UAE continues to make progress in combatting ML/TF
UAE Progress Update
As FATF week starts in Paris, a topic of interest is the grey listing status of the UAE. Financial Crime News published a post which also included a detailed 28 page progress report in October, 2023 and a 2 page summary Country Financial Crime Dashboard, and has now today published updates to both. For the 2024 Dashboard see HERE: FCN UAE Dash Feb2024 and for the Progress Report see HERE: UAE Update 18 Feb 2024
Whilst improving technical compliance is the first task for a country it’s how these elements translate into effectiveness the key and from the data, the UAE has been able to demonstrate both, so lifting it from the grey list I expect. Improvements – ML/TF/PF Risk understanding is much better for both public and private, sophisticated and not so sophisticated, national and international co operation is much improved not just for TF but also ML and other crimes, with some big names still to be delivered/extradited (Kinahan/Gupta), supervision is more effective and clearer on what is expected and the private sector is expected to deliver to expectations or face sanctions, even licenses are at stake, the FIU has been completely revamped from its under resourced, bureaucratic, reactive state body into a much more proactive active and PPP supporting institution reaching out domestically and internationally, and law enforcement now prioritising ML and related investigations prosecutions & convictions & asset confiscations with judicial time understanding & support.
Seat of the new AML Authority – EU Public Hearings
Today, a joint hearing organised by the EU Parliament and the Council was held, with each of the remaining 9 bidding countries, each having 1 hour each to present, with 10 minutes for opening remarks, followed by a Q&A and 3 minutes to conclude.
This is the first time a public hearing has been used to determine the seat of an EU Agency, courtesy of a decision by the European Court of Justice. Nine Agencies submitted formal applications. The final decision will be taken on the 22nd February 2024
JF Lopez Aguilar Co Chair of the session and Spanish MEP and Former Spanish Minister of Justice opened the session reminding the context for the hearing stating that, “ML/TF are threats not only to the stability of our financial systems but also for public security.
South Africa Country Financial Crime Dashboard 2023 by FCN
Today Financial Crime News is publishing a Financial Crime Country Dashboard for South Africa. This December 2023 Dashboard includes, for example approx 150 data points which have been collected and are represented over 2 pages. It informs as to the nature of the financial crime threats, the main vulnerabilities, how resilient South Africa is to these threats and its overall level of response, with important KRI and KPI data, all from publicly available sources albeit assessed and analysed for accuracy and relevance by FCN.
FCN Country Risk Scores & Ratings: South Africa is rated 61/100 and having a Moderate to High Threat level, with a “Low – Moderate” Response at 66/100, resulting in an overall Risk of Moderate – High at 63/100, using the FCN Methodology.
Nigeria Country Financial Crime Dashboard 2023 by FCN
Financial Crime News is publishing its first Country Financial Crime Dashboard for Nigeria. See: HERE: FCN Nigeria Dec 2023 PBLSD
According to the FATF MER published in 2021, “Nigeria has undertaken positive steps to increase its risk understanding, and authorities demonstrated a broad general understanding of the types of ML risks facing the country, both through its AML/CFT National Risk Assessment and other related studies. Although Nigeria recognises the wide range of both ML and TF threats and vulnerabilities it faces, the depth and sophistication of its understandings of key ML risks, including of corruption and fraud, legal persons (including free zone enterprises (FZEs)) and politically exposed persons (PEPs), are underdeveloped considering their complexity, materiality and scope. Nigeria’s understanding of TF risks is significant, but could be improved in material respects, e.g.,
Kenya Financial Crime Country Dashboard 2023 by FCN
Today Financial Crime News has updated its Kenya Financial Crime Dashboard in the new 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 December 2023 Dashboard for Kenya see HERE: FCN Kenya Dec 2023 Pbd 2
FCN Country Risk Scores & Ratings: Kenya is rated 71/100 and having a Moderate to High Threat level, with a “Moderate” Response at 55/100, resulting in an overall Risk of Moderate – High at 63/100, using the FCN Methodology.
