Dominica’s Fight Against Money Laundering and Terrorist Financing Leaves Much to Be Desired

A recent review of Dominica’s efforts to combat money laundering (ML) and terrorist financing (TF) has raised concerns about the quality of its disseminations and the effectiveness of its anti-money laundering (AML) and counter-terrorism financing (CFT) measures.

Concerns with Money Laundering Efforts

The review found that while Dominica has made some progress in identifying ML investigations and prosecutions, the number of these cases is not commensurate with the country’s risk profile. The country takes a reactive approach to identifying ML, rather than being proactive, and as a result:

• Complex schemes involving professional networks and cash smuggling are not being detected.
• There is a lack of prioritization within the judicial system, which hampers the successful prosecution of cases to convictions.

Concerns with Confiscation of Criminal Proceeds

The review also highlighted concerns about the confiscation of criminal proceeds, noting that:

• While there is a sound legal framework in place, the system for freezing, seizing, and confiscating assets is not being effectively enforced.
• ML cases are not prioritized within the judicial system.

Concerns with Terrorist Financing

The review noted that Dominica has a strong legal framework in place to combat TF, but that:

• The country’s risk assessment did not consider several vulnerabilities, including cross-border wire transfers and non-profit organizations (NPOs).
• No TF cases have been prosecuted or convicted during the period under review.
• There is a lack of criminal justice, regulatory, and other measures to disrupt TF.

Concerns with Counter-Terrorism Financing Policy

The review highlighted concerns about the effectiveness of Dominica’s CFT policy, noting that:

• While there are broad powers in place for financial information gathering, there is no national CFT policy to continuously assess the TF threat or identify requirements for training and professional development.

Conclusion

While Dominica has made some progress in combating ML and TF, there are significant gaps and weaknesses in its AML/CFT regime. To improve its efforts, the country’s authorities must:

• Take a more proactive approach to identifying ML cases.
• Prioritize ML investigations.
• Implement effective measures to disrupt TF.
• Strengthen its legal framework for confiscation of criminal proceeds.
• Develop a national CFT policy to continuously assess the TF threat and identify requirements for training and professional development.