Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2026 Update (June)

Determinations

i.p.b.

i.p.

i.p.b.

i.p.

i.p.

i.p.

i.p.

i.p.

i.p.

n.a.

LC

Ratings

PC

PC

LC

LC

C

C

C

C

C

C

Recommendation (A.1, framework)

Consistent guidelines should be available to ensure that all entities, arrangements and AML-obliged persons comply with their requirements to identify beneficial owners. Barbados should ensure that, in practice, where no natural person meets the definition of a beneficial owner, the identification of the senior managing official as the beneficial owner is made in accordance with the standard. Barbados should ensure that adequate, accurate and up-to-date beneficial ownership information is available for all relevant legal entities and arrangements in line with the standard.

Underlying factor

In Barbados, all companies incorporated under the Companies Act and foreign companies carrying out an undertaking in Barbados are required to maintain up-to-date records of their beneficial owners. However, there is no requirement in the Barbadian law on the frequency for the review or the update of beneficial owner information for partnerships and trusts. While the principal elements required by the standard with respect to the identification of beneficial owner(s) of legal entities are present, the requirement to identify persons holding a senior managerial position when no beneficial owner is identified is not contemplated in the definition. In accordance with the Companies Act, companies are also required to submit an annual statement by way of the annual return which certifies that accurate and up-to-date beneficial ownership information was maintained for the preceding year, at the registered office of the company. However, the compliance with this obligation is very low (27% in 2021). Although companies must maintain up-to-date records of their beneficial owners, the system in place does not ensure that changes in beneficial ownership are brought to their attention.

A second source of beneficial ownership information relies on AML-obliged persons. Beneficial ownership information should be updated by the AML-obliged persons throughout the business relationship. However, there is no specified frequency for updating beneficial ownership information. In addition, the beneficial ownership information may not be available in all cases, as there is no requirement for all legal persons and arrangements to engage AML-obliged persons.

Finally, the binding guidelines applicable to legal entities, legal arrangements and AML-obliged persons are inconsistent.

(see paragraphs 37, 62, 65, 73, 76-77, 80-81, 116 and 121 of the Barbados’ 2022 Supplementary Report for more information)

Summary of actions reported

Barbados reported that compliance with filing obligations has increased from 27% in 2021 to 89.9% in 2022, linked to the clean-up of the register to eliminate inactive companies which started in 2022. The Anti-Money Laundering Authority guidelines have been aligned with the other guidelines with respect to the threshold for controlling ownership interest. The amended Corporate Affairs and Intellectual Property Office Guidelines (2025) state that senior managing officials should be identified as beneficial owners when no other natural person can be identified, and the Financial Services Commission guidelines are in the process of being amended accordingly. Barbados has introduced specified frequencies for the updating of beneficial ownership information.

Conclusion

Barbados has made progress to address the recommendation. The clean-up of the register is a positive measure that has resulted in better compliance rates with obligations to declare maintaining beneficial ownership information at a registered office. The Anti-Money Laundering Authority guidelines have been aligned with the other guidelines on the threshold for controlling ownership interest. The change in the Corporate Affairs and Intellectual Property Office guidelines, allowing companies to identify a senior managerial natural person where no individual meets the definition of beneficial owner through ownership or control, is a suitable measure. Similar changes are in the process of being implemented in the Financial Services Commission guidelines. Updating requirements with specific timeframes have also been introduced. Nevertheless, the actions reported by the authorities do not cover all the aspects that had been identified as needing improvement. Barbados should report further progress in the next self-assessment.

Status determined

In the process of being addressed

Actions required

In its next self-assessment, Barbados should –

• Continue reporting on actions and outcomes with regards to filing obligations, including ensuring the quality of the information filed.

• Report on implementation of the requirement to report on changes in beneficial ownership information within specified timeframes, including through the application of sanctions.

• Report on measures to ensure adequate, accurate and up-to-date beneficial ownership information of entities and arrangements that do not have the obligation to always engage an AML-obliged person, such as general partnerships.

• Finalise amendments to the Financial Services Commission guidelines to include the option of identifying senior managing officials as beneficial owners if no natural person meets the definition of beneficial owner.

Recommendation (A.1, practice)

Effective supervisory and enforcement measures should be taken to ensure that all entities comply with their requirements to maintain identity and ownership information.

