PRESENTATION ON

ANTI-MONEY LAUNDERING & COMBATING THE

FINANCING OF TERRORISM (AML/CFT):
BACKGROUND AND RECENT UPDATES
&
TEN KEY OBLIGATIONS

TO
BELIZE INTERNATIONAL FINANCIAL SERVICES
ASSOCIATION (BIFSA)

BY AMB. A. JOY GRANT

DIRECTOR, FINANCIAL INTELLIGENCE UNIT (FIU)
10 MAY 2016

Financial Intelligence Unit 4998 Coney Drive, Belize City (501) 223-2729/223-0596

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It is a pleasure for me to present at your Spring Seminar on the cutting edge issue of
Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT).
I believe that there is need for more effective communication and outreach between the FIU
and a cross section of stakeholders as well as the public on an issue that increasingly is the
subject of much discussion and debate. In my short tenure, I have come to realise that there is
much misunderstanding and many misconceptions about the role of the FIU and our obligations
to curb the scourge of money laundering and terrorist financing. I am heartened that
associations such as BIFSA are interested and remain engaged in these issues and undoubtedly
will partner with the FIU in fostering understanding among its members who on a daily basis
are required to implement measures to mitigate the risks of money laundering and terrorist
financing.
The FIU has been in the news in recent weeks with headlines detailing arrests at the airport or
borders of individuals who violate the ban on large amounts of currency leaving the country or
fail to declare currency in excess of the stipulated amount when leaving or entering Belize.
While the currency declarations might be the most obvious connection that the general public
makes with anti money laundering efforts, and the FIU, the issue of AML/CFT is much wider in
perspective.
I will use this presentation to highlight briefly the international context of money laundering to
set the stage for measures taken at the domestic level to address this problem.

What is Money Laundering?

Money Laundering refers to a financial transaction or scheme that aims to conceal the identity,
source and destination of illicitly obtained money. By that definition, one can surmise that
money laundering has been a part of most societies for decades, but has been difficult to detect
because of the covert nature of the business.
As persons involved in the financial sector, you will be among the first to be contacted by a
money launderer who is seeking to legitimize his illicit earnings through legitimate institutions
such as banks and other financial service providers. You may unwittingly have entertained and
assisted many in the past but, with rigorous attention and understanding of your risks and
adherence to clearly defined regulations on Customer Due Diligence (CDD), these illicit schemes
may be reduced considerably.
Money laundering has become more prominent on the international radar since the late 1980s.
It is a global problem and a global approach has been adopted to address it.

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The Offence of Money Laundering
A person commits the offence of Money Laundering if the person knowing or having reasonable
grounds to believe that any property in whole or in part, directly or indirectly represents any
persons proceeds of crime -

 Converts or transfers that property for the purpose of concealing or disguising the illicit
origin of the property or assisting any person who is involved in the commission of the
crime to evade the legal consequences of his actions.
 Conceals or disguises the true nature, source, location, disposition, movement rights
with respect to or ownership of that property1.

International Action: Development of Global Standards

The 1998 United Nations Convention against the illicit traffic in Narcotic Drugs and Psychotropic
substances is the first international legal instrument to define and criminalize money
laundering. Subsequently in September 2003 and December 2005 respectively, the UN
Convention against Transnational Organised Crime and the UN Convention against Corruption
came into force.2
According to the UN Office on Drug and Crime, “both instruments widen the scope of the
money laundering offence by stating that it should not only apply to the proceeds of illicit drug
trafficking, but should also cover the proceeds of all serious crimes. Both Conventions urge
states to create a comprehensive domestic supervisory and regulatory regime for banks and
non bank financial institutions, including natural and legal persons, as well as any entities
particularly susceptible to being involved in a money laundering scheme. The Conventions also
call for the establishment of Financial Intelligence Units3” at local level.
Following the terrorist events of September 2011, the link was made between terrorism,
transnational organised crime, the international drug trade and money laundering. UN Security
Council Resolution 1373 of September 28, 2001 imposed obligations on Member States to put
measures in place for:

 the prevention and suppression of financing terrorist acts;

 the criminalisation of terrorism related activities and the provision of assistance to carry
out these acts; and
 the exchange of information and denial of funding and safe haven for terrorists.

