The National AML/CFT Coordinating Council (“NAMLCC”) remains steadfast in its mission to protect the Virgin Islands from the evolving threats of money laundering (“ML”), terrorist financing (“TF”), and proliferation financing (“PF”). In pursuit of this objective, NAMLCC continues to make significant strides in safeguarding the financial and security landscape of the Virgin Islands.
In 2021, NAMLCC introduced the Virgin Islands’ inaugural National AML/CFT Policy and a three-year Strategy, aimed at mitigating ML and TF risks. These foundational documents were designed to address the ML/TF risks outlined in the Virgin Islands’ 2016 National Risk Assessment (NRA) and ensure compliance with international standards.
Since then, a series of ML, TF, and PF risk assessments have been conducted. These efforts, combined with insights from the Fourth Round Mutual Evaluation Report (MER), have provided a more comprehensive understanding of the Virgin Islands' current and emerging ML, TF, and PF risks.
As a result of these findings, NAMLCC approved an updated National AML/CFT/CPF Policy and accompanying Strategy for 2024-2026 in June 2024. These updates are in line with FATF Recommendation 2, which requires that AML/CFT policies be informed by regularly reviewed risk assessments. The updated documents will provide a clear and focused approach to mitigating the distinct risks associated with ML, TF, and PF.
Speaking on the importance of this initiative, Premier Dr the Honourable Natalio Wheatley, Chairman of NAMLCC, stated: "As we continue to face the ever-evolving threats of money laundering, terrorist financing, and proliferation financing, it is essential that the Virgin Islands remains agile and proactive in our response. The revised Policy and Strategy are critical steps forward in safeguarding the Virgin Islands’ financial system and ensuring compliance with international standards. We are committed to working closely with all stakeholders to implement these strategies effectively, and to ensure that the Virgin Islands remains a safe and secure jurisdiction for legitimate business."
One of the key revisions addresses feedback from the MER, which highlighted the need to differentiate between the actions taken to address ML, TF, and PF risks. In response, the updated Policy and Strategy are now organized into three separate sections, each dedicated to the unique challenges of ML, TF, and PF. This allows for a more targeted approach to risk management and strategic planning.
The revised Policy outlines the Virgin Islands' legislative and institutional framework for combatting ML, TF, and PF. It also clarifies the Virgin Islands' jurisdiction over legal persons and arrangements formed in the Virgin Islands—a key area of concern noted in the MER. The Policy retains its focus on six critical areas: prevention, detection, investigation and sanction, regulation, articulation, and promotion of cooperation. However, each of these areas now includes specific policy objectives tailored to address ML, TF, and PF risks independently.
The 2024-2026 Strategy serves as a roadmap for implementing the objectives outlined in the revised Policy. It details the necessary actions to be taken over the next three years to effectively mitigate the risks posed by ML, TF, and PF. The Strategy also identifies the key stakeholders responsible for executing these actions and emphasizes the importance of coordination and cooperation across agencies.
A central focus of the new Strategy is addressing the risks posed by legal persons and legal arrangements. This includes strengthening mechanisms for detecting, regulating, investigating, and sanctioning such entities. The Strategy also underscores the importance of cooperation among competent authorities and law enforcement agencies, as effective collaboration is critical to the success of the Virgin Islands' AML/CFT/CPF regime.
Both the updated Policy and Strategy include a robust monitoring and evaluation process to ensure that the actions taken align with the stated objectives and that the Virgin Islands continues to comply with all relevant international standards.
Together, the revised Policy and the 2024-2026 Strategy form a cohesive plan aimed at strengthening the Virgin Islands' ability to combat ML, TF, and PF. NAMLCC remains committed to ensuring that the Virgin Islands’ AML/CFT/CPF regime is effective, up-to-date, and capable of responding to emerging threats. Through these efforts, the Virgin Islands will continue to protect its economy and uphold its compliance with FATF standards.