Underlying factor

Although penalties for non-compliance with identity and ownership filing and record keeping obligations have been introduced into Barbadian law, they are not effectively applied in practice.

(see paragraphs 82 to 96 of the Barbados’ 2022 Supplementary Report for more information)

Summary of actions reported

Barbados reported that stricter penalties are available for non-compliance with beneficial ownership identification and record keeping obligations under the amended Companies Act.

As part of enforcement actions, the 14 510 companies on the company register were risk-rated for compliance with beneficial ownership identification and record keeping obligations. Four non-compliant companies were sanctioned with fines and one company was referred to the Director of Public Prosecution due to non-payment of the fine. The risk-rating is an ongoing process.

In November 2022, the International Business Unit issued a Notice of Imposition of Pecuniary Penalties for Beneficial Ownership deficiencies to a Corporate and Trust Service Provider, resulting in a fine and provision of evidence for remediation of the deficiencies.

Conclusion

Barbados has made progress to address the recommendation. It has put in place a risk-based supervisory system and provided evidence of the application of sanctions. The submissions reflect actions taken in respect of companies identified as high risk, but more evidence would be needed to reflect the levels of compliance by entities across risk categories, types of violations noted and application of sanctions where appropriate. Barbados should report further progress in the next self-assessment.

Status determined

In the process of being addressed

Actions required

In its next self-assessment, Barbados should –

• Report further supervisory actions over a broad segment of supervised companies, including statistics on remediation actions and sanctions where appropriate.

• Indicate the types of violations related to identity and ownership filing and record keeping obligations noted during supervision for which penal actions were taken.

Recommendation (A.1, practice)

Barbados is recommended to continue and enlarge its enforcement efforts to all entities with the implementation of a comprehensive and effective supervision and enforcement programme to ensure the availability of accurate and up-to-date legal and beneficial ownership information in line with the standard.

Underlying factor

The Compliance Units under the International Business Unit and the Anti Money Laundering Authority have been recently set up. Regulatory cycles have started on companies with an annual revenue above BBD [Barbadian dollars] 1 million (EUR 439 898) through the monitoring of their corporate and trust service providers. However, the supervision of companies under this threshold, representing around 90% of all companies in Barbados, and of general partnerships, where the engagement with corporate and trust service providers is not mandatory, remains very limited.

(see paragraphs 79 and 90 of the Barbados’ 2020 Report and paragraphs 86 to 96 and 108 to 116 of the Barbados’ 2022 Supplementary Report for more information)

Summary of actions reported

Barbados reported that following a register clean-up, all companies with annual revenue below BBD 1 million (EUR 439 898) were risk-rated against their obligation to maintain ownership information. Subsequently, 100% of high-risk companies and 30% of medium-risk companies were inspected and sanctions applied for non-compliance. All medium-risk companies that were inspected were found to be compliant. The supervision process is ongoing.

Partnerships which engage a Corporate and Trust Service Provider or another AML-obliged person are covered by the supervisory processes of the International Business Unit and the Anti-Money Laundering Authority Compliance Unit, respectively, both of which have included enforcement actions.

Conclusion

Barbados has made progress to address the recommendation. A risk-based approach to supervision has led to inspections of all high-risk companies and a third of medium-risk companies. There is evidence of enforcement actions in the form of pecuniary sanctions and strike-offs. The submissions reflect actions taken in respect of companies identified as high risk, but more evidence would be needed to reflect the levels of compliance by entities across risk categories, types of violations noted and application of sanctions where appropriate. No actions have been reported with regards to the supervision of partnerships that do not engage a service provider. Barbados should report further progress in the next self-assessment.

Status determined

In the process of being addressed

Actions required

In its next self-assessment, Barbados should –

• Report further on actions of supervision and oversight over a broad set of entities (including low-risk companies and partnerships).

• Clarify how supervisory actions provide for the availability of beneficial ownership information on partnerships, including those not engaging an AML-obliged person.

Recommendation (A.1, practice)

Barbados should review its system whereby a significant number of noncompliant companies remain with legal personality on the Commercial Register and should implement appropriate supervision.

Underlying factor

The significant number of non-compliant, and potentially inactive, companies (at least 63% of entities registered with the Commercial Register) that maintain legal personality but do not comply with their filing obligations raises concerns that updated legal and beneficial ownership information might not be available in all cases.

