Regulators and financial intelligence units are tasked with challenging jobs to fight money laundering and terrorism financing, but some have room for improvement. Financial institutions observe that some regulators and units give unfavorable audit reports not necessarily due to legal breaches, but because of subjective methods rather than proper risk assessment. Excessive compliance costs are incurred without clear evidence that they reduce financial crimes. Regulators and units should ensure regulatory actions have benefits exceeding costs to avoid counterproductive policies. Proper risk understanding and mitigation is important over prescriptive rules and one-size-fits-all approaches.
Fundamental controlling tool of fraud prevention and detection designed for company owners and top management. Protect at work and in business those honest against those unfair.
www.forensicline.eu
This presentation explains how you can prevent and deter fraud in your nonprofit organization, why some employees commit fraud and how to spot behavioral "red flags," what to do if you discover fraud in your organization, and common fraud schemes to watch for.
On December 5, 2013, Ron Steinkamp, principal, government advisory services at Brown Smith Wallace, presented at the 2013 MIS Training Institute Governance, Risk & Compliance Conference. Ron focused on the following keys to fraud prevention, detection and reporting:
1. Anti-fraud culture
2. Fraud policy
3. Fraud awareness/training
4. Hotline
5. Assess fraud risks
6. Review/investigation
7. Improved controls
Fundamental controlling tool of fraud prevention and detection designed for company owners and top management. Protect at work and in business those honest against those unfair.
www.forensicline.eu
This presentation explains how you can prevent and deter fraud in your nonprofit organization, why some employees commit fraud and how to spot behavioral "red flags," what to do if you discover fraud in your organization, and common fraud schemes to watch for.
On December 5, 2013, Ron Steinkamp, principal, government advisory services at Brown Smith Wallace, presented at the 2013 MIS Training Institute Governance, Risk & Compliance Conference. Ron focused on the following keys to fraud prevention, detection and reporting:
1. Anti-fraud culture
2. Fraud policy
3. Fraud awareness/training
4. Hotline
5. Assess fraud risks
6. Review/investigation
7. Improved controls
Bank Secrecy Act: De-Risk or Up Your Game?Jay Postma
September 24, 2014 presentation before the Georgia Bankers Association annual compliance conference covering Bank Secrecy Act, Culture of Compliance, De-Risking, BSA/AML Program Improvement, Money Services Businesses (MSBs), and Third Party Payment Processors (TPPPs or TP3s).
February 6, 2014 presentation to Community Bankers Association of Georgia's BSA Officer's School covering Money Services Businesses (MSBs), Bank Secrecy Act / Anti-Money Laundering (BSA/AML), Office of Foreign Asset Control (OFAC), and operational considerations.
Good day all,
Please find attached the June 2017 edition of our very informative Newsletter.
We look forward to your continuing support and comments. Please send all comments and suggestions to training@kawmanagement.com or training.kawmgmt@candw.ag.
Happy reading
A review of common fraud areas that occur in closely held businesses, how to prevent them and what your legal remedies are if you are a victim of fraud.
Bovill - the UK financial services regulatory consultancy - runs regular briefings. These are the slides from the February briefing on anti-money laundering. For more information visit http://www.bovill.com/FinancialCrime.aspx.
Information on the event is below:
Taking a company-wide approach to money laundering
“The FCA has made it very clear that responsibility for the overall culture of firms sits at the top. We need leaders and senior managers within the industry to set the tone for how their staff behave.”
Tracey McDermott, Director of Enforcement and Financial Crime, FCA
The regulator has recently reiterated their intention to carry out further thematic and enforcement work in financial crime. However, many firms still have a fragmented approach to managing the risks of money laundering.
The responsibility for preventing financial crime is shared across the firm from the back office to the boardroom. Firms need to take a company-wide approach to tackling money laundering to ensure they are complying with regulation and managing risks effectively.
