What is the role and function of the FIU?
In this battle against money laundering and terrorist financing, we all have an important role to
play and most certainly the Financial Intelligence Unit (FIU).
Those involved in the fight against money laundering and terrorist financing must have access to
certain kinds of financially related information in order to conduct financial investigations. In this
regard, the FIU plays an increasingly important role in this process.
Money launderers manipulate their illicit proceeds in an endeavor to conceal or disguise their true
source and movement, with the ultimate objective of integrating these proceeds into, and through,
the legitimate economy. Those that finance terrorism seek to conceal the source of the funds and
disguise their illicit use of funds in support of terrorism. Financial investigations are assisted
greatly by a country’s comprehensive regime that requires the reporting of certain information
and record keeping and that facilitates information sharing among competent authorities, both
domestically and internationally. The primary goals of financial investigations are to identify,
trace, and document measures; and to support the prosecution of criminal activity.
Financial Investigations seek to discover the financial trail left by criminals. As part of this
process, investigators analyze financial institution account records, real estate records, documents
on liens and judgments, corporate registries, brokerage and mutual fund accounts, insurance
contracts and a full spectrum of other financial and business related records. Illicit financial
operations have recently grown more sophisticated and complex, requiring traditional
investigators to acquire new and specialized financial intelligence tools.
The Financial Action Task Force on Money Laundering (FATF), which is recognized as the
international standard setter for anti-money laundering (AML) and combating the financing of
terrorism (CFT), provides in The Forty Recommendations on Money Laundering (The Forty
Recommendations), that each country should establish an FIU. Further, FATF urges countries to
impose measures on financial institutions and certain non-financial business and professions
requiring them to maintain records on the identities of their clients and their transactions, and to
report any suspicious transactions. Information generated by these reporting and record keeping
requirements is to be reported to the country’s FIU and is used to reconstruct transactions, to
establish the link between individual clients and a particular business, to prove the “state of mind”
of an individual, and finally, to identify the role of an individual in a criminal or terrorist
financing activity.
Information reporting and record keeping requirements generate substantial financial data, much
of which is not easily useable by competent authorities without further analysis. If a country’s
AML and CFT institutional frameworks are to be at all effective, the country must institute a
reliable, efficient system for processing, analyzing, and disseminating this information. Without
such a system in place, law enforcement has a much more difficult time detecting criminal or
terrorist financial dealings. The pressing need for effective data analysis of possible financial
crime explains, in part, the proliferation of FIUs and the growing importance of their roles in the
international effort to prevent, detect and prosecute money laundering and terrorist financing.
The Egmont Group of Financial Intelligence Units (Egmont Group), which is the international
standard setter for FIUs, adopted the following definition of an FIU:
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An FIU is a central, national agency responsible for receiving (and, as permitted, requesting),
analyzing, and disseminating to the competent authorities, disclosures of financial information (i)
concerning suspected proceeds of crime, or (ii) required by national legislation or regulation, in
order to counter money laundering and terrorist financing.
In June of 2000, the FATF listed The Bahamas among 14 other offshore financial centres, which
it identified as Non-Cooperative Countries and Territories in preventing money laundering. In
addition, the Financial Stability Forum (FSF) launched its separate attack on The Bahamas
claiming that we had weak legislation governing money laundering and gave us its lowest ranking
for its regulatory oversight. These were serious and alarming challenges to our legitimate and
long-established industry.
In response, there were several legislative and administrative changes brought about by the
FATF’s blacklisting which were designed to bring the financial services sector into compliance
with international standards. One of the new laws enacted was the Financial Intelligence Unit
Act, 2000, which came into effect on December 29th 2000. This piece of legislation created and
empowered the FIU.
The FIU of The Bahamas is an autonomous body attached to the Ministry of Finance. The main
rationale for such an arrangement is to establish a “buffer” between the financial sector (and,
more generally, non-financial businesses and professionals subject to reporting obligations) and
the law enforcement authorities in charge of financial crime investigations and prosecutions.
