HM Treasury has published its latest advisory notice on the subject of money laundering and terrorist financing controls in ‘higher risk jurisdictions,’ naming the Bahamas as one such jurisdiction on the strength of a decision by the Financial Action Task Force, the world’s AML standard-setter.

Regulation (33)(6)(c) of the UK’s Money Laundering Regulations 2017 obliges firms (‘relevant  persons’) to take into account “geographical risk factors” when assessing risk and the extent of measures to offset that risk. These risk factors are said to include the issue of whether a country is identified by a credible source such as a report published by the FATF as one that is not doing enough to counter money laundering and terrorist financing in a way that is consistent with the FATF’s recommendations.

The Treasury says that the Bahamas still needs to (1) develop an electronic case management system for international co-operation; (2) demonstrate a risk-based supervision of non-bank financial institutions; (3) give the right people timely access to accurate basic and beneficial ownership information; (4) increase the quality of the financial intelligence unit’s 'products' to help police conduct complex and stand-alone money-laundering investigations; (5) show the FATF that the authorities are investigating and prosecuting all types of money laundering, including complex cases; (6) show that confiscation proceedings are concluded for all types of money-laundering cases; and (7) close gaps in the jurisdiction’s efforts against terrorist finance.