This report provides a summary of the AML/CFT measures in place in The Bahamas as at the date of the on-site visit (30 November to 11 December 2015).

1. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017 1
Anti-money laundering and counter-
terrorist financing (AML/CFT)
measures in the Bahamas
Fourth Round Mutual Evaluation
Key findings, ratings and priority actions
July 2017
http://www.fatf-gafi.org/publications/mutualevaluations/documents/mer-bahamas-2017.html

2. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017
Ratings – Effectiveness (1/3)
2
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which the
Bahamas
have
achieved this
objective
1. ML and TF risks are understood and, where appropriate,
actions co-ordinated domestically to combat ML and TF
Low
2. International co-operation delivers appropriate information,
financial intelligence, and evidence, and facilitates action
against criminals and their assets
Moderate
3. Supervisors appropriately supervise, monitor and regulate
financial institutions and designated non-financial
businesses and professions (DNFBPs) for compliance with
AML/CFT requirements commensurate with their risks.
Moderate
4. Financial institutions and DNFBPs adequately apply AML/CFT
preventive measures commensurate with their risks, and
report suspicious transactions.
Moderate

3. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017 3
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which the
Bahamas
have
achieved this
objective
5. Legal persons and arrangements are prevented from misuse
for money laundering or terrorist financing, and information
on their beneficial ownership is available to competent
authorities without impediments
Moderate
6. Financial intelligence and all other relevant information are
appropriately used by competent authorities for money
laundering and terrorist financing investigations.
Moderate
7. Money laundering offences and activities are investigated
and offenders are prosecuted and subject to effective,
proportionate and dissuasive sanctions
Low
8. Proceeds and instrumentalities of crime are confiscated. Low
Ratings – Effectiveness (2/3)

4. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017 4
Immediate outcome of an effective system to combat money
laundering (ML) and terrorist financing (TF)
Extent to
which the
Bahamas
have
achieved this
objective
9. Terrorist financing offences and activities are investigated
and persons who finance terrorism are prosecuted and
subject to effective, proportionate and dissuasive sanctions.
Low
10. Terrorists, terrorist organisations and terrorist financiers are
prevented from raising, moving and using funds, and from
abusing the non-profit sector.
Low
11. Persons and entities involved in the proliferation of weapons
of mass destruction are prevented from raising, moving and
using funds, consistent with the relevant United Nations
Security Council Resolutions.
Low
Ratings – Effectiveness (3/3)

5. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017 5
Ratings – Effectiveness
0
0
5
6 High
Substantial
Moderate
Low

6. 6
Ratings – technical compliance
(1/5)
AML/CFT POLICIES AND COORDINATION
1. Assessing risks & applying a risk-based approach Pa Pa Pa Pa Partially compliant
2. National cooperation and coordination Pa Pa Pa Pa Partially compliant
MONEY LAUNDERING AND CONFISCATION
3. Money laundering offence CoCoCoCo Compliant
4. Confiscation and provisional measures CoCoCoCo Compliant
TERRORIST FINANCING AND FINANCING OF PROLIFERATION
5. Terrorist financing offence LarLarLarLar Largely compliant
6. Targeted financial sanctions related to terrorism & terrorist
financing No No No No Non compliant
7. Targeted financial sanctions related to proliferation Pa Pa Pa Pa Partially compliant
8. Non-profit organisations Pa Pa Pa Pa Partially compliant

7. 7
Ratings – technical compliance
(2/5)
PREVENTIVE MEASURES
9. Financial institution secrecy laws CoCoCoCo Compliant
Customer due diligence and record keeping
10. Customer due diligence Pa Pa Pa Pa Partially compliant
11. Record keeping LarLarLarLar Largely compliant
Additional measures for specific customers and activities
12. Politically exposed persons Pa Pa Pa Pa Partially compliant
13. Correspondent banking CoCoCoCo Compliant
14. Money or value transfer services CoCoCoCo Compliant
15. New technologies Pa Pa Pa Pa Partially compliant
16. Wire transfers LarLarLarLar Largely compliant

8. 8
Ratings – technical compliance
(3/5)
PREVENTIVE MEASURES (continued)
Reliance, Controls and Financial Groups
17. Reliance on third parties Pa Pa Pa Pa Partially compliant
18. Internal controls and foreign branches and subsidiaries Pa Pa Pa Pa Partially compliant
19. Higher-risk countries Pa Pa Pa Pa Partially compliant
Reporting of suspicious transactions
20. Reporting of suspicious transactions CoCoCoCo Compliant
21. Tipping-off and confidentiality CoCoCoCo Compliant
Designated non-financial Businesses and Professions (DNFBPs)
22. DNFBPs: Customer due diligence Pa Pa Pa Pa Partially compliant
23. DNFBPs: Other measures Pa Pa Pa Pa Partially compliant

9. 9
Ratings – technical compliance
(4/5)
TRANSPARENCY AND BENEFICIAL OWNERSHIP OF LEGAL
PERSONS AND ARRANGEMENTS
24. Transparency and beneficial ownership of legal persons Pa Pa Pa Pa Partially compliant
25. Transparency and beneficial ownership of legal arrangements Pa Pa Pa Pa Partially compliant
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES
Regulation and Supervision
26. Regulation and supervision of financial institutions Pa Pa Pa Pa Partially compliant
27. Powers of supervisors Pa Pa Pa Pa Partially compliant
28. Regulation and supervision of DNFBPs Pa Pa Pa Pa Partially compliant
Operational and Law Enforcement
29. Financial intelligence units CoCoCoCo Compliant
30. Responsibilities of law enforcement and investigative
authorities Pa Pa Pa Pa Partially compliant
31. Powers of law enforcement and investigative authorities LarLarLarLar Largely compliant
32. Cash couriers Pa Pa Pa Pa Partially compliant

10. 10
Ratings – technical compliance
(5/5)
POWERS AND RESPONSIBILITIES OF COMPETENT AUTHORITIES
AND OTHER INSTITUTIONAL MEASURES (continued)
General Requirements
33. Statistics Pa Pa Pa Pa Partially compliant
34. Guidance and feedback LarLarLarLar Largely compliant
Sanctions
35. Sanctions Pa Pa Pa Pa Partially compliant
INTERNATIONAL COOPERATION
36. International instruments LarLarLarLar Largely compliant
37. Mutual legal assistance LarLarLarLar Largely compliant
38. Mutual legal assistance: freezing and confiscation LarLarLarLar Largely compliant
39. Extradition LarLarLarLar Largely compliant
40. Other forms of international cooperation LarLarLarLar Largely compliant

11. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017 11
Ratings – technical compliance
8
10
21
1
Compliant
Largely compliant
Partially compliant
Non compliant

12. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017
Key findings
 The Bahamas is still completing its ML/TF National Risk Assessment (NRA) and
has yet to develop documented national AML/CFT policies. There is a
reasonable understanding of ML/TF risks among competent authorities in the
Bahamas on account of the NRA exercise, there is a need for this understanding
to be placed within the context of The Bahamas as an international financial
centre and for it to be shared with relevant stakeholders. Measures also need to
be taken to mitigate ML/TF risks. A good foundation for national coordination
and co-operation at national level has been established through the Task Force
 The Financial Intelligence Unit (FIU) is a well-structured and resourced unit.
While the financial intelligence disseminated by the FIU is generally of good
quality, the law enforcement authority (LEA) indicated that some of it required
additional work in the furtherance of ML investigations. The focus of
investigations and prosecutions on predicate offences has resulted in no ML
convictions for the last four years and one ML case that was before the court at
the time of the on-site visit..
 The Bahamas has assessed its TF risks as low. There have been no TF
investigations, prosecutions, confiscations or convictions. The legislative
framework for targeted financing sanctions (TFS) and proliferation financing is
deficient.
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13. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017
Key findings
13
 Financial institutions(FIs) and designated non-financial businesses and
professions (DNFBPs) are overall well aware of their regulatory AML/CFT
obligations. As a result of this, they apply quite strong customer due diligence
(CDD) procedures as well as other mitigating measures in a highly rule-based
manner. However, a large number of unverified facilities in the domestic
banking sector still exists.
 FIs that are not part of a large international group did not demonstrate
sufficient awareness of their specific inherent ML/TF risks. They had not
performed an institutional ML/TF risk assessment to define the specific risks
with regard to their operations, environment, products etc. It is essential that
such institutions, as well as their supervisors, pay more attention to conducting
periodic ML/TF risk assessments.
 The number of suspicious transactions reports (STRs) filed by financial
institutions is limited, taking into consideration the substantial size of the
financial sector in The Bahamas and the substantial presence in The Bahamas of
inherent higher risk activities such as private banking and trust. More emphasis
should be put on guidance reporting and on the feedback provided to reported
STRs.

14. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017
Key findings
 The FIs and DNFBPs supervisory regimes are comprehensive and well
developed. Supervisory powers are in general adequate and co-ordination
among supervisory regulators works well. The FIs and DNFBP supervisors
generally promote clear understanding of AML/CFT obligations. However,
the application of sanctions is too limited. A risk-based approach for the
credit unions and the
 A variety of legal persons can be created in The Bahamas. The Registrar
General maintains the national company register. Beneficiary ownership
(BO) information is required to be maintained by FIs and registered agents.
No sanctions have been imposed on legal persons.
 The Bahamas has a well-functioning system for international co-operation
which provides constructive mutual legal assistance (MLA) and extradition.
International co-operation is facilitated through agreements, memoranda
of understanding (MOUs) and asset-sharing protocols. The time to respond
to requests can be improved.
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15. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017
Priority Actions for the Bahamas to
strengthen its AML/CFT System
15
 The Bahamas should complete the NRA process, analysing the threats and
vulnerabilities within the context of the jurisdiction as an international
financial centre and identify priority actions and allocate resources to
mitigate ML/TF risks, based on the NRA.
 The ODPP and the LEAs should actively seek to conduct ML investigations.
 The authorities need to pursue the confiscation/forfeiture of criminal
proceeds from ML offences equally as with predicate offences.
 During its review process the FIU should continue to seek to improve the
quality of its product to ensure that it remains relevant and meets the
needs of the LEA, in furthering its investigations. An analysis of the
responses provided in the feedback form, which is sent along with the STR
may help in this regard.
 There should be greater emphasis placed on identifying TF. Further, focus
should be placed on ensuring the capacity and framework is present
should the need arise to investigate and prosecute TF.

16. Anti-money laundering and counter-terrorist financing measures in the Bahamas – Mutual Evaluation Report – July 2017
Priority Actions for the Bahamas to
strengthen its AML/CFT System
 Establish in legislation, mechanisms for domestic designation, freezing without
delay, delisting and unfreezing procedures in accordance with UNSCR 1267 and
UNSCR 1373 and successor resolutions.
 Financial and DNFBP supervisors should have available and more often apply a
wide range of sanctions including administrative fines.
 The Registrar General should analyse, monitor and verify basic information
submitted for registration of legal persons.
 The Bahamas should put in place measures commensurate with the risk to
identify and pursue the proceeds of foreign tax evasion.
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