exemption in regards to that employment made by the Minister pursuant to subsection 4.
- A person having in his or her employment a foreign national or a Commonwealth citizen without there being in force a valid work permit or order of exemption as required by subsection 2, and any foreign national or Commonwealth citizen who is employed in contravention of subsection 1, shall be guilty of an offence and liable, on summary conviction, to a fine of 500 Eastern Caribbean dollars, and in default of payment to imprisonment for six months and, in the case of a continuing offence, to a further fine of 500 Eastern Caribbean dollars for each day upon which the offence continues and to imprisonment for six months.
- Notwithstanding the foregoing provisions of this section, the Minister may, by order, exempt any individual or class of individuals from the requirements of subsection 1 either unconditionally or subject to conditions specified in the order.
- In criminal proceedings instituted pursuant to this section it shall be presumed that the accused or, as the case may be, the alleged employee is a foreign national or Commonwealth citizen unless the contrary is proved by the defence.6
It is also at the discretion of the minister of government with the responsibility for granting work permits under the provisions of the Foreign Nationals and Commonwealth Citizens Act to permit a person skilled in an area not readily available in Grenada to apply for and be granted a work permit.
The following are the requirements for obtaining a work permit:
- completed, signed and dated application forms, in the case of companies’ forms are to be signed and sealed by a director of the company;
- four passport-sized photographs (2" x 2.2" and of international standard). The name of the applicant must be written on the back of the photographs;
- police record or clearance;
- certificates of qualification;
- a character reference from a previous employer or reputable person if the applicant has no previous employment;
- a letter from a prospective employer addressed to the Minister for Labour, through the Permanent Secretary of the Department of Labour;
- a copy of the certificate of incorporation of a company or the business registration certificate;
- the resumé of the applicant;
- a copy of the page with the applicant’s photograph and details from his or her passport and the page detailing the most recent date of arrival in Grenada;
- recent tax compliance and VAT receipts;
- an NIS compliance certificate; and
- the previous work permit must be submitted in cases of renewal or change of employer.
Aliens Land Holding Act
A person classified as a non-national of Grenada who wishes to invest in Grenada, outside the requirements legislated on by the Citizenship by Investment Act, requires an alien land holding licence that regulates their investment.
The requirements for a person being granted an alien landholding licence is legislated by Section 4(1) of the Aliens Land Holding Act and are as follows:
- bank’s reference letter (addressed to the Permanent Secretary);
- two character references (addressed to the Permanent Secretary);
- police character references for the applicant from the country in which the applicant has most recently resided for a period of at least 20 years (where it is not usual for the police to give a certificate of character, the police must give a letter to that effect). (Valid only for six months);
- three completed alien land holding application forms;
- an employment letter or statement of employment (if retired letters are not applicable); and
- a copy of the page in the passport with the applicant’s photograph and details.
By virtue of being granted an alien land holding licence, that person is entitled to reside within the jurisdiction of Grenada and occupy their property, with the legal requirement to report to the Immigration Authority within a minimum of every three months up to a maximum of six months until an application is made by the person for permanent residence and citizenship thereafter. An application for alien land holding is generally processed within a 90-day period. For a person who was granted an alien land holding licence to work within the jurisdiction of Grenada, a work permit will be required to seek employment.
Citizenship Act and Constitution of Grenada
Section 98 of the Grenada Constitution stipulates that ‘any person who is married to a citizen of Grenada or who has been married to a person who was, during the subsistence of the marriage, a citizen of Grenada shall be entitled, upon making application in such a manner as may be prescribed by or under a law enacted by Parliament, and if he is a British protected person or an alien taking the oath of allegiance, to be registered as a citizen of Grenada’.7
Children born outside Grenada under the age of 18 to persons not born in Grenada but who acquired citizenship through one of the aforementioned means can apply for and may be granted citizenship of Grenada. Children born to persons born within the jurisdiction of Grenada may apply for Grenada citizenship at any age as there are no restrictions.
Citizenship by Investment Act
In 2013 Grenada introduced legislation regulating economic citizenship for persons wishing to apply to become citizens of Grenada. The Citizenship by Investment Act makes provision for persons being able to qualify for Grenada citizenship under the following three categories:
- Permanent residence with the investment of US$75,000 into the National Transformation Fund and application for citizenship within one year thereafter with a further investment of US$125,000 into the National Transformation Fund.
- Citizenship through investment of a minimum of US$250,000 into an approved project. This project must be reviewed and recommended by the Citizenship by Investment Committee and thereafter approved by the minister with responsibility for Grenada citizenship through the investment programme, who is presently the Prime Minister of Grenada.
