The Ministry of Energy, Business Development and Consumer Affairs, through its Business Compliance Division, is responsible for the administration and oversight of Beneficial Ownership (BO) reporting obligations. The Beneficial Ownership Unit is responsible for monitoring and enforcing compliance with BO reporting obligations. The Compliance function undertakes risk-based reviews, investigations, and remedial actions to address non-compliance.
Objective of the Assignment
The objective of this assignment is to establish, and operationalise a robust Compliance Section within the Beneficial Ownership Unit, while managing and executing a comprehensive, risk-based compliance monitoring and investigative programme. The assignment aims to ensure the consistent application of Beneficial Ownership legislative requirements, the development of sustainable compliance systems and procedures, and the timely identification, remediation, and escalation of non-compliance to the Enforcement Section, in accordance with due process and international best practices.
Scope of Services
A. Establishment and Operationalisation of the Compliance Section
The Consultant shall support the establishment, strengthening, and operational readiness of the Compliance Section within the Beneficial Ownership Unit, including:
- Compliance Section Set-Up and Operational Framework: Lead the development and refinement of the Compliance Section's operational framework, including internal workflows, investigation pathways, escalation thresholds, and reporting lines; support the structuring of compliance functions across desk-based reviews, onsite or targeted reviews, investigations, and referrals to the Enforcement Section; develop an implementation roadmap to transition the Compliance Section into a fully operational, risk-based compliance function.
- Risk-Based Compliance Systems and Tools: Design and implement risk-based compliance methodologies, including risk scoring criteria, sampling approaches, and prioritisation frameworks for reviews and investigations; develop and standardise compliance tools, templates, checklists, and investigation instruments to ensure consistency and defensibility of compliance actions; work closely with the ICT Lead and project team to ensure compliance workflows are appropriately supported within the Beneficial Ownership portal and related systems.
- Development and Documentation of SOPs: Develop, document, and maintain Standard Operating Procedures covering all Compliance Section activities, including risk-based compliance monitoring; audits and investigations; issuance of compliance notices and information requests; escalation and referral to Enforcement; recordkeeping, audit trails, and confidentiality safeguards. All procedures must align with applicable legislation, due process requirements, and international best practices.
- Training, Supervision, and Capacity Building: Design and deliver structured training programmes for Compliance staff on risk-based compliance and investigative techniques; use of the Beneficial Ownership portal and related systems; legal standards, evidentiary considerations, and procedural fairness; documentation and reporting standards. Provide day-to-day supervision, mentoring, and on-the-job coaching to build investigative capability and professional judgment within the Compliance Section. Support cross-functional training with Verification, Exchange of Information, and Enforcement Sections, as appropriate.
- Knowledge Management and Sustainability: Establish mechanisms for institutional knowledge retention, including compliance manuals, guidance notes, case studies, and training materials; support management in embedding compliance processes into routine operations and performance monitoring frameworks; prepare handover notes or transition documentation to ensure continuity and sustainability beyond the consultancy period.
B. Execution of Compliance Monitoring and Investigative Functions
- Apply and continuously refine approved compliance procedures, workflows, inspection tools, and risk frameworks in the execution of compliance activities.
- Conduct and supervise complex audits, compliance reviews, and investigations into BO filings.
- Identify discrepancies, red flags, and potential concealment within ownership structures.
- Issue clarification requests and compliance notices in accordance with due-process requirements.
- Monitor implementation of remedial actions and escalate unresolved breaches to Enforcement.
- Develop compliance procedures, workflows, inspection tools, and risk frameworks.
- Analyse compliance trends and produce policy-relevant insights.
- Prepare investigation summaries, compliance reports, and enforcement referrals.
- Provide ongoing supervision, mentoring, and targeted technical guidance to compliance staff in the execution of daily compliance and investigative functions.
- Liaise with domestic regulators and relevant stakeholders as required.
Characteristics of the Consultancy
- Consultancy Category & Modality: The contract consists of 12 monthly payments to be awarded on completion of monthly deliverables.
- Contract Duration: July 1, 2026 – June 30, 2027
- Place of Work: Barbados
Schedule of Payments
Payments will be made as 100% divided into equal monthly payments of $9,105.30 for 12 months, on approval of the Consultant's monthly Personal Performance Report.
Qualifications and Experience
- A degree in Business Administration, Finance, Law, Economics, Accounting, International Relations, or International Business, with not less than five years' supervisory experience in a Compliance or Regulatory function; OR
- A postgraduate qualification in the areas above with not less than three years' supervisory experience in a Compliance or Regulatory function.
Knowledge
- Knowledge of AML Compliance generally.
- Knowledge of the corporate landscape in Barbados.
- New Beneficial Ownership Legislation (developing).
- Companies Act Cap. 308.
- Trust Miscellaneous Provisions Act 2018-49.
- Corporate and Trust Service Providers Act 2015-12.
- Private Trust Companies Act 2012-22.
- Foreign Currency Permits Act 2018-44.
- Money Laundering and Financing of Terrorism Act 2011-23.
- FATF 40 Recommendations.
- IBU Anti-Money Laundering Guidelines.
- IBU Beneficial Ownership Guidance.
Reports
The Consultant is required to submit monthly Performance Reports for the duration of the contract. Reports will review all aspects of the work underway and completed, and provide an assessment of level of completion. Reports must be submitted in hard and soft copies. Payment of fees is subject to the Ministry's acceptance of the Performance Reports. Should the Ministry not accept a deliverable, deficiencies must be remedied within fourteen (14) calendar days of being requested to do so.
Confidentiality
The Consultant shall maintain strict confidentiality of all information accessed or generated during the assignment.
Non-Entitlement to Permanent Appointment
Award of this contract does not confer any entitlement, expectation, or right to appointment to any permanent, pensionable, or established post within the Public Service or any Government entity.
