Caribbean Financial Sector Urged to Strengthen Anti-Crime Frameworks

Justice of the Supreme Court of the Commonwealth of The Bahamas, Hon. Madam Justice Cheryl Bazard, KC, is calling on the Caribbean financial services sector to urgently and continuously strengthen resilient systems capable of combatting evolving financial crimes and other global threats.

She was addressing the Jamaica Institute of Financial Services (JIFS) 15th Annual Anti-Money Laundering, Counter-Financing of Terrorism and Counter-Proliferation Financing (AML/CFT/CPF) Conference at The Jamaica Pegasus hotel in New Kingston on Tuesday (October 13).

The two-day conference is being held under the theme ‘Beyond Compliance: Building Confidence in an Evolving Risk Landscape’.

“The era of defensive tick-the-box compliance is officially over. Caribbean financial systems can no longer afford the illusion of safety. We are entering the era of demonstration, a profound non-negotiable paradigm shift that demands we move relentlessly from mere technical compliance to active, demonstrable, operational effectiveness. Laws must be operational and able to stand up to scrutiny,” Justice Bazard emphasised.

She pointed out that this transformation is not a theoretical choice, noting that it is an economic survival mandate reshaping the legal and regulatory frameworks of every island nation in the region.

“As the Caribbean Financial Action Task Force (CFATF) draws the curtain on the fourth round of mutual evaluations, having finalised the remaining reviews for jurisdictions like Curaçao and Saint-Martin, the region is moving into the CFATF fifth mutual round of assessments.

“The rules of engagement have fundamentally changed. The message coming out of global standard setters is unyielding. Having an immaculate paper policy will no longer save a Caribbean jurisdiction from being grey-listed,” Justice Bazard said.

She noted that under the Financial Action Task Force’s fifth round of mutual evaluations, utilising the updated 2022-2025 assessment methodology, regulators assess whether financial institutions and national systems are delivering tangible criminal justice and risk-mitigation outcomes, rather than merely determining whether written policies exist.

Justice Bazard maintained that these systems must be calibrated to foster financial inclusion by lowering barriers to entry for low-risk, unbanked domestic populations, thereby keeping money within the regulated financial system, while aggressively raising barriers against high-risk non-resident flows.

“We cannot fight 21st century financial crime with 20th century legacy platforms. Let us build programmes that do not just look immaculate on a piece of paper. Paper accepts whatever words you put on it without judgment, argument, or refusal. We must instead build programmes that work relentlessly in practice. We must build environments where compliance is not a checkbox but our strongest competitive advantage. The rules are changing. The world is watching. The responsibility is ours,” she emphased.

Justice Bazard further underscored that, “the global landscape will not pause for us to catch up”, adding “our role is no longer just to enforce the rules of yesterday but to anticipate the challenges of tomorrow”.

“Compliance is often viewed as a barrier… but in an unpredictable world, you are the architects of stability. By evolving your frameworks today, you ensure your organisations can withstand the shocks of tomorrow,” she stated.

The conference, which concludes on October 14, explores developments in anti-money laundering, counter-financing of terrorism and counter-proliferation financing (AML/CFT/CPF), with a focus on practical approaches to managing risk, strengthening institutional resilience and demonstrating the effectiveness of financial crime-prevention frameworks.