Anti-money laundering and counter-terrorist financing

Version 1.0 · Effective 23 October 2026

Trade Commerce Bank is committed to preventing the use of the bank for money laundering, terrorist financing, sanctions evasion and other financial crime. This statement summarises how we meet that commitment.

Legal framework. The bank is subject to the anti-money laundering and counter-terrorist financing laws of the Commonwealth of Dominica, including the Money Laundering (Prevention) Act No. 8 of 2011, the Proceeds of Crime Act No. 4 of 1993, the Money Laundering (Prevention) Regulations 2013, and the Anti-Money Laundering and Suppression of the Financing of Terrorism Code of Practice 2014. We are supervised for these purposes by the Financial Services Unit.

Governance. The board of directors approves the bank’s AML and CTF policy and oversees its application. The bank has appointed a Compliance Officer, who reports to the board.

Risk-based approach. We assess the money laundering and terrorist financing risk of each client, product, delivery channel and jurisdiction, and apply controls in proportion to that risk.

Customer due diligence. Before opening an account, we identify and verify each client, its beneficial owners and the persons authorised to act for it, and we establish the purpose of the relationship and the source of funds. We establish the source of wealth where our risk assessment requires it, and always for higher-risk relationships. We apply enhanced due diligence to higher-risk relationships, including politically exposed persons. We do not open anonymous accounts or accounts in fictitious names, and we do not deal with shell banks.

Ongoing monitoring. We monitor transactions and review client information throughout the relationship.

Sanctions. We screen clients and transactions against applicable sanctions lists, including those of the United Nations.

Reporting. We report suspicious activity to the Financial Intelligence Unit of the Commonwealth of Dominica, as the law requires.

Record keeping. We keep due diligence and transaction records for the period required by law.

Training and audit. Staff receive AML and CTF training when they join and regularly afterwards.

Correspondent banks. Our AML and CTF questionnaire and supporting documents are available to correspondent banks and partners on request. Use the enquiry form on this website or write to enquiries@tradecbank.com.