The Parliament of Barbados gazetted the Money Laundering and Financing of Terrorism (Prevention and Control) (Amendment) Bill, 2026 on September 17, 2026, introducing a mandatory registration regime for designated non-financial business entities and professionals (DNFBPs) and sharply raising anti-money-laundering penalties. The Bill amends Act 2011-23, the principal AML statute, and was published in Official Gazette Part A CLXI No. 110.
The legislation creates a new Compliance Unit led by a Chief Compliance Officer to supervise DNFBPs, requires every DNFBP to register and pay an annual fee before carrying on covered activity, and lifts the maximum section 36 fine from $5,000 to $50,000. A 90-day transitional window lets incumbents continue operating while they register. The Bill has not yet received Presidential assent, and commencement is set by proclamation separately from assent, so the registration deadline does not bite immediately.
Who must register with the Chief Compliance Officer, and by when?
Section 47A requires every designated non-financial business entity or professional to register with the Chief Compliance Officer before engaging in any activity listed in paragraphs 1, 2, 3 or 5 of the Second Schedule. The amended Schedule explicitly covers dealers in precious metals or precious stones (paragraph 2) and persons who operate a gaming institution (paragraph 5). Section 4 now applies the full AML regime to DNFBPs as it does to financial institutions, bringing attorneys-at-law, accountants and real-estate agents within the supervisory perimeter.
Licensed corporate and trust service providers are carved out: section 9(4) excludes entities already licensed under the Corporate and Trust Service Providers Act, 2015 (Act 2015-12) from the Chief Compliance Officer's supervision. Registrants must pay a prescribed annual fee, with fees set by Ministerial Order under the new section 50A, and the Chief Compliance Officer must keep a register of DNFBPs.
Incumbents already carrying on a covered activity immediately before commencement may continue as if registered, but that transitional relief expires 90 days after commencement. Knowingly or recklessly making a false statement in registration is itself an offence, carrying a fine of $50,000 or one year's imprisonment or both.
How do the AML penalties and thresholds change?
The Bill sharply increases financial exposure for non-compliance. Section 36(1) replaces the fixed $5,000 fine with a maximum of $50,000, and section 36(2) rises from $500 to a maximum of $1,000. Two key reporting thresholds double: sections 18(4) and 23(3) both move from $100,000 to $200,000. The table below summarises the before and after positions.
| Provision | Before | After |
|---|---|---|
| Section 36(1) fine | $5,000 (fixed) | not exceeding $50,000 |
| Section 36(2) fine | $500 (fixed) | not exceeding $1,000 |
| Section 18(4) threshold | $100,000 | $200,000 |
| Section 23(3) threshold | $100,000 | $200,000 |
| DNFBP registration | not required | mandatory under section 47A |
What new supervisory structure governs DNFBPs?
Section 9 restructures the Authority into two arms. The Financial Intelligence Unit (FIU), led by a Director, retains the receipt, analysis and dissemination of suspicious-transaction reports under sections 23, 24, 28, 29, 30, 32 and 48. The new Compliance Unit, led by the Chief Compliance Officer, takes over DNFBP supervision and exercises the Authority's powers under sections 31, 33, 34, 35 and 36.
Section 13 prevents the Authority from delegating the Chief Compliance Officer's functions to the Director, keeping the supervision and intelligence arms separate. The Chief Compliance Officer may also issue guidelines under section 26 making certain customer-diligence duties apply to precious-metals dealers and gaming operators only above a financial-transaction threshold set in those guidelines.
What scope changes affect payment service providers?
The definition of "financial institution" now includes a payment service provider within the meaning of the National Payment System Act, 2021 (Act 2021-1), and the Third Schedule routes supervisory oversight of payment service providers between the National Payment System Act framework and the Central Bank of Barbados. The old "non-financial business entity or professional" definition is deleted and replaced with "designated non-financial business entity or professional".
Elsewhere, references to "Corporate Affairs and Intellectual Property" become "Companies" in the identification-record definition and the Third Schedule, while "Director of International Business" becomes "Director of the Business Compliance Division". Section 34(1)(d) adds the clarification that a contravention dealt with administratively "does not constitute an offence under this Act", drawing a cleaner line between administrative penalties and criminal offences.
Continuous, per-jurisdiction monitoring by Obsidian surfaces a gazetted amendment like this the moment it publishes, before the trade press echoes it.
Subscribe to the free newsletter
What to do next
- Confirm whether your firm is a DNFBP under the amended Second Schedule and whether the section 9(4) carve-out for licensed corporate and trust service providers applies.
- Track the Bill through Presidential assent and the commencement proclamation, since the 90-day registration clock starts only on commencement.
- Brief compliance, finance and legal teams on the higher penalty exposure, the new registration and annual-fee obligations, and the payment-service-provider scope expansion.
- Obsidian will flag the assent and commencement proclamation the moment they publish, so your team starts the 90-day clock on time.
