An Exclusive IMGW News Report – Saint George’s, Grenada – 16 & 19 June 2025 (Updated)
Grenada’s Citizenship-by-Investment (CBI) programme has entered a new chapter of regulatory reform, as the country’s Investment Migration Agency (IMA) lifts its suspension on marketing agent Heng Sheng (Grenada) Development Pte. Ltd. (Heng Sheng) and Grenada National Resort (GNR) Approved Project following a three-month investigation.
While the agency found no evidence of direct owner-financing by Heng Sheng, it identified some irregularities in certain applications from sub-agents. The case has sparked a broader compliance reset, particularly in relation to sub-agent oversight.
Resort construction has continued uninterrupted, with our design, engineering, and build teams achieving weekly targets. Our monthly updates are available on the HSG website.
Around Zhou, Director of Business Development for the Grenada National Resort.
Reinstatement Under Stricter Oversight
Through Circular No. 6 of 2025, the IMA confirmed the partial reinstatement of Heng Sheng’s operations. The company may resume processing CBI applications, provided that all funds originate from independently verified sources and there is no evidence of unauthorised price discounting or third-party deposits.
Applications flagged for financial inconsistencies – particularly those involving sub-agent activity – are being returned for remediation. Applicants must re-submit with credible documentation confirming the independence of their financial means. In addition, the IMA has introduced Tier-2 interviews for flagged applicants and mandated new forms, including Attestation and Bank Credit Advice documentation.
“The Heng Sheng episode underscores the increasing pressure on Caribbean CBI jurisdictions to tighten oversight, eliminate non-compliant sales practices, and restore investor confidence”
Heng Sheng has removed 25 sub-agents for failing to comply with the IMA’s compliance requirements. The IMA has also stated that Heng Sheng and the Grenada National Resort will bear all additional compliance and due diligence costs.
Heng Sheng Responds
To gain deeper insight into Heng Sheng’s position following its reinstatement, IMGW News Editor-in-Chief Ray de Bono sat down with Around Zhou, Director of Business Development for the Grenada National Resort.
Q&A with Around Zhou, Business Development Director for Grenada National Resort
1. Now that Grenada’s IMA has reinstated your CBI application processing under enhanced compliance measures, how would you describe the company’s current position and priorities?
💬 Around Zhou, HSG: Our priorities are clear: first, to continue hitting our construction milestones at the Grenada National Resort, a landmark new development for the Caribbean, and second, to maintain the highest standards of integrity, transparency, and compliance. Resort construction has continued uninterrupted, with our design, engineering, and build teams achieving weekly targets. Our monthly updates are available on the HSG website.
2./3. Have there been any key internal adjustments or improvements Heng Sheng has implemented in response to the concerns raised earlier this year? As investigations remain ongoing, how is Heng Sheng engaging with regulators to ensure transparency and best practices moving forward?
💬 AZ: Firstly, we maintain an active and regular dialogue with the IMA and fully endorse its enhanced due diligence measures, including the new Attestation Form and Bank Credit Advice requirements.
Secondly, HSG has established a dedicated compliance task force to ensure seamless alignment with IMA regulations and to uphold the highest standards across our agent network. It’s important to note that the IMA made it very clear last week at its Local and Marketing Agents Meeting on the subject of Circular 6 (held on 11 June) that no financial irregularities were found at the Heng Sheng level. Regarding our removal of 25 sub-agents, this was done due to the sub-agents’ inability to comply with IMA regulations.
Thirdly, and most significantly, we’ve developed a comprehensive proposal for an Independent Compliance Initiative for Grenada’s CBI program. This proposal includes three key components: an independent third-party auditor to verify all compliance processes; standardised due diligence protocols that exceed current requirements; and regular public reporting to ensure full transparency.
We look forward to presenting this framework to the IMA for discussion at the earliest opportunity.
4. Could you share any updates on the Grenada National Resort project or other future plans Heng Sheng is pursuing within the investment migration space?
💬 AZ: Progress on the Grenada National Resort continues at an impressive pace and we’re well on our way to completing this landmark development for Grenada. Resort construction has continued uninterrupted, with our design, engineering and build teams achieving weekly targets. Our monthly updates are available on the HSG website.
Broader Industry Implications
The Heng Sheng episode underscores the increasing pressure on Caribbean CBI jurisdictions to tighten oversight, eliminate non-compliant sales practices, and restore investor confidence. Grenada’s firm response and procedural enhancements may serve as a reference point for other nations seeking to uphold the integrity of their programmes.
IMC Lifts Suspension of Heng Sheng’s Membership Following Grenada’s Decision
In a recent development, the Investment Migration Council (IMC) has lifted its suspension of Singapore Heng Sheng (Grenada) Development Pte. Ltd’s membership. This decision follows the resolution outlined in Circular No. 6 of 2025 by IMA Grenada on 4 June 2025. Initially suspended on 8 April 2025 under the guidelines of Circular No. 3 of 2025, the IMC now considers the matter resolved and closed, effective immediately.
