Human Trafficking and Migrant Smuggling Plague Montserrat
A recent national risk assessment has identified a medium-level threat from human trafficking in Montserrat, despite limited instances of this crime. The context of the island’s vulnerability to exploitation has been factored into the assessment.
Tax Crimes Remain a Concern
Tax crimes, including evasion and fraud, remain a concern for Montserrat. The jurisdiction has nine pending cases related to tax offenses, prompting a medium-level ML threat rating. To address these concerns, Montserrat has strengthened its anti-money laundering/combating the financing of terrorism (AML/CFT) framework and recruited new tax experts.
Drug Trafficking: A Medium-Level Threat
During the five-year period reviewed, cannabis was the primary drug smuggled into Montserrat. Although infrequent occurrences of this offense were detected, with relatively small quantities discovered, a medium-level ML threat rating was assigned due to the potential harm it could cause to the state and other jurisdictions.
National Risk Assessment Highlights Vulnerabilities
The assessment team identified several areas where vulnerabilities exist:
- Quality and Accessibility of Intelligence Gathering and Processing: The number of suspicious activity reports (SARs) has decreased, with limited investigative value. However, Montserrat has developed new AML/CFT policies and procedures to address this issue.
- Quality of National AML/CFT Policy and Strategy: The lack of an approved national strategy hinders the government’s efforts to combat money laundering and terrorist financing. To address this, a draft document is being prepared.
- Capacity and Resources of Investigation and Financial Crime Prosecutions: While the Office of the Director of Public Prosecutions (ODPP) has received training in prosecuting money laundering/terrorist financing cases, it still faces shortages in human resources.
Sector Assessment: Sectors Susceptible to Money Laundering
The assessment identified the following sectors as most susceptible to money laundering:
- Credit Union
- Money Service Business
- Domestic Bank
- Real Estate
- Legal Professionals
Credit Union and Money Service Businesses Under Scrutiny
The credit union, subject to prudential and AML/CFT oversight by the Financial Services Commission (FSC), was found to have a medium-level ML risk. The money service businesses, evaluated as having a medium-level ML threat, were found to be attractive vehicles for all stages of the money laundering process.
Recommendations
To combat human trafficking, migrant smuggling, and other financial crimes, Montserrat is advised to:
- Enhance intelligence gathering and sharing
- Develop an approved national AML/CFT strategy
- Increase human resources at the ODPP
- Implement stricter regulations for credit unions and money service businesses
By addressing these vulnerabilities, Montserrat can better prevent the potential harm caused by these criminal activities.