Title: FinCEN Issues Warning to US Financial Institutions About Money Laundering Risks in Dominica

Overview

July 2021 – The Financial Crimes Enforcement Network (FinCEN) of the United States Department of the Treasury has renewed its advisory to American financial institutions regarding potential money laundering risks in the Commonwealth of Dominica.

FinCEN’s Advisory (Issue 21-1)

• Issued: July 2021
• Updated: Originally issued in July 2000
• Purpose: Warn financial institutions about increased money laundering risks associated with Dominica

About Dominica

• Population: Approximately 65,000
• Location: Between Caribbean Sea and North Atlantic Ocean
• Economy: Significant agricultural exports and offshore financial sector
• Financial Hub: Significant player in the Caribbean offshore financial sector

Money Laundering Concerns

Despite certain positive aspects of its laws and regulations, Dominica’s legal, supervisory, and regulatory systems offer opportunities for criminals:

1. Lack of Explicit Money Laundering Laws

   • Laws exist only against money laundering related to narcotics trafficking

2. Inadequate Offshore Bank Supervision

3. Anonymous Accounts in Offshore Banks

4. Refusal to Report Suspicious Transactions

5. Bearer Shares and Secrecy Laws

   • Issued by International Business Companies (IBCs)

FATF Classification

• Categorized as non-cooperative country in fighting money laundering

Recommendations for US Financial Institutions

• Increased scrutiny of transactions originating from/routed through Dominica
• Report any suspicious transactions ($5,000 threshold)
• Visit FinCEN’s website, contact communications office, or fax queries for more information

Legitimate Business Dealings

The advisory issuance doesn’t restrict legal business dealings with Dominica. US officials stand ready to provide technical assistance to help the Dominican government address their counter-money laundering systems.