JOINT FINANCIAL INTELLIGENCE UNIT
Stewart McGlynn
Chief Inspector of Police
Joint Financial Intelligence Unit
AML Seminar to Accountants - JFIUAML Seminar to Accountants - JFIU4 March 20104 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
Case Example 1
Mr. X, Chairman of Board of Directors for ABC Company
XYZ company
US$9.7M loanUS$10M pledge
Sole Owner of XYZ company is Mr. X
JOINT FINANCIAL INTELLIGENCE UNIT
Effective CDD / KYC
Good quality STR, allowing JFIU to perform its function
Protection
Learning Points
JOINT FINANCIAL INTELLIGENCE UNIT
Case Example 2 – Good Auditing Practice
Company X
Winding-up
Audit
Fraud and False Accounting
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 3 – Good KYC / CDD
Director of Company X
wanted in Japan
Frequent substantial withdrawals
from Bank account of Company X in Hong Kong
KYC / CDD By Accountant
for Company X
Discovery
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
Think About This
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
Country Comparison STR filed by Accountants
Country 2005 2006 2007Employment in Accountancy in
2008
Singapore0/2,076
(0%)
2/3,290
(0.06%)
2/7,621
(0.03%)875
UK
14,567/
195,702
(7.44%)
9,896/
213,202
(4.64%)
8,110/
220,484
(3.68%)
N/A
HK0/13,505
(0%)
0/14,557
(0%)
3/15,457
(0.02%)3715
JOINT FINANCIAL INTELLIGENCE UNIT
STR filed by Accountants
2005 2006 2007 2008 2009
No. of STR Received
13,505 14,557 15,457 14,838 16,062
Filed by Accountant
0 0 3 6 11
Percentage (%)
0.00% 0.00% 0.02% 0.04% 0.07%
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