Bovill’s briefing looked at Anti-Money Laundering (AML), covering:
• Governance arrangements: as the foundation for effective communication and issue resolution
• Risk management: the difficulties of negotiating the right level of due diligence for higher risk customers and what tools can be used to help with this process
• Systems and controls: ensuring that these are fit for regulatory purpose and are appropriately maintained within your firm.
Most companies have ethics and compliance policies in place and those policies usually include training for employees. That training typically includes material about policies prohibiting discrimination and harassment, bribery and excessive gift-giving. But it usually does not teach employees how to recognize signs of fraud and how to report them.
Employee fraud awareness training is one of the most important ways your company can protect itself from fraud which, according to the Association of Certified Fraud Examiners, costs the average company five per cent of its revenues every year.
CPAs responsibilities to detect fraud in audits, required approaches, types of financial statement frauds and specific case examples of different types of financial statement fraud
Countering Financial Crime - The Importance of Effective TrainingAperio Intelligence
We are a corporate intelligence and financial crime advisory firm based in the City of London. We specialise in: conducting enhanced due diligence on high risk customers and third parties; integrity due diligence on critical acquisitions and investments; market entry and political risk analysis; and investigations. We provide tailored training and advisory services relating to financial crime, in particular anti-money laundering and sanctions compliance. Our clients include some of the world’s leading regulated financial institutions and corporations. Our team has decades of collective experience in advising clients on financial crime and intelligence gathering, helping them to manage risk and maximise potential.
Contact us today for further information on how we can help you.
Bank Secrecy Act: De-Risk or Up Your Game?Jay Postma
September 24, 2014 presentation before the Georgia Bankers Association annual compliance conference covering Bank Secrecy Act, Culture of Compliance, De-Risking, BSA/AML Program Improvement, Money Services Businesses (MSBs), and Third Party Payment Processors (TPPPs or TP3s).
February 6, 2014 presentation to Community Bankers Association of Georgia's BSA Officer's School covering Money Services Businesses (MSBs), Bank Secrecy Act / Anti-Money Laundering (BSA/AML), Office of Foreign Asset Control (OFAC), and operational considerations.
Good day all,
Please find attached the June 2017 edition of our very informative Newsletter.
We look forward to your continuing support and comments. Please send all comments and suggestions to training@kawmanagement.com or training.kawmgmt@candw.ag.
Happy reading
A review of common fraud areas that occur in closely held businesses, how to prevent them and what your legal remedies are if you are a victim of fraud.
Bovill - the UK financial services regulatory consultancy - runs regular briefings. These are the slides from the February briefing on anti-money laundering. For more information visit http://www.bovill.com/FinancialCrime.aspx.
Information on the event is below:
Taking a company-wide approach to money laundering
“The FCA has made it very clear that responsibility for the overall culture of firms sits at the top. We need leaders and senior managers within the industry to set the tone for how their staff behave.”
Tracey McDermott, Director of Enforcement and Financial Crime, FCA
The regulator has recently reiterated their intention to carry out further thematic and enforcement work in financial crime. However, many firms still have a fragmented approach to managing the risks of money laundering.
The responsibility for preventing financial crime is shared across the firm from the back office to the boardroom. Firms need to take a company-wide approach to tackling money laundering to ensure they are complying with regulation and managing risks effectively.
Bovill’s briefing looked at Anti-Money Laundering (AML), covering:
• Governance arrangements: as the foundation for effective communication and issue resolution
• Risk management: the difficulties of negotiating the right level of due diligence for higher risk customers and what tools can be used to help with this process
• Systems and controls: ensuring that these are fit for regulatory purpose and are appropriately maintained within your firm.
Most companies have ethics and compliance policies in place and those policies usually include training for employees. That training typically includes material about policies prohibiting discrimination and harassment, bribery and excessive gift-giving. But it usually does not teach employees how to recognize signs of fraud and how to report them.
Employee fraud awareness training is one of the most important ways your company can protect itself from fraud which, according to the Association of Certified Fraud Examiners, costs the average company five per cent of its revenues every year.
