Financial Crime World

FATF Assessment of Dominica’s Anti-Money Laundering Regime

The Financial Action Task Force (FATF) has assessed Dominica’s anti-money laundering (AML), combating the financing of terrorism (CFT), and proliferation financing (PF) regime. Here are some key points from the report:

Money Laundering (ML)

  • Reactive Approach: Dominica takes a reactive rather than proactive approach to identifying money laundering.
  • Lack of Prioritization: Money laundering cases are not prioritized within the judicial system, hindering successful prosecution.
  • Confiscation Measures: The confiscation of criminal proceeds is pursued as a policy objective, but alternative measures like cash confiscation are used extensively.

Terrorist Financing (TF)

  • Strong Legal Framework: Dominica has a strong legal framework for the criminalization of TF.
  • Low Risk Assessment: However, the National Risk Assessment (NRA) deemed the risk of TF to be “low,” despite not considering several TF vulnerabilities.
  • No Prosecutions: Authorities have not prosecuted any cases related to TF in the period under review.

Terrorist Financing and Proliferation Financing (TF-PF)

  • Regulatory Framework: Dominica has updated its legal framework required by UNSCR 1267 and 1373, but the Central Authority procedures are deficient.
  • Training and Awareness: Regulated entities have demonstrated an awareness of TFS requirements, but specific training has not been provided on TF risks and vulnerabilities in NPOs.

National Risk Assessment (NRA)

  • Limited Assessment: The NRA did not capture several sectors and activities, including cross-border wire transfers, NPOs, legal persons, and VASPs.
  • TF Vulnerabilities: Dominica deemed the risk of TF to be “low,” but several TF vulnerabilities were not considered.

Recommendations

Based on this report, some potential recommendations for Dominica could include:

  • Enhancing its AML/CFT framework to address identified gaps and vulnerabilities.
  • Improving prioritization and prosecution of ML cases within the judicial system.
  • Conducting a comprehensive sector review of NPOs to inform the country’s assessment of TF risk.
  • Providing specific training on TF risks and vulnerabilities in NPOs for regulated entities.
  • Implementing effective measures to freeze and confiscate assets of designated persons.

These are just some potential recommendations based on the report, and actual actions would depend on Dominica’s specific circumstances and priorities.