- Significant investment by a prospective applicant for Grenada citizenship by making a financial investment of an amount prescribed by the said Minister responsible for the Grenada citizenship by investment programme, which is considerable benefit to the Grenadian economy and will help to create or maintain employment opportunities for Grenadian citizens.
iii The immigration authorities
In Grenada the ports are divided into airports and seaports and there are currently eleven ports of entry and the various Immigration Authorities of Grenada are responsible for regulating the entry of non-nationals and nationals.
The airports of entry are Maurice Bishop International Airport (Grenada) and Lauriston Airport (Carriacou). The sea ports of entry are St. George’s Port, Port Louis Marina, Prickly Bay Marina, Le Phare Bleu, Grenville Port, St. George’s Cruise Ship Terminal, Hillsborough Port (Carriacou) and Tyrell Bay Port (Carriacou).
The following are the main immigration authorities and their responsibilities within the jurisdiction of Grenada.
The Immigration and Passport Department
The Immigration and Passport Department is an extension of the Royal Grenada Police Force with special responsibility for administrating the atate’s affairs in the exercise of control of the movement of people (nationals and non-nationals) in and out of Grenada, Carriacou and Petite Martinique as a matter of national security.
Grenada Customs and Excise Division
The Grenada Customs and Excise Division’s primary duty is to collect revenue, facilitate trade and travellers, and assist in securing the social, ecological and economic environment of Grenada, in accordance with all laws and regulations related to customs, with equity, integrity and transparency.
Grenada Airports Authority
The Grenada Airports Authority’s primary focus is outlined in its mission statement as providing safe, secure, efficient and profitable world-class airport facilities and services, consistent with international standards through a highly skilled and committed workforce in support of the economic development of Grenada.
Grenada Ports Authority
The Grenada Ports Authority is responsible for the administration and operation relative to cargo handling, the cruise sector and tourism of the Port of St. George’s. The Grenada Ports Authority also has jurisdiction over Prickly Bay, St. David’s Harbour and Grenville Port, on the main island of Grenada, as well Tyrrel Bay on the island of Carriacou.
iv Exemptions and favoured industries
As a developing nation Grenada has an emerging economy with great potential for further economic growth. Over the past 30 years Grenada’s gross domestic product has had an annual growth rate of around 3 per cent. In recognition of Grenada’s growth potential in 1985 through the enactment of the Grenada Industrial Development Corporation Act, the Grenada Industrial Development Corporation was established as the main national investment agency in Grenada.
The Grenada Industrial Development Cooperation (GIDC) is the main statutory body established by the government of Grenada, whose main purpose is to stimulate and facilitate the development of industry.
While the GIDC does not provide exemptions for the immigration rules as provided for by the laws of Grenada, the GIDC provides services to foreign investors, including acting as a ‘liaison’ service between potential investors and the government by assisting them to obtain work permits, alien land holding licences, land development and building permits, land leases, or such approvals or documentation as are necessary for carrying out business in Grenada.
Additionally Grenada offers a wide range of investment opportunities and the GIDC provides favourable investment incentives in key industry areas for business immigrants looking to start up business in Grenada.
It is important to note, however, that these incentives are geared towards attracting business immigrants to Grenada.
These incentive areas include:
- information communication technologies;
- health and education services;
- sporting facilities;
- tourism and hospitality services;
- agribusiness; and
- energy development.
II INTERNATIONAL TREATY OBLIGATIONS
As regards immigration and employment-related matters, Grenada is a signatory to two regional treaties: the Revised Treaty of Chagaramus and the Revised Treaty of Basseterre and several fundamental International Labour Organization (ILO) Treaties, tax information exchange agreements (TIEAs) and double tax conventions (DTCs) as of August 2014. Grenada is not a signatory to any of the UN treaties on refugees and stateless persons.
i Regional treaties
Revised Treaty of Chaguaramas
On 5 July 2001, Grenada signed the Revised Treaty of Chaguaramas that establishes the Caribbean Community, including the Single Market and Economy (CSME). This treaty provides for the free movement of persons, goods, services and capital within the CSME.
The Caribbean Community and Common Market (CARICOM) is an amalgamation of 15 Caribbean nations and dependencies, whose main aim is to encourage economic growth, integration and cooperation among its member states.
Citizens of CARICOM signatory states are considered to be CARICOM nationals and include nationals of Antigua and Barbuda, Barbados, Belize, Dominica, Grenada, Haiti, Jamaica, Suriname, and Trinidad and Tobago.
