Sunday, November 12, 2023


Compliance officers must always be mindful of the Law of Unintended Consequences, when an innocent legitimate undertaking or event spawns a golden opportunity for money launderers and/or financial criminals. We have noticed the fanfare surrounding the initiation of nonstop airline service between Barbados and Grand Cayman, announced recently by Cayman Airways. touted as a needed connection between the British West Caribbean and the larger East Caribbean English-speaking republics, designed to facilitate tourism, it will have the net result of making international money laundering  eminently more convenient, in our humble opinion.

If you have been reading our recent articles* about the lawsuit alleging widespread probate and real estate fraud by a group of Barbados lawyers, acting in concert to deprive heirs of their valuable oceanfront land, only to steal it and sell it off to foreign resort operators, you know that these attorney-criminals often end up with a pile of US Dollars, and have been known to deposit them in banks in Grand Cayman, correctly fearing eventual discovery of their untoward and illicit acts of fraud. This new nonstop airline service by Cayman Airways will only make placement of the proceeds of their crime easier, as the Cayman Island regulations not only permit travelers to arrive with cash, but the jurisdiction is a  de facto dual currency economy; the USD is accepted universally there.

Given the paucity of business activity between Barbados and Grand Cayman, save the infrequent tourist seeking a direct airline connection between the two points, to save transferring through an intermediary point, there's really no commercial reason for the new scheduled nonstop service.  Is this really a nod to all those Bajan lawyers hiding their criminal proceeds abroad in a convenient jurisdiction, where there are few questions asked about Source of Funds and Source of Income from foreign attorneys? We cannot say, but the matter bears watching. 


* Alex Mitchell el al vs. Mia Amor Mottley et al, Miami-Dade County Circuit Court.

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