Real estate main money-laundering risk for the Caribbean Netherlands
Money laundering via the real estate/realty sector is the largest money-laundering risk on Bonaire, St. Eustatius and Saba, according to the second National Risk Assessment on money laundering and terrorist financing for the three BES-islands (NRA BES) conducted by WODC.
Other important money-laundering risks that apply to all three islands are money laundering via licensed banks, via underground banking and unlicensed money or value transfer services, and via the physical placement or transfer of cash by sea and/or air. For Bonaire, three other large money-laundering risks emerged in the second NRA BES: money laundering via legal entities, via loan-back constructions and via falsification of company turnover. Because no indications were found for the occurrence of terrorist financing on the Caribbean-Dutch islands, the second NRA BES focuses on determining the most important money-laundering risks.
The study is based on the methodology applied – also by WODC – in the European-Dutch NRAs on money laundering and terrorist financing from 2020. The main money-laundering threats were identified by experts involved in the prevention and/or repression of money laundering, after which they determined the potential impact of these threats and the resilience of the available policy instruments for the prevention and/or repression of money laundering. The potential impact of each threat was then compared with the resilience. This results in a ranking of the money-laundering threats by their residual potential impact that is not countered by the policy instruments.