US Department of State’s BINLEA lists Dominica among Major Money Laundering Countries of 2016

​Dominica is listed by the US Department of State Bureau for International Narcotics and Law Enforcement Affairs (BINLEA), among Major Money Laundering Countries of 2016. Twenty (20) other Caribbean Countries are included in that list. The US Department of State released the list in its March 2017 International Narcotics Control Strategy Report, on Money Laundering and Financial Crimes. The report defines a major money laundering country by statute, as one “whose financial institutions engage in currency transactions involving significant amounts of proceeds from international narcotics trafficking”.
 
Dominica is listed at number ten (10) on the list of Caribbean Countries; following Antigua & Barbuda, Aruba, Bahamas, Barbados, Belize, British Virgin Islands, Cayman Islands, Cuba and Curacao. The other Caribbean countries listed include the Dominican Republic, Grenada, Guyana, Haiti, Jamaica, St Maarten, St. Kitts & Nevis, St. Lucia, St. Vincent & the Grenadines, Trinidad & Tobago.
 
The US report says due to Dominica’s geographical location between the French territories of Guadeloupe and Martinique, the country is used as a transhipment point for narcotics and other criminal activities. It says for the past few years, money laundering cases involved fraudulent investment schemes, advance fee fraud schemes, credit card fraud schemes, and the placement of euros from criminal activities into the financial system, from the neighbouring French territories of Marie Galante, Les Saintes, Guadeloupe and Martinique.
 
The report added that Dominica has achieved technical compliance with international Anti Money Laundering (AML) standards. It says AML legislation enacted in 2014 “clearly sets out provisions with which relevant entities are bound to comply” and, “there are offenses and penalties created for non-compliance.”
 
However, the US Department of State is unsure of the country’s ability to maintain statistics on matters relevant to the effectiveness and efficiency of its AML regime, and revealed that Dominica has not started the process of monitoring agents licensed to incorporate International Business Companies or Corporations (IBC’s). 
 
The report also identified Dominica’s Citizenship By Investment (CBI) Program as having “vulnerabilities that present AML and regional security risks, and that may make it susceptible to abuse by criminal actors.”
 
The report stated that law enforcement officials continue to harness all available resources to curtail the illegal drug trade, despite the “great challenge” of the porous borders which they face, in effectively policing the various coastlines for drugs, and smuggling of goods such as firearms and cash.
 
The US report on Dominica’s money laundering status concluded however, that Dominica is not currently subject to any US or international sanctions.