Christie Justus Law — Research Papers · CJL-WP 2026/01
Naomi Eglantine Christie · LL.B. (Distinction) · L.E.C. (Honours) · LL.M., New York University, 2015 — International Legal Studies · Attorney-at-Law, admitted to the Bar of Guyana, October 2013, and to the Bar of Grenada, 2014.
September 2026 · 27 pages · 121 footnotes · PDF
Small states that live under mutual evaluation legislate in a particular way. This paper asks what kind of law results when a statute is written to an assessor's methodology, on the assessor's calendar and in the assessor's vocabulary. It answers by reading Guyana's Anti-Money Laundering and Countering the Financing of Terrorism Act 2009, its eight amending Acts and the Guyana Compliance Commission Act 2023 against the Caribbean Financial Action Task Force's fourth-round Mutual Evaluation Report of 2024. The argument is that, in such a state, compliance is itself a mode of legislation: the Recommendation supplies the outline, the assessment criteria supply the sections, the on-site date supplies the deadline, and Parliament supplies the form. What results is technically strong and structurally derivative, a statute amended in waves that follow the evaluation cycle rather than any domestic criminology. Alvarez's account of international organisations as law-makers, Koh's transnational legal process and the Chayeses' managerial model of compliance are each put to that record, and each is found incomplete for a state with no vote in the standard-setting body. The 2024 evaluation — technical ratings largely compliant, effectiveness ratings largely moderate, no conviction for money laundering — is then read as the predictable output of the process described, and three lessons are drawn from the drafting chair, on offence design, supervisory institutions and commencement.
Keywords: money laundering; FATF; Guyana; CFATF; legislative drafting; soft law; mutual evaluation; transnational legal process
Naomi Eglantine Christie · LL.B. (Distinction) · L.E.C. (Honours) · LL.M., New York University, 2015 — International Legal Studies · Attorney-at-Law, admitted to the Bar of Guyana, October 2013, and to the Bar of Grenada, 2014. The author served as State Counsel (Litigation and Legislative Drafting) in the Attorney General's Chambers and Ministry of Legal Affairs of Guyana, where her duties included legislative drafting in the anti-money-laundering field; this paper is written from that chair. Correspondence: naomi@christiejustuslaw.com.
© 2026 Naomi Eglantine Christie. This paper may be downloaded, printed and circulated without charge for personal, academic and teaching use, with attribution. It states the law as the author understands it at the date on the cover; it is not legal advice to any person. Pending matters are described as pending.