Financial Crime World

Title: Dominica Strengthens Financial Compliance Framework against Money Laundering and Terrorist Financing

CFATF Evaluates Dominica’s Progress in AML/CTF Regime

Dominica, a Caribbean nation, has made significant strides in enhancing its Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regime. The progress was outlined in the Mutual Evaluation Report issued by the Caribbean Financial Action Task Force (CFATF) in July 2023.

  • The CFATF is an inter-governmental body consisting of 24 member states.
  • They evaluated Dominica’s progress in implementing the FATF 40 Recommendations.

Key Findings and Recommendations

According to the report, Dominica identified the following as primary ML/TF risks:

  1. Drug trafficking
  2. Firearm trafficking
  3. Fraud/ATM scams

The report recommended:

  • A more comprehensive risk assessment
  • Focusing on sectors like legal persons, non-profit organizations (NPOs), virtual asset service providers (VASPs), and the Citizenship by Investment (CBI) program

Improvements and Cooperation

Dominica has taken steps to strengthen its AML/CTF framework:

  1. Through the National Anti-Money Laundering Advisory Committee (NAMLAC) and its sub-committees, key competent authorities (CAs) and agencies have:
    • Enhanced cooperation and coordination
    • Implemented legislative and regulatory changes
    • Provided staff training
    • Improved domestic coordination and cooperation

Financial Intelligence and ML Investigations

Significant improvements have been made in financial intelligence and ML investigations:

  1. Dominica’s Financial Intelligence Unit (FIU) has:
    • Increased human and technical resources
    • Received more Suspicious Transaction Reports (STRs)
    • Improved investigations and prosecutions of ML offenses

However, there’s still room for improvement:

  • Not all ML investigations are fully consistent with the country’s risk profile

Areas for Improvement

Areas of concern for Dominica include:

  1. TF risks: Understanding and implementing requirements related to TF risks
  2. DNFBPs: Clarification and improvements in the regulation of Designated Non-Financial Businesses and Professionals (DNFBPs)
  3. Beneficial Ownership Information: Making beneficial ownership information more readily available on legal persons and arrangements

Conclusion

Dominica has demonstrated progress in strengthening its AML/CTF framework, but work still needs to be done:

  • Addressing concerns related to understanding and implementation of TF risks
  • Clarifying and improving regulations for DNFBPs
  • Ensuring the availability of beneficial ownership information on legal persons and arrangements

By addressing these areas, Dominica will be well-equipped to combat ML/TF effectively and maintain the integrity of its financial system.