Investors with ties to foreign governments or state entities will be automatically ineligible for Samoa’s Citizenship by Investment (CBI) programme, according to the Acting Chief Executive Officer of the Ministry of Commerce, Industry and Labour (MCIL), Fuimaono Christopher Smith.

Fuimaono said the due diligence framework under the Citizenship Investment Act 2015 gives the Citizenship Investment Committee “full authority to investigate any matter relevant to an applicant’s background.”

“The Citizenship Investment Regulations 2016 explicitly mandate that this investigation must utilise intelligence from both formal government and local, on-the-ground sources,” he said.

He added that the legal requirement is designed to uncover the true ownership of companies and confirm any state involvement. Discovering state ownership, Fuimaono said, is treated as a direct security risk and automatically disqualifies an applicant under national integrity rules.

Fuimaono confirmed that oversight of the programme rests with the Citizenship Investment Committee, established under Section 12 of the Citizenship Investment Act 2015. The committee includes five senior public officials who serve by virtue of their government positions: the Chief Executive Officer of the Ministry of Finance, Saoleititi Maeva Betham-Vaai.

The Chief Executive Officer of the Ministry of Customs and Revenue, Fonoti Talaitupu Li‘a Taefu.

The Chief Executive Officer of the Ministry of the Prime Minister and Cabinet, Agafili Tomaimanō Shem Leo.

The Governor of the Central Bank of Samoa, Maiava Atalina Emma Ainuu-Enari.

The CEO of MCIL chairs the committee, though that position is currently vacant, with recruitment being finalised through the Public Service Commission.

Fuimaono said the committee members are ex officio, meaning they automatically hold their seats due to their senior government roles rather than political appointments.

According to the CBI Draft Policy Framework, the government supports adding immunity clauses to protect officials who make good-faith decisions. The measure would shield committee members from personal liability and allow them to act decisively without fear of frivolous lawsuits.

“The members are not appointed in the traditional sense,” Fuimaono said. “They are ex officio members, meaning they sit on the committee automatically because of the high-ranking government positions they hold. There is no separate selection process detailed in the Act.”