Wildlife Trafficking Syndicate ensnared by United Forces
On 13 June 2019, the US Department of Justice, U.S. Attorney’s Office, Southern District of New York indicted four individuals, Moazu KROMAH, Amara CHERIF, Mansur Mohamed SURUR, and Abdi Hussein AHMED charged with participating in a conspiracy to traffic more than US$7 million in rhino horns and elephant ivory. In addition, KROMAH, CHERIF, and SURUR were charged with conspiracy to commit money laundering, and SURUR and AHMED were charged with participating in a conspiracy to distribute and possess with intent to distribute more than 10 kilograms of heroin. One of those charged is now in the US, another awaiting extradition in Senegal and two remaining Kenyans still at large, on the run.
This is not just important in terms of the action taken but how co operation across agencies and between public and private sectors and effective information sharing made a difference.
Crypto asks for more effective AML regulation – by Malcolm Wright
In February 2019, FATF issued its proposed recommendations for AML governance of the crypto industry. Under pressure from the international community, the FATF aimed to bring amendments to Recommendation 15 (New Technologies) into force at the June 2019 plenary. Within the proposals, one point was opened for consultation; colloquially known as 7(b) the proposal seeks to introduce wire transfer recommendations required of the traditional banking sector into the crypto industry. That is, originator and beneficiary information is collected, screened and transmitted between correspondent institutions with the objective to prevent criminals and terrorists having unfettered access to the financial system.
The crypto industry responded but not for the reason many thought; the response was not to fight against regulation or kick the can down the road for another day but to make sure that the regulation could be effective.
Message from the Editor / Publishing SSA TA – 2020
FCN Sub Saharan Africa Threat Assessment – Publication is now available: – see below
Recent FCN Publications
Where is the UK now in tackling MS/HT after the Modern Slavery Act 2015?
The UK, to its shame, led the world in the 17th & 18th centuries in commercialising slavery, through, in particular, the transatlantic human trafficking trade from West Africa to the Americas and the Caribbean, along with other European countries. To its credit, in the 19th century it was the first of the European countries to abolish the trade , with the passing of the Slavery Abolition Act in 1833, that supplied the slaves, or those in the Americas that received these slaves. The effect of this piece of legislation was to formally free the 800,000 Africans who were then the “legal property” of Britain’s 46,000 slave owners. The terms for their freedom were still onerous. They received no compensation, and were still compelled to provide 45 hours of unpaid labour each week for their former masters, for a further 4 years after their supposed liberation.
People Smuggling and the Small Boats Crossings to the United Kingdom
One of the Top 5 Priorities of Rishi Sunak’s UK Government is to “stop small boats”, with 2022 a record year and 44,755 people making it to the UK this way. On arrival most claim asylum. In 2018 the numbers making this crossing was just 299.
The record number of asylum seekers are on top of record legal migration, with immigration topping 1 million in the year to June 2022 doubling from 2020, and net migration at 560,000 up from 32,000 in 2020.
Whilst the numbers crossing in small boats is very high, put into context, these “illegal” crossings represent just 4.2% of total UK immigration, (to June 2022) with 65% expected to be granted legal asylum anyway, the “illegal” percentage reduces to 1.8%.
Interview with Mike Haley CEO “CIFAS” the “Credit Industry Fraud Avoidance System”
In this Interview with Mike Haley, the CEO of CIFAS, we explore all things fraud, not just in the UK but around the world. Mike is one of the worlds leading experts on combatting Fraud and CIFAS is the oldest and probably the largest fighting financial crime “private to private” and “private to public” information sharing collaboration in the world focussed on fraud).
1 – Is Fraud at epidemic even pandemic levels and if so, what’s driving it?
The description of fraud as an epidemic or pandemic seeks to raise the spectre of a disease that is widespread and out of control, however, we often use these labels without considering their epidemiological roots. An epidemic is a disease that affects a large number of people within a community, population, or region, whereas a pandemic is a disease affecting more than one country or region.
#2 UK Economic Crime Plan – Review by FCN
The UK Economic Crime Plan is finally published and sets out welcome plans to further combat economic crime over the next 3 years. In many ways it’s a remarkable achievement in public private collaboration and demonstrates the benefit of joined up thinking, from so many, which if progressed and successfully implemented, could represent meaningful change in the UK ‘s approach.
There are no big surprises but it’s thorough and comprehensive, which indicates ambition and commitment. There are still many choices still to be made despite the inclusion of actions, which are in some cases placeholders for important decisions to come.
The main positive highlights are that there is finally increased funding to do what could and should have been done years ago and that the focus is moving more towards increasing asset recoveries, that information sharing is at the core of the Plan as well as PPPs including on crypto and fraud is being recognised for the major threat that it poses both to the public sector and to the private sector, including against individuals.
Scams – Lucky 7 or 7 Years Bad Luck – What’s in a Number?
With scams everywhere and on the increase, the main ones can be explored through the lens of the human natures involved. Whilst these scams are carried out most often using cyber means it’s the human elements that remain the key to whether they succeed or fail.
Whilst scammers are unlikely to be pious or religious types, and so are likely unconcerned to learn that they may well be breaching 7 of the 10 Commandments. These are: 1) they worship money and no god, 2) they make idols, from crime, 3) they steal again and again, 4) they bear false witness against their neighbours, by their deception, 5) they covert other people’s goods, 6) they do not honour their fathers or mothers, & 7) they operate 24/7 with no break for the sabbath!
FATF EU Grey List Countries Compared and Why is Russia not yet Included on either
For those keeping track of countries listed by FATF & the EU both institutions have updated their lists recently with the FATF on 24th February and the EU on 20 December 2022 (see below for the current status – which for the EU came into force for newly added countries just this week on 16th March, 2023).
FATF removed Morocco, Cambodia and added Nigeria and South Africa. The EU added The Democratic Republic of the Congo, Gibraltar, Mozambique & the UAE and removed Nicaragua, Pakistan and Zimbabwe. Of added interest, the EU list doesn’t include Albania & Türkiye (both on the FATF list) and has yet to delist Cambodia and Morocco or add Nigeria and South Africa but these are likely to happen over the next 12 months.
Kenya Financial Crime Dashboard 2023 by FCN
Following the publication of the FATF 4th Round Review and Report for Kenya, Financial Crime News has updated its Kenya Financial Crime Dashboard last published in February 2022, in its new 2023 format.
This new format includes, for example approx 150 data points which have been collected and are represented in the 2 page Financial Crime Dashboard. It informs as to the nature of the financial crime threats, the main vulnerabilities, how resilient Kenya is to these threats and its overall level of response, with more KRI and KPI data than ever before, all from publicly available sources albeit assessed and analysed for accuracy and relevance by FCN.
For a copy of the 2023 Kenya Financial Crime Dashboard see HERE: Kenya Dashboard 16:3:23 Pbd
For a copy of the 2022 Financial Crime Dashboard for Kenya see HERE.