Entity combating financial corruption issues policy directives

by Linda Straker

• 5 policy directives published in 17 April 2025 edition of Government Gazette
• All regulated entities to conduct enhanced due diligence measures proportionate to risk arising from high-risk jurisdictions
• Failure to register with commission can result in EC$5,000 fine

The Anti Money Laundering/Counter Terrorism Financing Commission, which is one of the entities combating financial corruption, has issued 5 policy directives aimed at reminding the relevant stakeholders about their mandatory obligations under the Proceeds of Crimes Act — the law which established the entity.

Published in the 17 April 2025 edition of the Government Gazette, the policy directives/notices are signed by Willan Thompson, Chairman of the Commission and are addressed to “All Regulated entities; All financial institutions and Designated Non-Financial Business and Professionals (DNFBPs) and All Supervisors of Regulated entities.”

Backdated to September 2024, the directives said that all regulated entities are reminded of their obligations to include/adhere to CDD requirements and identification of associate PEPs, foreign PEPs and International Organisational PEPs.

In financial regulation, a politically exposed person (PEP) is one who has been entrusted with a prominent public function while Customer Due Diligence (CDD) is a crucial process in financial crime prevention, requiring institutions to identify, verify, and monitor customer relationships to prevent and detect illegal activities like money laundering and terrorist financing.

“All DNFBPs are required to report annually to the AML/CFT Commission of their compliance with CDD requirements relating to identification of associate PEPs, foreign PEPs and International Organisational PEPs,” said sub section (b) of the notice.

Policy directive 5 states that all regulated entities are required to take/conduct Enhanced Due Diligence measures proportionate to the risk arising from high-risk jurisdictions of Iran, the Democratic People’s Republic of Korea (DPRK) and Myanmar.

“These jurisdictions have significant strategic deficiencies in their regimes to counter money laundering, terrorist financing, and financing of proliferation. Regulated entities are to apply countermeasures to protect the international financial system from money laundering, terrorist financing, and proliferation financing (ML/TF/PF) risks emanating from these countries. This list of countries is often externally referred to as the “blacklist” countries,” said the notice.

The vision of the commission, which is currently located at the National Stadium, is to “Develop an Effective National System for Combating Money Laundering and Terrorism Financing,” while its mission is to ensure a “Robust Financial Infrastructure to Combat against Money Laundering and Terrorism Financing.”

As a result, all designated non-financial business and professionals including professionals such as lawyers and law firms, accountants and accounting firms, real estate agents and real estate firms, car dealers and jewellers as wells as charities, foundations, civil society organisations and non profit organisations such as church and political parties must register with the commission. Failure to register can result in a EC$5,000 fine and to a further EC$300 for each day the offence continues.

The commission’s purpose is to

• Advise the Minister of Finance in relation to the detection and prevention of money laundering in Grenada
• Issue amendments to the Proceeds of Crime Act (POCA) Guidelines from time to time
• Advise the Minister as to the participation of Grenada in the international efforts against money laundering and terrorist financing
• Regulate anti-money laundering activities and provide education and training

The principal function of the commission is to implement the anti-money laundering policies of the regional Financial Action Task Force (FATF), which is an intergovernmental body established in 1989 by the Group of Seven countries (G7) to combat money laundering and terrorist financing.