FEEDBACK AND TYPOLOGIES 2008-2011 – Simon Gaudion- Senior Investigation Officer, Financial Intelligence Service publishes the Feedback and Typologies report, which is the Financial Intelligence Service’s (FIS) review of the STR regime from 1st January 2008 up until year end 2011.

In the introduction to the repot he says:

To start 2012 off there has been a change of personnel within the FIS, with Martyn Waters moving on to pastures new and myself stepping in to the role left by him. As with all new roles it takes a little while to settle in but hopefully that has now happened and I look forward to the challenges that lay ahead during my term in the FIS.

As you are aware it has been some time since we last reported on the activity of the STR regime, and this has primarily been due to the implementation of the online reporting system which both the private sector as well as ourselves had to get used to.

We also had the IMF inspection in May 2010, which required considerable input from both the private sector and law enforcement alike.

These things are behind us now hence we are ready to put some overdue feedback to industry.

The new FATF International standards on combating money laundering and the financing of terrorism and proliferation were also announced in February 2012, with some of the key changes being;

1. Combating the financing of the proliferation of weapons of mass destruction through the consistent implementation of targeted financial sanctions when these are called for by the UN Security Council.
2. Improved transparency to make it harder for criminals and terrorists to conceal their identities or hide their assets behind legal persons and arrangements.
3. Stronger requirements when dealing with politically exposed persons (PEPs).
4. Expanding the scope of money laundering predicate offences by including tax crimes.
5. An enhanced risk-based approach which enables countries and the private sector to apply their resources more efficiently by focusing on higher risk areas.
6. More effective international cooperation including exchange of information between relevant authorities, conduct of joint investigations, and tracing, freezing and confiscation of illegal assets.
7. Better operational tools and a wider range of techniques and powers, both for the financial intelligence units, and for law enforcement to investigate and prosecute money laundering and terrorist financing.

   These will undoubtedly bring about some changes but how widespread is yet to be seen.

As you will see from the data laid out in this report the online reporting system has thrown up some statistics which required further research but it can only report on that data that you, as Money Laundering Reporting Officers or nominated officers place into the system, therefore there are learning points for us all here, in that, the more detailed the report you place on the system the better the statistical data will be recorded for your future perusal and hopefully, benefit. In 2011 we received 1136 STRs.

From 1st January to the end of July we had to manually input 164 paper based disclosures, which at the time equated to 21% of the total received.

I am pleased to say that from 1st August 2011 until the end of 2011 we only manually input 6 disclosures received, which equated to 1.7%, and hopefully this year that figure will drop again.

All of these developments, especially with the online reporting system, would not be possible to achieve without the continuing support and engagement of the private sector.

The STR regime is one of the most important public/private sector partnerships we have in the Bailiwick and exerts a powerful deterrent effect on criminals both here and across the globe.

The landscape for fighting organised crime continues to develop and I am convinced that success will be achieved through extracting and exploiting the full worth and value of the regime and the data that it collects. With this in mind I hope that your find the latest report informative and fully reflecting the work we have all done.

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