Artificial intelligence (AI) is now part of the regional conversation on financial crime. However, the Caribbean is still in the early stages of building the frameworks that make AI safe and effective. As confirmed by both DPO Caribbean and a 2025 Portulans Institute review, no island jurisdiction in the Coralisle Group footprint - that is 21 countries, including The Bahamas - has enacted an AI law, and most remain in strategy or readiness phases.
According to the latest reports from the United Nations Education, Scientific and Cultural Organisation (UNESCO), Jamaica has officially published national AI policy recommendations prepared by a government-appointed task force, which its Cabinet is now reviewing. Bermuda has adopted a public sector AI policy and, in March 2025, published a detailed discussion paper by the Bermuda Monetary Authority on responsible AI in financial services.
More recently, on November 26, 2025, Trinidad and Tobago, in partnership with the UNESCO office for the Caribbean, launched “a comprehensive national exercise to assess the country’s preparedness for the ethical, inclusive and human-centred adoption of artificial intelligence (AI)”. Antigua and Barbuda is drafting a national strategy. The rest of the region is relying on data protection law, telecommunications rules and financial sector supervision as they shape their national positions.
This uneven picture places more responsibility on institutions. AI adoption is not simply a technology question. It is a governance question. As I wrote in ‘The Compliance Blueprint’, strong compliance frameworks depend on clarity, accountability and consistent execution. AI raises the stakes on all three. If an institution has weak data, fragmented processes or poor risk discipline, AI will magnify those weaknesses, not correct them.
This article will touch on three practical pillars for how Caribbean financial and designated non-financial businesses need to approach AI.
Data
The first is data. The information that AI systems receive determines how well they work. In the region, many financial institutions still have legacy onboarding processes, inconsistent risk scoring and siloed customer files. Prioritising structured data, standardising definitions and clearly identifying who is responsible for data quality is crucial for companies before they experiment with AI. Without this work, AI will produce noise rather than insight.
Governance
The second is governance. AI in anti-money laundering (AML) is model risk. The use of AI in AML poses a model risk. The process requires oversight, documentation, testing, monitoring and clear human accountability. It will be important for regulators to see that AI-influenced decisions can be explained, challenged and escalated. Even in jurisdictions without AI legislation, expectations around transparency and proportionality continue to rise. Institutions should design governance frameworks to satisfy the standards already emerging in Bermuda, Jamaica and Trinidad and Tobago, rather than anchor to the lowest common denominator.
Capability
The third is capability. AI will change AML roles. Automation will reduce time spent on routine tasks such as initial alert triage and data retrieval. But the core responsibilities of investigators remain the same: Judgment, context, ethical decision-making and escalation. Teams need better data literacy and stronger critical thinking skills to challenge AI outputs rather than accept them at face value.
In short, AI offers value, but not without disciplined foundations. Caribbean institutions that invest in data, governance and people will see real AML improvement. Those who treat AI as a shortcut will inherit new risks without the benefits. The region does not need a rush toward tools; it needs a measured, responsible approach anchored in sound compliance principles.
• NB: About Derek Smith Jr
Derek Smith Jr has been a governance, risk and compliance professional for more than 20 years with a leadership, innovation and mentorship record. He is the author of ‘The Compliance Blueprint’. Mr Smith is a certified anti-money laundering specialist (CAMS) and holds multiple governance credentials. He can be contacted at hello@pineapplebusinessconsultancy.com



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