Caribbean Financial Action Task Force Report on Dominica’s Anti-Money Laundering/Combating the Financing of Terrorism Regime
Executive Summary
This report provides an assessment of Dominica’s efforts to combat money laundering, terrorist financing, and proliferation financing. The Caribbean Financial Action Task Force (CFATF) has evaluated the country’s Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) regime and identified areas where improvement is needed.
Key Findings
Money Laundering
- Reactive approach: Dominica has a reactive approach to identifying and investigating money laundering cases, which is not commensurate with its risk profile.
- Investigations: While investigations have been conducted, the number of cases is insufficient compared to the country’s risk profile.
Terrorist Financing
- Strong legal framework: Dominica has a strong legal framework for criminalizing terrorist financing, but its National Risk Assessment (NRA) did not consider several vulnerabilities.
- Prosecutions and convictions: There have been no prosecutions or convictions for terrorist financing in the period under review.
Confiscation of Proceeds
- Sound legal framework: Dominica has a sound legal framework for freezing, seizing, and confiscating instrumentalities and proceeds of crimes.
- Ineffective enforcement: However, the declaration system for cross-border movements of cash or bank notes is not being effectively enforced.
Terrorist Financing Regime
- Up-to-date legal framework: Dominica’s legal framework for terrorist financing is up to date, but the Central Authority procedures do not accurately distinguish between what is required under UNSCR 1267 and 1373.
National Policy on CFT
- Lack of national policy: Dominica lacks a national CFT policy that would continuously assess the TF threat, identify requirements for training and professional development of competent authorities (CAs), and allow for the development of policies by CAs.
Areas for Improvement
- Enhance proactive approach to money laundering cases
- Strengthen terrorist financing regime
- Improve confiscation of proceeds system
- Provide training on TF risks and vulnerabilities in NPOs
The CFATF will continue to monitor Dominica’s progress in addressing these deficiencies and may recommend further action if necessary.