CPAs responsibilities to detect fraud in audits, required approaches, types of financial statement frauds and specific case examples of different types of financial statement fraud
Countering Financial Crime - The Importance of Effective TrainingAperio Intelligence
We are a corporate intelligence and financial crime advisory firm based in the City of London. We specialise in: conducting enhanced due diligence on high risk customers and third parties; integrity due diligence on critical acquisitions and investments; market entry and political risk analysis; and investigations. We provide tailored training and advisory services relating to financial crime, in particular anti-money laundering and sanctions compliance. Our clients include some of the world’s leading regulated financial institutions and corporations. Our team has decades of collective experience in advising clients on financial crime and intelligence gathering, helping them to manage risk and maximise potential.
Contact us today for further information on how we can help you.
Good day all,
Please find attached the September 2017 edition of our very informative Newsletter. Apologies for the tardiness.
We look forward to your continuing support and comments. Please send all comments and suggestions to training@kawmanagement.com or training.kawmgmt@candw.ag.
Happy reading.
Overcoming compliance fatigue - Reinforcing the commitment to ethical growth ...EY
This presentation is based on EY FIDS' 13th Global Fraud Survey. It highlights the state of fraud, bribery and corruption, comprising global as well as India findings.
For further information, please visit: http://www.ey.com/FIDS
Governments across the globe have been taking measures to increase the scrutiny of AML/CFT processes and controls, to fight Financial crimes. Individuals and firms are required to comply with minimum standards; failure to keep up with the changing requirements can lead to penalties and legal consequences.
Please find and upload an article on ONE of the following topics and.pdfJUSTSTYLISH3B2MOHALI
Please find and upload an article on ONE of the following topics and discuss it\'s significance by
Monday at midnight. Then, read and review three other articles submitted by your classmates by
Wednesday at midnight:
A. Financial Systems Fraud
B. Data Coding Schemes
C. DFD/ERDs
please type here
Solution
A) financial system fraud
The Association of Certified Fraud Examiners (ACFE) routinely reports that numerous types of
extortion – proportional to around 5 percent of incomes – influence partnerships every year. This
is a stunning sum and regardless of whether this number is marginally exaggerated, the potential
for extortion to happen in associations isn\'t – and it\'s something that each pioneer in money
related control and hazard administration ought to consider important.
Fraud by representatives, and by outsiders who may connive with workers, can happen in most
budgetary and business frameworks including acquiring, installments, charging, finance, stock
and sending, P-cards, and travel and excitement costs. Obviously, the danger of
misrepresentation ought to be considered when outlining controls all through money related and
business forms – be that as it may, there are a few motivations to look past the customary ways
to deal with averting and recognizing extortion.
Fraud and hazard make stunning misfortunes in the budgetary administrations industry as crooks
imagine new tricks to take subsidizes and launder filthy cash into the economy. This profoundly
affects every one of us including banks, financier, protection and human services suppliers.
Advancements in expository innovation can recognize misrepresentation, identify dangers and
alleviate hazard for your monetary association. Rotator Visual System Examination consolidates
nimble information incorporation with dynamic relationship mapping and intuitive visual
investigation enabling investigators to profile information and distinguish examples of conduct
demonstrative of criminal movement.
Financial Risk
Rotator empowers exact ID of monetary hazard because of extortion and illegal tax avoidance.
Show cases under scrutiny utilizing rich representations. Distinguish shrouded connections
utilizing propelled hazard investigation, and find value-based ways that point to co-schemers
Know Your Client
Guarantee consistence with \"Know Your Client\" strategy necessities. Perform upgraded due
constancy on new and existing records\' budgetary execution. Make a corporate culture where
Visual System Examination bolsters the majority of your \"Know Your Client\" prerequisites.
Client Securing
Rotator conveys quantifiable and successful client obtaining and maintenance techniques.
Examine past monetary execution and client esteem prompting focused on procurement systems.
Measure the viability of your promoting efforts.
