a) Grenada completed its National Risk Assessment (NRA) in relation to money laundering (ML) in 2019 and identified the following as higher-risk predicate offences- theft and robbery (medium-high), fraud (high) and drug trafficking (medium-high). While Competent Authorities (CAs) and regulated entities (REs) were aware of the ML risks, there was a reasonable understanding of the vulnerabilities consistently across the REs, as well as the threat from foreign predicates. Further, the ML NRA did not include the assessment of non-profit organisations (NPOs), legal persons and Grenada’s citizenship by investment (CBI) programme. Grenada completed a TF and PF risk assessment in June 2021 which identified the TF and PF risks as medium-low. However, interviewees’ understanding of the TF risk was fair given that the TF and PF risk assessment was not yet disseminated to any stakeholders at the time of the onsite. Grenada has implemented preliminary mitigating measures to address its ML risks such as the Strategic Intelligence Cell (SIC) and Stem Flow, however, the abovementioned risks (NPOs, legal persons and Grenada’s CBI programme) remain to be addressed. Further, TF risks are not being adequately addressed. 

b) Grenada has pursued the investigation and prosecution of ML consistent with the findings from the NRA and context of the jurisdiction. However, it appears that the assessment of risk followed a cyclical process and was based largely on reports of the occurrence of the crime and its subsequent investigation and omitted critical financial information to better understand the ML risk. There has been no investigation or prosecution for TF, consistent with the risks identified. Grenada utilizes mutual legal assistance (MLA) to a limited extent to enhance investigations as necessary and there is a moderate level of use of financial intelligence in investigations of ML, associated predicate offences and TF. Further, the number of suspicious transactions reports (STRs) filings were concentrated across only 4 sectors (Banks, Credit Unions, Money Service Businesses (MSBs) and Insurance) which can negatively impact identification of suspected ML/TF activities. 

c) Grenada has not implemented Targeted Financial Sanctions (TFS) pursuant to the United Nations Security Council Resolutions (UNSCR) 1267, its successor resolutions or UNSCR 1373. Grenada has not implemented any laws or measures to address the financing and proliferation of weapons of mass destruction (PF).