Financial Crime World

Jamaica’s Central Bank: Fortifying AML/CFT/CFP Framework against Money Laundering, Financing of Terrorism, and Weapons of Mass Destruction

The Central Bank of Jamaica, an essential institution in maintaining financial stability and price stability, reinforces its stance against Money Laundering (ML), financing of Terrorism (FT), and financing of the Proliferation of Weapons of Mass Destruction (WMD).

Objective

  1. Preventing illicit activities: The primary objective of Jamaica’s Central Bank’s Anti-Money Laundering/Combatting the Financing of Terrorism/Combatting the Financing of the Proliferation of Weapons of Mass Destruction (AML/CFT/CFP) policy is to prevent the bank from inadvertently being used for ML, FT, or WMD activities.
  2. Compliance with Financial Sanction Directives: Ensuring the Central Bank complies with targeted financial sanction directives from the United Nations, if applicable.

Context and Background

  • Maintaining financial stability and price stability
  • Formulating monetary policy
  • Implementing prudential and macro-prudential policies
  • Acting as banker to the Government and holding and managing the external reserves of Jamaica
  • A diverse base of customers, including Central Government, Public Bodies, Commercial banks, Primary Dealers, Regulatory Bodies, Central Banks, and Government Agencies

Legislative Framework and Systems

  • Armed with applicable local legislation, such as the Proceeds of Crime Act (POCA) and the Terrorism Prevention Act (TPA)
  • Following the guidelines set out by the Financial Action Task Force (FATF) and the Caribbean Financial Action Task Force (CFATF)

Risk Based Framework

  • Assessing unique risks and vulnerabilities
  • Conducting regular risk assessments
  • Mitigating emerging threats and vulnerabilities

Policy Elements

a) Internal Controls

i. Fit and Proper Checks ii. Anti-Bribery and Corruption Prevention iii. Post-Employment Conditions iv. Adherence to Policies and Procedures v. Annual Training Requirements for Critical Persons vi. Training for the Executive Management and Board vii. Records Retention Policy viii. Cybersecurity ix. The Board of Directors’ Responsibility x. Relationship with Audit, Risk, and Compliance Functions xi. The Senior Nominated Officer and the Nominated Officer

b) Reporting Requirements

  • Reporting “Threshold Transactions” and “Suspicious Transactions” to the Financial Investigations Division
  • Following a structured Approach for Dealing with the United Nations Security Council Resolution Implementation Act

c) Customer Due Diligence

  • Performs due diligence on its customers to mitigate ML/FT/WMD risks i. Banking Services ii. High Risk Transactions/Business Relationships iii. Additional Considerations: Correspondent banking, custody arrangements, wire transfers, and non-face-to-face customers iv. Data Protection: Ensuring adequate data protection measures to safeguard sensitive customer information.