The core functions of the FIU is to receive, obtain, analyze and disseminate information on
suspicious transactions (STRs) from financial institutions in The Bahamas, which may relate to
the proceeds of offences under the Proceeds of Crime Act, 2000 and since December 2004 the
Anti-Terrorism Act, 2004.
In August 2006, the FIU revised the 2001 Suspicious Transactions and Anti-Money Laundering
Guidelines with exclusive focus on the reporting of Suspicious Transactions (STRs) and the
extension of the Guidelines to include financing of terrorism. The revision was also prompted by
the need to keep pace with emerging trends in the financial services industry both locally and
internationally. An initial draft was released for comments to the financial services industry,
including local regulators and the general public in November 2006; the feedback was good. The
official document was projected for March 2007.
Ever so often, the FIU has to issue advisories to the general public. For instance, the ever-present
Nigerian Scam Letter continued to present a wide array of permutations prompting the issuance
of a “Public Notice” by the FIU in August 2006 advising caution.
I cannot emphasize enough that the FIU is more than a mere database (depository) for financial
information required to be submitted by legislation or national regulatory authorities. One of the
functions of the FIU is to analyze suspicious transaction reports. At the FIU, we must analyze all
data that we receive because so many suspicious transaction reports (STRs) and other financial
disclosures often appear on the surface to be innocent transactions. Ordinary deposits,
withdrawals, fund transfers, or the purchase of a security may, however, be important pieces of
information detecting and prosecuting money laundering and terrorist financing. The Unit retains
records of all information received for a period of 5 years from the time of receipt.
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It is only through examination and analysis that the FIU can detect criminal financial transactions.
Distinguishing truly suspect transactions from those that are unusual requires informed analysis.
Without it, the most sophisticated data gathering in the world will be utterly useless. In order to
facilitate a thorough analysis of STRs, the FIU frequently request information from financial
institutions via Production Orders. The FIU can take provisional measures to deal effectively with
cases where urgent action is needed to preserve assets that might become subject to confiscation.
Hence, the FIU has the power to place a 72-hour restraint on any account or transaction. In
addition, upon request from the Commissioner of Police, we can restrain an account(s) or
transaction for an additional five days after an STR was sent to the police for investigation.
Upon analyzing an STR, we will then make an assessment as to whether or not the police should
become involved to investigate the matter. It is important to note that it is the responsibility of the
police to conduct the investigation and not the FIU. We are pleased to say that we enjoy an
excellent working relationship with the Royal Bahamas Police Force in particular the Commercial
Crime Section of the Central Detective Unit, the Tracing and Forfeiture Section of the Drug
Enforcement Unit, the Security & Intelligence Branch and Interpol. In this regard, we frequently
provide information, subject to conditions, to the Commissioner of Police.
The FIU never abuses its powers and all information in its possession is confidential. After all,
the relationship between the FIU and the financial sector is one built on trust. In this train of
thought, the FIU always endeavor to keep the financial sector in “the loop”. While there are
obviously constraints on what the FIU can tell a reporting institution about a particular report
(especially if that report involves an ongoing enquiry) the Unit always give general feedback to
institutions about the quality and usefulness of their reports.
The FIU is also very active in the international area. To begin with, because so much of money
laundering and terrorist financing are cross-border activities, the FIU is required to share financial
intelligence with other FIUs worldwide in order to be effective partners in the international fight
against these crimes. Another feature of the FIU is its ability to cooperate in an efficient and rapid
manner with all its foreign counterparts. Is it important to note that the sharing at the international
level occurs through direct and secure communication with our counterparts. The FIU continues
to hold discussions with a number of Financial Intelligence Units with a view to signing
Memorandum of Understanding for the sharing of information with other countries. We have
shared information with numerous countries in the past such as the United Kingdom, United
States of America, Canada, Bolivia, Bulgaria, Luxembourg and Italy to name a few. The FIU
provides information (sometimes via Spontaneous Disclosures) relating to the commission of an
offence to any Foreign Financial Intelligence Unit subject to any conditions as may be considered
appropriate by the Director.
