- BOJ’s National Risk Assessment flags real estate developers as high risk.
- 385 development projects worth $299 billion examined for laundering patterns.
- Cash-only self-financed projects are the primary laundering method identified.
- Real estate developers currently fall outside Jamaica’s AML legal framework.
- Jamaica’s overall money laundering risk has improved to medium for 2025.
- Motor vehicle dealers also cited alongside developers as top-risk sectors.
Jamaica’s real estate development sector carries a high risk of being used to launder criminal proceeds, according to the Third National Risk Assessment (NRA) published by the Bank of Jamaica in June 2026. The finding, reported by the Jamaica Gleaner on June 24, places property developers alongside motor vehicle dealers as the two sectors most exposed to money laundering activity in the current economic environment.
The assessment is significant not only for what it identifies but for what it reveals about the gap in Jamaica’s legal framework: real estate developers, as a distinct sub-sector, are currently not covered by the Proceeds of Crime Act’s designated non-financial institutions order. In plain terms, they carry no legal obligation to conduct anti-money laundering due diligence on the individuals and entities financing their projects.
The Data Behind the Assessment
The BOJ and the Real Estate Board examined 385 development applications filed between 2021 and 2024, representing an aggregate declared cost of $299.6 billion. Of that total, high-risk funding sources accounted for approximately 7.8 per cent of project costs. While that percentage may appear modest, at those aggregate values it represents a substantial figure.
The primary money laundering method identified was the use of cash in developments described as “100 per cent self-financed.” Properties paid for entirely in cash, without traceable financing structures, create conditions in which illicit funds can be invested in the construction phase and emerge on the other side as legitimised real estate assets. This technique — sometimes called layering through development — requires no bank accounts, no mortgage transactions, and no paper trail beyond construction invoices.
Who Else Is in the Risk Frame
The NRA’s language on the real estate sector goes further than residential development alone. The report notes that “real estate development, motor vehicle trade, selected professional services, and trade-based money laundering linked to construction inputs and vehicle imports represent nascent areas of attraction for mal-actors.” Construction input imports — materials, equipment, and fittings — are cited as a route through which criminal funds can be embedded in legitimate supply chains.
Jamaica’s Broader AML Position
Jamaica’s overall residual money laundering risk improved by one notch to medium in 2025, an improvement attributed to stronger institutional coordination, improved financial intelligence, and more consistent use of asset-restraint powers. That improvement matters for Jamaica’s international standing, particularly in relation to correspondent banking relationships and the risk of being placed on international watchlists.
However, improvement at the macro level does not resolve sectoral vulnerabilities. The real estate sector has repeatedly appeared in NRA findings as an area requiring tighter oversight. A 2023 Jamaica Gleaner investigation found the sector was still lagging on AML compliance, and the picture painted by the 2026 NRA suggests the gap has not yet closed.
Implications for the Property Market
For buyers, sellers, and legitimate developers, the findings raise a practical concern: the absence of AML due diligence requirements for developers means that transactions can proceed with no systematic verification of funding sources. A buyer purchasing a unit in a development financed with illicit funds may have no way of knowing the source of that financing — and in certain enforcement scenarios, property associated with criminal proceeds can be subject to asset restraint under the Proceeds of Crime Act.
For the broader market, the concentration of unverifiable cash transactions in the development sector affects property valuations. Artificially inflated land prices and development costs, driven partly by cash-flush participants with no need for commercial returns, can distort the market for legitimate buyers and developers who rely on transparent financing.
What Needs to Change
The NRA’s implicit recommendation is regulatory: real estate developers should be brought under the AML compliance framework that currently applies to real estate agents, attorneys, and financial institutions. Until that gap is closed, the sector will continue to operate with a compliance asymmetry that creates opportunity for those seeking to clean illicit funds through construction and property development.
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1 Comment
Stronger scrutiny should not be treated as hostility toward development. Legitimate builders and buyers benefit when ownership, financing and beneficial interests are transparent. The real question is whether enforcement will reach powerful operators as readily as ordinary purchasers.