Press Release – Financial Intelligence Unit – July 18, 2019 – 
The Financial Intelligence Unit (FIU) has been monitoring media reports relating to issues surrounding the enterprise known as Sanctuary Bay or Sanctuary Belize, Atlantic International Bank Limited and the United States Federal Trade Commission. The FIU generally does not make public statements on its investigations (past or ongoing) in accordance with international best practices, unless a prosecution is publicly underway. To provide clarity and in response to several inquiries received, the FIU issues the following statement.
In September 2016, the Director of the FIU received a referral from the Governor of the Central Bank regarding complaints made by a purchaser in the real estate development known as Sanctuary Bay. The referred party was invited to several meetings with FIU staff. During that time, complaints were shared, and available evidence provided. An assessment was undertaken of the available evidence to determine whether all the elements of certain criminal offenses could be established, and a determination was made that the likelihood of a successful prosecution under the Criminal Code or the Money Laundering and Terrorism (Prevention) Act (MLTPA) was negligible. The FIU then pursued other available avenues and cooperated with other domestic competent authorities to ensure that enforcement of existing national compliance obligations was being pursued. The FIU continued to monitor various persons associated with the enterprise, as is its standard operating procedure.
On October 31, 2018, the FTC filed a civil enforcement action in a federal district court in Maryland, United States against Ecological Fox LLC, an associated company of the Sanctuary Bay group, and others. The United States District Court of Maryland granted the FTC a temporary restraining order against Ecological Fox LLC and Others. On November 7 of 2018, the FTC pursued enforcement of the temporary restraining order in Belize by requesting banks operating within Belize to voluntarily comply with the order. To assist the FTC and provide the necessary legal basis for domestic banks to restrain any assets, the FIU issued a temporary administrative freezing order of its own pursuant to provisions under the MLTPA. In the interim, research was conducted to ascertain whether further legal assistance could be provided by the FIU to the FTC to permanently restrain assets until they could be made available for restitution, disgorgement, and other equitable relief for those affected. It was determined that for the FIU to provide further legal assistance to restrain assets in accordance with its mandate and legal avenues available under the MLTPA, there must be criminal proceedings ongoing or criminal proceedings would be initiated imminently. The FTC was advised of this and of the fact that other legal remedies may be at their recourse through Belize’s civil courts. The FIU has had no further communication with the FTC since November 13, 2018, nor was it made aware of ongoing foreign criminal investigations or proceedings. Consequently, the FIU had no choice but to allow the administrative freezing order it had issued to lapse.
In conclusion, the FIU iterates that matters between the Sanctuary Bay group, AIBL, and the FTC are ongoing and will be resolved in the United States. Furthermore, the vast majority of transactions which form the basis of this complaint were executed in the United States, and not in Belize. The FIU continues to be a fully supportive international partner in combating transnational financial crime. In this case, extraordinary efforts were made to do the same.
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