National Risk Assessment Process Sint Maarten

Money Laundering and terrorism financing present global threats. In the context of Sint Maarten’s position as a small international business and tourism destination with first class electronic funds transfer and which also uses the Euro and the United States dollar, we cannot exclude ourselves from the responsibility of preventing as far as possible, the use of our jurisdiction by criminals. The continued integrity and stability of our economy and financial system should provide strong support for our growth as a nation. The converse, being infiltration by the criminal fraternity, could seriously damage these. This is a responsibility the Sint Maarten Government takes particularly seriously.

Recommendation 1 of the Financial Action Task Force, the global standard setting body against Money Laundering and Terrorism Financing, indicates that every country should identify, assess, and understand these risks for its economy, its system and its government framework.

Based on a process of assessment, further indicated as a National Risk Assessment, and abbreviated as NRA, countries should apply a risk-based approach to ensure that measures to prevent or mitigate money laundering and terrorist financing are introduced commensurate with the risks identified.
The NRA is performed at national level and the development of this assessment and plan of action is intended to cover approximately one year and a half, ending approximately December 2023 with a final report. The results of this assessment are thus intended to assist Sint Maarten in creating a more robust framework against money laundering and terrorism financing.

A finalized National Risk Assessment will reflect the commitment by the Government of Sint Maarten to uphold the highest international standards in protecting this jurisdiction against criminal abuse. However, this NRA is not a one-time event: It is anticipated that this developed NRA in the future will need to be updated at least every four-years as to be able to adapt and follow through on new and emerging trends of crimes.

A sound financial sector, a sound investment climate, and a safe Sint Maarten are of paramount importance. Sint Maarten welcomes honest entrepreneurs, investors, financial institutions, and clients. Sint Maarten however as such will not take part, actively nor passively, in concealing the source of criminal funds or in facilitating cash flows for terrorist purposes.

Central to the compilation of this NRA will be a methodological joint participatory process that will enable Sint Maarten to identify the main drivers of ML/TF risks. This process will be guided by a methodology (tool) developed by the World Bank (WB). An introductory workshop informing on the use of this WB tool was presented to the Sint Maarten main stakeholders in June of this year (2022). Besides government entities, financial institutions and other businesses will be invited to actively participate in this process and in the near future will be requested by representatives of the “Centrale Bank van Curaçao en Sint Maarten” (CBCS), and the Financial Intelligence Unit (FIU), to participate in interviews, focus groups, or fill out questionnaires which will be useful in finalizing this NRA.

It is important to stress on the fact that for the development of this NRA, input from both public and the private sector stakeholders in Sint Maarten will be vital to finalize and put into action a complete and all-encompassing national risk plan against the crimes of money laundering and terrorism financing.
In completing this exercise months from now, Sint Maarten will gain a collective understanding of the money laundering and terrorist financing risks that it faces. Through an Action Plan that will be developed alongside this NRA, we will be in a strong position to enhance the existing framework and where necessary introduce new measures to provide further protection.

Sint Maarten will also be in an enhanced position to enter the 4th round of mutual evaluation by the Caribbean Financial Action Task Force which for Sint Maarten is set to initiate in 2024.