Jamaica’s real estate developers and motor vehicle dealers have emerged as top money laundering risks, according to the Third National Risk Assessment (NRA) published by the Bank of Jamaica this month.
“Real estate development, motor vehicle trade, selected professional services, and trade-based money laundering linked to construction inputs and vehicle imports represent nascent areas of attraction for mal-actors,” the report stated.
Overall, the NRA gave the country a medium risk rating for the period spanning 2021 to 2025 — an improvement from the medium-high rating in the previous report, which highlighted the remittance sector as the main vulnerable channel. Funds are now flowing through designated non-financial businesses and professions.
The report is the most comprehensive risk profile produced under the National Anti-Money Laundering Committee framework. Both the real estate dealer sector and motor vehicle dealers carry a residual risk rating of medium-high.
The motor vehicle trade is flagged as a persistent integration channel, attractive because it can “absorb substantial funds, involve beneficial ownership opacity, and create opportunities to commingle criminal and legitimate proceeds.”
In real estate, the NRA warns that “high transaction values, beneficial ownership opacity, legal entities, third-party funding, rapid resale and cross-border investment create material vulnerabilities” that can obscure the true owners and source of wealth behind property purchases. Property sales reached roughly $132 billion, equivalent to US$840 million, in 2024, representing 3.8 per cent of GDP — up from roughly 1.5 per cent at the time of the previous assessment.
Real estate developers, assessed as a distinct sub-sector, fall entirely outside the Proceeds of Crime Act’s designated non-financial institutions order, meaning, they carry no legal obligation to apply anti-money laundering due diligence on their clients, the report stated. The BOJ and the Real Estate Board examined 385 development applications filed between 2021 and 2024, with an aggregate declared cost of $299.6 billion, equivalent to some 8.6 per cent of 2024 GDP. High-risk funding sources — classified as self-finance, private investors and mixed financing — accounted for roughly 7.8 per cent of total project costs. The primary money laundering typology identified was developments “reported as 100 per cent self-financed” with payments for labour and materials made in cash. The Financial Gleaner awaits a response to queries sent to the Incorporated Masterbuilders Association of Jamaica.
The report noted, however, that the sector generally operated legitimately. “Overall, the study found no widespread irregularities in multi-stage construction patterns or lot/unit configurations that would signal layering through project structuring,” it noted.
At the national level, Jamaica’s overall residual money laundering risk has improved by one notch to medium in 2025, attributed to stronger institutional coordination, improved financial intelligence, and more consistent use of asset-restraint powers. “Criminal actors face greater barriers to integrating proceeds through the formal system,” the NRA stated, characterising the current threat environment as one of “constrained adaptation rather than uncontrolled displacement”.
The principal predicate threats driving money laundering remain narcotics trafficking, fraud and cybercrime — the three offence groups generating “significant and repeatable proceeds” — with corruption assessed as a material supporting threat.
The report calls for tighter funding-source disclosures in the development sector, sustained oversight of legal arrangements in real estate development complexes, and analytics-led targeting of outliers. It also notes that the Real Estate Board is currently seeking legislative amendments to strengthen beneficial ownership and source-of-funds provisions.
business@gleanerjm.com