Further, the Financial Intelligence Unit of the Commonwealth of The Bahamas became the 54th
member of the Egmont Group of Financial Intelligence Units during the Group’s June 2001
meeting, held in The Hague, Netherlands (there are 121 member nations). The FIU is an active
participant in the Egmont “Outreach” Working Group and has monitored and successfully
sponsored the FIU’s of the following countries for membership in the Egmont Group: Anguilla,
Antigua & Barbuda, Barbados, Dominica, Belize, St. Vincent & The Grenadines, St. Kitts and
Nevis and Grenada. The FIU continues to monitor and sponsor the FIUs of Turks & Caicos
Islands, Guyana, Montserrat, St. Lucia, Trinidad & Tobago and Haiti for membership in the
Egmont Group.
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Members of the Egmont Group have access to a secure website, which is not available to the
public, to exchange information.
The Caribbean Financial Action Task Force (CFATF) is comprised of thirty member countries
whose goal is to develop and promote strategies in the fight against money laundering and
terrorist financing at national, regional and international levels. The Bahamas is an active member
of CFATF. The Bahamas’ FIU participates in the Plenary, Typology and Heads of FIU Meetings
of CFATF.
Pursuant to the provisions of the Financial Intelligence Unit Act, 2000, the FIU continues to
provide training on AML/ CFT, legal and analytical issues to financial institutions upon request.
Most of the entities requiring training have been Banks and Trust companies, but training has also
been provided to real estate companies, law firms, internal auditors and to co-operative societies.
The staff, particularly Legal Counsel and the Analysts is the primary trainers in this regard and
have been exposed to a wide array of AML/CFT training both locally and abroad.
Pursuant to section 10 of the Financial Intelligence Unit Act, 2000, the Unit publishes annual
reports. The reports outline the operations of the FIU for the previous year inclusive of
expenditure, initiatives, statistics, trends, and typologies.
There are seventeen members of staff at the FIU. The staff consists of a Director, Deputy
Director, Public Accountants, Counsel and Attorney, Head of Operations, Police Officers, IT
Specialist and support staff.
In moving forward, the FIU intends to launch an online document scanning, storage and retrieval
system.
With the establishment of the FIU, this provides another means by which The Bahamas has
exhibited its commitment to international cooperation, combating money laundering and terrorist
financing.
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What is a National AML/CFT Strategy?
At this juncture, it is only practicable that we define what a National AML/CFT Strategy is?
Essentially, the National Strategy sets forth a comprehensive action plan that responds to the
challenges that money laundering and terrorist financing presents. A National Strategy illustrates
the importance of reducing predicate crime, maintaining the integrity of the financial system,
combating global “public bad” and supports the view of the AML/CFT regime as having
prevention and enforcement pillars with multiple elements. Important factors to consider in
formulating a National Strategy includes what needs to be improved, what is the priority and what
kind of resources are available.
Money laundering, at its simplest, is the act of making money that comes from Source A look like
it comes from Source B.
A more detailed definition states, “Money laundering occurs when criminals seek to make
illegally obtained funds look legitimate by funneling them through a string of banks and
businesses until the money’s origin is obscured. Money laundering is an integral component of
large-scale criminal enterprises. Drug trafficking, firearms smuggling, international bank and
securities frauds, and other specified unlawful activity generate illicit proceeds that criminals
must conceal. Criminals often employ lawyers, bankers and accountants to disguise their
unlawful monies as legitimate income by developing ingenious, high-tech, multinational schemes
that abuse legitimate financial institutions. Once criminals successfully disguise their illicit
proceeds, they can reinvest them in their criminal organizations, expand their operations, and
profit from their crimes.”
Money launderers want to be able to transfer funds across international lines, move money
quickly, and minimize inquiries into their finances and activities. Persons often question why so
much attention is placed on money laundering and the principal reasons why international
agencies and national governments seek to prevent money laundering include:
1. Prevent money laundering.
Failure to prevent money laundering permits criminals to benefit from their actions, thus making
crime a more attractive proposition. It also allows criminal organizations to further criminal
activity. These factors combine to increase the level of crime. International measures to prevent
money laundering make the world a safer place in which we live.
