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The Canada-Caribbean Remittance Corridor
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provide such a mechanism. Because of a limited or expensive banking system, cross-border cash transportation is a common practice for many Haitians wanting to transfer funds in and out of Haiti. Haitian diasporas abroad often send money home through friends and family who are traveling back to Haiti. This being the case, the shift to a declaration or disclosure system would not penalize Haitian citizens, or other travelers carrying legitimate funds. A through review of the current system would be useful in deciding future direction.
3. Ensuring effective implementation of regulatory requirements Education of maisons de transfert Finding. Maisons de transfert have an uneven understanding of all the applicable laws and regulations. Some think that they are simply making business decisions when what they are doing is required by law and regulation. Others think that certain business practices are required when they are not (payouts in US dollars, for example). As well, knowledge and understanding of the requirements seem to vary from one company to another. Recommendation. ■ Educate maisons de transfert on all applicable legal and regulatory requirements by conducting meetings with senior management and compliance officers, and organizing seminars and training. Rationale. Clarify the legal and regulatory requirements, and communicate them to the maisons de transfert. Educational outreach should then be organized.
Implementation of AML/CFT Measures by maisons de transfert Finding. Maisons de transfert are required to develop and implement internal AML policies and procedures. While most of the maisons de transfert have developed such policies and procedures, the degree of effort committed to implementing them seems to vary widely among maisons de transfert. Recommendations. ■ Provide senior management and compliance officers with training on AML requirements and how to strengthen their implementation of AML requirements. ■ Strengthen on-site inspection of AML compliance. ■ Consider applying sanctions to non-compliant maisons de transfert. Rationale. It is critical that maisons de transfert bring their AML/CFT measures into conformity with FATF standards. Otherwise, they will find it difficult to operate or find partners in sending countries.
Supervision of the maisons de transfert Finding. While the BRH’s recent effort to create a new supervisory unit for maisons de transfert is a first step toward improvement, continued and even enhanced efforts are necessary. To date, because of resource constraints and a limited number of skilled staff, only