Joint effort
Offer vital money related information investigation comes about with key colleagues, offices and
administrators. Spare the aftereffects of your money related information.
Enterprise Fraud Management: How Banks Need to AdaptCapgemini
Fraud prevention is becoming one of the biggest areas of concern for the financial services industry. But first generation Fraud Management systems are falling short. By moving towards more enterprise approach to fraud management, financial institutions can combat the increasingly treacherous fraud and cyber crime landscape while reaping numerous benefits for the organization.
Fraud, bribery and corruption: Protecting reputation and valueDavid Graham
In support of International Fraud Awareness Week, Deloitte Risk Advisory has published a series of articles, the second of which has been introduced below. This article lists ten areas that executives and the audit committee should evaluate to help mitigate reputational risks of fraud, bribery and corruption
This guideline takes you through a step-by-step guide on how to conduct a money laundering business risk assessment. The slides consider each core division of an aml risk assessment.
Videos are more engaging, more memorable, and more popular than any other type of content out there. That’s why it’s estimated that 82% of consumer traffic will come from videos by 2025.
And with videos evolving from landscape to portrait and experts promoting shorter clips, one thing remains constant – our brains LOVE videos.
So is there science behind what makes people absolutely irresistible on camera?
The answer: definitely yes.
In this jam-packed session with Stephanie Garcia, you’ll get your hands on a steal-worthy guide that uncovers the art and science to being irresistible on camera. From body language to words that convert, she’ll show you how to captivate on command so that viewers are excited and ready to take action.
In this presentation, Danny Leibrandt explains the impact of AI on SEO and what Google has been doing about it. Learn how to take your SEO game to the next level and win over Google with his new strategy anyone can use. Get actionable steps to rank your name, your business, and your clients on Google - the right way.
Key Takeaways:
1. Real content is king
2. Find ways to show EEAT
3. Repurpose across all platforms
Come learn how YOU can Animate and Illuminate the World with Generative AI's Explosive Power. Come sit in the driver's seat and learn to harness this great technology.
When most people in the industry talk about online or digital reputation management, what they're really saying is Google search and PPC. And it's usually reactive, left dealing with the aftermath of negative information published somewhere online. That's outdated. It leaves executives, organizations and other high-profile individuals at a high risk of a digital reputation attack that spans channels and tactics. But the tools needed to safeguard against an attack are more cybersecurity-oriented than most marketing and communications professionals can manage. Business leaders Leaders grasp the importance; 83% of executives place reputation in their top five areas of risk, yet only 23% are confident in their ability to address it. To succeed in 2024 and beyond, you need to turn online reputation on its axis and think like an attacker.\
Key Takeaways:
- New framework for examining and safeguarding an online reputation
- Tools and techniques to keep you a step ahead
- Practical examples that demonstrate when to act, how to act and how to recover
Mastering Multi-Touchpoint Content Strategy: Navigate Fragmented User JourneysSearch Engine Journal
Digital platforms are constantly multiplying, and with that, user engagement is becoming more intricate and fragmented.
So how do you effectively navigate distributing and tailoring your content across these various touchpoints?
Watch this webinar as we dive into the evolving landscape of content strategy tailored for today's fragmented user journeys. Understanding how to deliver your content to your users is more crucial than ever, and we’ll provide actionable tips for navigating these intricate challenges.
You’ll learn:
- How today’s users engage with content across various channels and devices.
- The latest methodologies for identifying and addressing content gaps to keep your content strategy proactive and relevant.
- What digital shelf space is and how your content strategy needs to pivot.
With Wayne Cichanski, we’ll explore innovative strategies to map out and meet the diverse needs of your audience, ensuring every piece of content resonates and connects, regardless of where or how it is consumed.
Monthly Social Media News Update May 2024Andy Lambert
TL;DR. These are the three themes that stood out to us over the course of last month.
1️⃣ Social media is becoming increasingly significant for brand discovery. Marketers are now understanding the impact of social and budgets are shifting accordingly.
