total 37. 6 13. 9 51. 6 7. 6 30. 0 0. 7 13. 3 8. 3 43. 3 5. 7 31. 2 0. 5 13. 4 6. 2 44. 6 of which retail commerc'l / other of which cash non - cash source : central bank of the bahamas chart 1 : domestic deposit inflows in 2018 ( $ billions ) source : central bank of the bahamas table 2 : canadian banks ’ share of domestic deposit inflows, 2018 ( % ) deposited funds bsd non - bsd total 82 % 98 % 87 % 68 % 86 % 96 % 98 % 70 % 90 % of which retail commerc'l / other of which cash non - cash 85 % 84 % 96 % 98 % 86 % 88 % we can see that the three canadian banking groups accounted for 90 per cent of the funds placed in commercial deposit accounts, and nearly all non - bahamian dollar gross deposits. on the commercial and, particularly, the cross - border side, the standard of aml / cft risk management in these operations in nassau or freeport would be the same as in toronto or winnipeg. bahamian - owned banks are less engaged in commercial banking, but have about 30 % of the deposits placed by individuals. let ’ s now look at the 17 individual categories where global experience suggests we should be looking hardest for money laundering. source : central bank of the bahamas the aggregate 2018 deposits in each segment can be viewed from several perspectives : by bahamian dollars versus foreign currency accounts, and split by cash versus non - cash deposits. broadly speaking, cash carries more aml risk than non - cash deposit. that said, only about 10 per cent of the funds deposited in bahamian banks in 2018 fell into these 17 sector categories, with the remainder in less potentially troublesome areas. there are several lessons apparent from the data. first, many segments which the international community and standards setting bodies flag as susceptible are simply too small in the bahamas to constitute a material money laundering risk in the domestic economy. examples include diplomatic establishments, pawnshops, and wholesale jewellery stores. the domestic banks have yet to commence taking deposits from crypto - asset sources, but this may change in the future. second, nearly all segments are dominated by non - cash deposits. when looking at retail jewellery stores, auto dealers, and maritime sectors, for example, very low cash flows were evident, with electronic payments such as credit and

our domestic sector is keenly aware of the relevant issues, and over all is not a material aml risk ; our international sector will always be a material potential risk, but we have at least acceptable and increasingly sound controls in place ; there are material data issues in the cross border real estate and ibc areas, which are being addressed at the moment ; and in general terms, larger and foreign - owned financial institutions are somewhat ahead of smaller and bahamian - owned institutions in aml risk management. above all, as an industry and as a society, we are definitively out of the money - hiding business. given that many jurisdictions cannot make this claim, the world ’ s dirty money managers are on notice that they should take their business elsewhere. from what we can see, which vision is not yet as perfect as we would like, the world ’ s dirty money managers are heeding this message. what about reputation? on the reputation front, we are dealing with an essential and possibly existential global fallacy. that fallacy is that in the field of dirty money, small countries with large international financial sectors are the problem. now it is true that countries such as the bahamas have in the past been part of the problem, hence, our massive reforms since 2000 and more recently. the other fallacy we are struggling with is that financial crime is an impossibly intractable problem, so, there is no point trying to empirically study the issue. these two fallacies combine to create an environment in which it is very hard for jurisdictions such as the bahamas to reap the reputational benefits from becoming highly resistant to money laundering and other financial crimes. it is obvious to informed observers that : - the world has been unable to appreciably intercept the flow of dirty money, which could be in the trillions annually and tens of trillions in embedded asset terms. this - compares with illicit asset recoveries, which could be generously measured in the low tens of billions. the world ’ s large countries, starting with the united states, great britain, and the eu, are both the sources and the destinations for the great bulk of the world ’ s dirty money4 ; although one of the lessons from the outside should be in how our jurisdiction mobilises its enforcement resources. put simply, life isn ’ t fair when you are a small country daring to compete in international financial services. so what do we do about this? the central bank and the rest of the bahamian