Jersey Financial Services Commission

Similar documents
ANTI-MONEY LAUNDERING/ COUNTERING THE FINANCING OF TERRORISM STRATEGY GROUP

AMENDMENTS TO THE MONEY LAUNDERING (JERSEY) ORDER 2008

Guidance for completing Phase 1 of risk based supervision data

NOTICE TO BANKS MONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186

Anti-Money Laundering Policy and Procedure

PROCEEDS OF CRIME (MONEY LAUNDERING) & TERRORIST FINANCING (AML/ATF)

PROCEEDS OF CRIME (MONEY LAUNDERING) & ANTI-TERRORIST FINANCING (AML/ATF)

Draft. HANDBOOK FOR THE PREVENTION AND DETECTION OF MONEY LAUNDERING AND THE FINANCING OF TERRORISM Draft May 2006

PCM Brokers DMCC. Anti-Money Laundering Policy

GD 2017/0059 ISLE OF MAN FINANCIAL INTELLIGENCE UNIT Strategic Delivery Plan June 2017

FINANCIAL INTELLIGENCE UNIT (UKFIU)

Anti-Money Laundering Policy June 2017

Joint Equity. Anti-Money Laundering Compliance Manual

MONEY LAUNDERING AND TERRORISM FINANCING IN THE CORPORATE SERVICE PROVIDERS SECTOR. Domestic Trends

ANTI-MONEY LAUNDERING/ COUNTERING THE FINANCING OF TERRORISM STRATEGY GROUP PROPOSALS TO UPDATE JERSEY S AML/CFT FRAMEWORK

MONEY LAUNDERING - HIGH VALUE DEALERS

The Anti-Money Laundering Regime: A Jersey Overview

Guide to Phase 1 of risk based supervision data for Sole Traders:

REGULATORY OVERVIEW. In addition to the licensing requirements on corporations that carry on regulated activities, any individual who:

MONEYVAL Jersey Report Industry Briefing. 08 June 2016

ANTI-MONEY LAUNDERING POLICY

Anti Money Laundering Policy

National Film & Television School ( the School ) Anti-Money Laundering Policy 1

David Oliver Senior Manager Compliance

Anti-Money Laundering - A Practical Guide 27th September Doug Hopton Director DTH Associates Limited

ABCsolutions Inc. CREA - Introduction

Anti-money Laundering Bulletin

Money Laundering And The Proceeds Of Crime

Anti-Money Laundering Law of the People's Republic of China

Financial and Commercial Services UNIVERSITY OF BRADFORD ANTI-MONEY LAUNDERING POLICY

KUWAIT TURKISH PARTICIPATION BANK INC. SUMMARY OF ANTI MONEY LAUNDERING AND COMBATING FINANCE OF TERRORISM POLICY

Anti-Money Laundering Awareness Training Insurance Industry-Hong Kong

SFC consultation paper on proposed anti-money laundering and counterterrorist

HANDBOOK FOR LEGAL PROFESSIONALS, ACCOUNTANTS AND ESTATE AGENTS ON COUNTERING FINANCIAL CRIME AND TERRORIST FINANCING

Financial Intelligence Service. Bailiwick of Guernsey

POSITION PAPER NO IMPLEMENTATION OF FATF SPECIAL RECOMMENDATION VII ON WIRE TRANSFERS

DATA PRIVACY & FAIR PROCESSING NOTICE

gamevy Anti- Money Laundering Detecting and Preventing Financial Crime Training for Gamevy

Customer Identification Procedures for Brokers

READING COMMUNITY LEARNING CENTRE

SWITZERLAND BENEFICIAL OWNERSHIP TRANSPARENCY

ANTI-MONEY LAUNDERING AND COUNTER TERRORISM FINANCING PROCEDURE MANUAL. Fcorp Services Ltd

ANTI-MONEY LAUNDERING POLICY. (2 nd Edition)

June Background

We are the Sanne Group, a listed multinational provider of alternative asset and administration services.