2. Financial Stability.
The unchecked use of the financial system for money laundering has the potential to undermine
individual financial institutions and ultimately the integrity of the entire financial sector. Some
might argue that developing economies cannot afford to be too selective about the sources of
capital they attract. But postponing action is dangerous. The more it is deferred, the more
entrenched organized crime can become. As with the damaged integrity of an individual financial
institution, there is a damp effect on foreign direct investment when a country’s commercial and
financial sectors are perceived to be subject to the control and influence of organized crime.
Fighting money laundering and terrorist financing is therefore a part of creating a business
friendly environment, which is a precondition for lasting economic development.
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3. Increase in financial crime.
A continued increase in criminal activity and the successful use and laundering of the proceeds of
crime endangers respect for the law; thereby financial stability is of vital importance. This in turn
promotes economic crime such as fraud, exchange control violations and tax evasion.
4. Corruption.
Money laundering facilitates corruption; ultimately the accumulation of economic and financial
power by unscrupulous politicians or by criminal organizations can undermine national
economies and democratic systems. Poverty simply cannot be eradicated in countries where high
levels of corruption exist.
5. A vicious cycle.
The effect of successfully cleaning drug money is clear: More drugs, more crime, more violence.
Further, since the dawn of the new money laundering issue in 1986, nothing has galvanized the
nations of the world and some of their most powerful organizations to reinforce moneylaundering
laws more than the September 11th terrorist attacks on the United States and the global
dragnet to capture those responsible. Although terrorist funds are not usually derived through
illegal means, these funds, however, are used for a purpose rather than the profit of crime.
The connection between money laundering and terrorism is somewhat complex, but it plays a
crucial role in the sustainability of terrorist organizations. Most people who financially support
terrorist organizations do not simply write a personal check and hand it over to a member of the
terrorist group. They send the money in roundabout ways that allow them to fund terrorism while
maintaining anonymity. And on the other end, terrorists do not use credit cards and cheques to
purchase the weapons, plane tickets and civilian assistance they need to carry out a plot. They
launder the money so authorities cannot trace it back to them and foil their planned attack.
Interrupting the laundering process can cut off funding and resources to terrorist groups. Hence,
uncovering the roots of illegally obtained funds and terrorist financing is one of the biggest
challenges facing the world today.
With this in mind, the Financial Intelligence Unit (FIU) continues to perform its function as
mandated by the Financial Intelligence Unit Act, 2000 as it is responsible for receiving,
analyzing, obtaining and disseminating information, which relates to or may relate to the
proceeds of offences under the Proceeds of Crime Act, 2000. In this vein, the FIU remains in the
forefront of the fight against AML/CFT in The Bahamas, as it is the central agency in The
Bahamas for the receipt of all suspicious transaction reports. Moreover, the FIU is open to
suggestions and ideas from the financial sector and the general public in any suitable forum with
a view to suppressing AML/CFT in our country.
While we have made important strides since the package of financial legislation in 2000 with a
view to concentrate our attention on the abuse of the financial system by criminals, the techniques
criminals and terrorists use to exploit the financial system continue to evolve. Building on the
successes and experience of the past, we are resolved to remain vigilant and proactive in our
efforts to disrupt and dismantle the organized criminal activities that threaten not only our
financial system but also our national security and inevitably our way of life. Money laundering
7
techniques are innumerable, diverse, complex, subtle and secret. Money laundering is a dynamic
threat requiring a dynamic response.
More important, as a small nation competing worldwide in the financial arena, the costs
associated with not complying with global standards no doubt may well exceed the related
benefits. Given the prominence of financial services to the domestic economy, coupled with
global competition, The Bahamas cannot afford to “stand pat” and rest on our laurels. It is
important to note that the implementation of National AML/CFT Strategies by numerous
countries is an emerging trend in the global community.