2️⃣ Instagram’s new algorithm and latest guidance will help us maintain organic growth. Instagram continues to evolve, but Reels remains the most crucial tool for growth.
3️⃣ Collaboration will help us unlock growth. Who we work with will define how fast we grow. Meta continues to evolve their Creator Marketplace and now TikTok are beginning to push ‘collabs’ more too.
In this presentation, Danny Leibrandt explains the impact of AI on SEO and what Google has been doing about it. Learn how to take your SEO game to the next level and win over Google with his new strategy anyone can use. Get actionable steps to rank your name, your business, and your clients on Google - the right way.
Key Takeaways:
1. Real content is king
2. Find ways to show EEAT
3. Repurpose across all platforms
The session includes a brief history of the evolution of search before diving into the roles technology, content, and links play in developing a powerful SEO strategy in a world of Generative AI and social search. Discover how to optimize for TikTok searches, Google's Gemini, and Search Generative Experience while developing a powerful arsenal of tools and templates to help maximize the effectiveness of your SEO initiatives.
Key Takeaways:
Understand how search engines work
Be able to find out where your users search
Know what is required for each discipline of SEO
Feel confident creating an SEO Plan
Confidently measure SEO performance
The What, Why & How of 3D and AR in Digital CommercePushON Ltd
Vladimir Mulhem has over 20 years of experience in commercialising cutting edge creative technology across construction, marketing and retail.
Previously the founder and Tech and Innovation Director of Creative Content Works working with the likes of Next, John Lewis and JD Sport, he now helps retailers, brands and agencies solve challenges of applying the emerging technologies 3D, AR, VR and Gen AI to real-world problems.
In this webinar, Vladimir will be covering the following topics:
Applications of 3D and AR in Digital Commerce,
Benefits of 3D and AR,
Tools to create, manage and publish 3D and AR in Digital Commerce.
Most small businesses struggle to see marketing results. In this session, we will eliminate any confusion about what to do next, solving your marketing problems so your business can thrive. You’ll learn how to create a foundational marketing OS (operating system) based on neuroscience and backed by real-world results. You’ll be taught how to develop deep customer connections, and how to have your CRM dynamically segment and sell at any stage in the customer’s journey. By the end of the session, you’ll remove confusion and chaos and replace it with clarity and confidence for long-term marketing success.
Key Takeaways:
• Uncover the power of a foundational marketing system that dynamically communicates with prospects and customers on autopilot.
• Harness neuroscience and Tribal Alignment to transform your communication strategies, turning potential clients into fans and those fans into loyal customers.
• Discover the art of automated segmentation, pinpointing your most lucrative customers and identifying the optimal moments for successful conversions.
• Streamline your business with a content production plan that eliminates guesswork, wasted time, and money.
Core Web Vitals SEO Workshop - improve your performance [pdf]Peter Mead
Core Web Vitals to improve your website performance for better SEO results with CWV.
CWV Topics include:
- Understanding the latest Core Web Vitals including the significance of LCP, INP and CLS + their impact on SEO
- Optimisation techniques from our experts on how to improve your CWV on platforms like WordPress and WP Engine
- The impact of user experience and SEO
Unleash the power of UK SEO with Brand Highlighters! Our guide delves into the unique search landscape of Britain, equipping you with targeted strategies to dominate UK search engine results. Discover local SEO tactics, keyword magic for UK audiences, and mobile optimization secrets. Get your website seen by the right people and propel your brand to the top of UK searches.
To learn more: https://brandhighlighters.co.uk/blog/top-seo-agencies-uk/
1. Common Sense Not So Common with Regulators and FIUs
Regulators and Financial Intelligence Units (FIUs) in many jurisdictions have one of the most
challenging jobs in this globalized and ever increasing criminal environment. To say that these
bodies around the region are not fighting Money Laundering and Terrorism would be nothing
short of untruthful. Criminals no doubt are also getting smarter and remain a step ahead of
Regulators, Financial Intelligence Units (FIUs) and Financial Institutions.
