Combating And Training Against Money Laundering

In fact, in 2000 when The Bahamas was blacklisted, the government of The Bahamas had taken an unusual step to repeal the historical bank secrecy law of The Bahamas within less than six months. The legislation for the elimination of bank secrecy was passed into law along with other regulatory laws intended to tighten banking laws as well as the removal of The Bahamas from the blacklist.

Having achieved these obstacles, The Bahamas must not become comfortable, ignoring the need for continuity and preparedness in proactively dealing with its regulatory, inspection, compliance and enforcement system. These functions to a great degree have been very effective in recent years prompting the Financial Action Task Force decision to remove The Bahamas from the "Watchlist". However, we must remember that the Financial Action Task Force operational approach is continuity in observation and The Bahamas is not free of future action if The Bahamas jurisdiction becomes deficient in its management of the banking systems to ensure that no form of money laundering can happen without being detected and prosecuted.

Towards this end, the various regulatory authorities must seek to investigate all financial institutions in the country to ensure that systems are put in place to ascertain the mechanism in place for staff training, particularly in Anti-Money Laundering. This is important because the topologies of money laundering is changing as people get smarter at disguising funds, the system must adapt to track criminals and evaders from using The Bahamas' financial system.

The emerging trend of politically exposed persons being shown to be frequently connected with most money laundering, raises further questions on The Bahamas' preparedness to deal with the trend. Political exposed persons (PEP) have been global problems, as various corrupt regimes around the world sought for avenues to hide their stolen money. Due to these PEP’s high level of international and local connections, they are able to infiltrate the banking system of any country including the United States of America, United Kingdom, France, Switzerland, and The Bahamas.

Are the banks in The Bahamas providing enough budgetary allocation to train their staff in money laundering issues and development? Certainly, the answer to that is no! However, this does not suggest that the banks are not providing adequate training for compliance officers. The issue of money laundering goes beyond compliance to being knowledgeable about the different topologies of money laundering as well as emerging trends. In a recent publication by a money-laundering organization based in Miami, the organization stressed the fact that these trends will continue to evolve and banks and financial services providers must continue to be vigilant, taking extra precaution to stay ahead of the game.

Among the issues raised is the adequacy of training that the present compliance personnel are getting. Being compliant in respect to The Bahamas Anti-money Laundering legislation and its strict adoption in financial services transaction does not adequately protect banks and the nation from money laundering. The key aspect of money laundering protection and compliance falls on the ability of banks' staff to detect the different money laundering topologies that comes their way in the process of dealing with clients. Money laundering detection will be extremely difficult if the staffs are not periodically trained on burning money laundering issues, and safeguarding techniques.

The Bahamas Compliance Officers Association is doing a fantastic job in the development of mechanism to ensure the strict compliance to The Bahamas financial regulatory requirement and the development of competent members that are competent to deal with compliance issues. However, we must look beyond regulatory compliance to topologies and the ability of money launderers to adapt its practices to regulatory requirements, which will make compliance not sustainable to detect breaches. This is where anti-money laundering training becomes strategic to The Bahamas to ensure that we do not go back to old regime of money laundering deficiencies.

The Central Bank of The Bahamas must ensure that its supervisory personnel checks for banks training programs with a view to enforce the regular and periodic training in anti-money laundering. Anti-money laundering training must be vigorously pursued and a censor must be made against any financial services institution in The Bahamas that does not allocate substantial budgets for the continued training of its staff. The removal of The Bahamas from the FATF "Watchlist" did not come on a platter of gold, hence the various regulatory and enforcement authorities must ensure that training is strictly and methodologically implemented.