Financial Crime World

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Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Framework in Dominica

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This report assesses Dominica’s compliance with international standards for AML/CFT and identifies areas for improvement.

Key Findings

Money Laundering (ML)

  • Dominica has a sound legal framework to combat ML, but its implementation is limited.
  • The Financial Intelligence Unit (FIU) conducts strategic analysis, but it does not reflect all higher-risk areas identified in the National Risk Assessment (NRA).
  • ML investigations and prosecutions are reactive rather than proactive, and cases involving professional ML networks and complex ML are not being detected.
  • Alternative measures like confiscation of cash are used extensively, but ML cases are not prioritized within the judicial system.

Confiscation of Proceeds

  • Dominica has a sound legal framework for freezing, seizing, and confiscating instrumentalities and proceeds of crimes.
  • The country has a declaration system for cross-border movements of cash or Bank Notes (BNIs), but it is not being effectively enforced.

Terrorist Financing (TF)

  • Dominica has a strong legal framework to criminalize TF, but its NRA did not consider several TF vulnerabilities.
  • Authorities in Dominica have not prosecuted any cases relating to TF during the period under review.
  • The country lacks a national CFT policy that would continuously assess the TF threat and identify requirements for training and professional development of Competent Authorities (CAs).
  • For the implementation of TFS-TF, Dominica has updated its legal framework required by UNSCR 1267 and 1373, but the Central Authority procedures do not accurately distinguish between what is required under the two UNSCR resolutions.

Recommendations

  1. Improve the effectiveness of ML investigations and prosecutions.
  2. Enhance the implementation of confiscation measures.
  3. Develop a national CFT policy that continuously assesses the TF threat and identifies requirements for training and professional development of CAs.
  4. Provide specific training to regulated entities on TF risks and vulnerabilities in Non-Profit Organizations (NPOs).
  5. Implement a targeted approach, outreach, or oversight of NPOs.

These recommendations aim to strengthen Dominica’s AML/CFT framework and enhance its effectiveness in combating ML and TF.