It is in this spirit that we are gathered today to seek your input in the formulation of a National
Strategy for the Prevention of Money Laundering and The Financing of Terrorism in and
through the Financial System of The Bahamas (“National Strategy”). To do so, developing
strong collaboration efforts for private sector participation is the key. The goals of a National
Strategy includes but limited to the following:
Goals, objectives, and priorities- Comprehensive, research-based goals, objectives, and priorities
for reducing money laundering and the financing of terrorism in The Bahamas;
Emphasis on training- a National Strategy emphasizes the importance of asset forfeiture as the
most direct method of depriving criminals of their ill-gotten gains. In this regard, focus is placed
on having highly trained and experienced Analysts, criminal and financial investigators and
prosecutors to dismantle large, complex, money-laundering schemes and to undertake asset
forfeiture investigations. Also, continuous study in AML/CFT typologies is necessary to keep up
with the evolving environment and to adjust AML/CFT procedures and due diligence programs
accordingly.
Enhancement of intergovernmental cooperation;
International cooperation – Large-scale money laundering schemes invariably contain crossborder
elements. Since money laundering is an international problem, international co-operation
is a critical necessity in the fight against it. National governments need to work with other
jurisdictions to ensure that launderers are not able to continue to operate merely by moving to
another location in which money laundering is tolerated.
A National Strategy establishes the formation of a system to collect information that will
provide law enforcement with an accurate picture of its anti-money laundering and counter
terrorist financing programs. Once a National Strategy is implemented, evaluation can begin to
determine the success level attained. Other measurable methods will include an examination of:
● Quantitative factors, such as the number of Suspicious Transaction Reports filed,
money laundering investigations, prosecutions, convictions and accounts restrained,
which will provide a numerical snapshot of our efforts from year to year.
● Qualitative factors – each investigation, prosecution, or conviction will be assigned a
weighted value to mirror the case’s complexity, importance, and scope.
● The criminal marketplace price of laundering money that will help determine whether
anti-money laundering efforts are making it more expensive and more difficult for
criminals to launder their illicit proceeds. After all, targeting the money laundering aspect
8
of criminal activity and depriving the criminal of his ill-gotten gains means hitting where
he is vulnerable. Without a useable profit, the criminal activity will not continue.
● Forfeiture and seizure data – related to money laundering activity that will represent a
monetary value of efforts underway.
Data regarding trends in money laundering and related financial crimes- the need for
additional information necessary for the purpose of developing and analyzing data in order to
ascertain financial crime trends;
Enhancement of the role of the private sector in prevention- the enhancement of partnerships
between the private financial sector and law enforcement (Royal Bahamas Police Force) with
regard to the prevention and detection of money laundering and the financing of terrorism,
including providing incentives to strengthen internal controls and to adopt on an industry wide
basis more effective policies.
A National Strategy emphasizes a need for clarity in rules and regulations for private sector to
fully understand its responsibility and obligations.
To safeguard the financial sector, the Financial Intelligence Unit (FIU), financial regulators, and
the Royal Bahamas Police Force will and must continue to work closely with the financial
industry to fight money laundering and the financing of terrorism. The FIU and financial
regulators will develop and publish guidelines alerting the financial industry to money laundering
threats and the development and application of AML controls. The FIU will also work to enhance
information sharing between the Royal Bahamas Police Force and the financial community.
The National Strategy paves the way forward. The Strategy directs the government’s resources
against money laundering and those who finance terrorist activities and individuals. It is a good
plan and a critical mission. In a local context, all stakeholders (that is law enforcement,
supervisors, regulators, policymakers and industry practitioners) will have an important role to
play in the ongoing observance of and maintenance of high standards and the success of a
National Strategy. This is truly a collaborative process reflecting the input of all the relevant
players. A national strategy is inevitable. Hence, we appreciate your valuable input as we
continue to battle the scourge of money laundering and terrorist financing.
WHY A NATIONAL
STRATEGY ON AML/CFT?
Prepared by
The Financial Intelligence Unit
Norfolk House, Fredrick Street
Nassau, Bahamas
15th October 2007
2
TABLE OF CONTENTS
• Global Trend
• Compliance with International Standards
• Need for a Single Comprehensive Document
• Scarce National Resources
• Need to Build Capacity
• Continuing Evolution in Financial Services
• National Security Considerations
• Need to be Pro-Active
3
GLOBAL TREND
• Development of National Strategies to Prevent
Money Laundering and Terrorism Financing is a
relatively new trend globally.
