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 establishing a Verification and Exchange of Information (VEOI) function to ensure the accuracy, completeness, validation, and lawful exchange of BO data in accordance with national legislation and international transparency standards.
Objective of the Assignment
The objective of this assignment is to provide strategic, technical, and operational leadership for the establishment and ongoing functioning of the Verification and Exchange of Information (VEOI) Section within the Beneficial Ownership Unit, ensuring compliance with statutory requirements, confidentiality standards, and international best practices.
Scope of Services
A. Establishment and Operationalisation of the VEOI Section
- Section Set-Up and Operational Framework: Lead the design and implementation of the organisational and functional framework for the VEOI Section, including roles, responsibilities, workflows, and reporting lines; develop a phased implementation plan for bringing the VEOI Section into full operational status; support Management in the identification of staffing needs and workflow dependencies.
- Information Systems and ICT Collaboration: Work closely with the ICT Lead and project team to support the implementation, configuration, and effective use of the Beneficial Ownership IT portal and any related systems; provide subject-matter input on verification, risk assessment, audit trail, and exchange of information functionalities; participate in system testing, user acceptance testing, and refinement of system workflows relevant to VEOI operations.
- Development and Documentation of SOPs: Develop, document, and formalise Standard Operating Procedures for all VEOI functions, including verification processes, escalation protocols, quality assurance, exchange of information requests, recordkeeping, and confidentiality safeguards; ensure SOPs are aligned with national legislation, data protection requirements, and relevant international standards; develop a procedures manual and supporting reference materials, inclusive of an Exchange of Information manual.
- Training and Capacity Building: Design and deliver structured training programmes for VEOI staff on use of the Beneficial Ownership portal and related ICT systems; verification methodologies and risk-based approaches; exchange of information protocols and statutory timelines; confidentiality, data protection, and information security obligations.
- Knowledge Transfer and Sustainability: Establish mechanisms for institutional knowledge retention, including training materials, SOP repositories, and guidance notes; support management in embedding VEOI processes into business-as-usual operations; prepare transition notes or handover documentation to ensure continuity beyond the consultancy period.
B. Verification Activities
- Lead and oversee all verification workflows within the VEOI Section.
- Conduct advanced reviews of complex and multi-layered ownership structures and supporting documentation.
- Apply and refine verification protocols to validate identification documents and BO submissions.
- Establish and maintain quality assurance mechanisms and verification procedures.
- Identify indicators of non-compliance or concealment and escalate cases to the Compliance Section with documented risk rationale.
- Analyse verification outcomes to identify trends, systemic weaknesses, and emerging risks.
- Provide technical guidance and on-the-job training to verification staff.
C. Exchange of Information Activities
- Serve as the primary point of contact for receiving, processing, and responding to BO information requests from domestic and international competent authorities.
- Assess the legal sufficiency, confidentiality safeguards, and completeness of incoming and outgoing information requests.
- Prepare accurate, timely, and secure responses in accordance with statutory timelines and cooperation frameworks.
- Maintain detailed audit trails of all information exchange activities.
- Build effective working relationships with domestic regulators and international partners.
- Prepare periodic and ad-hoc reports for senior management.
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.