Mauritius Financial Crime Country Dashboard 2023 by FCN
Today Financial Crime News is publishing a Financial Crime Country Dashboard for Mauritius. This December 2023 Dashboard includes, for example approx 150 data points which have been collected and are represented over 2 pages. It informs as to the nature of the financial crime threats, the main vulnerabilities, how resilient Mauritius is to these threats and its overall level of response, with important KRI and KPI data, all from publicly available sources albeit assessed and analysed for accuracy and relevance by FCN. For a copy of the Mauritius Dashboard see HERE: Mauritius Dashboard Dec 2023 PUBLD
Mauritius is often described as an island paradise, especially for tourists and is located in the southern hemisphere, in the south-eastern part of the Indian Ocean, and is part of southern Africa.
Seychelles Financial Crime Dashboard 2023 by FCN
FCN IS PLEASED TO PRESENT THE UPDATED FINANCIAL CRIME DASHBOARD: Seychelles FC Dashboard FINANCIAL CRIME ASSESSMENT: Seychelles August 2023 Pbd. FOR THE 2020 ASSESSMENT SEE HERE.
The Seychelles is an islands paradise, at least for foreign tourists, but as with everywhere else it faces common and unique financial crime threats. A new 25 page Financial Crime Assessment and 2 Page Dashboard updates the previous work published in 2020 are now available. Always fascinating to dig deep into different places and see both the evolving threat and the response.
Drugs & Corruption are the two dominant financial related crimes that have long been related and have turned the Seychelles into one of the most addicted to heroin places in the world.
Book Review: Freezing Order by Bill Browder
Financial Crime News, published a book review in 2019 on Bill Browder’s first Book titled “Red Notice” a tribute to the eponymous Sergei Magnitsky of “Magnitsky Act” notoriety who was tortured and murdered in custody by Russian authorities who stole hundreds of millions of dollars that Magnitsky a Russian Tax Lawyer had uncovered. See HERE.
In the sequel, “Freezing Order” Browder chronicles how a global money laundering investigation targeting powerful adversaries, is almost an impossible task, has cost many innocent lives but improbably resulted in millions of dollars of money and assets frozen.
It’s a must read for financial crime fighters, with the technical aspects well known but come to life with a context and a storytelling that reveals an uncomfortable truth that following the money, even in such a celebrated case is a huge challenge and wouldn’t have been possible without Browder, his friends and Sergei’s supporters persistence and journalistic and other private sector support and bravery, enabling public sector action.
Turkey Country Financial Crime Risk Dashboard 2023 by FCN
Financial Crime News is today publishing a Country Financial Crime Dashboard for Turkey.
The threats generating significant proceeds of crime and posing a “High” ML threat are illegal drug trafficking, migrant smuggling, human trafficking and fuel smuggling.“Medium” ML threat levels are for aggravated fraud; smuggling of tobacco, tobacco products and alcohol; illegal online betting and corruption.Turkey also faces severe threats from terrorism and has suffered from a significant number of terrorist attacks.
The sectors posing the highest ML/TF risks are related to activities involving Banking, money and value transfer services, including illegal money exchangers, Payment & E Money Institutions, Foreign Exchange Offices, Cryptocurrency Intermediaries, Real Estate Agents, Jewellers & Dealers in Precious Metals and Stones. Turkish increase in exports of critical goods to Russia raises risks that Turkish firms are targeted in connection with Western Sanctions circumvention.
The Early History of the FATF and what we can learn from the Founders and what this means for the Fight against Financial Crime, including Money Laundering
Today Financial Crime News is publishing an exploration of the early years in fighting financial crime when in the 1980’s and the early 1990’s the follow the money approach ushered in the ant money laundering era and saw the birth of the FATF.
EXTRACT:
The recent work of the FATF (Financial Action Task Force on Money Laundering Terrorism Finance and Proliferation Finance) is well known, but how and why it was established is less well understood and indeed may even be contested. It could have been a task force to tackle offshore tax havens but instead became a task force to tackle drug money laundering focused on large industrial countries and countries with large financial centres. It’s original aims were clear, – “success will provide a decisive contribution to the fight against criminal activities, and, above all against drug trafficking, & will improve the soundness of the international financial system”.
