Dominica Faces Criticism for Inadequate Fight Against Money Laundering and Terrorist Financing

A recent evaluation by international authorities has revealed that Dominica is struggling to effectively combat money laundering (ML) and terrorist financing (TF). The country’s Financial Intelligence Unit (FIU) was praised for its quality of disseminations, but criticized for lacking sufficient feedback on the outcome and quality of its work.

Money Laundering

• ML investigations in Dominica are often triggered by disseminations from the Analytical Department, but the number of these disseminations can be improved.
• The country’s FIU conducts strategic analysis, but fails to reflect all higher-risk areas identified in the National Risk Assessment (NRA).
• While Dominica has demonstrated instances of investigations and prosecutions, the extent is not commensurate with its risk profile. The country takes a reactive rather than proactive approach to identifying ML and lacks prioritization of ML cases within the judicial system, hampering successful prosecution.
• Confiscation of criminal proceeds in Dominica is also criticized, stating that while there is a sound legal framework, it is not being effectively enforced.

Terrorist Financing

• The country’s efforts against TF have been criticized, with no prosecutions or convictions secured during the review period.
• Dominica lacks a national Counter-Financing of Terrorism (CFT) policy, which would continuously assess the TF threat and identify requirements for training and professional development of authorities.
• While some progress has been made in implementing UN Security Council Resolution 1267 and 1373, the Central Authority procedures are deficient.

Recommendations

• Improve the quality and frequency of disseminations from the Analytical Department to trigger ML investigations.
• Ensure that the FIU reflects all higher-risk areas identified in the National Risk Assessment (NRA) in its strategic analysis.
• Prioritize ML cases within the judicial system and take a proactive approach to identifying ML.
• Enforce confiscation of criminal proceeds effectively, using alternative measures such as cash confiscation only when necessary.

Conclusion

While some progress has been made in implementing anti-money laundering and combating the financing of terrorism measures, significant work remains to be done. Dominica must address these shortcomings to effectively combat money laundering and terrorist financing.