• The U.S. has had such a strategy for the last several
years and same has been updated on a regular
basis.
• Member countries of the Egmont Group are now
moving in this direction e.g. Mexico, Brazil and
Guernsey.
• Slow start in this direction may be due to the novelty
of the exercise but pace will accelerate as countries
warm up to the concept and ML/TF continue to
present new challenges.
4
COMPLIANCE WITH
INTERNATIONAL STANDARDS
• The FATF’s 40 + 9 Recommendations have become
entrenched as the “Global Standard” for assessing
nation states’ efforts and commitment to combating
Money Laundering and Terrorism Financing.
• The National Strategy will provide a means to ensure
ongoing compliance with such standards while
having regard to any overriding national interests.
• The National Strategy will provide relevant
parties/stakeholders with a set of measurable goals
and outcomes.
• The document will be sufficiently flexible to allow for
future amendments to the 40+9 Recommendations.
5
SCARCE NATIONAL RESOURCES
• AML/CFT initiatives imposes tremendous costs on a
country’s national resources, especially small
countries such as the Bahamas with limited
resources.
• Scarce resources including time, money, equipment
and personnel have to be redeployed from other
productive uses.
• The current AML/CFT Regime is multi-faceted and
can be further enhanced through a coordinated
national effort which assesses risks/vulnerabilities
which ML/FT presents supported by
recommendations address same.
• A well coordinated plan, enshrined in a “National
Strategy” document will reduce costs by reducing
duplication of effort.
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NEED TO BUILD CAPACITY
• The development of well “trained” personnel within
the jurisdiction, via institutional AML/CFT training, is
a critical to the detection and prevention of money
laundering and terrorism financing.
• “Goals” and “objectives” identified in the National
Strategy will drive the process to develop the
requisite level of competency through on-going
AML/CFT training and capacity building in priority
areas.
• The “Train-the-Trainer” approach over time will
facilitate the institutionalization of AML/CFT training.
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CONTINUING EVOLUTION
IN FINANCIAL SERVICES
• The rate of change in Financial Services continues to
outpace the average person’s ability to comprehend
the technical features of some products/services
now available.
• The phenomenon is largely attributable to advances
in technology and shareholders and consumers
appetite for profits.
• Complex financial products/services presents the
risk of possible abuse for criminal purposes.
• The National Strategy should explore ways of
addressing this “gap” between potential/actual uses
of financial products and consumers’ knowledge
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NATIONAL
SECURITY CONSIDERATIONS
• Undetected funds derived from criminal activities can distort
the level of legitimate commercial activity in the domestic
economy i.e. a false economy.
• Corruption of public officials and influential persons in the
community as a result of access to “easy money” can
undermine societal underpinnings.
• ML/TF may attract undesirables to our shores and or financial
services industry with the potential for escalation in criminal
activities.
• ML/TF can impair the development of important financial
institutions and/or destabilize existing ones in the absence of
strong AML/CFT controls.
• The Bahamas has been identified as a potential source of “soft
targets” for terrorists which may/can negatively effect tourism.
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NEED TO BE PRO-ACTIVE
• Based upon information provided by stake
holders, there will be a better overall under
standing of areas presenting high risk of
ML/TF.
• Same will guide public and private sectors
in their AML/CFT efforts.
• Facilitate interagency cooperation
WHAT DOES THIS MEANS FOR THE BAHAMAS?
There is no question that Money Laundering and the Financing of Terrorism
can damage national financial systems. It is said among other effects, Money
Laundering and the Financing of Terrorism destabilizes national economies by
increasing the demand for cash, increasing volatility of interest and exchange rates
and in some cases even contribute to higher inflation.
According to the World Bank “illegitimate financial holdings, assets and
enterprises are unreliable sources of investment capital for sustainable economic
development. Countries with weak AML/CFT controls could damage their
reputation in international financial markets, and thus may not attract international
flows such as foreign direct investment and/or funding. Developing and transitions
economies strive to comply with international codes of conduct to combat money
laundering and the Financing of Terrorism.
