The Anti-Money Laundering Authority (AMLA) is the body
established under the The Money Laundering and Financing of
Terrorism (Prevention and Control) Act Cap 129 of the Laws of
Barbados, to supervise financial institutions in an effort to
prevent money laundering.
Asset Purchases
A form of business purchase in which the buyer obtains the
underlying assets of the business without assuming its
liabilities. The purchase price is allocated among the business
assets as part of the business Purchase Agreement.
Bank Secrecy
This prohibits banks to disclose information about an account
without the consent of the client.
Basel II
Basel II was initiated in 2004 to create an international
standard that banking regulators can use when creating
regulations about how much capital banks need to put aside to
guard against the types of financial and operational risks
banks face.
Beneficial Owner
The person(s) entitled to the benefits of ownership even though
another party, such as a broker or bank, has possession and
title to
Beneficiary
A person named in a life insurance policy, annuity, will,
trust, or other agreement to receive a financial benefit. A
beneficiary can be an individual, a company, an organisation,
or other type of entity.
Caribbean Financial Action Task Force (CFATF)
The Caribbean Financial Action Task Force (CFATF) is an
association of Caribbean states that have agreed to apply
common measures to address the problem of money laundering. The
CFATF created 19 Recommendations to complement the FATF’s 40
plus 9 Recommendations.
Cash Transaction
A transaction involving the physical transfer of currency from
one person to another.
Central Bank of Barbados AML/CFT Guidelines
The Central Bank of Barbados created Anti-Money Laundering
Guidelines that should be followed by financial institutions.
Co-mingling of Funds
Co-mingling of funds involves the purchase or investment in
businesses that customarily handle a high cash transaction
volume, allowing launderers to conceal illicit funds by mixing
with funds from the legitimate business as well inserting
criminal funds as false revenue mixed with income changing the
form.
Compliance
An act or process of complying with a demand or recommendation.
Corporation
A corporation is a legal entity, which is established under the
corporate laws of a particular country or jurisdiction.
Customer Due Diligence
Also known as Know Your Customer (KYC). Customer Due Diligence
involves the verification of the identity of your customers to
avoid opening accounts that could be for fictitious entities or
be used to conduct transactions that may support either Money
Laundering or Terrorist Financing activities. The basic steps
of customer due diligence begin with the identification of a
customer, the verification of the identity of the customer, the
collection of information on the customer"s purpose and
nature of the business relationship and the verification of the
source of funds and wealth.
Egmont Group
A group of Financial Intelligence Units who meet regularly to
find ways to cooperate, especially in the areas of information
exchange, training and the sharing of expertise.
Electronic Funds Transfer
An Electronic Funds Transfer (ETF) is a telegraphic transfer or
wire transfer that sends funds electronically from one city or
country to another, avoiding the risk associated with
transporting the currency.
Extortion
The use, or implicit threat of the use, of violence or other
criminal means to cause harm to person, reputation, or property
as a means to obtain property from someone else with his
consent.
Fiduciary
A fiduciary is a person who acts, holds assets, or maintains
accounts on behalf of (and for the benefit of), another person.
A fiduciary has an obligation to take such action or manage
such assets or accounts in the best interests of the other
person.
Financial Action Task Force (FATF)
The Financial Action Task Force (FATF) is a 33-member
organisation responsible for developing a world-wide standard
for anti-money laundering and combating the financing of
terrorism. Forty recommendations have been issued by the FATF
and adopted globally in the fight against Money Laundering.
Financial Intelligence Unit (FIU)
The central government authority that is responsible for
reviewing and initiating action on suspected illegal monetary
transactions.
FinCEN
The Financial Crimes Enforcement Network in the US.
Flight Capital
Flight Capital is a term used to describe the outflow of
capital from one country to another that is not part of normal
commercial or private transactions. In many cases the funds do
not return to the country of origin.
Gatekeepers
Gatekeepers are qualified professionals that may knowingly or
unknowingly facilitate the laundering of money or assets into
legitimate financial circles. Launderers will often try to use
a client account through a gatekeeper to both place funds and
to remain anonymous. Examples of gatekeepers are lawyers,
notaries, accountants, insurance companies, trust companies,
and real estate agents.
Global Tracking Lists
Global lists track persons, companies and countries with known
affiliations to either Money Laundering or Terrorist Financing.
Grantor
The person from whom a grant is made or a trust is set up.
Hawala
Also known as Hundi. A Hawala transfer is a system for
remitting money, primarily in Islamic societies, in which a
financial obligation between two parties is settled by
transferring it to a third party. Often there is no physical
movement of cash. Hawala transactions are usually based on
trust and leave no written record.
Hundi
Also known as Hawala. A Hundi transfer is a system for
remitting money, primarily in Islamic societies, in which a
financial obligation between two parties is settled by
transferring it to a third party. Often there is no
physical movement of cash. Hundi transactions are usually
based on trust and leave no written record.
Integration
Integration is often the third phase of money laundering. It
occurs once the funds are distanced from their origins and are
available to the criminal for use as legitimate funds. The
criminal is then able to re-invest funds into the financial and
business system.
Know Your Customer (KYC)
Also known as customer due diligence. KYC involves the
verification of the identity of your customers to avoid opening
accounts that could be for fictitious entities or be used to
conduct transactions that may support either Money Laundering
or Terrorist Financing activities. The basic steps of customer
due diligence begin with the identification of a customer, the
verification of the identity of the customer, the collection of
information on the customer's purpose and nature of the
business relationship and the verification of the source of
funds and wealth.
