Financial Crime World

Mutual Evaluation Report of St. Kitts and Nevis

Assessment of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Measures

The Caribbean Financial Action Task Force (CFATF) has conducted a mutual evaluation report on St. Kitts and Nevis to assess the country’s effectiveness in implementing measures to counter money laundering (ML) and terrorist financing (TF).

FIU Oversight: Key Concerns

  • The FIU is overseen by an external officer employed by the Ministry of Finance, raising security concerns about data confidentiality and independence.

Technical Framework for Investigations and Prosecutions

  • St. Kitts and Nevis has a well-established technical framework for investigating ML and conducting prosecutions.
  • The WCCU conducts investigations with well-trained and experienced investigators.
  • The main source of financial intelligence leading to ML investigations is the case disclosures (CDs) disseminated by the FIU to the WCCU.

Investigations, Prosecutions, and Confiscation Proceedings

  • Despite deficiencies identified in the NRA, measures were implemented, including legislative amendments that increased investigative techniques available to the WCCU.
  • The number of ML investigations reported by the WCCU is low, with six (6) each for 2019 and 2020, and two (2) for the first three months of 2021.
  • There were eight prosecutions before the court for self-laundering ML at the time of the onsite visit. However, there were no ML convictions in St. Kitts and Nevis during the review period.
  • The country did not have a national policy objective for confiscating criminal proceeds until March 2021.

Asset Recovery and Civil Forfeiture

  • St. Kitts and Nevis has limited experience in asset recovery with foreign counterparts, either for proceeds of foreign predicates located in the jurisdiction or proceeds from domestic predicates laundered outside St. Kitts and Nevis.
  • Legislation was enacted to include civil asset forfeiture in March 2021, but there has been no opportunity for this mechanism to be used during the review period.