1
MLTPA, section 3
2
UNODC website: https://www.unodc.org
3
UN Instruments and Other Relevant International Standards on Money Laundering and Terrorist Financing: The
United Nations Conventions and Resolutions. https://www.unodc.org/unodc/en/money-laundering/Instruments-
Standards.html

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Subsequent UN Security Council Resolutions4 called for more stringent measures to address
terrorist financing.
It is long recognised that as an individual country, one cannot fight money laundering and
terrorist financing alone. Rather, it requires international cooperation with focused strategies
aimed at attacking the economic power of criminal or terrorist organisations and individuals, to
weaken them by preventing them from benefitting from or making use of, illicit proceeds.
Belize, as a member of the international community, has no choice but to adhere to the
dictates of the international agenda in this regard. Lack of compliance with UN Security Council
Resolutions will undoubtedly ruin the country’s international standing, could lead to harsh
international sanctions such as blacklisting, and negatively affect the country’s ability to attract
donor funding so essential to our national development.

Financial Action Task Force (FATF)

In addition to the UN, another key international player on the anti-money laundering platform
is the Financial Action Task Force (FATF). In response to mounting concern over money
laundering, the FATF was established by the G-7 Summit held in Paris in 19895. Recognising the
threat posed to the banking system and to financial institutions, the G-7 Heads of State and
President of the European Commission convened the Task Force from the G-7 member States,
the European Commission and eight other countries. Currently, FATF comprises of 35 member
countries and two regional organisations6. Nine FATF-Style Regional Bodies (FSRBs)7 are
Associate Members of FATF.
The objectives of the FATF are to set standards and promote effective implementation of legal,
regulatory and operational measures for combating money laundering, terrorist financing and
other related threats to the integrity of the international financial system 8. In 1990, after
studying money laundering trends and techniques, FATF issued a set of 40 Recommendations
intended to provide a comprehensive plan of action needed to fight against money laundering.
These included recommendations for improving national legal systems, intensifying domestic
and international cooperation and enhancing the role of the financial sector in the fight against
money laundering.

4
UN Security Council Resolution 1267 (1999), 1373 (2001) 1540 (2004) 1566 (2004) and 1624 (2005) all call on
Member States to take specific steps to combat terrorism
5
http://www.fatf-gafi.org/about/historyof the fatf/
6
http://www.fatf-gafi.org/about/membersandobservers/
7
) The Caribbean Financial Action Task Force (CFATF), of which Belize is a member, is an example of an FSRB
8
http://www.fatf-gafi.org/about/whatwedo/

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In 2001, Nine Special Recommendations9 were added to address the emerging threat of
terrorist financing10 underscoring the intrinsic link between the proceeds of, and funding for,
terrorist activities with money laundering.
In 2012, after a thorough review and extensive consultation, the FATF published the revised
FATF Recommendations, now referred to as “The FATF Standards”. The FATF Standards are
universally recognised as the international standard for AML/CFT.11

Caribbean Financial Action Task Force (CFATF)

At the regional level, the Caribbean Financial Action Task Force (CFATF) was created in the
1990s. It is an organisation of 27 states and territories of the Caribbean Basin12 that have
agreed to implement common anti-money laundering measures in accordance with the FATF
Recommendations and other relevant international instruments.13 As noted previously, Belize
is a member of the CFATF. The main objective of CFATF is to achieve among its members,
effective implementation of, and compliance with, the FATF Standards. Its primary tool for
achieving that objective is the mutual evaluation review process.

Mutual Evaluation Review Process

The Mutual Evaluation Review Process is a peer review mechanism aimed at ensuring that
CFATF members comply with the FATF Standards. This mechanism ensures that there is an
objective and robust assessment by a team of AML/CFT experts from the Region. The multi-
national team assesses compliance through a stringent country evaluation.

9
Complete list of the most recent FATF Recommendations available at http://www.fatf-
gafi.org/publications/fatfrecommendations/documents/fatf-recommendations.html
10
Terrorist Financing is an integral part of the FATF recommendations. See Recommendation 5 (Criminalisation of
Terrorist Financing) Recommendation 6, (Targeted financial sanctions related to terrorism and terrorism
financing), Recommendation 7 (Implementation of targeted financial sanctions as called for by the United Nations
Security Council and Recommendation 8 (Measures to prevent misuse of Non Profit Organisations)
11
The FATF Standards comprise of the Recommendations and their Interpretive Notes, together with the
applicable definitions in the Glossary.
12
https://www.cfatf-gafic.org/index.php/home/cfatf-overview
13
Members agree to adopt and implement the 1988 UN Convention against Illicit Traffic in Narcotic Drugs and
Psychotropic substances, the 2001 UN Convention against Transnational Organized Crime, and the 2005 UN
Convention Against Corruption (known, respectively, as the Vienna Convention, Palermo Convention and Merida
Convention).

