“BAHAMIAN OFFSHORE FINANCIAL CENTRE AND THE OECD: FREE TRADE OR PROTECTIONISM?”
BY ALFRED M. SEARS, ESQ.
The listing of The Bahamas by the Financial Action Task
Force (“FATF”) as a “non-cooperative jurisdiction” with respect to money
laundering; the classification of The Bahamas by the Organisation of Economic
Cooperation and Development (“OECD”) as an “uncooperative jurisdiction” engaged
in harmful tax practices and the Advisory against The Bahamas issued by the
United States Treasury Department are without justification under international
law. The response of The Bahamas, in
addition to negotiating with the OECD, should include a complaint to the
International Court of Justice in the Hague and the World Trade Organisation
against the unlawful conduct of these countries. This concerted attack on The Bahamas is also contrary to the
principles of free trade, economic competition and non-protectionism in the
global economy.
On
the 22nd
June 2000 FATF published a list of fifteen (15) countries, which included The Bahamas, the Cayman
Islands, Panama, Israel, Liechtenstein, and the Philippines as jurisdictions as
“non-cooperative” in the fight
against money laundering.
There is no doubt that the effects on any tax free
offshore financial centre which implements all of the recommendations of the
OECD would be grave if not devastating.
This fact was acknowledged by the OECD itself. In the said Report, at page 7, the OECD admitted that: “The
Committee accepts that the changes necessary for jurisdictions meeting the tax
haven criteria that commit to remove their harmful tax practices may adversely
affect the economies of some of those jurisdictions. The OECD will work with other interested international and
national organisations to examine how best to assist co-operative jurisdictions
in restructuring their jurisdictions.”
While acknowledging the harm that is likely to be
experienced by those countries which implement their recommendations, the OECD
has not committed any resources to assist in the adjustment process. There is only a commitment to work with
other “to examine how best to assist” those countries. Clearly, The Bahamas, acting in concert with
CARICOM and other offshore financial centres need to negotiate a more concrete
commitment from the OECD.
UNITED STATES TREASURY
ADVISORY AGAINST THE BAHAMAS
Acting
in concert with the FATF and the OECD, in July, 2000 the United States
Department of the Treasury, Financial Crimes Enforcement Network, issued
Advisory #13 against The Bahamas alleging, in almost identical terms to those
of FATF and the OECD, that the Bahamian legal, supervisory and regulatory systems
relating to counter-money laundering, suffer from “serious systemic problems”.
Specifically, the Advisory claimed, amongst other things, that The
Bahamas supervisory system does not include rules for the reporting of
suspicious transactions by financial institutions; that banks are not required
to verify the identity of bank customers for whom Bahamian lawyers or certain
other intermediaries open accounts; that access to customers’ bank accounts can
only be obtained by Order of the Supreme Court, collectively defined as
“deficiencies in the counter-money laundering controls”.
Further the United States
Treasury Advisory complained that The Bahamas remains committed to bank
secrecy, that regulatory procedures for identification of customers and account
opening procedures are limited and that Bahamian International Business
Companies (“IBCs”) may issue bearer
shares. The Advisory required banks and
other financial institutions operating in the United States to exercise “enhanced scrutiny”, when dealing with transactions originating in or routed to or
through The Bahamas, or involving entities organised or domiciled or persons
maintaining accounts, in The Bahamas, to determine how the aforesaid
deficiencies in the counter-money laundering controls affect the possibility
that those transactions are being used for illegal purpose.
The said Advisory required the U.S. banks and financial institutions to apply United States law and federal financial institution supervisory guidelines to determine whether any transaction over $5,000.00 originating in or routed through The Bahamas requires reporting under the U.S. rules.
The
listing of The Bahamas by the OECD, the FATF and the issuance of the Advisory
of the United States Treasury Department against The Bahamas appear to be a
coordinated and calculated maneuver to force offshore financial centres such as
The Bahamas to abandon their tax free offshore financial centres upon which
their livelihood has been based and in which they have developed
expertise. According to Prime Minister
Hubert Ingraham, in a communication he made the House of Assembly on the 9th
August, 2000, “…the United States
Treasury Secretary said it in unmistakable, candid language, ‘we intend to
chase and put all tax havens out of business’…”.