Financial Institutions are observing that Regulators and Financial Intelligence Units, that conduct
Audit Assessments, are sometimes giving subpar and not so favourable reports. We are not
speaking about any breaking of the law by the Financial Institution during the Audit. In many
instances, the findings are not based on any Money Laundering and Terrorism Financing threats,
but rather because the Regulators and FIUs rate them on their own subjective and prescriptive
methods and are dictating instead of risk assessing as to how they feel the institutions’ Anti–
Money Laundering and Counter Financing of Terrorism Programs should be maintained. It is
quite obvious that the FATF revised recommendations on risk assessment of Anti-Money
Laundering and Counter Financing of Terrorism Programs either are not fully understood or are
simply not being practiced in some jurisdictions.
Even if the law makers’ ideal vision of an Anti–Money Laundering and Counter Financing of
Terrorism Program may in fact be more effective than what actually exists in the Financial
Institutions, it is unclear as to whether the benefits would outweigh the unnecessary costs that
Financial Institutions have been incurring. Conventional wisdom begs for these law making
organizations in the region to conduct qualitative and quantitative assessments of all
consequences of their regulatory actions. One would think that efforts would be made to ensure
that the benefits outweigh the costs of any regulatory action undertaken by these organizations
or the whole process would be counterproductive. If this is not done, the costs and benefits of
their subjective methodologies would be troubling to the industry and the economy thus;
resulting in in bad public policies by the respective governments.
There is clearly no indication that their recommendations and massive costs on institutions to
maintain their AML/CFT Programs are in any way reducing Money Laundering, Terrorism and
other Financial Crimes. Regulators and FIUs are always incentivized to be proactive and to be
firm in addressing any potential Money Laundering and Terrorist Financing Risk in the Financial
Institutions, as well as, nationally. However, it appears as though more focus seems to be on job
security, personal ego by some of these officers and also political mileage for some elected
officials in their effort to ramp up public support.
The irony, however, is that persons employed by these bodies for the most part, as well as, those
setting strategic directives do not have any knowledge of some of the industries they regulate.
One would think that it would make logical sense that people who lack knowledge in a particular
area, would place emphasis in ensuring that they are trained so that they can have knowledge of
the industry. This is not to say that they are not exposed to or would not have received training.
2. Of course, most of the key Stakeholders have received a considerable amount of training from
supporting organizations and from the private sector. The problem, however, is that most of the
trainings are limited to regulations and generic knowledge of an institution’s AML/CFT Program.
What makes matters worse, is when Audits and/or Assessments are done using a one size fits all
methodology.
The actions by some of these organizations are certainly having a domino effect on the sector
and are, therefore, affecting customer service standards. As a result, Financial Institutions such
as Banks, for example, are losing one of the core fundamental principles of Banking which is
customer service by truly knowing their customers. Customers are now treated as numbers and
the same yardstick is being applied for customers, even in cases of totally unrelated transactions.
The fight against Money Laundering and Terrorism Financing is now thwarting the core business
of Banking which is providing loans and offering effective and efficient banking services.
Regulators and Financial Intelligence Units appear to have shifted their focus on how much
institutions are spending on Compliance to institute internal procedures and training employees,
as opposed to the effectiveness of their compliance efforts and whether or not their risks are
properly mitigated.
Institutions are now operating out of fear rather than ensuring their risks are properly mitigated.
In everything, we can all agree that there is a risk and no one can stop Money Laundering and
Terrorism. FATF has pointed out the importance of not applying prescriptive risk assessment but
rather institutions should understand their business risk and put mitigating risk factors in place
to bring their inherent risks to some form of manageable residual risk. Regulatory fines, sanctions
and compliance costs have contributed to institutions retreating from high-risk regions and
businesses and preventing leaders from being strategic and thinking outside of the box. Vacuum
management and “Compliance Officers with Blinkers” seems to be the order of the day.