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At the end of the assessment process, the team’s findings are compiled into a report, called a
Mutual Evaluation Report. That report is then provided to the assessed country for comment
and a revised draft is circulated to the other CFATF member countries for comment. The final
draft is then presented by the Assessment Team and assessed country to the CFATF Plenary for
discussion and approval by all members. The report as adopted by Plenary is then published.14
Two critical parts of the Mutual Evaluation Report are the identification of deficiencies in a
country’s AML/CFT regime and assessor recommendations for remedial action. If a country is
deemed to have significant deficiencies in its AML/CFT regime, it is firmly directed to expedite
the pace of national efforts to rectify the shortcomings and may be referred to the
International Cooperation Review Group (ICRG) for assistance in this regard.
You may have been aware that, in 2011, Belize was rated partially compliant or non-compliant
with fourteen (14) of the FATF Key and Core Recommendations; Recommendations which are
considered essential to an AML/CFT regime. Belize was referred to the ICRG and an action plan
was developed. At the 2012 CFATF Plenary, Belize was placed on an enhanced follow up
process because of the slow pace at which the AML/CFT deficiencies were being addressed.
In 2013, Belize again reported on the actions taken in an effort to implement the assessor
recommendations. At that point, CFATF issued a negative Public Statement identifying Belize as
having strategic deficiencies in its AML/CFT regime and for not moving expeditiously to rectify
them.
A portion of the CFATF statement read as follows15:
Belize has taken steps towards improving its AML/CFT compliance regime
including improvements in criminalization of money laundering, strengthening
its customer due diligence requirements and the requirements of freezing
terrorist assets. However the CFATF has determined that Belize has failed to
make sufficient progress in addressing its significant strategic AML/CFT
deficiencies including certain legislative reforms.
The next step would have been for CFATF to call on its member countries to impose counter
measures against Belize to protect their financial systems from the risk presented by Belize.
In essence, the country was on the verge of being blacklisted.
Belize also faced the possibility of being referred to the FATF’s International Cooperation
Review Group to face further sanctions.

14
https://www.cfatf-gafic.org/index.php/documents/cfatf-resources/6693-procedures-for-the-fatf-fourth-round-
of-aml-cft-mutual-evaluations-1
15
CFATF Public Statement FATF Publications and documentation www.cfatf-gafic.org/index.php/member-
countries/a-d/ Belize

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Belize, in response to the Public Statement, redoubled its efforts and, in 2014, passed
numerous pieces of legislation. Legislative measures included comprehensive amendments to
the Money Laundering and Terrorism (Prevention) Act (MLTPA). These amendments included:

 Strengthening customer due diligence, record keeping, compliance and reporting

obligations for financial institutions and Designated Non Financial Businesses and
Professions (DNFBPs);
 Enhancing compliance with CFT obligations, particularly freezing and confiscating
terrorists assets, expedited implementation of targeted financial sanctions by the UN
Security Council; clarifying listing and delisting procedures and including Non Profit
Organisations (NPOs) in the AML/CFT supervisory regime;
 Establishing the National Anti-Money Laundering Committee (NAMLAC) as a statutory
body; and
 Extension of AML/CFT framework to Designated Non-financial Businesses and
Professions.
In response to these positive developments in Belize, the CFATF issued a Statement, indicating
that Belize no longer posed a risk to the international financial system. In May 2015, the CFATF
determined that Belize successfully qualified to exit both the ICRG review and the CFATF follow
up processes. In October 2015, it was further determined that Belize should be removed from
the pool of countries awaiting review by the FATF ICRG.
Despite this positive development, it does not mean that we should rest on our laurels or be
lulled into complacency. There will need to be ongoing measures taken by all our stakeholders,
including the financial sector, to ensure that Belize remains FATF compliant. Belize must now
prepare to undergo the Fourth Round of Mutual Evaluations.

