What is the aim of the NRA?

An NRA serves to identify the primary concerns for money laundering, terrorism financing, and proliferation of weapons of mass destruction risks that countries have. Governments conduct an NRA to be able to implement risk-based actions in the area of anti money laundering, counter financing of terrorism, and actions against the financing of proliferation of weapons of mass destruction.s item.

  Money laundering involves disguising financial assets so they can be used without detection of the illegal activity that produced them. Through money laundering, the criminal transforms the monetary proceeds derived from criminal activity into funds with an apparently legal source.

Terrorism financing involves the solicitation, collection, or provision of funds with the intention that they may be used to support terrorist acts or organizations. Funds may stem from both legal and illicit sources.

Proliferation financing involves the act of providing funds or financial services which are used, in whole or in part, for the manufacture, acquisition, possession, development, export, trans-shipment, brokering, transport, transfer, stockpiling or use of nuclear, chemical or biological weapons and their means of delivery and related materials (including both technologies and dual use goods used for non-legitimate purposes), in contravention of national laws or, where applicable, international obligations. 

Financial Action Task Force (FATF) recommendation 1 requires countries, financial institutions and DNFBPs to identify and assess the risks of potential breaches, non-implementation or evasion of the targeted financial sanctions related to proliferation financing, as contained in FATF Recommendation 7, and to take action to mitigate these risks.

FATF recommendation 1 states that: “Countries should identify, assess, and understand the money laundering and terrorist financing risks for the country, and should take actions, including designating an authority or mechanism to coordinate actions to assess risks, and apply resources, aimed at ensuring the risks are mitigated effectively. 

Based on that assessment, countries should apply a risk-based approach (RBA) to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified”…..

A Guidance on the Risk-Based Approach (RBA) to combating Money Laundering and Terrorist Financing was developed by the FATF in close consultation with representatives of the international banking and securities sectors since 2007. 

Since the adoption of revised The FATF Recommendations in 2012, the FATF introduced a new recommendation 1 and adopted a risk based approach for all countries on national level. 

Risk assessment, including the development of an NRA, is not a one-off event. It is (or should be) a continuous event that reacts to change. An NRA’s needs to be updated regular and a 4-year cycle is seen as reasonable. 

Usually, the NRA exercise includes policymakers, prosecution and law enforcement authorities, financial intelligence units, intelligence agencies, Central Banks including other regulatory and supervisory bodies, financial institutions, and designated non-financial businesses and professions (DNFBPs) such as Jewelers, real estate agencies, Casino’s and other lawyers and accountants.

 The results of an NRA should be shared with all mayor anti money laundering stakeholders in a country who should be aware of the different risk levels for different activities and sectors  in that country. In the case of Sint Maarten, you should think of the following entities:

· Financial Institutions and other designated non financial businesses and professions (DNFBPs) for which the assessment is a critical source of information contributing to business level risk-based obligations and risk assessments;

· Financial Regulators and Supervisors;

· Government policy makers and other authorities who formulate the national policies, to enable reasonable decisions on the regulatory framework and the allocation of resources to competent authorities.

· Operational agencies, including law enforcement, other investigative authorities, the financial intelligence unit and relevant border control agencies (customs, coast guard, immigration etc.);

· Non-Profit Organizations who should also be aware of potential risks of being abused by criminals. 

You can help the development of the Sint Maarten NRA by participating fully and with transparency when you are requested to respond to questions or interviews which will allow the developers to develop a a frank and realistic assessment. 

Please note that your information is anonymous and will not be used on an individual basis. Sectors are being assessed and general risk levels will be indicated for the assessed sectors.