Tag Archives: US Government

Strategy Report Volume II Money Laundering and Financial Crimes March 2017. Sint Maarten.

United States Department of State

Bureau for International Narcotics and Law Enforcement Affairs


Narcotics Control

Strategy Report

Volume II

Money Laundering and Financial Crimes

March 2017



Sint Maarten


Sint Maarten is an autonomous entity within the Kingdom of the Netherlands. The Kingdom retains responsibility for foreign policy and defense, including entering into international conventions. The Kingdom may extend international conventions to the autonomous countries. With the Kingdom’s agreement, each autonomous country can be assigned a status of its own within international or regional organizations subject to the organization’s agreement. The individual countries may conclude MOUs in areas in which they have autonomy, as long as these MOUs do not infringe on the foreign policy of the Kingdom as a whole. In 1999, the Kingdom extended the UN Drug Convention to Sint Maarten, and in 2010, the UNTOC was extended to Sint Maarten.

A governor appointed by the King represents the Kingdom on the island and a Minister Plenipotentiary represents Sint Maarten in the Kingdom Council of Ministers in the Netherlands.

In June 2016, Aruba, Sint Maarten, the Netherlands, and Curacao signed an MOU with the United States to stimulate joint activities and enhance sharing of information in the areas of criminal investigation and upholding public order and security and to strengthen mutual cooperation in forensics and the organization of the criminal justice system. While the MOU is a broad-based attempt to improve all of the criminal justice system, one priority area is cracking down on money laundering operations.


Sint Maarten has an offshore banking industry consisting of one bank.

Many hotels legally operate casinos on the island, and online gaming is also legal but is not subject to supervision.

Sint Maarten’s favorable investment climate and rapid economic growth over the last few decades have drawn wealthy investors to the island to invest their money in large scale real estate developments, including hotels and casinos. In Sint Maarten, money laundering of criminal profits occurs through business investments and international tax shelters. Its weak government sector continues to be vulnerable to integrity-related crimes.


INCSR 2017 Volume II Country Reports


KYC laws cover banks, lawyers, insurance companies, customs, money remitters, the Central Bank, trust companies, accountants, car dealers, administrative offices, Tax Office, jewelers, credit unions, real estate businesses, notaries, currency exchange offices, and stock exchange brokers.

The MLAT between the Kingdom of the Netherlands and the United States, rather than the U.S. – EU Agreement, which has not yet been extended to the Kingdom’s Caribbean countries, applies to Sint Maarten and is regularly used by U.S. and Sint Maarten law enforcement agencies for international drug trafficking and money laundering investigations.

Sint Maarten is a member of the CFATF, a FATF-style regional body, and, through the Kingdom, the FATF. Its most recent mutual evaluation can be found at: https://www.cfatf-gafic.org/index.php/documents/cfatf-mutual-evaluation-reports/sint-maarten-1



In July 2015, Sint Maarten’s FIU reported that hundreds of unusual financial transaction investigations were backlogged at the Sint Maarten Public Prosecutor’s Office. Approximately 1,138 reports totaling $243 million have not been investigated.

The UNCAC has not yet been extended to Sint Maarten.

Sint Maarten has yet to pass and implement legislation to regulate and supervise its casino, lottery, and online gaming sectors in compliance with international standards. In addition, the threshold for conducting customer due diligence in the casino sector does not comply with international standards.


The National Ordinance Reporting Unusual Transactions establishes an “unusual transaction” reporting system. Designated entities are required to file unusual transaction reports (UTRs) with the FIU on any transaction that appears unusual (applying a broader standard than “suspicious”) or when there is reason to believe a transaction is connected with money laundering. If, after analysis of an unusual transaction, a strong suspicion of money laundering arises, those suspicious transactions are reported to the public prosecutor’s office.

The harbor of Sint Maarten is well known for its cruise terminal, one of the largest in the Caribbean islands. The local container facility plays an important role in the region. Larger container ships dock their containers in Sint Maarten where they are picked up by regional feeders to supply the smaller islands surrounding Sint Maarten. Customs and law enforcement authorities should be alert for regional smuggling, TBML, and value transfer schemes.

Statement by Mustafa Mohamed: America’s designation of Hay’at Taḥrīr al-Shām.



Above is a   copy of an official US Department of Defense statement on its designation of  Hay’at Taḥrīr al-Shām, as a terrorist organization.


What follows is the English translation of Mustafa Mohamed’s response Muhamed was is the former spokesman of Jabhat an-Nusra, which   became Jabhat  Fatah al-Sham and according to Mustafa Mohamed : “JFS members, who have recently dissolved into the larger, unified body known as Hay’at Tahreer Al-Shaam (HTS)”.


