𝐊𝐞𝐲 𝐏𝐨𝐢𝐧𝐭𝐬
• 𝐏𝐄𝐏 𝐂𝐥𝐚𝐬𝐬𝐢𝐟𝐢𝐜𝐚𝐭𝐢𝐨𝐧: 𝐁𝐞𝐢𝐧𝐠 𝐨𝐧 𝐚 𝐩𝐨𝐥𝐢𝐭𝐢𝐜𝐚𝐥 𝐩𝐚𝐫𝐭𝐲’𝐬 𝐜𝐚𝐧𝐝𝐢𝐝𝐚𝐭𝐞 𝐥𝐢𝐬𝐭 𝐚𝐮𝐭𝐨𝐦𝐚𝐭𝐢𝐜𝐚𝐥𝐥𝐲 𝐜𝐥𝐚𝐬𝐬𝐢𝐟𝐢𝐞𝐬 𝐲𝐨𝐮 𝐚𝐬 𝐚 𝐏𝐨𝐥𝐢𝐭𝐢𝐜𝐚𝐥𝐥𝐲 𝐄𝐱𝐩𝐨𝐬𝐞𝐝 𝐏𝐞𝐫𝐬𝐨𝐧 𝐮𝐧𝐝𝐞𝐫 𝐀𝐌𝐋/𝐂𝐅𝐓 𝐥𝐚𝐰𝐬.
• 𝐎𝐅𝐀𝐂 𝐒𝐚𝐧𝐜𝐭𝐢𝐨𝐧𝐬: 𝐀𝐬𝐬𝐨𝐜𝐢𝐚𝐭𝐢𝐨𝐧 𝐰𝐢𝐭𝐡 𝐚 𝐩𝐚𝐫𝐭𝐲 𝐥𝐞𝐝 𝐛𝐲 𝐚𝐧 𝐎𝐅𝐀𝐂-𝐬𝐚𝐧𝐜𝐭𝐢𝐨𝐧𝐞𝐝 𝐢𝐧𝐝𝐢𝐯𝐢𝐝𝐮𝐚𝐥 𝐬𝐢𝐠𝐧𝐢𝐟𝐢𝐜𝐚𝐧𝐭𝐥𝐲 𝐢𝐧𝐜𝐫𝐞𝐚𝐬𝐞𝐬 𝐜𝐨𝐦𝐩𝐥𝐢𝐚𝐧𝐜𝐞 𝐫𝐢𝐬𝐤.
• 𝐆𝐮𝐲𝐚𝐧𝐚’𝐬 𝐀𝐌𝐋 𝐇𝐢𝐬𝐭𝐨𝐫𝐲: 𝐈𝐧 𝟐𝟎𝟏𝟒, 𝐆𝐮𝐲𝐚𝐧𝐚 𝐰𝐚𝐬 𝐠𝐫𝐞𝐲-𝐥𝐢𝐬𝐭𝐞𝐝 𝐛𝐲 𝐅𝐀𝐓𝐅 𝐝𝐮𝐞 𝐭𝐨 𝐥𝐞𝐠𝐢𝐬𝐥𝐚𝐭𝐢𝐯𝐞 𝐧𝐨𝐧-𝐜𝐨𝐦𝐩𝐥𝐢𝐚𝐧𝐜𝐞, 𝐧𝐞𝐚𝐫𝐥𝐲 𝐥𝐞𝐚𝐝𝐢𝐧𝐠 𝐭𝐨 𝐛𝐥𝐚𝐜𝐤𝐥𝐢𝐬𝐭𝐢𝐧𝐠.
• 𝐏𝐨𝐥𝐢𝐭𝐢𝐜𝐚𝐥 𝐂𝐨𝐧𝐬𝐞𝐪𝐮𝐞𝐧𝐜𝐞𝐬: 𝐓𝐡𝐞 𝟐𝟎𝟏𝟓 𝐬𝐧𝐚𝐩 𝐞𝐥𝐞𝐜𝐭𝐢𝐨𝐧𝐬 𝐰𝐞𝐫𝐞 𝐭𝐫𝐢𝐠𝐠𝐞𝐫𝐞𝐝 𝐭𝐨 𝐚𝐯𝐨𝐢𝐝 𝐛𝐥𝐚𝐜𝐤𝐥𝐢𝐬𝐭𝐢𝐧𝐠, 𝐰𝐡𝐢𝐜𝐡 𝐰𝐨𝐮𝐥𝐝 𝐡𝐚𝐯𝐞 𝐝𝐞𝐯𝐚𝐬𝐭𝐚𝐭𝐞𝐝 𝐆𝐮𝐲𝐚𝐧𝐚’𝐬 𝐞𝐜𝐨𝐧𝐨𝐦𝐲.