If the United States
Secretary of the Treasury were to succeed, the likely result of this policy
could be economic dependency for these countries upon other countries. There is no substantial evidence and data in
support of the claim that the existence of tax-free offshore centres
discourages taxpayer compliance, or contribute to undermining the integrity and
fairness of tax structures or increase the administrative cost to taxpayers in
the OECD member countries.
The
cartel-like policies being pursued by the OECD run counter to the concept of a
liberal and open global economy which has been espoused by the industrialised
countries over the past 55 years. These
same OECD countries have promoted a global economy, based on the principle of
free and unrestricted cross border business activities, free trade and
investment across national borders. The
post Bretton Woods world economy has been based on the gradual removal of
quantitative barriers and restrictions to free trade, as reflected in the
Charters of the World Bank, the International Monetary Fund and the General
Agreement on Trade and Tariff (now known as the World Trade Organisation). Rather than pursuing protectionism, the OECD
countries, in the area of financial services, should be promoting competition
among countries in the area of financial services in order to sustain
reasonable levels of tax burden.
The
argument by the OECD that offshore financial centres are “harmful tax
jurisdictions,” runs counter to the policies of free trade and liberalism
pursued over the last 55 years. The
OECD and the United States are taking us back to the pre-World War II period of
economic protectionism, by imposing new restrictions on the freedom of choices offered to
multinational enterprises to pursue legitimate business in the most cost
effective environment by using offshore financial centres to minimise their
global tax costs.
This
protectionist attack by the OECD on offshore financial centres, such as The
Bahamas, has even been criticised by certain agencies within the OECD
itself. The Business and Industry
Advisory to the OECD published a statement in June 1999 in which it criticised
the aforesaid 1998 Report of the OECD recommending the elimination of offshore
centres such as The Bahamas, in the following terms:
We believe that it is not erroneous to state that is unwarranted taxation by governments, rather than competition among them in the tax area, that is stifling to economic and business development. After all, countries do compete in other ways to attract business to their territories, so why single out taxation of one relatively limited form of activity as harmful? Tax competition tends to keep tax burden lower, which creates pressures for less wasteful, and, therefore more efficient use of public funds. In addition, it fosters increased efficiency in the allocation of scarce resources. Lower tax burdens also translates into lower cost for multinationals operating within the territory and internationally…
We interpret the Report as an attempt to mobilise the OECD nations to adopt a strategy designed to make low tax countries abandon the activities upon which their livelihood has been based for many years and in which they have developed recognised expertise. A result of such a strategy could make these countries economically dependent on other countries.”
I
submit that the existence of tax free financial centres, such as The Bahamas,
tend to impose discipline on high tax regimes, such as the OECD countries, by
forcing them to make more efficient use of tax revenues in their spending
decisions. The assertion by OECD
countries that “mobile activities”, primarily financial functions, are subject
to criminal manipulation must be carefully considered. It is accepted that the proper controls and
supervision are indispensable to maintain the integrity of any on or offshore
financial centre. However, we should
resist protectionist measures designed to keep multinational enterprises in
high tax regime environment, in the name of fighting money laundering. Multinational enterprises should be free to
carry on their activities in the most conducive and cost effective
environment. All countries, small and
large, should be free to compete in offering services to these entities in a
tax or non-tax environment. The Bahamas
should have the right to exercise is fiscal sovereignty by choosing to be a
tax-free jurisdiction and the freedom to choose between various fiscal
policies.
The
naked protectionism behind the OECD’s attack on offshore financial centres, it is submitted, is
against the long-term interest of a liberal global economy, based on free trade
and competition, of which the industrialised countries of the OECD will be the
major beneficiaries.
According to Article 2 (3) and (4) of
the United Nations Charter:
“All Members
shall settle their international disputes by peaceful means in such a manner
that international peace and security, and justice, are not endangered.
All Members
shall refrain in their international relations from the threat or use of force
against the territorial integrity or political independence of any State, or in
any other manner inconsistent with the purposes of the United Nations.”
“Intervention”
is defined by the International Law scholar, Professor Hersch Lauterpacht, as “…dictatorial interference in the sense of action
amounting to a denial of the independence of the State. It implies a demand which, if not complied
with, involves a threat or recourse to compulsion, though not necessarily
physical compulsion, in some form.” (Hersch Lauterpacht, International
Law and Human Rights, 1950).