Layering
Layering is often the second phase of money laundering. It
involves the movement and distancing of the placed funds to
hide the trail of the original deposit and make the funds more
useful so they can be moved or dispersed.
Loan Back
Using this method for money laundering, a criminal provides an
associate with a sum of illegitimate money and the associate
creates the paperwork for a loan or mortgage back to the
criminal for the same amount, including all of the necessary
documentation. This creates an illusion that the
criminal"s funds are legitimate. The scheme's
legitimacy is further reinforced through regularly scheduled
loan payments made by the criminal, and providing another means
to transfer money.
Money Laundering
Money Laundering is defined as the act or attempted act of
concealing the source of money or assets that come from
criminal activity.
Money Laundering Reporting Officer (MLRO)
A Money Laundering Reporting Officer (MLRO) is the officer
nominated within a financial institution to make disclosures to
the Financial Intelligence Unit.
Money Services and Currency Exchange
The use of Money Services and Currency Exchange enables
launderers to exchange foreign currency, by money orders or
cashier/travelers cheques that can subsequently be transported
out of the country. Money can also be wired to accounts in
other countries.
NCCT List
Non-Cooperative Countries and Territories (NCCT). A list of
non-cooperative countries and territories generated by the
Financial Action Task Force (FATF).
Nominee
A person in whose name title to real estate or ownership of
stock is held but who is not the actual proprietor or holder.
Office of Foreign Assets Control (OFAC)
The Office of Foreign Assets Control (OFAC) is a division of
the US Treasury Department which administers large sanction
lists that are country-based. The lists identifies potential
high risk money launderers, terrorist financers and drug
traffickers country individuals. These country lists may also
be covered under Non-Cooperative Countries and Territories
(NCCT) lists.
Placement
Placement is the first stage of the money laundering process.
It involves the process of placing illegitimate funds, through
deposits or other means, into traditional financial
institutions.
Politically Exposed Persons (PEPs)
Politically Exposed Persons are individuals who are or who have
been entrusted with prominent public functions and who can be
high risk due to their ability to move from country to country
without arousing suspicion and their access to very wealthy and
powerful networks leading to corruption. Some examples include
heads of government or state, members of the executive council
of government and members of a legislature.
Private Banking
Private banking is defined as special banking services
typically offered to high net worth clients with assets in
excess of $1 million.
Red Flags
Red Flags are actions or patterns of transactions that may
suggest illegal behaviour.
Refining
Refining is a money laundering method that involves the
exchange of small denomination bills for larger ones. An
individual may convert the bills at a number of different banks
in order not to raise suspicion. This serves to decrease the
bulk of large quantities of cash.
Specially Designated Nationals (SDNs) and Blocked Persons
Specially Designated Nationals (SDNs) and Blocked Persons. are
individuals from all over the world whose property is subject
to blocking (for example, restricted travel and monitoring of
financial assets).
Structuring ("Smurfing")
Structuring or ‘smurfing’ is the deposit of small amounts of
cash into any number of banks and/or bank accounts.
Suspicious Transaction
A suspicious transaction is a transaction whereby the last
point of contact has reasonable grounds to suspect that the
transaction may be linked to tax evasion, criminal offences or
terrorist acts. It should be reported if there is a suspicion
on the circumstances involved (the person or the transaction
itself).
Suspicious Transaction Report
A suspicious transaction report is sent to the Financial
Intelligence Unit (FIU) by financial institutions when
transactions are deemed suspicious of being related to criminal
or terrorist activity.
Tax Haven Countries
Tax Haven Countries offer special tax incentives/avoidance to
foreign investors and depositors.
Terrorist Financing
Terrorist Financing is a broad term that is defined as the
channels and methods used to provide financial support to
individuals and groups who encourage, plan, commit or assist in
acts of terrorism because of political, religious or
ideological reasons.
The Money Laundering and Financing of Terrorism (Prevention and
Control) Act Cap 129 of the Laws of Barbados
This act was created to help prevent and control Money
Laundering and related matters in Barbados to bring the
regulatory regime in line with international best practice.
Threshold Transaction (Barbados)
A threshold transaction in Barbados is defined as the transfer
of currency where the amount is $10,000 BDS or more.
Tipping
Tipping occurs when information or any other matter which might
prejudice the investigation is disclosed to the suspect of the
investigation (or anyone else) by someone who knows or suspects
(or, in the case of terrorism, has reasonable cause to suspect)
that: a police investigation into money laundering has begun or
is about to begin, or the police have been informed of
suspicious activities, or a disclosure has been made to another
employee under internal reporting procedures.
Trustee
Trustee refers to a holder of property on behalf of a
beneficiary. A trust can be set up either to benefit particular
persons, or for charitable purposes.
Trusts
A trust is a legal entity or arrangement in which financial
assets and securities are held by one person (the trustee) in
trust for the benefit of another person or group of persons
(the beneficiaries).
Unusual Activity
Transactions that fall 'outside the range of normal
behaviour'. For example, deposits or withdrawals that fall
just below the reporting threshold.
Value Tampering
Value tampering is the purchase of property from owners who
agree to sell their property, on paper, at a price below its
actual value and then accept the difference of the purchase
price "under the table".
World Check
World Check is a risk intelligence repository containing
detailed profiles of terrorists and those who finance
terrorism, money launderers, and many other high-risk
individuals and entities. It also covers Politically Exposed
Persons (PEPs) worldwide.