Financial Crime World

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Dominica’s Efforts to Combat Money Laundering and Terrorist Financing Receive Mixed Assessment

A recent assessment by international experts has highlighted both strengths and weaknesses in Dominica’s efforts to combat money laundering (ML) and terrorist financing (TF). While the country has made significant progress in developing a strong legal framework and implementing various initiatives, there are still areas that require improvement.

Comprehensive Risk Assessments Needed

The assessment noted that more work is required to understand related risks, including:

  • A comprehensive ML/TF assessment of non-profit organizations (NPOs)
  • Legal persons
  • Virtual asset service providers (VASPs)
  • Cross-border wires
  • The Citizenship by Investment (CBI) programme

Additionally, updated FI and DNFBP sectoral risk assessments are needed to enhance the country’s understanding of its ML/TF risk profile.

National Policy and Strategy Framework

Dominica has made significant strides in developing a national policy and strategy framework, which includes:

  • A strong legal framework for criminalizing TF
  • However, several TF vulnerabilities were not assessed during the review period, including:
    • Cross-border wire transfers
    • NPOs
    • Legal persons
    • VASPs

Prosecutions and Convictions

The assessment revealed that no cases relating to TF have been prosecuted in Dominica since the last review period. Seven cases were investigated, with six being closed and one remaining case considered for ML prosecution.

The absence of prosecutions and convictions for TF appears to be in line with identified risk-profile of the jurisdiction.

CFT Policy

The assessment noted that Dominica lacks a national CFT policy that would:

  • Continuously assess the TF threat
  • Identify requirements for training and professional development of authorities
  • Allow for the development of policies by authorities which would be in line with this national CFT policy

TFS-TF Implementation

Dominica has updated its legal framework required by UNSCR 1267 and 1373 and developed Central Authority procedures. However, the assessment noted that:

  • The Central Authority procedures do not accurately distinguish between what is required under the two UNSCR resolutions
  • The freeze without delay mechanism is also deficient

Recommendations

The assessment provided several recommendations for Dominica to improve its ML/TF combating efforts, including:

  • Conducting a comprehensive sector review of NPOs to inform the country’s assessment of TF risk
  • Implementing targeted outreach, oversight, or training for supervisors and authorities responsible for monitoring NPOs
  • Providing guidance on TFS requirements to FIs and DNFBPs
  • Issuing specific training on TF risks and vulnerabilities in NPOs

Overall, while Dominica has made significant progress in developing a strong legal framework and implementing various initiatives, there are still areas that require improvement. The country must continue to work towards strengthening its ML/TF combating efforts to ensure compliance with international standards.