Detective Sergeant John Poole, FIU Detective Garda Jimmy Cronolly, FIU.

Transcription

1 Detective Sergeant John Poole, FIU Detective Garda Jimmy Cronolly, FIU

2 Role of FIU Money Laundering Trends/Typologies Terrorist Financing Electronic Submission of STRs - GOAML

3 FINANCIAL INTELLIGENCE UNIT (FIU) Part of the Garda National Economic Crime Bureau (GNECB) - Police-based FIU - 11 Garda Officers & 7 administrative support staff Assisted by two in-house Money Laundering Investigation Teams (MLIU) cross-jurisdictional/complex ML cases PRIMARY ROLE/FUNCTION OF FIU: Receive, assess, & disseminate Suspicious Transaction Reports (STRs) from designated persons for investigation - MLIU Teams, CAB or Garda Divisions specially trained members... Also receive reports (Section 63 of 2010 Act) of suspected ML/TF from Competent Authorities, e.g. Central Bank, Accountancy Bodies, AMLCU, Law Society, etc. Dual reporting of STRs - Approximately 90% of STRs potentially of interest to the Office of the Revenue Commissioners Regular meetings with Rev. Commissioners to discuss STRs

4 FIU Database: All new data matched against existing data/fin. intelligence for any hits Can the FIU link the person(s) and source of funds with a predicate offence?? Cross-jurisdictional nature of ML/TF International enqs. through secure channels... Some STRs lead to full investigations Funds may be frozen, persons arrested and prosecuted for ML offences and/or associated predicate offences Good quality STRs are vital in the fight against ML/TF

5 , , , , , , , , , , , ,308 An Garda Síochána - Financial Intelligence Unit

6 Money Laundering Trends/Typologies ARE MAJOR CRIMINALS & MONEY LAUNDERING SYNDICATES GOING TO RISK USING THE FINANCIAL SYSTEM?? An Garda Síochána - Financial Intelligence Unit

7 TRADITIONAL PROFIT-GENERATING CRIMES: Drug trafficking, financial crime, brothelkeeping/prostitution, cross-border smuggling, tax evasion, etc.... TRADITIONALLY CASH-BASED FUNDS may or may not be laundered through the financial system FINANCIAL CRIME: STRs are reflecting an increase in the potential laundering of the proceeds of financial crime more so than any other predicate offence Financial crime includes white-collar crimes, cheque fraud, internet frauds (phishing, CNP fraud, ATM fraud, etc.), advance fee frauds, inheritance frauds, etc.... More recently: invoice re-direction fraud/ceo fraud An Garda Síochána - Financial Intelligence Unit

8 HOW ARE THE PROCEEDS OF FINANCIAL CRIME LAUNDERED? > Proceeds of domestic investments scams ( Ponzi/Pyramid scams) being laundered through the financial system (personal/business accounts) and often transferred to other accounts/multiple jurisdictions > Proceeds of complex frauds ( boiler-room frauds, Advance Fee Frauds/419 scams & Inheritance Frauds) committed outside jurisdiction being channelled through Irish financial system how?? Bank accounts opened in the name of an Irishregistered entity directors may be non-nationals using TCSPs funds being transferred into accounts and moved out of the country again very quickly

9 Proceeds of VAT carousel/mtic frauds being channelled through Irish bank accounts same day transfers into business a/cs. portion of funds remaining represents profits Accounts opened in false names using false documentation funds remain in account for a very short period of time and are then transferred to avoid same being frozen /confiscated if transactions look suspicious e.g. deposits re purchase of plant & machinery, etc. Identity Theft /Use of assumed identities Good quality false documentation being used.... Use of money mules - allowing personal accounts to be used for channelling proceeds of financial crime (proceeds of phishing, etc) unusual international credit transfers vis-à-vis profile of customer. He/she may then withdraw cash to make onward transfer via payment institutions... Breaks the audit trail

10 Investment structures (Funds, Trusts, Stocks/Shares) are potentially attractive mechanisms for money laundering variety & complexity of instruments available (nominee structures/numbered a/cs.) bribery, foreign bribery or corruption, etc.... Use of corporate structures: LBSs & entities used as a front Purchase of high-value goods (SUVs, boats, jewellery, gold, etc.) & properties (home/abroad) In addition to using the financial system, criminals/money launderers may use solicitors, accountants & other professionals to assist in laundering funds ( gate keepers ) - important to protect your reputation Self-launderers V Third-party money launderers International OCGs may use money laundering Syndicates An Garda Síochána - Financial Intelligence Unit

11 Globally, CASH remains a significant problem in the fight against ML/TF USE OF MULTIPLE LARGER NOTES ( 500 NOTES/ BIN LADEN NOTE )... The 500 note may be the note of choice for criminals - 1m in 20 notes weighs 50kgs V 1m in 500 notes weighs 2kgs... By 2018, no longer produced VIRTUAL/CRYPTO CURRENCIES A PASSING FAD?? CHALLENGE??: virtual currencies are the wave of the future for payment systems V virtual currencies provide a powerful new tool for criminals & terrorist financiers?? USE V MISUSE?? There is no evidence that there is a current crystallised risk for ML/TF purposes but the threat could greatly increase in the future with the expansion of ATM & merchant networks N.B. National Risk Assessment (NRA): published Oct An Garda Síochána - Financial Intelligence Unit

12 Fast & Secure Message Board 29 th of May 2017

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32 STR Receipts Trends/Typologies Alerts Section 56 Requests

33 1. Register 2. Complete STR 3. Attach documents 4. Preview & print copy for Revenue 5. Submit STR 6. Receive acknowledgement from FIU

34 Web: Ph: