Money Laundering Threats in Anguilla: A Growing Concern
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A recent assessment by the Financial Intelligence Unit (FIU) has identified a total of 21 predicate offenses that pose a significant money laundering (ML) threat to the jurisdiction. The FIU’s assessment focused on predicate offenses identified by the Financial Action Task Force (FATF) and the additional offense of gambling, which has been highlighted as a high-risk activity for ML in Anguilla.
Threat Rating Criteria
The FIU considered three key criteria to determine the threat rating:
- Criminal actors’ capacity
- Scope of ML activity
- Estimated proceeds of crime
These factors were evaluated to assess the level of sophistication, resources, and expertise of criminal actors involved in laundering criminal proceeds.
Very High ML Threats
Two predicate offenses were identified as posing a Very High threat to Anguilla’s financial system:
Human Trafficking and Sexual Exploitation
Human Trafficking is a relatively new and emerging crime in the jurisdiction, with intelligence suggesting that there are several individual networks facilitating the movement of persons and funds. While there is no evidence of organized criminal groups (OCGs) operating in Anguilla, these networks appear to be using the MSB sector to move illegal proceeds.
Sexual Exploitation is also a significant concern, as it has been linked to human trafficking. Intelligence suggests that individual actors, including owners of bars and pubs, may have connections with OCGs in other jurisdictions that facilitate this crime.
High ML Threats
Gambling
Gambling was identified as a High ML threat due to its high risk of money laundering activity. The exception is two licensed institutions tasked with regulating the industry, which are subject to strict anti-money laundering (AML) regulations.
Fraud
Fraud was also identified as a High ML threat, with both domestic and international criminal actors perpetrating frauds using various methods, including Nigerian 419 scams and Business Email Compromise Fraud.
NRA REPORT 2014-2020
The FIU’s assessment highlights the need for Anguilla to strengthen its AML/CTF regime to combat these growing ML threats. The report calls for increased cooperation between financial institutions, law enforcement agencies, and the FIU to share information and best practices in detecting and preventing ML.
As the global fight against money laundering continues, Anguilla must remain vigilant in addressing these emerging threats to protect its financial system and reputation.