(see paragraphs 37 and 101 to 106 of the Barbados’ 2022 Supplementary Report for more information)

Summary of actions reported

Barbados reported that through a register clean-up (which is ongoing), around 60% of the initial population of companies had been struck off by the end of 2024, reducing the risks related to inactive companies. This has resulted in higher compliance rates with the annual return filing obligations.

While after strike-off, a company’s status as a registered entity is revoked and it loses legal personality, the company’s and every director’s liability may be enforced as before. Companies may apply for restoration after being struck off, subject to the provision of outstanding annual returns and other documents and settlement of penalties and fees. The person granted custody of the documents and records of a dissolved company must keep those in Barbados for six years following dissolution.

Conclusion

Barbados has made progress to address the recommendation. The company register clean-up has been an important step and has resulted in improved compliance rates for filing of annual returns. However, companies can continue to become inactive, and the risk of their non-compliance and the non-availability of legal and beneficial ownership information remains. Since the issue of a large number of inactive companies continuing their legal personality in the company register has been a persistent issue in the past, the ongoing nature of the actions taken to ensure the integrity of the company register should be reflected over a longer timeframe and be supported through appropriate information (including statistical information on oversight activities). Barbados should report further substantive progress in the next self-assessment.

Status determined

In the process of being addressed.

Actions required

• In its next self-assessment, Barbados should –

• Provide information on the ongoing actions taken to ensure the integrity of the company register, including the actions and outcomes of oversight on inactive companies.

• Provide statistical information like year-wise compliance rates with obligations to file annual certifications of maintenance of legal and beneficial ownership information by companies.

• Provide information (including statistical information) on the actions taken to ensure the availability of legal and beneficial ownership information by struck-off companies seeking restoration.

Recommendation (A.2, practice)

Barbados is recommended to ensure that there is adequate oversight of the compliance of all entities with their accounting obligations.

Underlying factor

Barbados does not have a regular system of oversight in place with respect to all entities. As less than 40% of the entities are registered with the Barbados Revenue Authority, the availability of accounting records may not be ensured through the related tax audit regime.

(see paragraphs 134 to 140 of the Barbados’ 2022 Supplementary Report for more information)

Summary of actions reported

The company register has been cleaned up and a crosschecking exercise between the register and the tax authority has led to more overlap. Barbados reported that a number of entities were audited against compliance with the Income Tax Act with regards to the obligation to retain accounting records. Amendments to the Income Tax Act to require all companies registered on the company register to file corporate tax returns are in the process of being put into place.

Conclusion

Barbados has made progress to address the recommendation. The company register clean-up and the crosschecking exercise between the register and the tax authority mean the tax audit regime is better placed to examine availability of accounting records. It remains unclear how many entities were subject to audits and what the outcomes were. The amendments regarding the obligation for all companies to file corporate tax returns are yet to be passed and implemented. Barbados should report further progress in the next self-assessment.

Status determined

In the process of being addressed

Actions required

In its next self-assessment, Barbados should –

• Report on the outcomes of the proposal for legal changes in respect of its Income Tax Act.

• Report statistical information on return filing rates and audits.

• Report on the criteria used to select entities for audit, the percentage of entities subject to audits, and the outcomes of the audits.

Recommendation (A.2, practice)

Effective enforcement measures should be taken to ensure that all entities comply with their record-keeping requirements.

Underlying factor

No sanctions have been applied for any violation of record-keeping obligations. Although sanctions exist, no authority has yet applied them for failing to maintain records as required.

(see paragraphs 136, 138 and 141 of the Barbados’ 2022 Supplementary Report for more information)

Summary of actions reported

Barbados reported proposed amendments to the Income Tax Act in the form of pecuniary penalties for failure to maintain or provide information on accounting records. The amendments remain under review.

Barbados did not report the application of any sanctions.

Conclusion

No progress has been reported on addressing the recommendation. Barbados is urged to address the recommendation and report substantive progress in its next self-assessment.

Status determined

Has not been addressed

Actions required

In its next self-assessment, Barbados should –

• Report substantive progress to address the recommendation.

• Report statistical information on application of sanctions, as appropriate.

Recommendation (A.2, practice)

Barbados should review its system whereby a significant number of non-compliant companies remain with legal personality on the Commercial Register and should implement appropriate supervision.