• 𝐆𝐨𝐯𝐞𝐫𝐧𝐦𝐞𝐧𝐭 𝐑𝐞𝐬𝐭𝐫𝐚𝐢𝐧𝐭: 𝐂𝐨𝐧𝐭𝐫𝐚𝐫𝐲 𝐭𝐨 𝐜𝐥𝐚𝐢𝐦𝐬 𝐨𝐟 𝐯𝐢𝐜𝐭𝐢𝐦𝐢𝐳𝐚𝐭𝐢𝐨𝐧, 𝐭𝐡𝐞 𝐠𝐨𝐯𝐞𝐫𝐧𝐦𝐞𝐧𝐭 𝐝𝐢𝐝 𝐧𝐨𝐭 𝐟𝐫𝐞𝐞𝐳𝐞 𝐭𝐡𝐞 𝐬𝐚𝐧𝐜𝐭𝐢𝐨𝐧𝐞𝐝 𝐢𝐧𝐝𝐢𝐯𝐢𝐝𝐮𝐚𝐥’𝐬 𝐚𝐬𝐬𝐞𝐭𝐬, 𝐭𝐡𝐨𝐮𝐠𝐡 𝐥𝐞𝐠𝐚𝐥𝐥𝐲 𝐞𝐦𝐩𝐨𝐰𝐞𝐫𝐞𝐝 𝐭𝐨 𝐝𝐨 𝐬𝐨.
As long as you are on a political party’s list of candidates, you have automatically subjected yourself to the highest category of compliance risk under the Anti-Money Laundering and Countering the Financing of Terrorism Act (AML/CFT). This classification designates you as a Politically Exposed Person (PEP).
The AML/CFT Act defines a PEP to include not only the individual but also their family members and close associates. This risk is further heightened if you are affiliated with a political party whose principal founder is the subject of one of the most severe international financial sanctions—namely, by the Office of Foreign Assets Control (OFAC). A simple Google search reveals that only about 17,000 individuals and entities out of over 7 billion people globally have been sanctioned by OFAC. Clearly, such a designation carries serious and far-reaching consequences.
𝐆𝐮𝐲𝐚𝐧𝐚’𝐬 𝐀𝐌𝐋/𝐂𝐅𝐓 𝐇𝐢𝐬𝐭𝐨𝐫𝐲
Guyana was already on the brink of being blacklisted. In 2014, the country was grey-listed by the Financial Action Task Force (FATF) due to national-level breaches in updating the AML legislative framework in line with FATF recommendations. We came dangerously close to being blacklisted. See FATF reference here: https://www.fatf-gafi.org/en/countries/detail/Guyana.html….
This situation arose under a minority government, where the opposition refused to cooperate in passing the necessary amendments. This legislative deadlock was one of the main reasons for the 2015 snap elections—to avoid blacklisting. Had we been blacklisted, Guyana could have faced a fate similar to Venezuela’s: complete exclusion from the international financial system. This would have crippled our ability to pay for imports or export local goods.
𝐌𝐢𝐬𝐜𝐨𝐧𝐜𝐞𝐩𝐭𝐢𝐨𝐧𝐬 𝐀𝐛𝐨𝐮𝐭 𝐆𝐨𝐯𝐞𝐫𝐧𝐦𝐞𝐧𝐭 𝐕𝐢𝐜𝐭𝐢𝐦𝐢𝐳𝐚𝐭𝐢𝐨𝐧
The claim that the government is victimizing the sanctioned party and its affiliates is entirely unfounded. In fact, the government refrained from exercising its full authority under the AML/CFT Act. They could have frozen all financial assets of the sanctioned individual immediately upon the OFAC ruling. Instead, they allowed him to close his accounts and withdraw his funds.
I urge everyone to read the AML/CFT Act—particularly Part IV, Sections 38–66—to understand the legal framework and the government’s measured response in respect of the freezing of assets of a sanctioned entity or individual for breaches thereunder.