On 29 January, the FATF-style regional body, CFATF, published this report, adopted at the December Plenary. The MER follows the on-site visit in September 2019.

Notably, the report mentions concerns about the Citizenship Investment Programme (CIP), which has seen publicity and criticism in recent months.  It also says that while the island’s National Risk Assessment assessed the overall terrorism financing threat as low, there is a concern that this assessment is not reflective of the jurisdiction’s overall understanding of its risk.  It says that Saint Lucia is an international financial centre and has a reasonable number of International Business Companies (IBC) and active international trusts with beneficial owners from across the world. This information was not considered in the National Risk Assessment from a terrorism financing perspective. It is also said that while the CIP is mentioned in the National Risk Assessment Summary Report and the money laundering vulnerability rating of “Medium High” was noted, the terrorism financing risk posed by the CIP, as a niche offering in Saint Lucia, was not considered in the National Risk Assessment – despite CIP being promoted globally, including in jurisdictions with known terrorist activity (although the authorities are said to have indicated CIP applicants are approved after a vigorous due diligence process).

If you would like to make a (polite) gesture and make a (very) modest contribution to my ongoing costs of relocation, removal and computer costs, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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