The concept of “de-risking” has made financial activity less transparent and more susceptible to
misuse by criminals. For example, in some jurisdictions, the fear of losing correspondent Banking
relationships have forced Banks to not open accounts for certain businesses, such as Money
Services Businesses and Offshore Gaming, to name a few. These same institutions are regulated
and supervised in the same jurisdiction as the Bank and sometimes by the same Regulatory
Entity. Whether or not the Money Services Businesses or Gaming Companies get a favourable
rating, the prescriptive decision is still applied by Banks. No effort whatsoever is being placed by
Banks to even conduct an assessment of these businesses to see if their AML/CFT Program is
effective. Some countries have Citizenship by Investment Programs as an additional service to
boost their economies. Even with the added due diligence by the Citizenship by Investment Units
and the Agents, Agents are finding it difficult to open bank accounts in some Banks in the same
countries. Some Banks oblige and on-board this type of business. However, when the applicant
attains citizenship after going through all the due diligence by the Bank and the Government Unit,
they are still having problems opening a Bank account. As a result, criminals and those assisting
them will be more creative and beat the system while genuine customers will remain as outcasts.
3. The inconsiderate and unthinkable regulatory crackdown will support the principle of “too-big-
to fail” institutions. Smaller entities will not have the economies of scale needed to implement
the prescriptive Anti-Money Laundering and Counter Financing of Terrorism Programs. Smaller
entities will be forced out of business while those with overseas head offices will be able to
implement the prescriptive model and survive. The result of this will be a negative effect on the
economy resulting in more unemployment and lack of innovation in businesses, to name a few.
Financial Intelligence Units have been called out by citizens in some countries for abusing the
powers granted to them by law. One of the principles of the Egmont Group of Financial
Intelligence Units that set guidelines for FIUs, is that an FIU should not be given more power than
it can handle. Drugs, moving through the streets of any country, certainly will have economic
and social consequences that can be detrimental to a country. However, the way Drug
Prevention is approached by some employees of FIUs appears to be personal rather than
professional.
In some small countries, citizens tend to know almost everyone. Citizens in these countries are
sometimes lost in time zones. Sometimes FIU employees just cannot imagine or understand how
non-traditional funds are generated in this globalized era. However, it is one thing when you do
not understand how a citizen can generate wealth and another when it is simply based on a
grudge due to an individual’s age, race, gender, ethnicity or past knowledge of the individual.
Using simply power and no proper due diligence assessment and evidence gathering will result
in loss of confidence in the Agencies and lack of public support and cooperation when needed.
We can all agree that there is an absolute need to fight Money Laundering and other Financial
Crimes, but it must be done utilizing ethical due diligence practices since absolute power corrupts
individuals and institutions.
Statistics have also shown that there is a low percentage of Money Laundering convictions in the
Caribbean over the years. Besides the lack of fortitude to pursue certain cases, there is also that
issue with the charges being laid on criminals. Those with the power to lay charges sometimes
do not understand the charges themselves. Alleged criminals are sometimes charged for Money
Laundering after being caught with Drugs, for example, when no Money Laundering ever took
place. One of the fundamentals of Money Laundering is that there are three stages – Placement,
Layering and Integration. The problem is that we are so caught up with the term Money
Laundering and so quick to make a name for ourselves, that as soon as someone is caught with
drugs, they are charged with Money Laundering. It is understood that Drug Possession is a
Money Laundering Predicate Offence, which means that it can give rise to a Money Laundering
offence. However, law enforcement agencies need to be better educated so as to ensure proper
assessments are conducted and charges laid are properly categorised. Failure to this do this will
result in many cases being dismissed.
In concluding, it is expected and quite natural for Regulators and FIUs to focus almost exclusively
on maintaining the stability of the financial services sector and fighting Financial Crimes. It is also
expected and quite natural that Financial Institutions and systems should be effectively
4. supervised. However, there must always be a basis for doing so. Before implementing
procedures, the aim is to determine whether those efforts actually reduce Financial Crimes, and
if so, whether the benefits and costs are justified.