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Dominica’s Financial Sector Faces Low Money Laundering and Terrorist Financing Risk Profile

A recent assessment by international experts has confirmed that Dominica’s financial sector faces a low risk profile when it comes to money laundering (ML) and terrorist financing (TF). The country’s commitment to developing its national strategy and policy setting is seen as a positive step forward.

Cooperation and Coordination Boost Control Framework

The assessors noted significant coordination and cooperation between the Financial Intelligence Unit (FIU), law enforcement agencies, and other stakeholders. This has led to enhanced control framework and interdiction efforts.

CBI Program Remains Crucial to Economy

While the Citizenship by Investment (CBI) program is a key contributor to Dominica’s economy, accounting for 30% of GDP, the assessors highlighted that ML/TF and corruption risks associated with the program were not fully analyzed during the review period.

Realignment of National Policy Needed

To ensure that the threats, sectoral vulnerabilities, and TF risks are adequately addressed, a realignment of Dominica’s national policy is necessary. This will involve a comprehensive assessment of NPOs, legal persons, VASPs, and cross-border wire transfers.

TF Prosecutions Lacking

Despite having a strong legal framework for criminalizing TF, Dominica has not prosecuted any cases related to TF in the review period. The absence of convictions for TF raises concerns about the effectiveness and proportionality of sanctions.

Training and Professional Development Needed

To effectively combat TF, CAs require training and professional development. However, Dominica lacks a national CFT policy that would continuously assess the TF threat, identify requirements for training, and allow for the development of policies by CAs.

TFS- TF Implementation Lags

The implementation of TFS-TF without delay is critical. While Dominica has updated its legal framework and developed Central Authority procedures, the procedures do not accurately distinguish between what is required under UNSCR 1267 and 1373. The FSU as primary supervisory authority has implemented training to regulated entities on TFS requirements, but guidance on TFS obligations to FIs and DNFBPs is still lacking.

Sector Review of NPOs Needed

A comprehensive sector review of NPOs is necessary to inform Dominica’s assessment of TF risk. The FSU, supervisor of NPOs, must implement a targeted approach, outreach, or oversight of the sector.

In conclusion, while Dominica’s financial sector faces a low ML/TF risk profile, there are still areas that require attention and improvement to ensure effective combating of ML/TF and TF.