Dominica’s Efforts to Combat Money Laundering and Terrorist Financing Laudable, but More Work Needed

A recent assessment by international experts has highlighted Dominica’s commitment to combating money laundering (ML) and terrorist financing (TF), but also identified areas that require further attention.

Progress Made

The report noted that Dominica’s National Policy and Strategy on Anti-Money Laundering and Combating the Financing of Terrorism (2019-2024) is a positive development, which has led to increased coordination and cooperation among authorities. The country has also made progress in developing its financial intelligence capabilities, with the Financial Intelligence Unit (FIU) playing a key role in enriching financial information.

Areas for Improvement

However, the report also identified some areas that require improvement. For instance:

• While Dominica’s systems for vetting citizenship by investment applications are stringent, there is a need to analyze ML/TF and corruption risks associated with this program.
• The country was found to be lacking in its assessment of TF vulnerabilities, with several sectors and activities not being assessed, including:
  • Cross-border wire transfers
  • Non-profit organizations (NPOs)
  • Legal persons
  • Virtual asset service providers (VASPs)

Recommendations for Strengthening Efforts

To address these challenges, the report recommends:

• Conduct a comprehensive sector review of NPOs to inform the country’s assessment of TF risk.
• Develop 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.
• Implement effective, dissuasive, and proportionate sanctions for TF-related offenses.
• Provide more training and guidance on TFS requirements for regulated entities.
• Conduct a thorough analysis of ML/TF and corruption risks associated with citizenship by investment applications.

Conclusion

Overall, while Dominica has made some progress in combating ML and TF, there is still much work to be done to address the identified vulnerabilities and risks. The government and competent authorities must continue to prioritize this issue and take concrete steps to strengthen their efforts. By addressing these recommendations, Dominica can further strengthen its efforts to combat ML and TF, and ensure that the country’s financial system is transparent, secure, and resilient.