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Dominica’s Efforts to Combat Money Laundering and Terrorist Financing Fall Short
A recent report by [agency] has highlighted several areas where Dominica needs to improve its efforts to combat money laundering (ML) and terrorist financing (TF).
Positive Developments
While the country’s National Policy and Strategy on Anti-Money Laundering and Combating the Financing of Terrorism (2019-2024) is a positive development, more work is required to understand related risks.
Areas for Improvement
The report identified several areas where Dominica needs to improve:
- Comprehensive Assessment: A comprehensive assessment of non-profit organizations (NPOs), legal persons, virtual asset service providers (VASPs), cross-border wire transfers, and the Citizenship by Investment (CBI) programme is needed.
- CBI Programme: The CBI programme, which has contributed significantly to the country’s economy, was not thoroughly assessed in the report.
Control Framework
The report noted that Dominica’s control framework has been enhanced through:
- Coordination and cooperation between authorities
- Development of memoranda of understanding (MOUs)
- Joint operations
- Increased information sharing
- Purchase of detection equipment
Terrorist Financing Risks
In terms of TF, the report found that Dominica has a strong legal framework for criminalizing the financing of terrorism, but there are several vulnerabilities that need to be addressed. The country deemed its risk of TF as “low,” but the analysis performed did not consider several sectors and activities, including:
- Cross-border wire transfers
- NPOs
- Legal persons
- VASPs
Prosecution of Cases
The authorities have not prosecuted any cases relating to TF in the period under review.
National Policy on Combating Financing of Terrorism
There is a lack of national policy on combating the financing of terrorism.
Training and Oversight
Regulated entities have demonstrated an awareness of TF requirements, but there is a need for specific training on TF risks and vulnerabilities in NPOs. The supervisor of NPOs has not implemented a targeted approach, outreach, or oversight of that sector.
Conclusion
Overall, while Dominica has made some progress in combating ML and TF, more work needs to be done to address the identified vulnerabilities and improve its efforts in this area.