On 29th October, the Bahamas Weekly published a statement by the country’s Attorney General outlining what had been done since the mutual evaluation of the country by the Caribbean FATF in 2015 and the acceptance of the subsequent report in 2017 (and it being placed in enhanced follow-up procedure by the CFTATF and FATF’s ICRG).  It says that the Bahamas received ‘largely compliant or compliant’ ratings in 18 of the 40 FATF Recommendations, while posting ‘partially compliant’ ratings in 21 FATF Recommendations and ‘non-compliant’ rating for 1 FATF Recommendation.  Following acceptance of the report, the National AML/CFT Action Task Force commenced an ambitious plan to address all of the deficiencies noted in the 2017 MER, particularly to complete the National Risk Assessment (NRA), which examined the money laundering and terrorist financing risks in the financial services sector both domestic and international, and to gain the government’s approval of same. The statement lists the legislative changes introduced, and the guidance published by the Central Bank.  Whilst noting the progress made, FATF recently included the Bahamas on its monitoring (grey) list.  It says that the terms of an Action Plan adopted by the FATF Plenary in Paris this month clearly indicates that all required now of the Bahamas is the production of evidence to support the effective implementation of the steps taken.

Meanwhile, Tribune 242 of 29th October reported that the Bahamas will have resolved “99.9 %” of the remaining weaknesses in its anti-financial crime defences by year-end, with money laundering prosecutions having increased 40-fold, according to the Attorney General, and that that the Bahamas was aiming to be the first country assessed by a CFATF 4th round evaluation to seek a “re-rating” of its AML/CFT legal regime.


On 29th October, Squire Paton Boggs LLP published its EU Conflict Minerals Regulation Flowchart, a companion to its earlier one covering the US conflict minerals regulations.  It explains that the EU adopted its conflict minerals Regulation in 2017, targeting the trade in tin, tantalum, tungsten, and gold and linked to adverse impacts in conflict-affected or high-risk areas around the world.  The due diligence and disclosure obligations of the EU Regulation commence on January 1st 2021. However, it says, there will be consequences to having even indirect relationships with non-conformant smelters and refiners.  So, the article says, it is wise to analyse your supply chains before the obligations take effect and then actively manage your supply chain relationships to reduce the costs of compliance and to minimize any negative impacts on your business.  Like the US conflict minerals rule flowchart it also makes available, the firm’s EU conflict minerals regulation flowchart is intended to allow conflict minerals teams to work through the concepts of the Regulation to make quick references to relevant provisions of the Regulation.