Cu­ba, which is at the cen­tre of a mon­ey laun­der­ing case in which Re­pub­lic Bank has been named, is on a list of 15 coun­tries that have been iden­ti­fied as not be­ing suf­fi­cient­ly com­pli­ant with the rec­om­men­da­tions of the Fi­nan­cial Ac­tion Task Force (FATF), the in­ter-gov­ern­men­tal agency that de­vel­ops pro­vides in­ter­na­tion­al poli­cies to com­bat mon­ey laun­der­ing and ter­ror­ist fi­nanc­ing.

The list is host­ed on the Web site of T&T's Fi­nan­cial In­tel­li­gence Unit (FIU), which is re­quired to pub­lish the list of coun­tries by virtue of Sec­tion 17(1)(a) of the Fi­nan­cial In­tel­li­gence Unit Act of T&T. The pub­lic no­tice is dat­ed Feb­ru­ary 23, 2012-sev­en days af­ter it was is­sued by the FATF-and is signed by the FIU's di­rec­tor, Su­san Fran­cois.

There is a dou­ble as­ter­ix next to Cu­ba's name on the list which draws at­ten­tion to the fact that the Com­mu­nist coun­try "has not en­gaged with the FATF in the process." There is al­so a note be­low the list in which the FATF "calls on its mem­bers to con­sid­er the risks aris­ing from the de­fi­cien­cies as­so­ci­at­ed" with each of the 15 coun­tries deemed to be non com­pli­ant.

Re­spond­ing to claims by a US pros­e­cu­tor on Mon­day that mil­lions of dol­lars de­fraud­ed from the Amer­i­can health in­sur­ance pro­gramme, Medicare, end­ed up in Cu­ba, the gov­ern­ment of the Com­mu­nist coun­try on Wednes­day said it main­tains strict con­trols to avoid mon­ey laun­der­ing by banks op­er­at­ing in its ter­ri­to­ry.

"For­eign com­mer­cial banks that main­tain ac­counts in Cuban banks are oblig­ed to op­er­ate in strict com­pli­ance with in­ter­na­tion­al and Cuban rules and must guar­an­tee the re­li­a­bil­i­ty of their trans­ac­tions and the cor­rect use of their ac­counts," ac­cord­ing to the state­ment by Jo­hana Tabla­da, deputy di­rec­tor for US af­fairs at the Cu­ba's For­eign Min­istry.

An­ti-mon­ey laun­der­ing guide­lines is­sued by the Cen­tral Bank in Oc­to­ber 2011 re­quire lo­cal fi­nan­cial in­sti­tu­tions to en­sure that, at a min­i­mum, the guide­lines are al­so im­ple­ment­ed in their branch­es and sub­sidiaries abroad. "Where the lo­cal ap­plic­a­ble laws and reg­u­la­tions pro­hib­it the im­ple­men­ta­tion of this Guide­line, the Cen­tral Bank must be no­ti­fied," ac­cord­ing to the doc­u­ment.

Fur­ther, the Cen­tral Bank guide­lines re­quire that lo­cal fi­nan­cial in­sti­tu­tions "pay at­ten­tion to and re­port if sus­pi­cious," busi­ness trans­ac­tions "un­der­tak­en with per­sons and trans­ac­tions with fi­nan­cial in­sti­tu­tions in or from oth­er coun­tries which do not or in­suf­fi­cient­ly com­ply with the rec­om­men­da­tions of the Fi­nan­cial Ac­tion Task Force," such as Cu­ba.

Lo­cal fi­nan­cial in­sti­tu­tions with for­eign branch­es or sub­sidiaries are re­quired to con­duct an as­sess­ment of the an­ti-mon­ey laun­der­ing regime in the ju­ris­dic­tion in which those branch­es or sub­sidiaries op­er­ate. Mean­while, the As­so­ci­at­ed Press re­port­ed yes­ter­day that 46-year-old, Cuban-Amer­i­can Os­car Sanchez plead­ed not guilty to con­spir­ing to laun­der tens of mil­lions of dol­lars in the mas­sive Medicare fraud scheme.

Pros­e­cu­tors say Sanchez con­spired to send mon­ey from Medicare fraud to shell com­pa­nies in Cana­da be­fore it was passed through the Re­pub­lic Bank in Trinidad and then to Cu­ba. Pros­e­cu­tors say he gave cash to the fraud ring­lead­ers who did not want their mon­ey traced. Sanchez was born in Cu­ba and is a US cit­i­zen. He ap­peared in fed­er­al court in Mi­a­mi yes­ter­day, and his at­tor­ney en­tered the not guilty plea.

Sanchez is be­ing held in fed­er­al cus­tody be­cause pros­e­cu­tors con­sid­er him a flight risk. Pros­e­cu­tors are seek­ing more than $22 mil­lion in prop­er­ty from Sanchez. If con­vict­ed, he could face 13 years in prison.