Financial Compliance

Client Goal

Evaluation

Conducted a “shadow shopping” campaign with regulated banks, simulating random attempts to engage in illicit finance.

In coordination with the Central Bank of The Bahamas (CBB), Evaluasi conducted a scientifically rigorous “shadow shopping” campaign to test the regulatory compliance of international banks and trusts supervised by the CBB.

Evaluasi simulated random attempts to engage in illicit finance under natural conditions to observe the response and conformity to Know Your Costumer (KYC) practices of regulated firms. A total of 250 approaches were made across 75% of Bahamian internationally active public banks and trust companies between December 2022 and January 2023. 17 different nationalities were randomly assigned to the shadow approaches.

Finding 1

Bahamian banks are not receptive to unsolicited approaches from unknown clients (only 14% of approaches generated a response from targeted institutions).

Finding 2

None of the responses indicated any willingness to engage in illicit or dubious activities.

Finding 3

There was no discernible pattern among banks’ responses.

We recommend the CBB to expand the study to corporate social providers as to see if the findings hold across different firms and and to change the profile and depth of shadow approaches to make non-compliance more appealing. This could lead to substantially robust knowledge.

Past Performance

Nutrition Aid

Conducting 20 evaluations of several nutrition interventions for mothers, children, and other individuals across multiple countries and continents.

Humanitarian Aid

Evaluation of Rahma Worldwide’s (Rahma) 2022 distribution of humanitarian aid in Yemen.

Medical Services

Evaluation of individuals who had been tested for hearing loss but had not yet decided to purchase a hearing aid.

Financial Compliance

Conducted a scientifically rigorous “shadow shopping” campaign to test the regulatory compliance of international banks and trusts supervised by the CBB.