However, International Law recognises three limited exceptions to the general prohibition against intervening in the domestic affairs of sovereign nations. The first exception is the right of Individual and Collective Self Defense. Under Article 51 of the United Nations Charter, the right of self defense can be exercised if an armed attack occurs against a Member State of the United Nations, until the Security Council has taken measures necessary to maintain international peace and security. This right may also include anticipatory self defense, such as the United States quarantine of Cuba in October 1962. Clearly, no one would seriously contend that The Bahamas made an “armed attack” on the United States or other members of the OECD. Therefore, the actions of the OECD cannot be justified on the basis of collective self defense.
The second limited exception to the general rule of non-intervention in another country, under Articles 1(3, 55 and 56 of the United Nations Charter, is Humanitarian Intervention in order to protect human rights. This limited right is based on the theory that where egregious violations of human rights occur within a State whose government will not or cannot stop them, the general community of nations or another State may enter the territory of the defaulting State to secure an end to the outrage and compliance with a minimum international standard of human rights. Humanitarian intervention has been used to rescue religious minorities, such as the Indian activities in Bangladesh in 1971, the Entebbe operation in Uganda undertaken by Israel in July 1976. Surely it cannot be contended that the punitive measures of the OECD was motivated by any humanitarian concern.
The third limited exception to the general rule of non-intervention in another country is Self Help. Large countries often use self Help, often called “retorsion, retaliations, reprisals, intervention, minor coercion or measures short of war” to control smaller countries or advance their national interests. For example, the International Court of Justice in the Corfu Channel (United Kingdom v. Albania) 1949 I.C.J. 4, allowed Britain to send its war ships in Albanian waters to ensure the freedom of maritime commerce. While countries are generally allowed to used Self Help measures in response to some act of aggression, such as refusing to trade with others or to deny benefits to others, the legality of these measures will be questioned when the counter-measures are directed to an unlawful end. An unlawful end may be a condition where the purported offending State is required to change its internal or foreign policy in order to resume trade with the intervening State. Professor Oscar Schacter, a leading scholar of International Law, (Schacter, International Law in Theory and Practice 178 Rec. des Cours 185-186 (1982-V)) wrote that:
“In that case, an otherwise discretionary act, the retorsion, is used as a means of coercing the object of that retorsion to give up its sovereign right, quite apart from the alleged violation of law that gave rise to the retorsion. There is good reason to consider such use of retorsion as illegal because of its improper objective. One may characterize it as an abuse of rights, but it is more precise to refer to a primary rule that precludes such coercion. The rule is expressed in the unanimously agreed Declaration of Principles of International Law Concerning Friendly Relations (adopted by the United Nations General Assembly in 1970) in the following language:
‘No State may
use or encourage the use of economic, political or any other type of measures
to coerce another State in order to obtain from it the subordination of the
exercise of its sovereign rights and to secure from it advantages of any kind.’
However, its [retorsion] application in actual cases is not always readily apparent except in rather extreme situations (such as a demand that the offending State changes its government or cease relations with another State). Nonetheless, even acknowledging the impropriety of these ‘extreme cases (which are by no means hypothetical) can be a significant step toward recognizing that in some cases otherwise legal acts may be rendered illicit because of the wrongful end sought.”
By the admission of the FATF and the United States Treasury Advisory, the object of the punitive measures taken against The Bahamas was to force The Bahamas to dismantle its offshore financial services sector and make certain changes in its internal administration under the guise of fighting money laundering. However, it is now generally accepted that the real aim of these punitive measures is not in response to any aggression by The Bahamas, but is rather a response to the competition that offshore financial centres, such as The Bahamas, represent to the tax sources of the large industrial countries that control the OECD. It is submitted that this is an unlawful end, as it is calculated to force The Bahamas to dismantle a lawful economic activity for the benefit of high tax regimes. The punitive measures taken by the OECD and the United States were calculated to subordinate the exercise by The Bahamas of its “sovereign rights and to secure from it advantages” through the dismantling of its offshore financial centre.
The punitive measure taken by the FATF and the United States also fail under the requirements of proportionality and reasonableness. The magnitude of the punitive actions taken is disproportionate to any “offense” committed by The Bahamas. In fact, The Bahamas simply took seriously the principles of free competition in the area of financial services. The United States and other OECD countries cannot compete, because of their high tax regimes. Should The Bahamas be made to suffer because those countries cannot or refuse to be more efficient and imaginative in their financial services sectors, tax policies and general fiscal administration?
