By Caribbean News Global 
TORONTO, Canada – In response to concerns that “the termination of the TD Bank correspondent account of Bank of Saint Lucia BOSL is in progress at this time,” BOSL, on September 2, 2024, issued a statement to inform the public, in particular, its customers locally and overseas to “confirm stability of correspondent banking relationships amidst false claims.”
The BOSL statement further advised that “it has not lost, nor is it under any threat of the loss of its correspondence banking relationships as a result of the Saint Lucia Citizen by Investment Program (CIP).”
The Bank of St Lucia assured all its customers that its “ability to conduct international transactions in all currencies on behalf of its customers has in no way been interrupted. Moreover, none of our correspondent banks have expressed concerns about our due diligence processes for wire transfers including those related to the Citizen by Investment Program (CIP).”
While it is apparent that “a banker in the employ of BOSL” leaked “false claims” to “the termination of the TD Bank correspondent account” to inference “I don’t know what to do” – “that politicians now control the communications issued by the bank,” – the ostensible proximity of the chairman of BOSL, Evaristus Jn Marie, the banks’ management, Prime Minister, and Minister for Finance, Philip J. Pierre have the arduous task of asserting discerning measures to the Saint Lucian public.
A “bikini” press release is insufficient, except for the – Bam Bam Wall – as it is well known that Lucian rumours, misinformation and disinformation have legs of excellence.
TD Bank puts aside $2.6B for money laundering investigation
Lapses in its anti-money laundering (AML) program continue to cost Toronto-Dominion Bank (TD Bank). The lender announced third-quarter earnings Thursday (August 22) that include a $2.6 billion provision related to a possible investigation into the AML program. This follows a $450 million provision announced during the previous quarter.
US regulators have been examining the Canadian bank’s AML efforts, leading TD to embark on a “remediation” of the program.
“As part of this work, the bank has been making investments in its risk and control infrastructure, including onboarding leadership with deep subject matter expertise supported by increased staffing resources, implementing new cross-functional procedures for preventing, detecting and reporting suspicious activity,” the bank said in its earnings release.
TD Bank adds that it is also investing in data and technology, training and process design to allow for improved transaction monitoring and data analytics capabilities.
Earlier this year the bank said it had fired more than a dozen employees, and brought criminal charges and disciplinary action against some of them.
In addition to the investigations in the US, a Canadian banking regulator has fined TD for its failure to file suspicious-activity reports and document risks connected to money laundering and terrorist activity.
The bank’s AML troubles were also reportedly behind the collapse of TD’s $13.4 billion plan to acquire First Horizon Bank,” reports PYMNTS.
CIP St Lucia and corresponding banking matters
Much has been expressed that the current RICO lawsuit filed in US federal court, has consequences for Saint Lucia, including:
“The potential for losing correspondent banking with the US and visa-free access to the EU and UK – will negatively impact CIP, lifestyles, economic and monetary policy in Saint Lucia and other CIP Caribbean countries,” and that “notwithstanding the RICO lawsuit,” – “The blindfolds imposed on Saint Lucians in multiple aspects of CIP dealings,” from the onset should have been transparent with high degree of accountability.
The transformation
Even at this late stage of CIP St Lucia and matters of national interest, the levers of power are yet to utilize transparency and accountability, in preference to the aloofness to answer questions and provide valid information.
However, how long can the transformation from the opposition bench to governance account for being cagey, pompous and impertinent in a temporary state of mind?
On material information relevant to the RICO lawsuit, correspondent banking and CIP St Lucia are matters of national and international concern. Moreover, even as the domestic authorities may be led to believe, otherwise – these matters are largely externally controlled. And notwithstanding matters of sovereignty, and Commonwealth lineage, Saint Lucia is a party to international treaties, civil and legal institutions.
Subject to the domestic politics of low voter information, the impulse to control media and government communications and governmental trappings, greater care and attention is required to ongoing external actions.
For example, if a complaint is made as suggested to the “American regulator, the Financial Crimes Enforcement Network, (FinCEN):
“A bureau of the United States Department of the Treasury that collects and analyzes information about financial transactions in order to combat domestic and international money laundering, terrorist financing, and other financial crimes,” then, a much broader widow, will open on Saint Lucia for much deeper and intense scrutiny.
