Anti-Money Laundering and Counter-Terrorist Financing
The obligations framework
Barbados's AML/CFT regime is built on the Money Laundering and Financing of Terrorism (Prevention and Control) Act, regulations and guidance issued by the FIU as supervisory authority for AML/CFT compliance. Financial institutions and designated non-financial businesses and professions - including trust and company service providers, lawyers, accountants, real estate agents and dealers in precious metals - must operate a risk-based programme.
The five pillars
Candidates must know the pillars: (1) written internal policies, procedures and controls approved at senior management level; (2) appointment of a compliance officer with authority and resources; (3) ongoing employee training; (4) independent testing and audit of the programme; and (5) customer due diligence (CDD). CDD requires identifying the customer and verifying identity using reliable, independent sources, identifying beneficial owners (generally those holding a specified ownership or control threshold), understanding the purpose and intended nature of the relationship, and conducting ongoing monitoring. Enhanced due diligence applies to politically exposed persons, correspondent relationships and higher-risk jurisdictions; simplified measures are permitted only for demonstrably lower-risk situations.
Reporting and record-keeping
Institutions must file suspicious transaction reports with the FIU promptly, without tipping off the customer, and maintain records for the statutory period. Tipping-off is a criminal offence. Sanctions screening against terrorist lists is mandatory.
Traps and rule of thumb
Traps include confusing identification with verification (collecting a name versus checking a passport), assuming reliance on a third party removes liability, and forgetting that CDD is continuous, not a one-off onboarding step.
Rule of thumb: Identify, verify, understand, monitor, record, report. If any element is missing, the file is deficient regardless of how well the relationship performed.