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  • Advisory for Financial Institutions and NRSPs on COVID-19

      ADVISORY FOR FINANCIAL INSTITUTIONs AND NON-REGULATED SERVICE PROVIDERS (NRSPs) COVID-19 AND ITS IMPACT ON FINANCIAL CRIMES - INTERNATIONAL TRENDS   Advisory for Financial Institutions and NRSPs on COVID-19
  • Offences and Penalties

    The Offences and Penalties document is a summarization of the various offences under the Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) laws of St. Vincent and the Grenadines. Non-Regulated Service Providers (NRSPs) must comply with their AML/CFT obligations or they may be liable to criminal sanctions. Offences and Penalties Offences and Penalties
  • Advisory: COVID-19 Related Scams

      ADVISORY: COVID-19 Related Scams REFRAIN FROM: Providing personal, banking or financial information via the phone, email, social media or text. Purchasing medical or protective equipment online from disreputable or questionable sources. Downloading suspicious attachments or links. UNLESS: You verify the legitimacy of the request or transaction by directly contacting or researching the relevant governmental office, health office, charitable or official organization. You seek verification from guidelines issued by: The government regarding the disbursement of stimulus payments or COVID-19 contact tracing procedures. Financial Institutions as it pertains to online banking verification procedures. Advisory: COVID-19 Related Scams
  • Anti-Money Laundering Information for Jewelers

    Identifying suspicious transactions for Jewelers Customer’s purchase of jewels of high value does not correspond with what is expected from him/her (upon the identification of his profession or the nature of his/her business). Regular purchase of high value commodities or large quantities of a specific commodity in a way that does not match the usual transactions carried out by the customer or the usual pattern of the business for his/her income. Attempts to recover the amount of recent purchases without a satisfactory explanation or when the customer tries to sell what he/she recently bought at a price that is much less than the purchasing price. Customer attempts to sell high value jewels at a price much lower than their actual or market value. Customer’s willingness to pay any price to obtain expensive jewels without any attempt to reduce or negotiate the price. Delivers jewels or precious metals purchased with illicit funds to be repurposed and asserts full ownership of the product in question, but requests payment be made to another person or entity. Anti-Money Laundering Information for Jewelers
  • Anti-Money Laundering Information for the Legal Sector

    How can money be laundered in the Legal Sector? In carrying out their duties, lawyers are often required to hold clients’ funds, manage said funds, serve as a conduit for the sale and purchase of large properties, manage companies and trusts, and carry out executive duties. The level of involvement paired with the frequency of large monetary transactions, the shifting or protection of assets, and verification of information, makes lawyers prime targets for ML/TF transactions or behaviours.   Identifying suspicious transactions for Lawyers Criminals may: Appoint a lawyer in financial or commercial transactions and request the concealment of their name in any of these transactions. Resort to lawyers to create companies, particularly international business companies, from outside the country (offshore) in a way that shows that the objective of creating the company is to conceal the illicit source of the funds. Resort to lawyers to invest in the real estate market, but the purchase or sale prices are not commensurate with the real estate value. Request, upon hiring a lawyer to incorporate a company, to transfer/deposit the incorporation fees or the capital to/in the bank account of the lawyer through multiple accounts that he has no relation to without a reasonable justification. Request that the lawyer manages investment portfolios, in countries allowing such activity, and give instructions to conduct transactions that have no clear economic reason. Use the sources of funding for requested transactions, from large financial transactions that cannot be justified by any known business or corporate purpose. Request payments be made to third parties without clear reason or a valid corresponding transaction. Anti-Money Laundering Information for the Legal Sector
  • Forms

    SARS Registration Form De-Registration Form Compliance Officer Fit & Proper Questionnaire         Forms
  • Registration