THE BAHAMIAN RESPONSE TO THE
PUNITIVE MEASURES OF OECD AND THE UNITED STATES
The response of the Bahamian Government has been characterised by panic, confusion, conflicting statements, lack of adequate consultation and full and frank disclosure and the absence of a clear policy focus. It is curious that the Bahamian Government has not challenged the right of the OECD and the United States to dictate the internal economic policies of The Bahamas, when it is acknowledged even by the Government that the primary motivation behind the OECD’s attack is the promotion of the tax interests of high tax jurisdictions within the OECD.
Even though the Government is directly involved in the promotion of the financial services sector and has continuously represented to prospective investors, through its literature and promotional agencies, that The Bahamas is a well regulated offshore financial centre, the Prime Minister has nevertheless accepted the premise of the OECD’s attack on The Bahamas.
In a statement issued on the 26th June, 2000,
the Prime Minister stated that The Bahamas was “surprised and greatly disappointed to be included in a list of uncooperative
jurisdictions in relation to the prevention of Money Laundering released by the
Financial Action Task Force (“FATF”) on 22nd June, 2000.” The Prime Minister posited that “…the Government shall now undertake a
comprehensive review of all its laws, regulations and practices to ensure that
The Bahamas complies with the best practices pursued by the principal financial
centres worldwide. He announced
that certain bills will be introduced to amend the International Business Act,
the Trustee Act, The Bank and Trust Company Act, the Central Bank Act, The
Money Laundering (Proceeds of Crime) Act and the Mutual Legal Assistance
Act. Further, he informed that a
Financial Intelligence Unit would be established and immediate administrative
action will be taken so as to address the systemic delays in the Ministry of
Foreign Affairs and in the Office of the Attorney General as regards the
processing of requests for assistance under the provision of the Mutual Legal
Assistance Treaties. The Prime Minister
stated that “The Bahamas will respond
positively and promptly to the stated concerns of the FATF and the OECD.”
Although Prime Minister
Ingraham had stated that the Government had been “surprised and greatly
disappointed” by the actions of the OECD, Sir William Allen, Minister of
Finance, while addressing the House of Assembly on the 10th August,
2000, made a refreshingly frank admission acknowledged that The Bahamas has
known for some time that at some point there would have to be fundamental
changes made in our offshore Financial centre.
He stated, in part, that:
“We all recognised that at some point they would have had enough and
they could take civil action. We always
knew that industrial countries could take action because the banks came from
them. We knew also that we could only
do business if the industrial countries permitted us to close transactions in
their countries. They would prevent the
use of their clearing systems. We knew
that when they had enough, they were going to do that ”
The candid admission by Sir
William Allen raises the legitimate concern of whether we prepared ourselves
adequately for this foreseeable event.
Prime Minister Hubert Ingraham gave a national address on
the 23rd July, 2000 in which he stated that “…our inclusion on a
list associating The Bahamas with practices with which we have sought,
relentlessly, not to be connected was a tremendous disappointment and the cause
of great concern to my Government..”
Prime Minister acknowledged that in the view of the OECD, the FATF and
the CFATF secrecy no longer has a place in international financial
dealings.
Notwithstanding this view,
the Prime Minister stated that his Government was committed to the continued
growth and success of the financial services sector, within the framework of “international best practices”. The Prime Minister also made a telling
admission. He stated: “My Government accepts the legitimacy of a number of deficiencies
identified in the FATF Report on The Bahamas, particularly as they relate to
weaknesses in the regulatory supervision of financial institutions and
non-financial institutions such as legal and accounting firms and management
companies, in their conduct of financial transactions.” The Prime Minister then promised to present
certain legislative bills to Parliament to “raise
standards in The Bahamas in accordance with the best practices observed by the
major financial centres of the world namely, New York, Toronto, London Paris,
Frankfurt, Geneva and Zurich.” He
announced that beginning the 24th July, 2000 he, the Minister of
Finance, the Governor of the Central Bank, the Director of Legal Affairs and
the Permanent Secretary in the Prime Minister’s Office will hold meetings with
appropriate American and Canadian representatives in Washington, D.C., New
York, US and in Ottawa and Toronto in Canada.
