History of the Barbados FIU/AMLA

THE OFFICIAL LAUNCH OF THE ANTI-MONEY LAUNDERING AUTHORITY
AND
THE FINANCIAL INTELLIGENCE UNIT

Although operational since August 2000 the Anti-Money Laundering Authority and the Financial Intelligence Unit were formally launched on Monday 13th August 2001 at a ceremony. The feature address was delivered by the Honourable David Simmons the then Attorney General of Barbados. The Launching Ceremony was also addressed by Ms Desiree Cherebin, Chairperson of the Anti-Money Laundering Authority.

The following is the context of her speech:

Distinguished guests, ladies and gentlemen, it is indeed a pleasure for me as Chairperson of Barbados’ Anti-Money Laundering Authority to say a few words at this the official launch of the Authority and its operational arm, the Financial Intelligence Unit (FIU).

Following its establishment in September 2000, the FIU has been working diligently to introduce systems and procedures, to ensure that the provisions of Barbados’ Money Laundering Prevention and Control Act, which was proclaimed in April 2000, are effectively implemented. The composition of the board of the Authority ensures that a number of key government agencies are involved in Barbados’ efforts to combat money laundering, at the policy level. Board members are the Commissioner of Police, the Comptroller of Customs, the Commissioner of Inland Revenue, the Supervisor of Insurance, the Registrar of Corporate Affairs and Intellectual Property and representatives of the Governor of the Central Bank and the Solicitor General. The Deputy Chairman of the Authority is Mr. Jeff Cumberbatch, Senior Lecturer at the Faculty of Law of the University of the West Indies.

The Authority was fortunate from its inception to have two senior police officers, both of whom are also attorneys, assigned to the FIU as senior investigators and with the assistance of a Consultant Mr. Graham Pinner, from the Australian Transaction Reporting and Analysis Centre (AUSTRAC), a number of initiatives have been undertaken to date. Mr. Pinner’s services were made available to Barbados by the United Nations Global Programme against Money Laundering for the period September 2000 to May 2001. Efforts have been made to expose the investigators to money laundering intelligence procedures and they have both attended a number of training sessions and have had attachments at other FIU’s.

Since its establishment the Authority has been working closely with financial institutions in both the onshore and offshore sector and their respective regulators to ensure that these institutions comply with the provisions of the anti-money laundering legislation including keeping proper transaction records, implementing effective know-your-customer procedures, adequately training staff and reporting unusual transactions to the FIU. To this end the Authority in conjunction with the Central Bank of Barbados issued Know-Your Customer Guidelines for Licensed Financial Institutions in March this year to all financial institutions licensed under the Financial Institutions Act and the Offshore Banking Act, following consultation with the industry. These guidelines are in keeping with the forty recommendations of the Financial Action Task Force (FATF) and the nineteen recommendations of the Caribbean Financial Action Task Force, a sub-regional body of the FATF.

Anti-money laundering guidelines for the insurance industry have also been drafted in collaboration with the office of the Supervisor of Insurance and will be issued by the Authority in the near future, following the receipt of comments from the industry. The Registrar of Cooperatives has also advised that the Know-your-customer guidelines issued by the Authority for the banking sector will be adapted for use by credit unions. The Authority has also held discussions with the International Business Division of the Ministry of Industry and International Business on the implementation of anti-money laundering procedures for international business companies and other entities under its supervision.

The cooperation and commitment of the financial institutions in Barbados’ efforts in the fight against money laundering cannot be over emphasized. Directors and senior management of these institutions have a responsibility to ensure that effective anti-money laundering policies, procedures and controls are put in place and that their respective institutions are in compliance with the provisions of the anti-money laundering legislation. They must ensure that policy manuals and internal control programmes include sections relating to anti-money laundering procedures and that orientation seminars and training courses familiarize staff with the institution’s anti-money laundering policies. Compliance officers must be identified and unusual transactions brought to their attention for onward submission to the FIU. I am pleased to note that in its relatively short existence the FIU has established good working relationships with financial institutions in Barbados, holding discussions with a number of them and participating in their training seminars. Financial institutions have also begun to submit unusual transaction reports to the FIU and their ready cooperation in Barbados’ efforts to counter money laundering is highly commendable.

As part of its outreach programme, in May this year the Authority in conjunction with the Central Bank of Barbados and Citibank’s Global Corporate and Investment bank’s regional compliance office, also hosted an anti-money laundering seminar for officers and staff of licensed deposit-taking financial institutions. Over two hundred persons attended the sessions held over a two-day period and were given useful insights into the methods used by a large international bank to counter money laundering throughout its global branch network.

In addition to working with financial institutions and their regulators, the FIU has been sensitizing governmental and other agencies on the role that they each can play in the fight against money laundering. Discussions and training sessions have been held with a number of government departments including the Police, Customs and the Post Office to highlight the provisions of the legislation, to share intelligence and to agree on areas of cooperation. The Authority also proposes to engage in dialogue with the various professional bodies to discuss ways in which their members can assist in the fight against money laundering. Discussions have already been held with the Institute of Chartered Accountants of Barbados and similar discussions will shortly be held with other professional organizations including the Bar Association, the Travel Agents Association and the Association of Professional Valuers.

The public also needs to be made aware of the magnitude of the threat posed by money laundering to our economy and as part of its strategic plan for 2001, the FIU is in the process of formulating a public awareness and education programme in conjunction with the Government Information Service.

Barbados is committed to working with other countries in the region and around the world to combat money laundering and the Authority has therefore established close working relationships with the Caribbean Financial Action Task Force, the Caribbean Anti-Money Laundering Programme and other regional and international agencies involved in the fight against money laundering. The necessary steps have been taken to implement the FATF and CFATF anti-money laundering recommendations and to ensure that Barbados is compliant with all of the twenty-five criteria recently used by the FATF to define “non-cooperative” countries. The Anti-Money Laundering Prevention and Control Act is currently under review and a special committee has been established by the FIU to adequately prepare for the second CFATF mutual evaluation of Barbados scheduled to take place in November this year. The Authority has also been assisting other countries in the region, some of which have found themselves on the FATF “non-cooperative” list, with the upgrading of their anti-money laundering laws and procedures and has welcomed visits from them to observe our systems. The Authority will also shortly be seeking membership to the Egmont Group, an international umbrella body of financial intelligence units, to broaden our efforts against the concealment of ill-gotten gains.

As I indicated earlier financial institutions have submitted a number of unusual transaction reports and the necessary investigations have been carried out by the FIU and appropriate recommendations made to the Director of Public Prosecutions. In addition the FIU is in the process of creating a database, with assistance form the Royal Barbados Police, for the processing and storage of reported transactions. A web page is also currently under development, which would provide ready public access to information on the work of the Authority and the FIU, the legislation and other related information.

For Barbados to be successful in its efforts to combat money laundering, close working relationships have to be maintained among a number of agencies – the financial institutions and their respective regulators, law enforcement personnel, other governmental and private sector agencies, as well as regional and international entities and of course the public. The Authority and the FIU will continue to foster such relationships to ensure that the provisions of the anti-money laundering act are adhered to and that issued guidelines are followed. It is therefore important for the FIU to be adequately funded and staffed and the Authority will continue to ensure that the necessary resources are readily made available to facilitate a successful and effective anti-money laundering programme for Barbados.

Thank you.
Desiree Cherebin – Chairperson Barbados’ Anti-Money Laundering Authority

August 13, 2001