Madame Speaker, with your kind permission, I beg to make the following statement with regard to the Virgin Islands’ first National Risk Assessment (NRA) that is currently being undertaken.
Madame Speaker, as part of the Financial Action Task Force’s (FATF) International Standards on Combating Money Laundering and the Financing of Terrorism and Proliferation, countries are required to be able to identify, assess and understand their money laundering and terrorist financing risks, and put measures in place to effectively mitigate those risks.
In order to do this, countries must look at all sectors of their economy to determine where the greatest money laundering and terrorist financing risks lie, and identify ways in which to mitigate these risks.
Madame Speaker, in an effort to effectively fulfill these requirements, my Government has developed a structure to oversee the conduct of this National Risk Assessment, thereby ensuring that the Territory will be able to successfully meet the FATF standards and continue to maintain the high level of Anti Money Laundering and Countering the Financing of Terrorism (AML/CFT) compliance it is recognised for internationally.
On April 10 my Government held the inaugural meeting of the National Risk Assessment Council, which is the policy making body responsible for all matters related to, or concerning the conduct, of the NRA.
The Council is chaired by me and its membership includes His Excellency the Governor, the Deputy Governor, the Hon. Attorney General, the Financial Secretary, the Managing Director/CEO of the Financial Services Commission, and a private sector representative in the person of Dr. Michael O’Neal.
Madame Speaker, since that time much work has been carried out to prepare the Territory for this very important exercise.
Driving these preparations is the National Risk Assessment Steering Group which is chaired by Mr. Cherno Jallow, QC and comprises a number of individuals with varying expertise in the subject of AML/CFT – namely, Mr. Glenford Malone of the FSC as Deputy Chairman, Mr. Errol George of the FIA, Mr. Kenneth Baker of the FSC, Ms Alva McCall of the FSC, Detective Elvis Richards of the RVIPF, Ms Simone Martin of the FSC, Mr. Sheldon Scatliffe of the FSC and Ms Tiffany Scatliffe of the Office of the DPP.
Madame Speaker, the Steering Group has been working diligently to prepare those persons who will be conducting the NRA, as well as the public for the commencement of this exercise.
In early July, 40 persons from a wide cross-section of government agencies were trained in AML/CFT and other soft skills that will be required to successfully execute their duties as NRA assessors.
I had the distinct pleasure of addressing that gathering to emphasise to the participants the importance of the National Risk Assessment to the Territory’s international cooperation profile and the preservation of the BVI as an international finance centre.
Madame Speaker, the success of the NRA exercise depends on the level of participation by the various entities within the sectors that have been identified to be assessed, and the quality of the data collected.
As such, Phase I of the NRA exercise consisted of asking over five hundred entities from various sectors within the local economy to complete pre-assessment questionnaires that were developed to solicit information that would help to identify where potential money laundering and terrorist financing risks may lie within those sectors.
These entities included financial institutions, Non-profit Organizations, entities referred to as Designated Non-financial Business and Professions (comprising lawyers, accountants, real estate agents, and notaries public), other designated non-financial businesses (comprising jewelers, furniture, yacht and car dealers) and key government agencies (including the Governor’s Office, Financial Services Commission, Financial Investigation Agency, International Tax Authority, Office of the Director of Public Prosecutions, Attorney General’s Chambers and Royal Virgin Islands Police Force).
Based on the analysis carried out on these questionnaires, entities were identified to participate in Phase II of the NRA exercise.
Phase II, which began on 15 September, consists of onsite interviews. This comprises six teams which will respectively be dealing with law enforcement, high value goods dealers, designated non-financial business and professions, other non-financial businesses, financial institutions and competent authorities.
The onsite interviews are being conducted by these assessment teams in order to validate the information previously collected, or in some instances to gather additional information and acquire new information from those entities that did not respond to the initial questionnaires.
In addition, a data analysis team has been established, comprising three persons based in and working from the NRA Secretariat.
Madame Speaker, this is a very data intensive process which is projected to last approximately seven months and will require the ongoing cooperation of the entire BVI public.
This is effectively a national effort and we must all seek to cooperate with the process in order to achieve the desired outcome. I am, therefore, seeking the public’s indulgence by asking them to fully cooperate with the NRA assessors if they are selected to participate in an onsite interview.
I also wish to assure the public that any information collected during this assessment process will be used solely for the purposes of the National Risk Assessment and will not be shared with any regulatory or law enforcement agency or divulged to any third party not connected to the national risk assessment, so persons should not be reluctant to provide any information requested of them.
All the assessors have been sworn to confidentiality to which they are being strictly held.
Madame Speaker, while this exercise may seem far removed from the daily life of the average citizen, it does impact each and every one of us, as we all need to be cognizant of the potential role any of us could unwittingly play in the laundering of money or the financing of terrorism.
It is for this reason that a Public Education Committee has been established to sensitise the public on AML/CFT issues.
Madame Speaker, this Committee’s responsibility is three-fold:
First, to help persons understand the nature, scope and consequence of money laundering and the financing of terrorism and proliferation, thereby enabling them to guard against being used to perpetuate such activities or becoming innocent victims;
Second, to provide them with information that would allow them to decipher the triggers or red flags relative to money laundering and the financing of terrorism and proliferation so that they can become effective partners of law enforcement to stem the tide of criminality associated with such activities and ensure stability in the community; and
Third, to make our citizens realize that the good reputation of the Virgin Islands is fundamental to the growth of business and the funding, expansion and development of social services.
Madame Speaker, I am pleased to report that the Public Education Committee has taken its role seriously.
The Committee has produced various literature on ML and TF which can be found in print at various business places around the Territory as well as online at the official NRA website at www.bvinra.org and on some of the online media.
In addition, they have appeared on local talk shows in an effort to reach as wide an audience as possible. Madame Speaker, I have been assured that this outreach will continue for the life of this exercise to ensure that the public is properly educated on what is taking place.
The final outcome of this exercise, Madame Speaker, will be the production of a National Risk Assessment Report which will outline the findings of the exercise and make recommendations for any required remedial action.
By conducting this National Risk Assessment, we will be able to determine whether our current systems are indeed sufficiently effective and, where such effectiveness is found to be lacking, the National Risk Assessment Council will ensure that the required policy, legislative, administrative and other changes are effected in a timely manner.
This should enable the Territory to be well-prepared for its next Mutual Evaluation in 2017.
I thank you Madame Speaker.