Dear Yesu,
I thank you for your letter dated March, 2014.
I am pleased to observe that your letter embraces several positions which I have articulated publicly. For example, you have recognised the importance of passing the bill quickly and that our obligation to do so stems from our international responsibilities and accordingly, ought not to be the subject of political bargain whereby politicians seek to extract political gains for their support of the bill. I also note that you have recognised that the tabled bill by the government in its current form; is sufficient to comply with the minimum standards of the Caribbean Action Task Force and the Financial Action task Force.My position is that the bill in its current form should be passed forthwith.
As regards the amendments proposed by APNU, government is prepared to compromise on these amendments and indeed, we have laid in the Special Select Committee counter-amendments. These counter-amendments proposed are designed to address the major concerns raised by APNU in relation to the strengthening of the governance architecture of the Financial Intelligence Unit (FIU) in the legitimate regime, while at the same time insulating it from political influence and indeed, any form of politicisation, in order to maintain its independence and functional autonomy. In your letter you have correctly underscored the importance of an independant Financial Intelligence Unit.
In this regard, our counter-amendments provide for the establishment of an authority as contemplated by the APNU and your letter. However, this authority shall comprise the heads of agencies that have a role and responsibility in relation to the combating of money laundering and countering financial terrorism. We propose that the Commissioner of Police, the Director of Public Prosecutions, the Governor of the Central Bank, the Commissioner General of the Guyana Revenue Authority, the Solicitor General, the Head of CANU, the Registrar of Deeds and Companies and representatives from the Private Sector Organisation in the area of banking and commerce comprise of this authority and appointed by the Minister of Finance.
You will observe from our counter proposal that subjectivity and discretion are wholly removed from the appointment process almost all those persons are statutory office holders. I believe that the formulation addresses the conceptual concern of the APNU in terms of strengthening the governance infrastructure in the law while at the same time removing the process from the realm of politics.
As regards currency seizures, your view coincides with the government’s on the issue. In fact, the current law requires no change in this issue and CFATF did not recommend any in relation to this matter.
Like you, I am firm in my belief we must root out from our society the use of proceeds derived from criminal activities.
DONALD RAMOTAR
President
Republic of Guyana

extracted from the Guyana chronicle