Human Trafficking and Migrant Smuggling Pose Medium-Low Threat to Montserrat
A recent national risk assessment has identified human trafficking and migrant smuggling as a medium-level threat to Montserrat. The assessment team considered the limited instances of human trafficking in the island nation and factored in its unique context, resulting in a medium ML threat rating.
Tax Crimes: A Growing Concern
Tax crimes, including tax evasion and fraud, are another significant concern for Montserrat. With nine pending cases related to tax offenses, the assessment team assigned a medium ML threat rating to address these concerns. To combat this issue, Montserrat has strengthened its anti-money laundering (AML) and combating the financing of terrorism (CFT) framework by recruiting new tax experts.
Drug Trafficking: A Medium-Level Threat
During the five-year period reviewed, cannabis was the primary drug smuggled into Montserrat. Despite strict AML/CFT legislation aimed at preventing the possession of controlled substances, infrequent occurrences and relatively small quantities discovered resulted in a medium ML threat rating.
National Risk Assessment Identifies Key Vulnerabilities
The assessment team identified several vulnerabilities that Montserrat must address to ensure its AML/CFT systems align with international standards. These vulnerabilities include:
- Quality and accessibility of intelligence gathering and processing: Montserrat has developed new AML/CFT policies and procedures, but there is a need for improved intelligence gathering and sharing.
- National AML/CFT policy and strategy: The absence of an approved national strategy hinders the government’s efforts to combat money laundering and terrorist financing.
- 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 and terrorist financing cases, there is a need for increased human resources.
Sector Assessment Identifies High-Risk Sectors
The assessment team identified several sectors that are most susceptible to money laundering. These sectors include:
- Credit Unions
- Money Service Businesses (MSBs)
- Domestic Banks
- Real Estate
- Legal Professionals
Credit Union and MSB Assessments
The credit union in Montserrat is subject to prudential and AML/CFT oversight, but the assessment team rated its ML risk as medium. The ML threat was determined to be medium-low, and the ML vulnerability was rated as medium.
Conclusion
While human trafficking and migrant smuggling pose a moderate threat to Montserrat, tax crimes and drug trafficking also require attention. To address these concerns, the island nation must strengthen its AML/CFT framework, improve intelligence gathering and sharing, and enhance the capacity of its investigation and financial crime prosecution agencies.