Fourth Round of Mutual Evaluations

The Fourth Round Evaluations will focus on effective implementation of the country’s AML/CFT
regime and whether certain specified outcomes are being achieved. It will no longer be
sufficient to comply “on paper”. The public and private sector will both have to demonstrate
compliance in actual practice. Although Belize is not scheduled to undergo evaluation for some
time, preparation must begin now.
At this stage, it is critical that Belize fulfils its obligation under FATF Recommendation 1 in
executing a National Risk Assessment. The National Risk Assessment is crucial for a country to
identify, assess and understand the threats, vulnerabilities, and impact that money laundering
and terrorist financing present in that country. This is distinguished from the usual risk
assessment conducted by financial institutions in the course of their routine business
processes.

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The National Anti-Money Laundering Committee will commence this exercise for Belize this
year.

Domestic Action: Belize’s Implementation of International Standards

Money Laundering and Terrorism (Prevention) Act, 2008
The Money Laundering and Terrorism (Prevention) Act, 2008 (MLTPA), which came into force in
January 2009, established provisions for the investigation and prosecution of money
laundering, terrorism, terrorist financing and other related crimes. The MLTPA sought to
implement the 2001 FATF 40 plus 9 Recommendations. The Act defines the offences of money
laundering16, terrorism17 and terrorist financing18 and the penalties involved for each19. It also
outlines some of the powers of the FIU as they specifically relate to the AML/CFT regime20 and
establishes the role and sanctioning powers of AML/CFT supervisory authorities21 . Other
provisions include:

 Investigative powers, including power to search and seize;

 Procedures for the freezing and forfeiture of criminal proceeds and terrorist property;
 Requirements for relevant entities to take preventive measures to help combat money
laundering and terrorist financing;
 Penalties for violations of the Act; and
 Establishment of the Confiscated and Forfeited Assets Fund.

Since 2009, there have been several amendments to the Act, all aimed at bringing the law into
compliance with FATF Recommendations. As stated previously, comprehensive amendments
were made to the MLTPA in 2014. The Act was more recently amended in April 2016, to further
strengthen compliance with FATF standards, implement UN Security Council Resolutions 2178
and 2253 in response to growing global terrorist threats and to streamline the currency
declaration process.

16
MLTPA, section 3
17
MLTPA, section 5
18
MLTPA, sections 68 and 69
19
MLTPA, sections 4 and 5, respectively
20
MLTPA, section 11
21
MLTPA, sections 21, 22 and Schedules 3 and 5.

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MLTPA as amended in 2016: Main Changes
These are the more critical components of the amendments:

 Clarify the conduct that is prohibited in the context of terrorism and terrorist financing,
including funding individual terrorists or terrorist organisations, and provides expanded
definitions on terrorism to include planning and preparation, recruitment, training and
travel related to carrying out terrorist activities.
 Define “cash” to include stored value instruments such as prepaid cards.
 Rules for cash declarations for persons travelling to and from Belize are changed. The
threshold for making a cash declaration is now raised from BZD$10,000 to BZD$20,000.
Cash declarations are now reconciled with Customs declarations in line with the
recently enacted Customs Regulation (Amendment) Act, No. 6 of 2016, and the
Memorandum of Understanding signed in February 2016 between the FIU and the
Customs Department. This means cash declarations should be made to Customs
Officers at your point of departure from or arrival into Belize. It is no longer necessary
to come to the FIU to make a cash declaration.
 The ban on leaving Belize with more than BZD$20,000 in cash is now repealed. Persons
who wish to take currency out of, or bring currency into Belize, must comply with the
Exchange Control Act and Regulations.
 With regard to reporting entities, Sections 16 and 17 of the Act have been amended to
remove the BZD$6,000 threshold requirement for recordkeeping applicable to casinos.
It also requires casinos to report all transactions of BZD$6,000 or more. There is further
clarity on the authority of the Financial Intelligence Unit to require information from
any person to clarify or amplify information disclosed in a Suspicious Transaction Report
(STR).
 Section 15(6A) of the Act discontinues the requirement to terminate a business
relationship for failure to renew identification information. It now requires reporting
entities to terminate a business relationship only when they are unable to undertake
ongoing monitoring of the business relationship. This brings the Act in line with the
FATF Standards.

National Stakeholders involved in the AML/CFT Process

I think it important at this juncture to clarify the role of the different stakeholders involved in
the AML/CFT process so as to dispel the confusion that often arises about who does what. Key
players include not only the FIU, but Customs, Police, Central Bank, the International Financial
Services Commission (IFSC) and others.