Further, Article 32.5(A) of the Revised Treaty of Chaguaramas establishes that ‘a person is also regarded as a national of a member state not only by being a citizen of that state but if he/she has a connection with the State of a kind which entitles him/her to be regarded as belonging to or being a native or resident of the State for the purpose of the laws thereof relating to immigration’.
In 1989, at the Grande Anse Declaration and Work Programme for the Advancement of the Integration Movement held at Grand Anse Grenada, under the tutelage of the heads of government of CARICOM member states, the CSME was founded. This was given effect by the Revised Treaty of Chaguaramas of 2001.
The key elements of the CSME include:
- free movement of goods and services;
- right of establishment;
- common external tariff;
- free circulation;
- free movement of capital;
- a common trade policy; and
- free movement of skills and labour.
Those defined under the CSME as eligible for the free movement of skills are:
- a university graduates;
- b holders of associate degrees or equivalent qualifications;
- c household domestics with a CVQ or equivalent qualification;
- d artisans with CVQ qualifications;
- e media workers;
- f artists;
- g musicians; and
- h sportspersons.
The free movement of skills and labour entails the right to seek employment in a member state and the elimination of the need for work permits and permits of authorisation.
However, while the right to unfettered movement exists, an important aspect of moving to another CARICOM member state for work purposes is the need for a certificate of recognition of CARICOM skills qualification, which can be obtained by a CARICOM national (eligible under one of the defined skill categories) applying to the ministry responsible for CARICOM affairs in his or her home country.8
While CARICOM, under the CSME, allows for the free movement of skills and labour for the purposes of gainful economic activity as a wage earner or non-wage earner across CARICOM member states, no such right to free movement exists regarding free movement across member states solely for the purposes of residency, citizenship or naturalisation.
If a CARICOM national wishes to migrate from one member state to another, he or she must still apply for residency or citizenship, subject to the residency or citizenship requirements of the intended country.
Revised Treaty of Basseterre
On 20 January 2011 Grenada signed the Revised Treaty of Basseterre establishing the Organisation of Eastern Caribbean States (OECS) Economic Union. This treaty provides for the free movement of persons, goods, services and capital within the OECS.
ii International treaties
Grenada ratified the following ILO treaties:
- the Right to Organise and Collective Bargaining Convention 1949 (No. 98) (9 July 1979);
- the Forced Labour Convention 1930 (No. 29) (9 July 1979);
- the Migration for Employment Convention (Revised) 1949 (No. 97) (9 July 1979);
- the Abolition of Forced Labour Convention 1957 (No. 105) (9 July 1979);
- the Freedom of Association and Protection of the Right to Organise Convention 1948 (No. 87) (25 October 1994);
- the Equal Remuneration Convention 1951 (No. 100) (25 October 1994);
- the Discrimination (Employment and Occupation) Convention 1958 (No. 111) (14 May 2003);
- the Minimum Age Convention 1973 (No. 138) (14 May 2003); and
- the Worst Forms of Child Labour Convention 1999 (No. 182) (14 May 2003).
Grenada has also ratified treaties concerning transparency and exchange of information for tax purposes. The island’s network of exchange of information arrangements comprises 19 bilateral agreements. Seventeen of these are covered by TIEAs (Aruba, Australia, Belgium, Denmark, Faroe Islands, Finland, France, Germany, Greenland, Iceland, Ireland, the Netherlands, Norway, Poland, Sweden, the United Kingdom and the United States and two by DTCs (South Africa and Switzerland).9
III THE YEAR IN REVIEW
Grenada in 2014 commenced processing citizenship by investment applications, which are intended to generate significant investment into the economy. The programme has experienced much growth and continues to advance, and this has been the catalyst for amendments to the Citizenship by Investment Act, including but not limited to the introduction of applications for Grenada citizenship by an applicant making a significant investment and amendments to the various government fees for the filing and processing of the citizenship application.
The significant investor change was intended to indicate to the significant investor that Grenada welcomes them and that they and their family can enjoy all that Grenada offers without restrictions and can operate their business, which will inject revenue into the Grenada economy.
The amendment of the fee structure brought the fee structure of the programme more in line with the cost of doing business in the jurisdiction of Grenada.
The Citizenship by Investment Programme is managed by an autonomous committee called the Citizenship by Investment Committee, which is a creature of statute established pursuant to Section 3 of the Citizenship by Investment Act. Applications are generally processed within 90 working days.
