Dear Editor:
AS the Chairperson of the Ambassadorial Working Group within the fraternity of the Organisation of African, Caribbean and Pacific States (OACPS) on International Tax Governance and Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT), I would like to note the editorial published in Kaieteur News on 28 July, 2025, titled, “Bank Action – the Question Before Guyanese,” and make the following statement.

“Given the sensitive nature of the subject matter and the complexity of the international financial regulatory environment, I wish to offer some clarifying context, drawn from collective experiences and ongoing dialogue between the OACPS and international bodies such as the European Union, the Financial Action Task Force (FATF), and the OECD.
While I will refrain from commenting on the specific case referenced in the editorial, it is important to frame this discussion within the broader legal and regulatory framework that governs financial institutions in Guyana and by extension, globally.

Matters involving banking relationships—especially account closures—must be assessed through the lens of regulatory compliance, risk management and the overarching objective of preserving the integrity of a nation’s financial system.

Guyana’s financial institutions operate within a regulated environment under the Laws of Guyana, which align with international financial standards.
These include requirements on customer due diligence and Know Your Customer (KYC) procedures, which are central to both domestic law and global AML/CFT protocols.
KYC measures serve to safeguard not only the institution in question, but all customers of a licensed financial institution, such as a commercial bank. Their purpose is to enhance transparency and good governance over the depositors’ funds, mitigate financial crime and maintain the trust necessary for financial systems to function effectively.

Guyana, like its sister nations, does not operate in isolation; its financial ecosystem is part of a globally interconnected framework. Departing from these obligations would not only risk reputational harm, but could also threaten access to international financial systems and instruments.

There are consequences for any state whose action, intentionally or unintentionally, destabilises the global financial system.
As Guyana’s economy grows and becomes increasingly integrated into the global market, its financial institutions face greater visibility and corresponding responsibility.
In this context, international standards—such as those developed by the Basel Committee on Banking Supervision and the FATF—impose obligations to implement comprehensive, risk-based

approaches to customer verification and transaction monitoring, especially on those classified as PEPs (Politically Exposed Persons) and their close associates.
Enhanced due diligence is essential for individuals maintaining large account balances, persons who are classified as PEPs, and their close associates.
Therefore, by local legal obligations, all licensed financial institutions in Guyana must report any deficiencies or concerns discovered about KYC documentation to the Financial Intelligence Unit and the Bank of Guyana. Failure to do so may attract regulatory consequences.

Section 33 of the Financial Institutions Act (1995) empowers the Bank of Guyana to act where a licensed financial institution is engaged in, or is about to engage in, practices deemed unsafe, unsound, or in violation of applicable laws and regulations.

Section 11 of the same Act further empowers the Central Bank to revoke the licence of a financial institution that fails to comply with its legal obligations after being given a reasonable opportunity to rectify any shortcomings. Such directives are not optional — they are binding.

Account closures are legal and regulatory tools available to financial institutions where risk mitigation necessitates such action. It would, therefore, be misleading and unhelpful to frame such decisions as personal or arbitrary.

Banks must safeguard the integrity of their internal control systems and the interests of the wider customer base. The whole is always more important than the part when it comes to the financial system.

Indeed, the closure of accounts—even those belonging to diplomatic missions—has occurred in other jurisdictions, including within the European Union. These actions are taken in adherence to international standards and in compliance with national regulatory frameworks—not as punitive measures, but as necessary steps to preserve the integrity of the national financial system.
In conclusion, sound risk management and regulatory compliance are fundamental to the safety and soundness of a nation’s financial system.

When a financial institution determines that maintaining a banking relationship may pose a risk to that system, it is not only within its rights but in fulfilment of its obligations to take appropriate action. The national interest—and the integrity of the financial system—must remain paramount.
Yours truly,
H.E. Sasenarine Singh
Ambassador of Guyana to the Kingdom of Belgium and Netherlands, Permanent Representative to the European Union and Permanent Representative to the Organisation of African, Caribbean and Pacific States