According to the Asia Pacific Group, which enforces the recommendations of the global anti-money-laundering Financial Action Task Force in its region, Vanuatu has criminalised money laundering and terrorist financing adequately and is now running a proper financial intelligence unit.

The APG is a so-called 'FATF-style regional body' and, as such, issued a 'mutual evaluation report' in 2015 that was highly critical of the island jurisdiction. It found gaps in Vanuatu's AML body of law and governmental organisation, inducing it to formulate an expensive plan of action in early 2016.

Since that time, according to the FATF, Vanuatu has made progress and can now boast that it has:

• adequately criminalised money laundering and terrorist financing;
• established adequate procedures for the confiscation of assets related to money laundering;
• established an adequate body of law for the identification, tracing and freezing of terrorists' assets and the assets of entities 'sanctioned' by the United Nations;
• made its financial intelligence unit fully operational and effective;
• made more strenuous efforts to prevent money laundering, especially in respect of wire transfers;
• 'established transparency' (whatever that may mean) for the financial sector and for legal persons and arrangements;
• established an adequate "supervisory and oversight programme" for the whole financial sector and for trust and company service providers; and
• opened up channels for international co-operation and "domestic co-ordination," a phrase that presumably refers to the Government ensuring that its various organs (such as the Reserve Bank of Vanuatu, the jurisdiction's regulator for offshore business, and the FIU) work in relative harmony.

The FATF will send inspectors to visit Vanuatu in the next few months (the days of real mutual evaluations, by which one country would vet the efforts of another, are long gone) to find out whether the jurisdiciton has actually started to make these reforms and is 'sustaining' them. Such a visit is normally the final step before the FATF stops subjecting it to endless reviews.