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Navigating The Complexity of Ownership From The Lens of Sanction By Extension

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Lapses in UBO Identification, Sanctions Compliance, and Corporate data

Tuesday, 30th April. 13:00 - 14:00 London Time (GMT+1)

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Louie Vargas

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Michael Harris

CFATF Successfully Concludes 4th Round Mutual Evaluation of Guyana

21 September, 2023

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The Caribbean Financial Action Task Force (CFATF) visited Guyana on September 15th to supervise their compliance framework with the Anti-Money Laundering (AML) and Financial Action Task Force (FATF) regulations and methodologies. 

The CFATF successfully concluded its 4th visit to Guyana to analyze their compliance procedure with the rigid methods according to international regulatory authorities. Several financial institutes, government, law enforcement, and state agencies, including the private sector and professional organizations, participate in this assessment. The initial findings of the investigation were presented by the mission leader, Avelon Perry, and her team to the Attorney General and Minister of Legal Affairs, Mohabir Anil Nandlall, and the Countering the Financing of Terrorism (CTF), Anti-Money Laundering (AML), and National Coordination Committee (NCC). 

According to the initial high-level outcomes, Guyana has adequate coordination for the NCC to identify and reduce threats of money laundering as well as terrorist financing. From all reports, Guyana as a jurisdiction performed brilliantly and earned praise from regulatory bodies throughout the assessment. The CFATF group also acknowledged the risk assessment Guyana concluded, including the National risk assessment in 2021 and the various dissemination among the shareholders. They also attest to the coordination of National Policy and Strategy in these actions and determined that a number of policies were completed during these risk assessments, including the latest amendments in the AML/CFT regulations and the legislative creation of Guyana Compliance Commission and the Real Estate Authority. 

Some loopholes noted in the assessment are the need for Attorneys-at-law and Accountants to understand AML/CFT laws efficiently, which was passed by the Guyana compliance authorities. Furthermore, the investigation adds Guyana needs a unified approach to conclude money laundering cases because they have in-line cases, but delays in the administration of these cases, which may have contributed to Guyana’s low rate of money laundering.

The team noted that the recent 2023 amendments have addressed some technical issues with targeted financial sanctions for financing terrorism and proliferation but that given the laws’ recent passage, internal processes for their implementation may need to be modified. The assessment team also appreciated Guyana and informed that these findings will be changed after the final review, which will conclude in May or June, at the CFATF 2024 Plenary, carried out in Trinidad and Tobago. 

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