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Financial Intelligence Unit
The Belize FIU was established in 2002 in response to international attention to financial crimes
and the need to implement domestic measures to deal with money laundering. The FIU Act 22
established the Unit as a statutory body with full operational independence. The FIU’s main
tasks include:
a) Investigating and prosecuting financial crimes;
b) Performing functions of a Supervisory Authority under the MLTPA;
c) Ensuring coordination and cooperation between law enforcement agencies,
Government Departments, regulatory authorities, private institutions and members of
relevant professions in evolving methods and policies to prevent and suppress financial
crimes;
d) Taking measures as may be necessary to counteract financial crimes;
e) Sharing information and cooperating with foreign Financial Intelligence Units in the fight
against financial crimes; and
f) Informing and educating the public and financial and business entities of their
obligations under measures that have been or might have been taken to detect, prevent
and deter the commission of financial crimes23.

The Role of other Stakeholders in AML/CFT Regime

Although the FIU is central to the national AML/CFT regime, it cannot implement the necessary
measures on its own. The AML/CFT agenda is wide in its scope and reach and involves a cross
section of stakeholders all of which have separate yet interconnected mandates. As such, a
collaborative approach is necessary to implement that agenda. In accordance with the FATF
Recommendations, countries are required to put in place effective mechanisms which enable
cooperation and coordination among law enforcement and other relevant authorities at both
the policy making and operational levels.
At the policy level, key players are brought together by their membership in the National
Anti-Money Laundering Committee. Members of NAMLAC are stipulated in the MLTPA and
include:

 Director of the FIU

 Solicitor General
 Director of Public Prosecutions
 Financial Secretary
 Governor of the Central Bank of Belize
 Comptroller of Customs

22
Financial Intelligence Unit Act, No. 35 of 2002
23
FIU Act, section 7

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 Supervisor of Insurance and Private Pensions
 Chief Executive Officer of the Ministry responsible for the Police
 Commissioner of Police
 Director of Immigration
 Such other persons as the Minister may from time to time appoint24

The NAMLAC meets on a quarterly basis to perform its functions of fostering coordination and
advising the Prime Minister on matters related to AML/CFT.
At the operational level, each stakeholder performs different roles under the MLTPA. However,
for the sake of brevity, they can be place in two categories; law enforcement and supervisory
authorities.

Law Enforcement
Law enforcement authorities are integral to the AML/CFT regime. These authorities include the
Belize Police Department, Belize Customs and Excise and the Immigration Departments. Each
agency is governed by its own legislation25 and has its own role to play in the overall AML/CFT
regime. For example, Police are the lead agency in the detection and investigation of crimes
that may prove to be predicate offences to money laundering. Any acquisitive crime, or crime
that generates proceeds, can be a predicate offence to money laundering. As such, crimes over
which the Police have investigative powers are inextricably linked to the crime of money
laundering. Because of this, the police play an essential role in assisting the FIU in carrying out
its investigative and prosecutorial functions in relation to money laundering offences.
Customs has main responsibility for, not just collection of duties, but also law enforcement at
the nation’s borders. Because of its strategic presence, Customs plays an essential role in
anti-money laundering efforts through the detection of illegal cross border currency
transactions and trade-based money laundering. Plus, as noted previously, Customs is now the
lead agency for collection of currency declarations. The information collected in these
declarations, is immediately transmitted to the FIU for analysis and, when warranted,
investigation.
The Immigration Department is crucial to Belize’s ability to implement travel bans mandated by
the UN Security Council. It is also involved in providing international cooperation in tracking
movements of known and suspected criminals into and out of Belize.

24
MLTPA, section 77B
25
Customs Act, Cap. 49; Police Act; Cap. 138; Immigration Act, Cap. 156; Revised Statutes of Belize, 2011 Edition

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Supervisory Authorities
The Third Schedule of the MLTPA identifies several agencies as AML/CFT supervisory
authorities. These include the Central Bank, the FIU, the Supervisor of Insurance and Private
Pensions, the Ministry of Finance and, most importantly to you, the IFSC. As is the case with
law enforcement, each of these supervisory authorities is governed by its own legislation 26.
In addition to licensing and prudential regulation, supervisory authorities are charged with
monitoring reporting entities’ compliance with their AML/CFT obligations as set out in the
MLTPA and its subsidiary legislation and guidelines.
Supervisory Authorities may conduct their monitoring from offsite, or they may engage in
onsite compliance visits. They are given specific powers to enter and inspect a place of
business and to require production of information. When a reporting entity is deficient in
meeting its AML/CFT obligations, supervisory authorities are empowered to, among other
things, issue directions for remedial action and impose sanctions27.

