Terrorist Financing is the provisioning of financial support, in any form to a terrorist or terrorist organization; or the provisioning of financial support to a terrorist or terrorist organization to facilitate a terrorist act. Terrorist or terrorist organizations get funding mainly from two sources namely, legitimate and illegitimate sources.

A Financial Intelligence Unit (FIU) is a central, national agency responsible for receiving (and, as permitted, requesting), analyzing and disseminating to the competent authorities, disclosures of financial information: (i) concerning suspected proceeds of crime and potential financing of terrorism, or (ii) required by national legislation or regulation, in order to counter money laundering and terrorism financing. (Source: The Egmont Group of Financial Intelligence Units)

The Judicial Model is established within the judicial branch of government wherein "disclosures" of suspicious financial activity are received by the investigative agencies of a country from its financial sector such that the judiciary powers can be brought into play e.g. seizing funds, freezing accounts, conducting interrogations, detaining people, conducting searches, etc.The Law Enforcement Model implements anti-money laundering measures alongside already existing law enforcement systems, supporting the efforts of multiple law enforcement or judicial authorities with concurrent or sometimes competing jurisdictional authority to investigate money laundering.The Administrative Model is a centralized, independent, administrative authority, which receives and processes information from the financial sector and transmits disclosures to judicial or law enforcement authorities for prosecution. It functions as a “buffer” between the financial and the law enforcement communities.The Hybrid Model serves as a disclosure intermediary and a link to both judicial and law enforcement authorities. It combines elements of at least two of the FIU models. (Source: The Egmont Group of Financial Intelligence Units)

The Financial Action Task Force (FATF) is an inter-governmental body whose purpose is the development and promotion of policies, both at national and international levels, to combat money laundering and terrorist financing. The Task Force is therefore a "policy-making body" which works to generate the necessary political will to bring about national legislative and regulatory reforms in these areas.

Since its creation the FATF has spearheaded the effort to adopt and implement measures designed to counter the use of the financial system by criminals. It established a series of Recommendations, known as the 40 Recommendations which are regularly updated to ensure that they remain up to date and relevant to the evolving threat of money laundering and terrorism financing that set out the basic framework for anti-money laundering and counter-financing of terrorism financing efforts and are intended to be of universal application. The FATF has 36 members. (Source: www.fatf-gafi.org)

The Caribbean Financial Action Task Force (CFATF) is a FATF Styled Regional Body (FSRB), an organisation of twenty-seven states of the Caribbean Basin, which have agreed to implement common countermeasures to address the problem of criminal money laundering. It was established as the result of meetings convened in Aruba in May 1990 and Jamaica in November 1992.

The main objective of the Caribbean Financial Action Task Force is to achieve effective implementation of and compliance with its recommendations to prevent and control money laundering and to combat the financing of terrorism. The Secretariat has been established as a mechanism to monitor and encourage progress to ensure full implementation of the Kingston Ministerial Declaration. (Source: www.cfatf-gafic.org)

Any business transaction where the identity of the person involved, the transaction or any other circumstance concerning that business transaction gives any officer or employee of the financial institution reasonable grounds to suspect that the transaction

involves proceeds of crime;

involves the financing of terrorism; or

is of a suspicious or an unusual nature.

All categories of businesses referenced at Schedule I and II of the Money Laundering (Prevention) Act No. 8 of 2011 (as amended) are required to file STRs with the FIU.

These businesses include:

• Banks
• Offshore Banks
• Building societies
• Securities exchange
• Mutual Funds
• Insurance companies
• Credit unions
• Money Exchange (e.g. casa de cambio)
• Money Lending and Pawning
• Money Broking
• Money transmission services
• Venture risk capital
• Banking business as defined in the Offshore Banking Act 1996
• Investment business
• Trusts Business
• Foreign exchange
• Car dealerships
• Jewellery Business
• Real Estate Agents
• Casinos (gaming houses)
• Internet Gambling and wagering services
• Lottery Agents
• Barristers-at-Law and Solicitors
• Accountants
• Charities
• Courier services
• Management companies
• Asset management and advice-custodial services
• Nominee service
• Registered agents
• Any business transaction conducted at a post office involving money orders
• Security brokerage
• Telecommunications companies
• Utility companies
• Dominica Social Security
• Inland Revenue Department

A report made by a financial institution about suspicious or potentially suspicious activity. The criteria to decide when a report must be made varies from country to country but generally is any financial transaction that does not make sense to the financial institution, is unusual for that particular client or appears to be done only for the purpose of hiding or obfuscating a transaction.

Generally, you should pay attention to all transactions or activities that are inconsistent with the known profile of the customer.

• The customer is reluctant to provide details of their identity.
• A cash transaction is unusually large.
• The customer requests currency in large denomination notes.
• Non-disclosure of the source of funds by the customer.li>
• Dubious explanations as to the source of funds.
• Structuring of transactions.

If your organization is subject to the requirements of the Money Laundering (Prevention) Act No. 8 of 2011 and Suppression of Financing of Terrorism Act No. 9 of 2011, you must take steps to identify any activity you suspect may be linked to money laundering or terrorist financing. If you know or suspect there is such a link you must report it to the Financial Intelligence Unit (FIU).

A financial institution or person carrying on a scheduled business (i.e. relevant business or designated non-financial business and profession (DNFBP) is required to pay attention to –

• All complex, unusual or large business transactions, whether completed or not;
• All unusual patterns of transactions, whether completed or not;
• Insignificant but periodic transactions, that have no apparent or visible economic or lawful purpose;
• Electronic funds transfers that do not contain complete originator information;
• Relations and transactions with persons, including business and other financial institutions, from countries that have not adopted comprehensive anti-money laundering legislation.

Where a financial institution or person carrying on a scheduled business suspects or has reasonable grounds to suspect that a transaction, proposed transaction or attempted transaction, is related to a money laundering offence or that the funds or property are the proceeds of crime, it shall promptly report the transaction to the Unit in a form approved by the Director of the Unit.

Your Compliance Officer can file a report with the FIU manually by downloading a copy of the STR form from the FIU’s website or requesting a copy from the FIU directly, which can be sent to them via e-mail.

The completed STR can be sent by courier to the: