Financial Crime World

Dominica’s Fight Against Money Laundering and Terrorist Financing: A Progress Report

In recent years, Dominica has made significant strides in strengthening its efforts against money laundering (ML) and terrorist financing (TF). The country has developed a comprehensive national strategy, updated its legal framework, and enhanced cooperation between law enforcement agencies. This progress report provides an overview of the current state of play and identifies areas that require further attention.

A Strong Foundation

National Strategy and Policy

Dominica’s strong commitment to national strategy and policy setting is a positive development. The country has developed a National Policy (2019-2024) and National Strategy (2019-2024) to combat ML/TF. This demonstrates the government’s dedication to addressing these threats.

The legal framework required by United Nations Security Council Resolutions 1267 and 1373 has been updated. This ensures that Dominica is in compliance with international standards for combating ML/TF.

Cooperation and Training

Law Enforcement Agencies

Law enforcement agencies in Dominica are equipped with broad powers to obtain financial information for identifying and investigating ML/TF cases. Domestic cooperation amongst authorities takes place to a satisfactory extent during financial investigations.

Training

The Financial Services Union (FSU) has implemented training to regulated entities to raise awareness of the requirements under the Sanctions Framework Act (SFTA). While regulated entities have demonstrated an awareness of TFS, the FSU has not issued guidance on TFS to financial institutions or designated non-financial businesses and professions (DNFBPs) on their obligations.

Challenges Remain

Outstanding Risks

The National Risk Assessment (NRA) did not capture several TF vulnerabilities, including:

  • Cross-border wire transfers
  • Non-profit organizations (NPOs)
  • Legal persons
  • Virtual asset service providers (VASPs)

Lack of Prosecution

Authorities have not prosecuted any cases relating to TF in the period under review.

National CFT Policy

The country lacks a national CFT policy that would continuously assess the TF threat, identify requirements for training and professional development of law enforcement agencies, and allow for the development of policies by these agencies.

Conclusion

Dominica’s efforts to combat ML/TF are commendable. However, more work is required to fully understand related risks and address vulnerabilities. The country must continue to strengthen its legal framework, enhance cooperation between authorities, and provide training to law enforcement agencies and regulated entities.

Key Recommendations:

  • Complete a comprehensive assessment of NPOs, legal persons, VASPs, cross-border wires, and the Cash-Based Initiative (CBI) program.
  • Develop a national CFT policy that continuously assesses the TF threat and identifies requirements for training and professional development of law enforcement agencies.
  • Provide guidance on TFS to financial institutions and DNFBPs on their obligations.