The requirements for the grant of citizenship under the Grenada citizenship by investment programme are as follows:
- a the main applicant must be at least 18 years of age;
- b applications must be made on the required forms legislated on by the Grenada Citizenship by Investment Regulations SRO 17 of 2013 together with certified copies of birth certificates, marriage or divorce certificates, colour copies of passports and identification cards, professional references and bank references;
- c police certificates must be provided;
- d the prescribed government fees must be paid pursuant to Grenada Citizenship by Investment (Amendment) (No. 2) Regulations SRO 38 of 2014; and
- e applicants are subject to a stringent due diligence process to ensure that all investors and prospective applicants meet the legal requirements.
The introduction of the citizenship by investment programme has allowed for the generation of economic growth and the injection of capital within Grenada and has been a contributing factor to meeting the austerity measures stipulated by the International Monetary Fund.
Apart from the introduction of and major change to the legislation governing the Citizenship by Investment programme, the law and policies regarding immigration remain generally the same and operate in the same way.
The Grenada Passport Office has introduced electronic permanent residence cards and the issuance of Grenada passports within 24 hours for an additional fee.
IV EMPLOYER SPONSORSHIP
There is no official sponsorship programme in Grenada. If an employer intends to employ a non-national, the employer will be responsible for making the requisite application for a work permit.
V INVESTORS, SKILLED MIGRANTS AND ENTREPRENEURS
There are three avenues for those wishing to engage in self-employed activities or establishing a business: economic citizenship via the Grenada Citizenship by Investment programme; acquisition of a work permit; and the right of establishment is provided for in Article 32 of the Revised Treaty of Chaguaramas and adopted into local law via the Caribbean Community (Movement of Factors) Act, the Caribbean Community Skilled Nationals Act and the CARICOM Enterprises Act. The OECS also has a right of establishment regime; however, it has not yet been fully implemented.
The right of establishment means that a national of a CARICOM member state has the right to:
- engage in any non-wage-earning activities of a commercial, industrial, agricultural, professional or artisanal nature; and
- create and manage economic enterprises, which include any type of organisation for the production of or trade in goods or the provision of services owned or controlled by a national or business entity of a member state in any member state.
The effect of this is that CARICOM nationals are free to establish or set up business enterprises without discrimination based on nationality.
Upon entry into the island a CARICOM national will be required to present the requisite documents to the immigration officers, including:
- a valid passport;
- proof of financial resources for personal maintenance, such as cash, travellers’ cheques or credit cards; and
- a return ticket.
Under the CSME a CARICOM national is entitled to a six-month stay in any member state.10
VI OUTLOOK AND CONCLUSIONS
Through the CBI programme, the issuance of work permits and alien land holding licences, Grenada encourages persons to reside within the jurisdiction and seeks to attract innovative foreign investments to stimulate the local economy.
Therefore, within the past year the government of Grenada has attempted to adhere to timelines for processing applications and documents and has not had increased fees for work permits and alien land holding licences.
Based on the policies of the government of Grenada, there is much stimulation and interest in Grenada for persons to retire, reside and establish businesses, which require and attract new skills to the island, thereby generating employment.
1 Sam M Bayat is the senior resident lawyer at Bayat Legal Services and Margaret Wilkinson is a partner at Wilkinson Wilkinson & Wilkinson. The information in this chapter was accurate as of May 2017.
2 Sections 5(1), 5(2), 5(3) and 5(3A) Immigration Act Chapter 145 of the 2010 Edition of the Continuous Revised Laws of Grenada.
3 Section 9 Immigration Act, Chapter 145 of the 2010 Edition of the Continuous Revised Laws of Grenada.
4 Section 24 Immigration Act, Chapter 145 of the 2010 Edition of the Continuous Revised Laws of Grenada.
5 Section 25 Immigration Act Chapter 145 of the 2010 Edition of the Continuous Revised Laws of Grenada.
6 Section 3 Foreign National and Commonwealth Citizens Act Chapter 145 of the 2010 Edition of the Continuous Revised Laws of Grenada.
7 Section 98, Grenada Constitution 1973.
8 https://caricom.org/skill-free-movement-in-the-caricom-single-market-and-economy-csme/ (last accessed on 13 April 2018).
9 www.keepeek.com/Digital-Asset-Management/oecd/taxation/global-forum-on-transparency-and-exchange-of-information-for-tax-purposes-peer-reviews-grenada-2014_9789264223035-en#.VTfraCFVikp#page9 (last accessed on 13 April 2018).
10 The Right of Establishment, a publication of the Caribbean Community Secretariat 2010.