AML/CFT Guidelines and obligations for Financial Sector

As a final note, I will now briefly outline ten of the most important of your AML/CFT obligations
as set out in the MLTPA and subsidiary legislation. This is, of course, a highly simplified list. For
example, within item 2 (“Institute Policies and Procedures”) many issues need to be covered.
However, the following list is designed to assist you to focus on the first priorities which
reporting entities should ensure are in place as a matter of urgency, if they are not yet wholly
embedded.
1. Conduct a Business Risk Assessment: Assess the money laundering/terrorist financing
risks inherent to your business products or services, and apply a risk based approach to
AML/CFT compliance. All reporting entities should clearly understand the money
laundering and terrorist financing risks for their business and should use that
understanding to allocate compliance resources more effectively and mitigate the risks.
2. Institute Policies and Procedures: These should be specific to your business and the
risks inherent in your business. Policies and procedures should also be subject to
independent review and audit for effectiveness on a regular basis and updated as
needed.
3. Conduct Customer Due Diligence: By now, you are all familiar with the rules regarding
CDD. However, by understanding your risks, you can identify instances where simplified
due diligence is acceptable or where enhanced due diligence is required.
4. Establish Source of Funds and Source of Wealth: Where did the money come from?

26
Central Bank Act, Cap. 262; FIU Act, Cap. 138.02; Insurance Act; Cap. 251; International Insurance Act, Cap. 269;
International Financial Services Commission Act, Cap. 272; Revised Statutes of Belize, 2011 Edition
27
MLTPA, sections 21 and 22

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5. Establish and understand the commercial rationale for the structure (remembering tax
advice): Lack of logical rationale or discernible business purpose behind a complex
structure is a red flag indicator of a potential money laundering or terrorist financing
scheme.
6. Risk rate your clients (remembering Politically Exposed Persons (PEPs) and country risk):
Politically Exposed Persons, especially foreign PEPs, and clients from countries with
weak AML/CFT controls may pose a higher risk and require enhanced due diligence or
monitoring. Remember the 2014 amendments to the MLTPA and amended definition of
PEP.
7. Appoint an MLCO: This is the person responsible for oversight of your AML/CFT
compliance regime. Ensure they have the knowledge and authority to perform this
function.
8. Train your staff (Board to Receptionist): Training is required by law. In addition to
sessions like this one, resources are available online.
9. Monitor Transactions and Review files: The MLTPA requires ongoing monitoring of all
business relations and enhanced monitoring in cases of higher risk.
10. Make Suspicious Transaction Reports: When a client or a transaction seems “off”, or if
business is refused because of suspected money laundering or terrorist financing risk,
make an STR.

Conclusion and way Forward

I would hope that this presentation may have provoked thought and provided further clarity on
the origins of, and players in, Belize’s AML/CFT regime and the obligations of service providers
such as yourselves. Although the burden may seem onerous, it is a necessary burden if Belize
wants to maintain itself in the international financial system.
Going forward, we at the FIU realise that there is need to tighten several loop holes and gaps
that may exist in the implementation of the AML/CFT regime. Both public and private sector
need to do their part to ensure that Belize is ready for its Fourth Round Mutual Evaluations.
However, it is important to bear in mind that it is not our intention to impede the flow of
legitimate business. By understanding your risks and taking steps to mitigate that risk,
legitimate commerce may move more freely.
It is my hope also that this session is the first of what will be a comprehensive education
program aimed at professionals in the financial sector. The issue of AML/CFT is one that is
continuously being revised to be current with the changing facade of illegal activities.
Belize has to take all reasonable steps to demonstrate to the international community that it is
determined and being proactive in preventing the proceeds of crime from being laundered
through its financial system. Thank you.

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Acronyms Meanings
AML/CFT Anti-Money Laundering and Combating the Financing of Terrorism
BIFSA Belize International Financial Services Association
CDD Customer Due Diligence
CFATF Caribbean Financial Action Task Force
DNFBP Designated Non Financial Businesses and Professions
FATF Financial Action Task Force
FIU Financial Intelligence Unit
FSRB FATF-Style Regional Bodies
ICRG International Cooperation Review Group
IFSC International Financial Services Commission
MLTPA Money Laundering and Terrorism (Prevention) Act
NAMLAC National Anti-Money Laundering Committee
NPO Non Profit Organisations
PEP Politically Exposed Persons
STR Suspicious Transaction Report
UN United Nations

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