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2025 INCSR: Volume 2 – Money Laundering St Lucia

  • Leahy amendment restrictions and domestic operations hamper bilateral cooperation to resolve financial crimes. 
  • Drug trafficking remains the primary source of illicit funds in Saint Lucia. 
  • In 2023, Saint Lucia amended the “Proceeds of Crime Act” (POCA). 
  • In 2024, Saint Lucia recorded one money laundering prosecution involving $35,226, two forfeiture orders amounting to $98,119, and eight cash seizures and detention orders totaling $116,388. 

USA / ST LUCIA – The 2025 International Narcotics Control Strategy Report (INCSR) is an annual report by the Department of State to Congress prepared in accordance with the Foreign Assistance Act. It describes the efforts of key countries to attack all aspects of the international drug trade in Calendar Year 2024. Volume I covers drug and chemical control activities. Volume II covers money laundering and financial crimes.

Saint Lucia, an island nation within the Organization of Eastern Caribbean States, promotes a citizenship by investment (CBI) scheme and is susceptible to drug trafficking and the laundering of illicit funds. The country serves as a transshipment point for narcotics, primarily from South America, en route to North America and Europe. Illicit funds flow in from these same markets and are integrated into the local economy using various money laundering methodologies.

Saint Lucia is a predominantly cash-based economy, and its open borders increase vulnerabilities to the movement of drugs and illicit cash. Businesses facilitate financial crimes through high cash and real estate turnover, the use of structured deposits below reporting thresholds, and the same-day transfer of funds through money remittance services, often involving multiple senders and a single recipient located in high-risk, drug producing countries.

Despite these challenges, law enforcement agencies and regulatory authorities in Saint Lucia have intensified their efforts through domestic joint operations and intelligence sharing, resulting in better control of financial crimes.

However, Leahy amendment restrictions and domestic operations hamper bilateral cooperation to resolve financial crimes.

Vulnerabilities and money laundering methodologies

Drug trafficking remains the primary source of illicit funds in Saint Lucia. Criminals physically transport most of the proceeds back to South America, while a small portion stays in Saint Lucia and is integrated into the financial system through structured deposits of foreign or local currency; third-party transactions; comingling of licit and Illicit proceeds through cash-intensive businesses, such as restaurants, retail stores, and car dealerships; and the use of funnel accounts through money remitters.

The Financial Services Regulatory Authority (FSRA) is the prudential supervisor for the financial services sector and oversees 17 credit unions, 10 international banks, 31 licensed or registered international insurance entities, 18 registered agents and trustees, 14 money services businesses, and seven international private mutual funds.

International business companies (IBCs) can be incorporated in one day in Saint Lucia using registered agents under the “International Business Companies Act.” However, the records kept by registered agents are nonpublic and only accessible under law by the Financial Intelligence Authority (FIA) and Inland Revenue Department. Saint Lucia considers IBCs “resident” companies able to do business locally and required to file an annual tax return based on unaudited financial statements. There is one free trade zone operating in Vieux Fort.

Saint Lucia’s CBI program allows individuals to apply for citizenship through various options, including a $100,000 donation to the National Economic Fund; specified purchase thresholds for real estate and government bonds; or a $3.5 million investment in an approved enterprise project. Applicants must apply through a government-approved local agent, make a source of funds declaration, and provide supporting evidence. The government established a CBI unit to manage the application process. The prime ministers of Dominica, Antigua and Barbuda, Grenada, and Saint Kitts and Nevis entered into an agreement in March 2024 to facilitate a joint approach to strengthening their CBI programs.

Subsequently, Saint Lucia also joined in June 2024. The agreement includes a minimum $200,000 investment, information sharing, common regulation, and common standards for agents.

Saint Lucia’s vulnerabilities are further amplified by gaps in beneficial ownership transparency and its exposure to regional and international financial flows, including through real estate transactions.

Key AML Laws and Regulations Saint Lucia has a robust AML/combating the financing of terrorism (CFT) legal framework, with the FIA serving as the main regulatory body for monitoring compliance with these laws. Key legislation includes the “Money Laundering (Prevention) Act” (MLPA) that establishes offenses related to money laundering and outlines reporting and compliance obligations and the “Proceeds of Crime Act” (POCA), which provides mechanisms for the seizure and forfeiture of criminal proceeds. In 2023, Saint Lucia amended the POCA to introduce a civil asset recovery framework to allow authorities to confiscate proceeds through civil proceedings and to list non-cash items that can be seized, thereby, expanding the scope of asset forfeiture.

Saint Lucia also has customer due diligence and suspicious transaction reporting frameworks in place under the MLPA, generally aligned with international standards. Saint Lucia has a bilateral mutual legal assistance treaty with the United States; the treaty can facilitate information exchange and cooperation on transnational crime but is rarely used.

The FIA is a member of the Egmont Group of Financial Intelligence Units. Saint Lucia is a member of the Caribbean Financial Action Task Force (CFATF), a FATF-style regional body. See Saint Lucia’s most recent mutual evaluation report for more information.

AML Legal, Policy, and Regulatory Deficiencies While Saint Lucia has made substantial progress, several areas require further attention, including enhanced measures to ensure proper identification of beneficial owners of legal entities and additional efforts to impose sanctions on institutions failing to comply with AML/CFT standards.

Enforcement/Implementation issues and comments

In 2024, Saint Lucia’s Inter-Agency Intelligence Committee ‒ comprising the FIA, Police Intelligence Unit, Drug Unit, and Customs Intelligence ‒ coordinated several joint operations that led to the seizure of narcotics and illicit assets. Limited bilateral coordination occurred with US authorities, in part due to ongoing Leahy restrictions.

Amendments to the POCA enhanced the civil asset recovery framework, enabling authorities to seize not only cash but also other criminal proceeds, such as vehicles and properties.

In 2024, Saint Lucia recorded one money laundering prosecution involving $35,226, two forfeiture orders amounting to $98,119, and eight cash seizures and detention orders totaling $116,388. 

Volume I

 Volume II

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