Mutual Evaluation Report of St. Kitts and Nevis

Caribbean Financial Action Task Force (CFATF)

Assessment of Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Measures

This report assesses the implementation of AML/CFT measures in St. Kitts and Nevis, highlighting key findings and recommendations for improvement.

Current System: The Financial Intelligence Unit (FIU) is overseen by an external officer employed by the Ministry of Finance.
Security Concerns: This setup raises concerns about data confidentiality and independence.
Recommendation: Ensure that the FIU is independently managed and overseen to maintain data confidentiality and integrity.

Investigation Numbers: There have been low levels of ML investigations, with only six investigations in 2019 and 2020, and two for the first three months of 2021.
Predicate Offences Comparison: A comparison of predicate offences for 2019 and 2020 with ML investigations highlights a low level of ML investigations.
Recommendation: Increase the number of ML investigations by providing adequate resources and training for investigators at the WCCU.

Prosecution Numbers: There were eight prosecutions before the court for self-laundering ML, but no convictions in St. Kitts and Nevis.
Assessment: It is impossible to assess the effectiveness, proportionality, and dissuasiveness of sanctions without convictions.
Recommendation: Strengthen prosecutions for ML by implementing a dedicated unit within the WCCU or DPP for conducting confiscation proceedings and asset forfeiture under POCA.

Confiscation Rates: Confiscation of proceeds and instrumentalities of crime is exceptionally low in St. Kitts and Nevis.
Cross-Border Reports: The CED has limited experience in asset recovery with foreign counterparts, either for proceeds of foreign predicates located in the jurisdiction or proceeds from domestic predicates laundered outside St. Kitts and Nevis.
Recommendation: Improve asset recovery efforts by increasing the number of cases where major predicate offences have been identified, and assets are available for confiscation in the event of a conviction.

Based on these findings, the CFATF recommends that St. Kitts and Nevis: