Across recent FATF and CFATF evaluations, the same pattern repeats: banks tend to perform well, but real estate agents, lawyers, accountants, and other DNFBPs are consistently identified as the weakest link in national AML/CFT systems — filing few or no suspicious transaction reports and showing limited awareness of the risks they carry. A high-value property purchased through a company, itself owned by another entity or trust, remains one of the clearest ways criminals put distance between themselves and their money.
For DNFBPs, that means the bar has moved. A brief onboarding form and a copy of a passport are no longer enough — regulators expect real client due diligence, genuine verification of who ultimately owns and controls the buying entity, and staff who can recognise and escalate a transaction that doesn't add up.
We help real estate and professional services businesses across the Caribbean build AML/CFT programmes proportionate to their size, train staff to spot the red flags that matter, and prepare for the increased regulatory attention this sector is now receiving.