The Prime Minister promised that, through widespread international and
local consultations with all relevant parties, to take all necessary steps to
have The Bahamas’ name removed from the FATF’s list and have the US Advisory
lifted.
RECOMMENDATIONS
1.
If “we have not struck any deal” with any
country or international organisation,
as Prime Minister Hubert Ingraham asserted, I recommend that The Bahamas
should challenge the validity of the punitive labeling of The Bahamas and lodge
a complaint with the International Court of Justice in the Hague against OECD
and the United States for unlawful economic measures and interference in The
Bahamas, contrary to the United Nations Charter, customary principles of
International Law and the principles of free trade and non-protectionism. If the right of The Bahamas to pursue a tax
free offshore financial centre is an essential expression of its right of self
determination and fiscal sovereignty, then the unjustified interference and
challenge of that right by another country or group of countries, even under
the pretext of money laundering, cannot be accepted. Cooperation in the fight against money laundering should not
preclude The Bahamas from offering itself as tax free offshore financial
centre. Further, I suggest that such a
legal challenge can be pursued while we are negotiating with the OECD and the
United States for the least harmful exit route for The Bahamas.
2.
The
Bahamas’ response to the OECD and the United States Treasury Advisory should be
coordinated with the Caribbean Community.
When The Bahamas signed the Treaty of Chaguaramas on the 4th
July, 1983, The Bahamas agreed, as member of CARICOM, to coordinate our foreign
policy initiatives and responses to challenges from non-community
countries.
3.
There
should be a bipartisan domestic response to the threat by the OECD and the
United States. Sir Stafford Sands
provide an example of mature political leadership for transitional periods in Bahamian
national life. In 1961, Sir Stafford
Sands, as Chairman of the Development Board, invited Sir Henry Milton Taylor,
then Chairman of the Official Opposition Progressive Liberal Party, to
accompany him on a trip to the United Kingdom to promote year-round
tourism. The two men agreed not to
discuss politics on their trip, but to focus their attention on the promotion
and expansion of the tourism sector in The Bahamas. Again in 1962 Sir Stafford Sand invited the Leader of the
Opposition to accompany the delegation to visit the European cities of West
Germany, Sweden and the United Kingdom to promote foreign investment in the tourism sector in The
Bahamas. Under our Constitutional
system the requirement of consultation is a primary principle of ordered
government. For example, the Prime
Minister is required to consult with the Leader of the Opposition on every
major appointment of the Judiciary and the Executive Branch. There is, therefore, the constitutional
convention that bipartisan consensus be secured when addressing those issues
which transcend the particulars of partisan concerns. I suggest that the present crisis facing our financial services
sector is such a national challenge which demands a bipartisan response.
4.
I
recommend that the Government appoint a negotiating team, drawing on the
collective intellectual talents, technical expertise, experiences and counsel
of all of our people, irrespective of race, partisan politics and gender, to
negotiate on our behalf a reasonable accommodation with the FATF, OECD and the
United States.
5.
I
recommend that we place a moratorium on the further enactment of any further
legislation related to money laundering until we would have had an opportunity
to engage in a widespread consultation with all sectors of our civil society to
determine how best to respond to the external challenge, with proper safeguard
for the reasonable expectation of privacy and the secure protection of the law
as guaranteed under the Constitution, and, most significantly, how to better
position our offshore financial services sector to be more competitive in the
future as well as the development of other sectors of our economy.
6.
I
call on the Government to make a full disclosure to the Bahamian people by
responding, amongst others, to the following issues:
(a)
Did
the Government give any undertakings to the United States and/or OECD and its
affiliated agencies between the period 1992 to June 2000 to implement any changes in its anti-money laundering
regime?
(b)
Did
the Bahamian Government agree to implement the 40 FATF recommendations and 19
Caribbean Financial Action Task Force recommendations which were part of the
Kingston Declaration on Money Laundering in November 1992 or any time
thereafter?
(c)
Did
the Bahamian Government sign a Memorandum of Understanding affirming its
commitment to implement the 40 FATF and 19 CFATF recommendations?
(d)
If
the Bahamian Government agreed to implement the 40 FATF and 19 CFATF
recommendations, did the Government in fact carry out its obligations
thereunder and, if not, would such failure have contributed to the placing of
The Bahamas on the List by the OECD and the Advisory of the US Treasury
Department?