JOINT FINANCIAL INTELLIGENCE UNIT Stewart McGlynn Chief Inspector of Police Joint Financial...
17
JOINT FINANCIAL INTELLIGENCE UNIT Stewart McGlynn Chief Inspector of Police Joint Financial Intelligence Unit AML Seminar to Lawyers - JFIU AML Seminar to Lawyers - JFIU 3 March 2010 3 March 2010
-
Upload
elisabeth-barnett -
Category
Documents
-
view
217 -
download
3
Transcript of JOINT FINANCIAL INTELLIGENCE UNIT Stewart McGlynn Chief Inspector of Police Joint Financial...
JOINT FINANCIAL INTELLIGENCE UNIT
Stewart McGlynn
Chief Inspector of Police
Joint Financial Intelligence Unit
AML Seminar to Lawyers - JFIUAML Seminar to Lawyers - JFIU3 March 20103 March 2010
JOINT FINANCIAL INTELLIGENCE UNIT
Suggested format & content detailed in JFIU website
Fax
Post
Verbal (urgency - follow-up by hardcopy)
STR Filing
JOINT FINANCIAL INTELLIGENCE UNIT
Urgency
Confidentiality
Tipping Off
Crime Report Vs STR
Concerns
JOINT FINANCIAL INTELLIGENCE UNIT
Acknowledgement of Receipt File Ref. Contact Person Details
Consent / No Consent Letter
Arrest / Prosecutions / Convictions
STR Quarterly Analysis Report
Feedback
JOINT FINANCIAL INTELLIGENCE UNIT
STR
Case Example 1
JOINT FINANCIAL INTELLIGENCE UNIT
Walk-in Client
Background Not Known
Purchase of sizeable commercial property investment
Source of finance unknown
STR Report Made
JOINT FINANCIAL INTELLIGENCE UNIT
Learning Points
Poor / Negligible CDD / KYC
Absence of risk based approach
Sub Standard STR
JFIU unable to make assessment
What would you think?
JOINT FINANCIAL INTELLIGENCE UNIT
Case Example 2
HK$ 170 MillionMr. X Resident inIn CountryY Company B
Company A
Law Firm12 installments of cash / cashier order
JOINT FINANCIAL INTELLIGENCE UNIT
Effective CDD / KYC
Risk based approach
Good quality STR, allowing JFIU to perform its function
Protection for you
Learning Points
JOINT FINANCIAL INTELLIGENCE UNIT
Case Example 3
UK Resident Mr. X
Paid US$ 316,750.00
Fake Letter from a local bank
PRC Pity worth US 8.35M
Mr. Z of law firm
Company A
Company C
Company B
JOINT FINANCIAL INTELLIGENCE UNIT
Learning Points
Reported knowledge of Crime Proceeds – Fraud
Crime report could have been made but STR acceptable in this case
Urgency? Unsure? Contact JFIU
JOINT FINANCIAL INTELLIGENCE UNIT
Case Example 4
Mr.X , a HKID holder
Law Firm
Purchase price HK$ 7,349,000
Paid Down-payment HK$ 734,900 (10%)
$ from gambling
JOINT FINANCIAL INTELLIGENCE UNIT
Learning Points
Common sense, proportionate approach to KYC and CDD
If it looks like a duck……….
No risk of prosecution
JOINT FINANCIAL INTELLIGENCE UNIT
Country Comparison STR filed by Law Firms
Country 2005 2006 2007Law Firms in
2008
Singapore0/2,076
(0%)
2/3,290
(0.06%)
2/7,621
(0.03%)806
UK
10,525/
195,702
(5.38%)
7,296/
213,202
(3.42%)
11,300/
220,484
(5.13%)
N/A
HK5/13,505
(0.04%)
11/14,557
(0.08%)
9/15,457
(0.06%)135
JOINT FINANCIAL INTELLIGENCE UNIT
STR filed by Law Firms
2005 2006 2007 2008 2009
No. of STR Received
13,505 14,557 15,457 14,838 16,062
Filed by Law Firms
5 11 9 35 70
Percentage (%)
0.04% 0.08% 0.06% 0.24% 0.44%
JOINT FINANCIAL INTELLIGENCE UNIT
Some Final Thoughts
JFIU understands the burden that CDD and KYC entails
Law / International Standards
Increase in quality STRs from the sector desirable – intelligence is our business
JFIU is here to help – Contact us
JOINT FINANCIAL INTELLIGENCE UNIT
Contact JFIU
Telephone:2866 3366
Fax :2529 4013
Email:[email protected]
Mail:GPO Box 6555 Hong Kong
Telephone:2860 3547
