Financial Crime World

Assessment of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Measures in Dominica

Executive Summary

The report highlights several areas where Dominica needs improvement in its AML/CFT measures. While some progress has been made, there are still concerns regarding the effectiveness of these measures.

Areas for Improvement in AML Measures

Inadequate AML/CFT Investigations

  • The report notes that while some ML investigations and prosecutions were demonstrated, they do not fully align with Dominica’s risk profile.
  • This may hinder the detection of complex cases involving professional networks or cash smuggling.

Limited Proactive Approach to ML Identification

  • Dominica takes a reactive approach to identifying money laundering cases.
  • This may lead to missed opportunities for early intervention and prevention.

Insufficient Prioritization of ML Cases in the Judicial System

  • The successful prosecution of cases to convictions is hampered by insufficient prioritization of ML cases in the judicial system.

Weak Enforcement of Confiscation of Criminal Proceeds

  • The proportion of non-declared or falsely declared cash or business assets that are confiscated is low.

Inadequate TF Risk Assessment

  • Dominica’s National Risk Assessment (NRA) did not consider several terrorist financing vulnerabilities, including cross-border wire transfers, Non-Profit Organizations (NPOs), and legal persons.

Areas for Improvement in CTF Measures

Lack of National CFT Policy

  • The jurisdiction lacks a national CFT policy that would continuously assess the TF threat, identify requirements for training and professional development of competent authorities, and allow for the development of policies by these authorities.

Inadequate Implementation of TFS-TF without Delay

  • Dominica’s Central Authority procedures do not accurately distinguish between what is required under UNSCR resolutions 1267 and 1373, and the freeze without delay mechanism is deficient.

Conclusion

While Dominica has made progress in implementing AML/CFT measures, there are areas where further improvement is needed to effectively prevent money laundering and terrorist financing.