The Anguilla Government has taken an early and further step, with the involvement of the public and private sectors, to achieve another clean and respectable evaluation of its critical offshore financial industry when the Fourth Round Mutual Evaluation comes up in 2020.
In order to accomplish a decent evaluation, the Government launched what has been called “the Anguilla’s National Risk Assessment” exercise on Monday, February 13. Chief Minister and Minister of Finance, Mr. Victor Banks, explained that the “exercise is to measure the island’s vulnerability to money laundering and terrorist financing” thus protecting the reputation of the financial industry of Anguilla.”
He continued: “While this is a Government-led initiative, it requires a national approach to ensure that the risks associated with money laundering and terrorist financing that affect our country are identified, understood and effectively mitigated.
“The National Risk Assessment is a necessary step in ensuring compliance with the Financial Action Task Force’s (FATF) standards on anti-money laundering and combating of terrorist financing. It underscores the Government’s continued commitment to strengthening Anguilla’s status as a well-regulated financial services centre, while demonstrating the Government’s recognition of the importance of meeting its international obligations.”
The Chief Minister further stated: “Our history, as a jurisdiction, reflects the fact that successive Governments have taken the issue of money laundering and terrorist financing seriously. Anguilla was previously evaluated by the Caribbean Financial Action Task Force during an on-site review for the Third Round Mutual Evaluation in July 2009 with the report produced in 2010. The public discussions led to the passage of the Proceeds of Crime Act 2009 and the consultation work that took place in the lead up to the Caribbean Financial Task Force Examiners’ visit to Anguilla. Since the 2009 mutual evaluation, Anguilla has made significant progress towards meeting all the international standards.” He reported that following legislative and other important steps towards having a strong regulatory framework, Anguilla had successfully passed through the Third Round Mutual Evaluation in November 2015.
Anguilla is now preparing to undergo an on-site review in 2020 as part of the Fourth Round Mutual Evaluation. The island’s Minister of Home Affairs, Mrs. Cora Richardson Hodge, is the chairperson of a recently-established National Risk Assessment Steering Council towards that end. The other Council members are the Chief Minister and Minister of Finance; Attorney General; Deputy Governor; Commissioner of Police; Director of the Financial Services Commission; Chairman of the Money Laundering Reporting Authority; Permanent Secretary, Finance; Chief of Staff at the Governor’s Office and a private sector representative.
Minister Cora Richardson-Hodge stressed that the establishment of the Steering Council “represents the Government’s political commitment to address risks associated with money laundering and terrorist financing that affect our country.”
She went on: “In the Fourth Round Mutual Evaluation, in addition to an assessment of its technical compliance, Anguilla will be assessed on effectiveness – that is: how well it is enforcing the legislation and guidelines, and how well all stakeholders (both public and private sector) are executing their functions and ensuring compliance. This means that the country must produce evidence of the effectiveness of its Anti-Money Laundering and Combating of Terrorist Financing regime, including not only required legislation, but also statistics that evidence the use of the legislation.”
The Minister added: “The experience of other jurisdictions makes it clear that completion of the exercise will take a considerable amount of time and effort by all stakeholders, both public and private. This is why the Government has found it necessary to launch Anguilla’s National Risk Assessment exercise well in advance of the proposed 2020 on – site review. This is to ensure that Anguilla is well placed to address any vulnerabilities that may be identified during the exercise.”
A key person in the exercise is the Chairman of the Anguilla Financial Services Commission, Mr. Gerry Halischuk, who also heads Anguilla’s National Risk Working Group which functions in collaboration with the Steering Council. The Working Group comprises the Head of the Financial Intelligence Investigation Unit; the Comptrollers of both Customs and Inland Revenue; Deputy Commissioner of Police; both the Deputy Director and the Senior Legal Counsel of the Financial Services Commission; the Compliance Manager in the Ministry of Finance; Crown Counsel in the Attorney General’s Chambers, Chief of Staff in the Governor’s Office and a private sector representative.
In broad terms, the “Working Group”, according to Mr. Halischuk, “will be responsible for organising and managing all aspects of Anguilla’s National Risk Assessment. This is to ensure that Anguilla is well placed to effectively identify and address the risks of money laundering and terrorist financing in Anguilla as they may arise.”
He also stated that “the Working Group will be organising a number of workshops and meetings with the various stakeholders both in the public and private sector. This will be in order to explain the exercise and gather information over the course of 2017.” Mr. Halischuk added: “The establishment of both the Steering Council and the Working Group and the active participation of top Government and public sector officials on the Steering Council, in particular the Chief Minister and the Minister of Home Affairs, emphasises the Government of Anguilla’s strong and continued commitment to ensuring a successful Fourth Round Mutual Evaluation and more generally meeting its international obligations.”
Attorney General, Mr. John McKendrick QC, said the Risk Assessment exercise was “a very real and important impact for Anguilla generally, and the financial sector in particular”. He went on: “I encourage everybody to get involved in the National Risk Assessment dialogue because the greater the dialogue we have between Government departments, the private sector, and everybody else who plays a role in financial services and combating money laundering, the greater will be the discussion and the more we will understand where our weaknesses and strengths are. It is only by having gone through that process that we can accurately and carefully assess where the risks are to financial services and crime in Anguilla.
“I think that has two very important outcomes for the people of Anguilla. First of all, if we accurately assess our strengths and weaknesses and identify our risks, then we would be more effective in combating financial crime and reducing white collar crime in Anguilla; and it would strengthen our capacity to liaise and cooperate with other jurisdictions to assist them to reduce money laundering and other white collar crimes…The second important outcome of the National Risk Assessment is by scrutinising and analysing what we are doing well and have an open dialogue about it. By that process, we will strengthen the institutions that build economic growth and success in Anguilla.”
