Montserrat Excels in The Fourth Round Mutual Evaluation if its Anti-Money Laundering and Countering Terrorist Financing Framework

Montserrat has successfully completed the Fourth Round Mutual Evaluation of its Anti-Money Laundering/Counter Financing of Terrorism/Countering Proliferation Financing (AML/CFT/CPF) Framework, conducted by the Caribbean Financial Action Task Force (CFATF). 

Montserrat’s Mutual Evaluation Report (MER) highlights the jurisdiction’s significant achievements and efforts at combating money laundering (ML), counter-terrorism financing (TF), and proliferation financing (PF), demonstrating the jurisdiction’s unwavering commitment to aligning with international standards.

CFATF Mutual Evaluation Report

As the smallest member of the CFATF in terms of population size and Gross Domestic Product (GDP), Montserrat has proven that size does not limit impact, demonstrating the essence of risk-based modelling applications. Operating comparatively with significantly limited resources, the jurisdiction has achieved remarkable results in this rigorous evaluation process.

About the Evaluation Process:

The Mutual Evaluation Report evaluates Montserrat’s progress over the past five years at adopting and implementing AML/CFT/CPF mechanisms. Conducted by independent assessors from CFATF member jurisdictions, in April 2024,Montserrat’s compliance with international standards was reviewed in two critical areas:

1. Technical Compliance: This measured Montserrat’s alignment with the 40 FATF Recommendations, assessing the adequacy and robustness of its legal, regulatory, and institutional frameworks and their enforcement means in addressing AML/CFT/CPF.
2. Effectiveness: This assessed Montserrat’s ability to implement its frameworks effectively, using the 11 Immediate Outcomes (IOs) as global benchmarks to evaluate the practical application of AML/CFT/CPF measures.

Montserrat’s Achievements:

Following the evaluation, Montserrat’s performance was discussed and approved at the CFATF Plenary held in Jamaica in December 2024. The jurisdiction’s ratings are as follows:

• Technical Compliance:
  • 18 Fully Compliant (C) ratings,
  • 16 Largely Compliant (LC) ratings, and
  • 6 Partially Compliant (PC) ratings.
• Effectiveness (Immediate Outcomes):
  • 2 Substantial Effectiveness (SE) ratings,
  • 7 Moderate Effectiveness (ME) ratings, and
  • 2 Low Effectiveness (LE) ratings.

These ratings represent an outstanding achievement for Montserrat and highlights its ability to meet global standards despite significant resource constraints.

Key Outcomes of the Assessment:

Based on these commendable results, Montserrat will not be placed on the FATF grey list or black list and will not be subject to increased monitoring. However, the jurisdiction must work to address the deficiencies identified in the report; progress on which would be monitored by the CFATF. 

This accomplishment reaffirms Montserrat’s position as a trustworthy and compliant jurisdiction, reinforcing confidence among international stakeholders, partners, and investors.

Acknowledging Key Contributors:

This success would not have been possible without the coordinated efforts and dedication of several key entities which form part of Montserrat’s National Anti-Money Laundering and Countering Terrorist Financing Committee (NAMLAC), chaired by the Hon. Attorney General Sheree Jemmotte-Rodney. 

We recognise the steadfast commitment of the following:

• The Members of Cabinet and the Legislative Assembly: Honourable members that gave high level political commitment to the jurisdiction’s efforts at strengthening its AML/CFT/CPF framework through the approving of applicable key policies, strategies, risk assessments, action plans, critical pieces of legislation and regulations, and for committing financial resources. 
• Governor’s Office: Her Excellency The Governor, Mrs. Sarah Tucker, Ms. Mitchell Webster (HOGO), and Mr. Phil Hickson (Policy Advisor).
• Attorney General’s Chambers (AGC): Chair of NAMLAC, Hon. Sheree Jemmotte-Rodney and Mr. Deron Boyce (National Risk Mitigation Officer).
• Deputy Governor, Hon. Lindorna Sweeney.
• Ministry of Finance: Mr. Kenya Lee (Financial Secretary {Ag.}) and Mrs. Dulcie James (Policy Advisor).
• Financial Services Commission (FSC): Mr. Fabian Singh (Commissioner) and Ms. Donilia Cuffy (Deputy Commissioner).
• Director of Public Prosecution: Mr. Oris Sullivan
• Financial Intelligence Unit (FIU): Mr. Charles Thompson (who occupied the role of Director of the FCAU for the period of MER assessment 2019-2023), Ms. Jessica Sweeney (Deputy Director).
• Montserrat Customs and Revenue Services (MCRS): Mr. Peter White (Director General).
• Royal Montserrat Police Service (RMPS): Commissioner Mr. Mark Payne and Team.
• Eastern Caribbean Central Bank: Mrs. Livia Birten-Mark, (Deputy Director, Financial Sector Supervision Department and Head of AML Supervisory Unit) and Ms. Suzette Lewis.
• Private Sector entities that play a role in the AML/CFT/CPF framework.

A special thanks is extended to the UK’s His Majesty’s Treasury Office for their ongoing support and commitment throughout this process. Each of these entities contributed significantly to the preparation, implementation, and demonstration of Montserrat’s compliance and effectiveness, making this outcome possible.

A Message of Gratitude and Forward Vision:

The Hon. Attorney General expresses her heartfelt gratitude to all team members and individuals involved in this success. This achievement is a testament to the power of collective action, resilience, and the strength of our institutions, proving that even the smallest jurisdiction can deliver results on par with the global network.

While we celebrate this milestone, our work continues. Montserrat is committed to ongoing improvement, refining its frameworks and policies to ensure continued alignment with international standards. We remain actively engaged with organizations such as CFATF, FATF, OECD and other global bodies to uphold our reputation as a responsible and compliant jurisdiction.

This achievement showcases Montserrat’s ability to thrive on the global stage despite its size, serving as a reminder that with determination, strategic planning, and collaboration, even the smallest of jurisdictions can turn limitations into opportunities for excellence.