    Section 155 of the Proceeds of Crime Act, 2013 requires that all entities which fall under the NRSP sector be registered by the FIU or be liable of an offence. Registration Process The Application Form and the Compliance Officer Fit and Proper Questionnaire MUST be completed and sent to the FIU via email or registered mail (P.O. Box 1826, Kingstown) Application Form Compliance Officer Fit and Proper Questionnaire Both forms MUST be accompanied by all relevant documents or information required  Application Form The application may either be accepted or refused by the FIU. Refusal may occur where: The application form is not completed The application fails to provide requested information/documentation The applicant does not intend to carry on the relevant business which it seeks registration for The applicant was previously de-registered Where it is contrary to public best interest The applicant poses a significant money laundering or terrorist financing risk The applicant does not have the capacity or willingness to comply with the specified obligations Once the application is accepted and the service provider is registered, a Certificate of Registration will be issued. In cases where the application is refused, the applicant will be informed by way of a written letter which will provide details of the reason for refusal. Compliance Officer Fit and Proper Questionnaire Each NRSP MUST: nominate a suitable candidate for the position of Compliance Officer. complete and submit the Compliance/Reporting Officer Fit and Proper Form to the FIU for approval. submit the relevant supporting documents such as certified copies of the nominee’s identification and academic and professional qualifications. The application can be: Approved Conditionally Approved Declined   The FIU will inform the NRSP of its decision by way of a written letter.     Registration
  • AML/CFT Guidelines

    This Guidance was compiled by the St. Vincent and the Grenadines Financial Intelligence Unit (“FIU”) to offer guidelines to the Non-Regulated Service Providers (NRSPs) on the implementation of Anti-Money Laundering and Counter Terrorist Financing (AML/CFT) measures and on how best to comply with the AML/CFT laws and regulations of St. Vincent and the Grenadines. The AML/CFT policy adopted by each NRSP should be a reflection of its money laundering and terrorist financing risk. Thus, the responsibility rests with each entity to develop and implement its own polices and AML/CFT measures in keeping with the AML/CFT laws and regulations of St. Vincent and the Grenadines. NRSPs Guidance manual     AML/CFT Guidelines
  • Supervision of Non-Regulated Service Providers (NRSPs)

    (Otherwise called Designated Non-Financial Businesses and Professions (DNFBPs))  Supervisory Authority for NRSPs Pursuant to Regulation 36 (b) of the Anti-Money Laundering and Terrorist Financing Regulations 2014, as amended by S.R.O No.25 of 2017 (AMLTFR), the Saint Vincent and the Grenadines Financial Intelligence Unit (SVGFIU) is designated as the supervisory authority of Non-Regulated Service Providers (NRSPs) which comprises of: Real estate agents Casinos Car dealers Jewelers Lawyers, Notaries, Accountants and Auditors who engage in the following activities: buying and selling of real estate management of client money, securities or other assets management of bank, savings or securities accounts organisation of contributions for the creation, operation or management of companies creation, operation or management of legal persons or arrangements   Over the years, the SVGFIU has conducted various training and awareness raising sessions/workshops to sensitise NRSPs of their Anti-Money Laundering/Counter-Financing of Terrorism (AML/CFT) obligations pursuant to the AMLTF Regulations. The Supervisory Department was subsequently established on 15th August, 2018.   Functions of the SVGFIU as Supervisory Authority for NRSPs The objectives of the Supervisory Authority include, but are not limited to: Determining applications for registration and taking appropriate action against NRSPs which carry out relevant business without being registered. Monitoring the compliance of NRSPs with their AML/CFT obligations under the relevant Laws, Regulations and Code. Taking appropriate enforcement action against NRSPs for breaches of, or non-compliance with, their AML/CFT obligations.   Registration of NRSPs The NRSPs are prohibited from carrying out any type of relevant business within Saint Vincent and the Grenadines unless registered (Section 155 (1) of the Proceeds of Crime Act, 2013 as amended by Act No.18 of 2017 (POCA)).  The Registration of NRSPs is scheduled to commence subsequent to the passage of the Non-Regulated Service Providers Regulations, 2019.   AML/CFT Obligations of NRSPs   Enforcement Actions The SVGFIU may take appropriate enforcement action against NRSPs for breaches of, or noncompliance with, their AML/CFT Obligations (section 152(2) (b) of POCA). However, the Supervisory Authority must ensure that the enforcement action imposed is effective, proportionate and dissuasive (section 152(4) of POCA). Enforcement actions include, but are not limited to: Warning letters Remedial actions Directives Administrative penalties Criminal sanctions   Next Steps: The Passage of the Non-Regulated Service Providers Regulations, 2019 Training and Awareness Raising The Registration of the NRSPs with the FIU Compliance Officer Approval Process Risk-Based Assessments Development of Compliance Programmes Implementation of policies, procedures, systems and controls to mitigate the risk of Money Laundering and Terrorist Financing Onsite / Offsite Compliance Examinations Supervision of Non-Regulated Service Providers (NRSPs)