Money Laundering/ Terrorist Financing Risks in The Bahamas: Key Findings
General Awareness and Training Needs
The following key findings highlight the need for improved awareness and training among Financial Institutions (FIs) and Designated Non-Financial Businesses and Professions (DNFBPs) in The Bahamas:
- Limited course of action: FIs typically conduct specific ML/TF risk assessments, but there is a lack of awareness about what to do when designated persons or entities on TFS lists are detected.
- Understanding of TF and PF risks: DNFBPs have limited understanding of TF and PF risks, indicating a need for training on updated FATF standards and obligations.
Regulatory Environment
The Bahamas’ regulatory environment has implemented various measures to address ML/TF risks:
- Licensing and registration requirements: Licensing and registration requirements adequately limit the possibility of criminals entering the financial sector.
- Supervision collaboration: Financial supervisors collaborate well on AML/CFT issues, exchanging relevant information and conducting joint onsite visits.
Supervision
The following key findings highlight areas for improvement in supervision:
- Onsite examinations: Onsite examinations by financial and DNFBP supervisors include ML/TF issues but need to be more risk-sensitive and focused on mitigating AML/CFT risks.
- Remedial actions: Remedial actions taken by financial supervisors are often characterized by a ‘one size fits all’ approach, with a low number of sanctions imposed.
Transparency of Legal Persons and Arrangements
The Bahamas has implemented various measures to ensure transparency in legal persons and arrangements:
- Entity incorporation: The Bahamas can incorporate various types of entities, but there is some level of ML/TF risk associated with inactive entities.
- Beneficial ownership information: Basic and beneficial ownership information is maintained by the Registrar General in The Bahamas.
- Sanctions effectiveness: While sanctions have been applied to legal persons, it is unclear whether they are effective, proportionate, and dissuasive.