The Bahamas as mature financial center has always been subject to close
scrutiny by international organizations. Therefore it is of utmost importance that
The Bahamas be complaint with the International AML/CFT standards set. The
National Strategy on Prevention of Money Laundering and the Financing of
Terrorism enables The Bahamas to develop and implement domestic systems that
are compatible with International AML/CFT standards and criteria.
The Financial Action Task Force (FTAFT) on Money Laundering has
developed international standards on AML/ CFT. The forty (40) plus nine (9)
Special Recommendations provide the basic framework for t he Prevention of
Money Laundering and the suppression of Terrorism Financing. The Bahamas, to
the extent possible, should always endeavour to be Complaint with these
international Recommendations.
Across, the world new measures are being introduced and existing measures
tightened to combat Money Laundering and the Financing of Terrorism. The
Development of a National AML/CFT is a first for the Bahamas and is in keeping
with an emerging global trend. Countries such as Brazil, Mexico, Guersney and the
United States of America have already produced their National Strategy on Money
Laundering. This National Strategy on the Prevention of Money Laundering and
Financing of Terrorism could be a road map which will ensure that The Bahamas,
given the importance of the financial services to our economy, has an Action plan
which will provide all relevant parties o identify where it is headed, and what is
required, in this global fight against Money Laundering and Financing of
Terrorism.
The Bahamas has an obligation to protect the integrity of its financial system.
While it is noted that it is important to comply with international standards it is
equally important that in developing our National Strategy that we consider our
jurisdiction’s culture and economy, and its legal and law enforcement traditions and
capabilities.
Further, this National Strategy on the Prevention of Money Laundering and
the Financing of Terrorism will demonstrate The Bahamas’ continuous efforts and
commitment, to use all tools available, which include input from law enforcement
agencies, financial and regulatory institutions, and the private sector, to confront
the global threat of Money Laundering and Financing of Terrorism.
The National Strategy will allow all strategic players and stakeholders to
collectively pool their expertise and to coordinate activities that will prevent the
laundering of money and the flow of terrorist fund through our financial system.
Further, a National AML/CFT Strategy will allow The Bahamas to identify
the Money Laundering “risks and vulnerabilities” in The Bahamas and to assess
each area, including non-designated, non-financial businesses and professions,
according to the associated level of risk.
Also, a National AML/CFT Strategy will identify “training needs” if any, and will
allow The Bahamas to formulate “national goals” based upon risks, vulnerabilities
and training needs.
By enabling The Bahamas to systematically assess the risks and
vulnerabilities associated with maintaining a robust AML/CFT Regime: The
National Strategy on the Prevention of Money Laundering and Financing of
Terrorism will, accordingly, allow stakeholders to better identify, measure and
mitigate these risks and vulnerabilities. Consequently, The Bahamas will be able to
make better choices about the allocation of its resources, be it on a national or
sector by sector basis.
Most importantly, The National AML/CFT Strategy allows The Bahamas to
assess its AML/CFT controls and assess whether or not it is meeting its international
standards. It allows the Country to examine where we are in respect our AML/CFT
Strategy, make recommendations for improvement and to say how we can
accomplish these things.
Finally, The Bahamas must remain vigilant and must continue to mount a
sustained and united effort to meet the ever changing threats and methods of money
launders and financiers of terrorism. A National Strategy on the Prevention of
Money Laundering & Financing of Terrorism asserts the Bahamas’ commitment to
protect our financial systems from these money launders and financiers of
terrorism, thereby maintaining our reputation as a mature financial Center in the
international financial market and preserving the significant strides accomplished
in this industry.
This National Strategy on the Prevention of Money Laundering and
Financing of Terrorism will be yet another step for The Bahamas to protect itself
from the adverse effect of being involved, in money laundering and the financing of
terrorism.
In closing let me remind you of an old and timeless saying which says
“prevention” is always better than “cure”. In regard to The Bahamas’ Money
Laundering and the Financing of Terrorism approach “It is always best to be
“proactive” than “reactive.”
I thank you for your kind attention.
From Investment Clubs, 2008/07/15 at 8:46 PM
