Fi­nan­cial Ac­tion Task Force (FATF) Forty Rec­om­men­da­tions — Na­tional Co­op­er­a­tion and Co­or­di­na­tion

The Star (St. Lucia) - - LOCAL - By The At­tor­ney Gen­eral’s Cham­bers and the Na­tional Anti-Money Laun­der­ing Over­sight Com­mit­tee

The man­date of the Fi­nan­cial Ac­tion Task Force (FATF) to con­trol the scourge of money laun­der­ing, ter­ror­ist fi­nanc­ing and fi­nanc­ing of the pro­lif­er­a­tion of weapons of mass de­struc­tion is one of great im­por­tance to us in the Car­ib­bean. Car­ib­bean States are mem­bers of the Car­ib­bean Fi­nan­cial Ac­tion Task Force (CFATF)—a re­gion­al­styled body bounded by the Forty Rec­om­men­da­tions. Full com­pli­ance by mem­ber states re­quires a clear un­der­stand­ing of the Rec­om­men­da­tions. This ar­ti­cle will ex­am­ine Rec­om­men­da­tion 2: Na­tional Co­op­er­a­tion and Co­or­di­na­tion.

Rec­om­men­da­tion 2 calls for coun­tries to have na­tional anti-money laun­der­ing/ coun­ter­ing fi­nanc­ing of ter­ror­ism poli­cies. These poli­cies should be in­formed by the risks iden­ti­fied when the coun­try con­ducts its risk as­sess­ment as re­quired by Rec­om­men­da­tion 1, and should be re­viewed reg­u­larly. It is also rec­om­mended that there be a des­ig­nated au­thor­ity over­see­ing the im­ple­men­ta­tion of the poli­cies, or have co­or­di­na­tion or other mech­a­nism that are ex­clu­sively re­spon­si­ble for these poli­cies.

Saint Lu­cia should en­sure that pol­icy mak­ers, en­force­ment au­thor­i­ties, the Fi­nan­cial In­tel­li­gence Au­thor­ity, su­per­vi­sors and all other rel­e­vant com­pe­tent au­thor­i­ties co­or­di­nate with each other from a pol­icy and op­er­a­tional level to com­bat money laun­der­ing, ter­ror­ist fi­nanc­ing and fi­nanc­ing of the weapons of mass de­struc­tion. Ad­di­tion­ally, these in­sti­tu­tions should have mech­a­nisms in place which are ef­fec­tive enough to al­low them to co­op­er­ate which each other re­gard­ing the de­vel­op­ment and im­ple­men­ta­tion of poli­cies and ac­tiv­i­ties to nul­lify these three prob­lem ar­eas.

This rec­om­men­da­tion calls for a col­lab­o­ra­tive ap­proach be­tween the stake­hold­ers in the pri­vate and pub­lic sec­tors and demon­strates the gains that can be made when work­ing to­gether.

In Septem­ber 2019 Saint Lu­cia will have its on-site visit by the asses­sors from the CFATF, who will be on is­land in­ter­view­ing stake­hold­ers. In ad­di­tion to the other thir­ty­nine rec­om­men­da­tions, an ex­am­i­na­tion will be done of how ef­fec­tively Rec­om­men­da­tion 2 has been im­ple­mented and a rat­ing will be as­signed. One of five rat­ings can be re­ceived: Com­pli­ant, Largely Com­pli­ant, Par­tially Com­pli­ant, Non-Com­pli­ant or Not-Ap­pli­ca­ble. It is the pri­mary ob­jec­tive of the Na­tional An­ti­Money Laun­der­ing Over­sight Com­mit­tee (NAMLOC) to pre­pare for this as­sess­ment.

Every Saint Lucian is en­cour­aged to learn more about com­bat­ting money laun­der­ing, ter­ror­ist fi­nanc­ing and fi­nanc­ing of the pro­lif­er­a­tion of weapons of mass de­struc­tion, and to co­op­er­ate with agen­cies in this fight.

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