SAINT VINCENT AND THE GRENADINES STATUTORY RULES AND ORDERS 2002 NO (GAZETTED 2002) PROCEEDS OF CRIME (MONEY LAUNDERING) REGULATIONS, 2002

Frequently asked questions & guidance notes

Financial Transactions and Reports Analysis Centre of Canada Centre d analyse des opérations et déclarations financières du Canada

Association of Accounting Technicians response to Law Commission Consultation on Anti-Money Laundering: the SARs regime

Handbook on International Co-operation and Information Exchange. for the use of overseas supervisory authorities

GUERNSEY FINANCIAL SERVICES COMMISSION CODE OF PRACTICE FOR BANKS. Effective 24 November 2003

9. SCREENING, AWARENESS AND TRAINING OF EMPLOYEES

CONSULTATION PAPER OVERRIDING PRINCIPLES FOR A REVISED KNOW YOUR CUSTOMER FRAMEWORK

GUERNSEY FINANCIAL SERVICES COMMISSION

Money Laundering and the Proceeds of Crime

Regulation of Fiduciaries, Administration Businesses and Company Directors, etc (Bailiwick of Guernsey) (Amendment) Regulations, 2008

Anti-Money Laundering and Counter Financing to Terrorist (AML/CFT) Workshop Series: AML Compliance Policies / Programme within a company

CENTRAL BANK OF BAHRAIN. Suspicious Transaction Report (STR) Form

Guidelines on Anti-Money Laundering and Countering Financing of Terrorism

Anti-Money Laundering. Renu Kiran

Practical Implementation of UN Standards and Financial Action Task Force on Money Laundering (FATF) Recommendations: Challenges and Assistance

Accountants and Tax Advisors

The Central Bank of The Bahamas

Trust Client Client Due Diligence. ABN AMRO Bank N.V., Jersey Branch

INSURANCE ACT 1986 INSURANCE (ANTI-MONEY LAUNDERING) REGULATIONS 2008

Your Aviva Business Insurance Important Information

JERSEY FINANCIAL SERVICES COMMISSION 5 TH ANNIVERSARY SEMINAR FATF REVISED 40 RECOMMENDATIONS

Guidance Note on Prevention of Money Laundering and Terrorist Financing. The Office of the Commissioner of Insurance

United Republic of Tanzania Financial Intelligence Unit Anti Money Laundering and Counter Terrorist Financing Guidelines to Insurers

Produced by Corbin Communications Ltd.

Anti Money Laundering and Combating Financing of Terrorism

ANTI-MONEY LAUNDERING POLICIES, CONTROLS AND PROCEDURES

R.S.A. c. P98 Anti-Money Laundering and Terrorist Financing Code R.R.A. P98-5. Revised Regulations of Anguilla: P98-5

ANTI-MONEY LAUNDERING REGULATIONS, 2011 ARRANGEMENT OF REGULATIONS

Policy on Anti Money Laundering and Countering Terrorist Financing

GUIDELINES FOR SUPERVISED FINANCIAL INSTITUTIONS ON THE PREVENTION OF MONEY LAUNDERING & COUNTERING THE FINANCING OF TERRORISM

The Role of Accountants in the Fight against Money Laundering

PROCEEDS OF CRIME AND ANTI-MONEY LAUNDERING ACT

Kenya Gazette Supplement No th March, (Legislative Supplement No. 21)

AML & ATF Policy and Procedures for Deposit Agents of Peoples Trust Company

SUSPICIOUS TRANSACTIONS AND ANTI-MONEY LAUNDERING GUIDELINES

EXPERIAN IRELAND INFORMATION NOTICE Version: 1 Adopted: 27 th September 2017

International Monetary Fund Washington, D.C.

Revisions to Money Laundering Order and AML/CFT Handbooks

International Premier Account Application Form

Home Insurance Important Information. Please read this and keep it for reference.

Financial Intelligence Act 13 of 2012 section 73(2)

SUPPLEMENT TO THE GUIDELINE ON PREVENTION OF MONEY LAUNDERING

3.1 The legislation defines the offences relating to money laundering as:

Home, Possessions and Student Insurance Important Information

Member States capabilities in fighting tax crimes

Standard 2.4. Customer identification and customer due diligence; Prevention of money laundering, terrorism financing and market abuse

HANDBOOK FOR FINANCIAL SERVICES BUSINESSES ON COUNTERING FINANCIAL CRIME AND TERRORIST FINANCING

DRAFT HANDBOOK FOR THE PREVENTION AND DETECTION OF MONEY LAUNDERING AND THE FINANCING OF TERRORISM FOR FINANCIAL SERVICES BUSINESSES PART 1