Underlying factor

The significant number of inactive companies (at least 63% of entities registered with the Commercial Register) that maintain legal personality but do not comply with their filing obligations raises concerns that accounting information might not be available in all cases. Such entities are not subject to effective supervision.

(see paragraphs 134 to 140 of the Barbados’ 2022 Supplementary Report for more information)

Summary of actions reported

Barbados reported that the clean-up of the corporate register has led to so far around 60% of the initial population having been struck off. Amendments to the Income Tax Act to require all companies, including those which have not carried out business in a given year, to file a corporate tax return are in the process of being put in place.

Conclusion

Barbados has made progress to address the recommendation. The number of inactive companies on the register has been reduced significantly, with this being an ongoing process. An important amendment to the Income Tax Act requiring all companies to file corporate tax returns is yet to be enacted and enforced. Barbados should report further progress in the next self-assessment.

Status determined

In the process of being addressed

Actions required

In its next self-assessment, Barbados should –

• Report on the outcomes of the proposal for legal changes in respect of its Income Tax Act.

• Report statistical information on return filing rates and outcomes of audits.

Recommendation (A.3, framework)

Barbados should ensure that up-to-date beneficial ownership information on all bank accounts in line with the standard is available.

Underlying factor

There is no specified frequency of updating beneficial ownership information, so there could be situations where the available beneficial ownership information is not up to date.

(see paragraph 144 of the Barbados’ 2022 Supplementary Report for more information)

Summary of actions reported

Barbados reported that the Central Bank of Barbados reviews Financial Institutions’ risk-based processes for updating beneficial ownership information. It does not prescribe a specific frequency for updating the information. The Central Bank is still considering how to address the recommendation.

Conclusion

Barbados has taken preliminary steps to address the recommendation but no material progress has been reported. It is urged to make substantive progress before the next self-assessment.

Status determined

Has not been addressed

Actions required

In its next self-assessment, Barbados should:

• Report substantive progress to address the recommendation.

Recommendation (B.1, practice)

Barbados is recommended to use its compulsory powers whenever necessary to ensure that all requested information is obtained in a timely manner for exchange purposes.

Underlying factor

Despite having sanctions for non-compliance with a request for information, the authorities of Barbados have not applied enforcement procedures in a streamlined and effective manner to ensure compliance by information holders.

(see paragraph 146 of the Barbados’ 2020 Report and paragraphs 151 to 155 of the Barbados’ 2022 Supplementary Report for more information)

Summary of actions reported

Barbados reported that it continued to use compulsory powers under the Income Tax Act, Section 76, to gather information. It reported on two concrete cases of use of access powers in 2025.

Conclusion

Barbados has made progress to address the recommendation. It provided concrete examples of recent successful application of access powers. Previous cases of non-compliance or delayed compliance with information requests as well as the issue of response times remained unaddressed. Barbados should report further progress in the next self-assessment.

Status determined

In the process of being addressed

Actions required

In its next self-assessment, Barbados should –

• Continue reporting on steps undertaken to ensure effective application of compulsory powers where non-compliance is noted while exercising access powers.

• Clarify if there have been cases of delays or non-compliance while gathering information and if compulsory action was applied in such cases.

Recommendation (C.5, practice)

Barbados should systematically provide an update or status report to its EOI partners within 90 days when the Competent Authority is unable to provide a substantive response within that time.

Underlying factor

During the period under review, Barbados has not always provided status updates to its EOI partners within 90 days when the Competent Authority was unable to provide a substantive response.

(see paragraphs 228 to 229 of the Barbados’ 2020 Report and paragraph 200 of the Barbados’ 2022 Supplementary Report for more information)

Summary of actions reported

For the monitoring period 2023 and 2024, Barbados received 23 EOI requests, of which 15 were responded to within 90 days and 4 are still pending. Barbados reported having provided status updates or partial responses in all cases that could not be fully responded to within 90 days. A dedicated email account was created to improve communication with partners and Barbados was working on starting the use of the Common Transmission System.

Conclusion

Barbados has made progress to address the recommendation. It has taken steps to improve communication with partners and reports providing status updates. One peer indicated difficulties in receiving a status update during the monitoring period. Barbados should report further progress in the next self-assessment.

Status determined

In the process of being addressed

Actions required

In its next self-assessment, Barbados should –

• Provide further statistical details on the communication with partners demonstrating that sufficient status updates have been provided in all cases.