Bank Secrecy Act Data is an integral component of the FBI’s geographic information mapping technology
“Currently, FinCEN provides the FBI with access to electronic copies of BSA filings to be imported into an FBI data warehouse. This platform allows specific data fields to be extracted and compared against investigative information and intelligence collected by the FBI and other agencies. Some of the information that is compared and examined includes names, Social Security numbers, dates of birth, passport numbers, addresses, business names and account numbers. A recent examination of millions of BSA documents revealed over 80,000 specific filings with some relationship to subjects of terrorism investigations.”
On Wednesday, August 28, 2024, as part of ongoing efforts to combat illicit finance and protect US national security, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued two rules to help safeguard the residential real estate and investment adviser sectors from illicit finance. Both rules deliver on key lines of effort outlined in the Biden-Harris administration’s U.S. Strategy on Countering Corruption.
US strategy on countering corruption
“When government officials abuse public power for private gain, they do more than simply appropriate illicit wealth. Corruption robs citizens of equal access to vital services, denying the right to quality healthcare, public safety, and education. It degrades the business environment, subverts economic opportunity, and exacerbates inequality. It often contributes to human rights violations and abuses, and can drive migration. As a fundamental threat to the rule of law, corruption hollows out institutions, corrodes public trust, and fuels popular cynicism toward effective, accountable governance.
Moreover, the impacts of corruption frequently reverberate far beyond the immediate environment in which the acts take place. In today’s globalized world, corrupt actors bribe across borders, harness the international financial system to stash illicit wealth abroad, and abuse democratic institutions to advance anti-democratic aims. Emerging research and major journalistic exposés have documented the extent to which legal and regulatory deficiencies in the developed world offer corrupt actors the means to offshore and launder illicit wealth. This dynamic in turn strengthens the hand of those autocratic leaders whose rule is predicated on the ability to co-opt and reward elites.
On June 3, 2021, president Biden established the fight against corruption as a core national security interest of the United States. As he wrote in National Security Study Memorandum-1 (NSSM-1), “corruption threatens United States national security, economic equity, global antipoverty and development efforts, and democracy itself….[B]y effectively preventing and countering corruption and demonstrating the advantages of transparent and accountable governance, we can secure a critical advantage for the United States and other democracies.”
Pursuant to NSSM-1, Federal departments and agencies have conducted an interagency review to take stock of existing U.S. Government anti-corruption efforts and to identify and seek to rectify persistent gaps in the fight against corruption. In parallel with this review, departments and agencies have begun to accelerate and amplify their efforts to prevent and combat corruption at home and abroad; bring transparency to the United States’ and international financial systems; and make it increasingly difficult for corrupt actors to shield their activities.
This first United States Strategy on Countering Corruption builds on the findings of the review and lays out a comprehensive approach for how the United States will work domestically and internationally, with governmental and non-governmental partners, to prevent, limit, and respond to corruption and related crimes. The Strategy places special emphasis on the transnational dimensions of the challenges posed by corruption, including by recognizing the ways in which corrupt actors have used the US financial system and other rule-of-law based systems to launder their ill-gotten gains.
To curb corruption and its deleterious effects, the US Government will organize its efforts around five mutually reinforcing pillars of work:
- Modernizing, coordinating, and resourcing US Government efforts to fight corruption; · Curbing illicit finance; · Holding corrupt actors accountable; · Preserving and strengthening the multilateral anti-corruption architecture; and, · Improving diplomatic engagement and leveraging foreign assistance resources to advance policy goals.
“By pursuing concrete lines of effort that advance strategic objectives under each of these pillars, and integrating anti-corruption efforts into relevant policy-making processes, the United States intends to lead in promoting prosperity and security for the American people and people around the world.”
CNG Insights
The idea and/or policy to remain quiet in the public eye awaiting legal proceedings on the RICO lawsuit, and not address numerous internal and external allegations, beyond mere “political underpinnings” is precarious to the intelligence and well-being of Saint Lucians.
“Governance is not the workings of little ministers,” according to sources, “ unexperienced in the execution, proper through processes and the workings of external agencies that govern international law.