Here is the complete statement by Mustafa Mohamed the official spokesman of Hay’at Taḥrīr al-Shām:   


The recent statement by the US special envoy for Syria, Michael Ratney, aims to cause disunity and discord in Syria by attempting to isolate former JFS members, who have recently dissolved into the larger, unified body known as Hay’at Tahreer Al-Shaam (HTS). The one page official statement, drafted in Arabic, did not have an English translation, nor was it available on their government website. Rather, the US administration chose to address a very particular Arabic-speaking audience by releasing their statement on the official Twitter page of the US Embassy in Syria. Twitter is an extremely popular platform amongst this constituency, and is where most information regarding the revolution is found, shared, discussed

and disseminated; so it is no wonder that the statement spread through cyberspace like wildfire among the mujahideen in a matter of minutes.

The statement is almost a clear designation of HTS as a terrorist organisation, and if it were not for the necessary formalities, I would have it considered it so. Regardless, I believe that the US will deal with HTS in whichever way it pleases, and just as their bloody military track-record clearly proves, they are not prepared to be held accountable by anyone, nor will any attack by them require verifiable proof to legitimatise or justify it. According to the statement, collective punishment only requires the presence of former JFS members in the ranks of HTS. That is one excuse that has been maintained by the American administration since their interference in the Syrian revolution to justify their crimes.

As long as there is one man that resembles AQ in one war or another, they have the right to blow Syria to smithereens. That man will not exist, and if for some reason he does not, they will find a way to say that he does.

The Americans are desperately counting on: a) using scare-tactics to convince the public that all evil that has come to them is a result of a hidden bogey-man that is secretly collaborating with the diabolical global organisation known as Al-Qaeda; b) creating disunity and discord amongst members of HTS by hoping they will ‘take the bait’ and believe that they may survive if they are subservient. The truth is: every tyrant uses false flags to offer hope, security and success to a weak, uneducated audience. While the Muslim Ummah is far from where it should be today, I can confidently say that even the layman can see through the smoke and mirrors here. I will go as far as saying that even those who are meeting with the Americans regularly, nodding their heads in agreement and doing their best to show those big pearly whites do not believe for a moment that America is the “friend” of the Syrian people.

It is politics, and many of those who have chosen to get involved are doing so assuming they are ensuring the interests of their cause (even though most are deluded and politically naive). In any case, everybody knows too well that there does not exist a nation on this earth that is driven by economic and political self-interests more than America.

Gaining the trust of the Muslim people is an unachievable mission that America is willing to spend billions to achieve. What makes me even more confident that their mission is a complete failure is the fact that even though Mujahideen are far from ideal, and even with the aggressive war waged against them, they still enjoy a relatively public support.

Members of society still believe in them and their cause. Of course there is frustration and anger amongst many, but that is only expected given the extreme circumstances we are going through, most of which is a result of the injustices and oppression raining down on the Syrian people.

I do not intend to justify mistakes or ignore deficiencies that exist in the ranks of the Islamic movement as a whole, some factions obviously being more erroneous than others, but placing the Muslim Mujahid in the same boat as the Americans is nothing short of criminal. Further, the Muslims are growing more aware and have developed an acuity that allows them to see the American administration for what they really are.

That is not going to change any time soon; if it does change for some, it will not be enough to harm the Islamic project, nor will it be enough to ensure the American project in the Middle East is achieved.

The statement written in Michael Ratney’s name was a threat; threats are made by those who are not willing to fight the fight, or at least are not ready just yet. There is something stopping them from making that call. America knows who they are in the eyes of the masses.

Another invasion of a Muslim country will only increase resentment and will certainly encourage acts of aggression against them1. That is not something America wants to do right now. They have much more to lose in a making that call than a country like Russia, for example.

This threat was an attempt steer less resolved members of HTS away from the Islamic project by encouraging them to think of ways to avoid the rubber stamp, ideas such as: fragmenting HTS, denouncing JFS members or even perhaps offering them as a sacrificial lamb.

If this did happen, it would result in JFS members becoming paranoid, looking over their shoulders all the time, creating an environment of non-trust amongst the one group. Assumptions will turn into truths. Conspiracy theories will become intellectual theorization.


Other non-JFS members of HTS will also become worried. Did they make the right choice? Is there any way forward? Were our critics right about us all this time? All of these questions will be flying around, and there will not be anyone to give a decisive answer.

However, none of these issues have mattered in the past when other, less obvious tactics were used to fragment the mujahideen and stop the revolution, and I believe it will not make a difference today.

He ended with the following Quranic injunction:

“And they planned, but Allah planned. And Allah is the best of planners” Qur’an 3:54.

The following is a clarification by Mohamed:

I anticipate this sentence in particular to be taken by some as a sort of subtle threat to America or a hidden message to the youth to carry out attacks in the West. Even though I am not writing this for the audience which will interpret my words this way, I believe that for the sake of my intended audience, it is my duty to clarify my position. I firmly believe that all acts of indiscriminate aggression against a civilian population is Islamically unacceptable, regardless who is carrying them out. Perhaps this can be detailed at a later date.