June 12, 2021

The Editor speaks: 274 Page Mutual Evaluation Report

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Colin Wilson

If I was to tell you I have read the very recently published Mutual Evaluation Report on “Anti-money laundering and counter-terrorist financing measures” you would know I was lying. It is 274 pages to wade through.

It went live yesterday (18) on the government website : https://www.cfatf-gafic.org/index.php/documents/4th-round-meval-reports.

We received the Press Release early this afternoon.

Premier Alden McLaughlin said:

“The Cayman Islands remain fully committed to upholding the highest global standards on money laundering and terrorist financing. Our anti money laundering and counter financial terrorism action plan will send a clear signal that we intend to maintain those standards.”

And:

“A dedicated task force, comprised of a cross section of government agencies, has been appointed to oversee the implementation of a comprehensive action plan and we are confident that all of the concerns identified in the CFATF report will be remedied within the one-year timeframe.”

When a government minister, even if it the premier, says he is confident I have to shake my old head, even if is a very slow shake now.

Too many ministers show no surprise at all when their published “confidences” are not met. I am utterly amazed if their confidences are met.

You see, we are in a world of compliance.

The big boys make sure us smaller, and the very small like us boys, comply. Even when they themselves are regularly found out they don’t comply.

They get a smack across the wrists and we get booted out of the park.

Just look at how our individual payments into our banks are scanned. Anything over ten thousand dollars and they want to know where we got it and the proof of where we got it and the person who gave it to us has also got to provide proof. The proof it wasn’t money laundered.

However, if you a big, big, player at the bank, and depositing millions, the due diligence is just hog wash. Proof. Well “Show me, whilst I close my eyes!”

Now, just look at the bodies who are supervising the Cayman Islands AML/CFT framework:

Cayman Islands Monetary Authority, the Department of Commerce and Investment, Cayman Islands Institute of Professional Accountants and Cayman Islands Legal Practitioners Association. Plus “others”.

The same groups that have ‘supervised’ Cayman Islands companies who have been found guilty (not by these groups mentioned) by mone-laundering.

It used to be in my day that “letters after your name baffled brains”. Now it’s the number of professional bodies that guard our money from crime syndicates.

The Royal Cayman Islands Police Service (RCIPS) is also said to be in the process of “enhancing its financial crimes unit with greater focus on money-laundering and terrorist financing investigations”.

“In addition the local police service has engaged with the UK’s National Crime Agency, to arrange for the secondment of personnel to conduct an overall strategic crime threat/risk assessment for the Cayman Islands. This assessment will include an analysis of risk in the financial sector.”

Presumably they are also going to look into all the money-laundering that has been going on through all the voluntary organisations that are now closing down through the rigors of the new legislation brought in to monitor them.

Now to start on page 1 of the 274 I have to wade through – over the next year, or two.

Will it stamp out money-laundering and terrorist financing investigations in the future?

No comment on that. If it keeps us in the expanding pool of compliance then it is all to the good. Just look at the cost but it does give more jobs to the boys.

I shall return later and provide you with my very own “Mutual Evaluation Report”. Number of pages ONE!

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