Swiss Data Privacy statement

EXECUTIVE SUMMARY. Executive Summary. Key Findings

Anti Money Laundering /Anti Terrorist Financing & FINTRAC (Financial Transactions & Reports Analysis Center of Canada) Training Presentation

The Financial Intelligence Service

financial intelligence centre REPUBLIC OF SOUTH AFRICA Financial Intelligence Centre FAIS Workshop Presented by The Financial Intelligence Centre

Anti-money laundering Annual report 2017/18

Transcription:

Jersey Financial Services Commission Suspicious Transaction Reporting JOINT FINANCIAL CRIMES UNIT

INTRODUCTION JFCU roles/responsibilities STR stats and trends STR pro-forma Common mistakes JFCU response to STRs Consent the legal position Management of client issues

INTRODUCTION Tipping Off issues Cash Handling Tax fraud Service of orders UK POCA provisions Likely impact here

Jeffrey Robinson The Laundryman After Foreign Exchange and the oil industry, the laundering of dirty money is the world s third largest business Companion only to Brutality Deceit Terrorism Murder Drug trafficking BANK PROFITS...

JFCU Roles and Responsibilities States of Jersey Police 6 policing promises 2002-2003 Maintain and enhance the Island s reputation as a financial centre of integrity

JFCU Functions STR/SAR receipt Research Dissemination Intelligence checks Overseas requests Database maintenance Financial analysis Investigations Evidence gathering Serious fraud Money Laundering Terrorist financing UN/EU Sanctions Asset tracing Restraints/Forfeiture

National Criminal Intelligence Service (NCIS) - UK - STRs 50000 45000 40000 35000 30000 25000 20000 15000 10000 5000 0 STRs 1987 1989 1991 1993 1995 1997 1999 2001

STR/SAR ANALYSIS Reporting rate has gone up 25 pcm pre 99 75 pcm 01 100 pcm + 02 2002 projection 1800 1600 1400 1200 1000 800 600 400 200 0 1998 1999 2000 2001 2002 STR

Crown Dependency STR comparison 2000 1800 1600 1400 1200 1000 800 600 400 200 0 Jersey Guernsey Isle of Man 2000 2001 2002

Jurisdiction in which STR subject resides (%) 45 40 35 30 25 20 15 10 5 0 Local UK EU Other Isle of Man Guernsey Jersey Average

Residency of subject? No serious/organised organised crime in Jersey Generating high value transactions Crime has happened elsewhere Criminal resides elsewhere Suspicious assets transiting through Jersey or being parked here

Disclosure Type : Date: Proceeds of Crime Drug Trafficking Terrorism To: Joint Financial Crimes Unit. Fax: 870537 JFCU Reference number:- From : - Disclosing Institution LEGAL Name of institution : Address : Sort code : Contact name : Direct Telephone No: Fax: Reference number : Subject(s) of disclosure Full name : Date & place of birth : Full address : Telephone No : (Work) (Home) (Mobile) (Fax) Occupation : Identification details : (passport etc.) Company name : Full address : Telephone No : Beneficial owner(s) :

Other associated persons or companies, full details (please add sheet if necessary):- Details of introducer/intermediary:- Account number : Date opened : Assets held: REASONS FOR SUSPICION Please describe any activity that prompted the report, giving reason for your suspicion and any steps that have already been taken. Please add continuation sheets as necessary. When submitting this report, please append any additional material that you may consider suitable and which may be of assistance to the JFCU, i.e. bank statements, correspondence, vouchers, transfers, account opening and identification documents, etc.

Word document Available as blank pro forma by e-mail: from d.minty minty@police. @police.gov.je or s.monins monins@police. @police.gov.je or i.clarkson clarkson@police. @police.gov.je

Common mistakes Legal name of entity Service of Production Orders Asset value Details of suspicions Supporting documentation General lack of detail and information

JFCU response Tailored - case by case assessment 3 generic responses 1. Note declined business or terminated relationship - no retrospective comfort! Consent to maintain relationship + 2. No consent to future transactions or 3. Future transactions at your own risk

JFCU response letter: However, this consent does not release you from your obligation in respect of all future transactions on the account or arising from the relationship to comply with the relevant anti-money laundering legislation and to have due regard to the JFSC Guidance Notes on the subject.

Rationale/explanation We will not have the knowledge of the client you do We will not give our blessing to continued suspicious transactions!! We may have knowledge or intelligence to support the notion that the subject is engaged in criminality, or that there are tainted proceeds involved