Financial Crime World

Anti-Money Laundering (AML) and Combating Terrorist Financing (CFT) Efforts in Dominica: A Comprehensive Assessment

Executive Summary

This report provides a comprehensive assessment of Dominica’s anti-money laundering (AML) and combating terrorist financing (CFT) efforts. The assessment highlights areas where improvements are needed to strengthen the country’s regime.

Risk Assessment and Investigations

  • Risk Profile: Dominica’s risk profile is not fully commensurate with the number of money laundering (ML) investigations, prosecutions, and convictions.
  • Investigations and Prosecutions: While there have been instances of ML investigations and prosecutions, the extent of these efforts does not match Dominica’s risk profile.

Investigations and Prosecutions

  • Money Laundering Cases: Dominica has demonstrated instances of ML investigations and prosecutions, but the number is limited compared to its risk profile.
  • Prosecution Rate: The prosecution rate for ML cases in Dominica is relatively low, indicating a need for improvement.

Confiscation of Proceeds

  • Policy Objective: Confiscation of criminal proceeds is pursued as a policy objective in Dominica.
  • Declaration System: However, the declaration system for cross-border movements of cash or bank notes is not being effectively enforced.

Terrorist Financing (TF)

  • Legal Framework: Dominica has a strong legal framework for the criminalization of TF.
  • Vulnerabilities: The National Risk Assessment (NRA) did not consider several TF vulnerabilities.
  • Prosecution Rate: No cases have been prosecuted related to TF in the period under review.

Central Authority Procedures

  • Broad Powers: CAs are equipped with broad powers to obtain financial information for identifying and investigating TF cases.
  • National CFT Policy: However, a national CFT policy is lacking, which hinders the country’s ability to effectively combat TF.

Traveler’s Checks (TFS)

  • Updated Legal Framework: Dominica has updated its legal framework required by UNSCR 1267 and 1373.
  • Central Authority Procedures: However, the Central Authority procedures do not accurately distinguish between what is required under the two resolutions.

Recommendations for Improvement

  1. Enhancing ML Investigations and Prosecutions: To better match Dominica’s risk profile.
  2. Improving Confiscation of Proceeds: Through effective enforcement of the declaration system for cross-border movements of cash or bank notes.
  3. Strengthening TF Measures: By addressing vulnerabilities and conducting a comprehensive sector review of non-profit organizations (NPOs).
  4. Developing a National CFT Policy: To continuously assess the TF threat, identify requirements for training and professional development of CAs, and allow for the development of policies by CAs.
  5. Providing Guidance on TFS Obligations: To FIs or DNFBPs on their obligations under the SFTA.

Overall, this report provides a comprehensive assessment of Dominica’s AML/CFT efforts and highlights areas where improvements are needed to strengthen its regime.