Financial Crime World

Dominica’s Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Framework

Money Laundering (ML)

  • Dominica’s Financial Intelligence Unit (FIU) conducts strategic analysis, but it does not sufficiently reflect all higher-risk areas identified in the National Risk Assessment (NRA).
  • The country has demonstrated instances of ML investigations and prosecutions, but the extent is not commensurate with its risk profile.
  • A reactive approach to identifying ML cases, particularly those involving professional networks, cash smuggling, complex schemes, and legal persons.

Confiscation of Criminal Proceeds

  • Dominica has a sound legal framework for freezing, seizing, and confiscating instrumentalities and proceeds of crimes.
  • However, the system is not being effectively enforced, as the proportion of non-declared or falsely declared cash or Bank Notes in Transit (BNIs) that are confiscated is low.

Terrorist Financing (TF)

  • Dominica has a strong legal framework for the criminalization of TF, but its NRA did not consider several TF vulnerabilities.
  • The country deemed the risk of TF to be “low,” but the analysis was not exhaustive.
  • Authorities have not prosecuted any cases related to TF in the period under review.

Terrorist Financing Sanctions (TFSS)

  • Dominica has updated its legal framework required by UN Security Council Resolutions 1267 and 1373.
  • However, the Central Authority procedures do not accurately distinguish between requirements under the two resolutions.
  • The Freezing Mechanism is also deficient.

National CFT Policy

  • Dominica lacks a national CFT policy that would continuously assess the TF threat and identify training and professional development needs for competent authorities.

Conclusion

While Dominica has made progress in its AML/CTF framework, there are areas of concern, including a lack of proactive approach to identifying ML cases, ineffective enforcement of confiscation measures, and inadequate consideration of TF vulnerabilities. Addressing these concerns will be crucial to strengthening the country’s AML/CTF regime.