Effectiveness and Technical Compliance

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Effectiveness and Technical Compliance evaluation of the Mutual Evaluation Report of The Turks and Caicos Islands, January 2020.

Risk and General Situation
Effectiveness
The effectiveness of risk assessment is moderate. Even though the TCI has been able to identify some money laundering and terrorist financing risks, vulnerabilities, and threats, it has not been able to consider important critical risk factors such as the cross-border movement of cash through the financial sector, and through customers.
Technical Compliance
The TCI has done a National Risk Assessment and it has used the World Bank Tool. The technical compliance is good.

Overall Level of Compliance and Effectiveness
Effectiveness
There is a moderate to low level of effectiveness. There is broad participation of agencies and private sector inputs have been responsible for collective thinking about the risks of ML and TF. The objectives of authorities responsible for ML/ TF work are not clear. The work being pursued by authorities is not risk-based because the work is both high-risk and low-risk about ML/TF. Even though the TCI has developed a national strategy for improving ML/TF investigations, there are no national priorities to address important crimes listed by the authorities. Also, the responsibilities in the National Strategy have been allocated to competent authorities (1). Moreover, the ML/TF risks presented at the TCI are not recognized by relevant authorities as high-risk priorities. Regulatory, supervisory, and law enforcement authorities did not understand the majority of ML/TF risks. At the same time, important sources of ML/TF funds originated from human trafficking, corruption, fraud, and human trafficking, and illegal immigration, these were not evaluated in the National Risk Assessment. Similarly, international crimes that were the source of ML/TF were also not addressed in the NRA. The ML/TF risks related to cross-border financial flows, internal financial flows through the financial institutions, and risks from exempt companies were not understood satisfactorily. Also, data from regulatory, enforcement, and supervisory sources were not understood and considered by the financial and DNFBP sectors.
Technical Compliance
There was satisfactory technical compliance. The National Risk Assessment gave an acceptable understanding of ML/TF risks. Also, the TCI has developed a satisfactory National Strategy for addressing the risks of ML/TF. The Anti-Money Laundering Committee was formed for coordinating risk assessment and AML/CFT policy.

Financial Intelligence, ML Investigations, prosecutions, and confiscation
Effectiveness
The effectiveness of these actions is moderate. The performance of the Financial Intelligence Agency of TCI has been good. It has coordinated well with the police force and the Financial Services Committee and ...