GD 2017/0059 ISLE OF MAN FINANCIAL INTELLIGENCE UNIT Strategic Delivery Plan 2017-18 June 2017
CONTENTS Foreword...3 Introduction...4 Who we are...4 What we do...5 2 Strategic Objectives, as identified by the FIU Board...5 Contents Financial Resources for 2017-18...6 Key Performance Targets for 2017-18...6 Priorities for 2017-18...7
ISLE OF MAN FINANCIAL INTELLIGENCE UNIT STRATEGIC DELIVERY PLAN 2017-18 FOREWORD I am pleased to present the Strategic Delivery Plan 2017-18 for the Financial Intelligence Unit ( FIU ). The priorities identified in this Strategic Delivery Plan build upon the objectives identified by the FIU Board for 2016/17 and aim to ensure that the FIU provides the central focus and lead for all AML/CFT intelligence with a particular focus on those matters identified as key priorities following the National Risk Assessment 2015 and the Moneyval 5th Round Mutual Evaluation Report. As highlighted by those assessments, 2017-18 will be a challenging year for the FIU but, as will be demonstrated in the FIU s 2016-17 Annual Plan, the FIU has already achieved success in tackling the deficiencies identified. 3 The capacity and resourcing of the FIU to adapt to the changing criminal environment and the resulting quality and currency of its intelligence will be critical to the FIU s ability to implement the strategy set out in this document. The FIU and the FIU Board are committed to the FIU continuing to make the improvements required in order that the FIU may play its role in pro-actively Foreword As set out in the Strategic Delivery Plan 2016-17, criminals use ever developing and diverse methods to launder money and/or to support acts of terrorism. It is in this context of the ever increasing sophistication of criminals that the FIU faces the challenge of building and sharing knowledge and information with its partners and providing high quality and timely analysis and advice to government. combatting global financial crime and terrorist financing and protecting the Island s future. John L M Quinn H.M. Attorney General Chair of the FIU Board
INTRODUCTION WHO WE ARE 4 Introduction / Who we are This Strategic Delivery Plan comes at the end of the first year of operation of the FIU. 2016/17 saw significant progress for the FIU with the recruitment of the FIU Director, the Operations Manager and new Supervisory and Financial Intelligence Officer staff. Additional funding has also been made available which has enabled the FIU to develop and implement a training programme for its staff, including specialist financial intelligence officer training and terrorist financing training. 2016-17 also saw the introduction of the FIU s online reporting system, Themis, for the reporting of suspicions of money laundering and terrorist financing to the FIU and also for the disclosure of information for the purposes of the exercise by the FIU of any of its functions under new provisions contained in the Financial Intelligence Unit Act 2016 (the Act ) which came into force in April 2016. The Act also provides wider information gathering powers to the FIU to enable it to carry out its functions effectively, with these powers already proving extremely useful. The FIU was established as a statutory body in 2016. Whilst the Island s financial intelligence function had previously been carried out by the Isle of Man Constabulary, the FIU as a stand-alone entity is now able to focus on and specialise in the intelligence function. The FIU is a full member of the Egmont Group of FIUs and adheres to the Egmont Group Statement of Purpose and its Principles of Information Exchange between FIUs. The strategic priorities of the FIU are determined by the FIU Board which is made up of H.M. Attorney General (Chair), the Chief Constable and the Collector of Customs & Excise. The functions of the FIU are exercised by its Director, subject to any directions given by the Board. A chart showing the organisational structure of the FIU as at 1 May 2017 is set out below.
WHAT WE DO The FIU plays a key role in the global fight against terrorism and financial crime with the FIU s functions being Receiving, gathering, analysing, storing and sharing information about financial crime (whether in the Island or elsewhere). Assisting with the prevention and detection of crime, and in particular, financial crime (whether in the Island or elsewhere). Cooperating with law enforcement agencies. Contributing to the reduction of crime, and in particular, financial crime and to the mitigation of its consequences. STRATEGIC OBJECTIVES The FIU s strategic objectives, as identified by the FIU Board, are: Understanding the money laundering and financing of terrorism threat, risks and harm facing the Island. Identifying and addressing cases of high level financial crime and corruption thereby ensuring that the Isle of Man continues to develop as a safe, well regulated and dynamic business centre, thereby protecting its international reputation by complying with recognised international standards. Re-assessing the Island s cross-border ML & TF threats in light of information gathered by partner agencies on the flows of funds into and out of the Island s financial sector Providing a high quality of international co-operation in support of the Isle of Man s long-standing commitment to complying with international standards on tax cooperation, transparency and combatting money laundering and the financing of terrorism. Providing intelligence to enable partner agencies to detect AML/CFT activity, investigate financial crimes (including tax evasion), disrupt criminal activity, secure prosecutions and confiscate proceeds of crime. Providing high quality and timely analysis and advice to government on emerging financial crime threats and typologies. Addressing the identified need for additional specialist financial intelligence investigators. Implementing a wide ranging training programme that ensures the FIU s compliance with international standards. Using technology to enhance both the performance and effectiveness of the FIU by improving the quality of the material it receives and produces. Engaging with industry in a meaningful partnership, particularly in regards to improving the quality of SARs/online reporting, ML and TF typologies and emerging threats. Producing and issuing an annual report for the FIU as required by the Financial Intelligence Unit Act 2016. 5 What we do / Strategic objectives
FINANCIAL RESOURCES FOR 2017-18 The FIU s budget reflects the fact that, as a stand-alone entity, the resources of the FIU (both in terms of staff and technology) must be increased to not only improve the effectiveness of the FIU but also to act as a deterrent against financial crime and thereby enhance the Island s international reputation. The salaries and other expenditure of the FIU are funded from sources which include the general revenue, secondment of officers from the DHA and Treasury Customs & Excise Division and approved re-claims from the Seized Assets Fund. As the 2017/18 FIU budget requirements were considered at a time when the FIU was not fully operational, it will be necessary for the FIU to make further revenue bids to Treasury in order for the FIU to meet its key priorities identified above. With the continued support of Treasury, and the other agencies with which it deals on a regular basis, the FIU fully expects to meet its priorities during the forthcoming year. 6 KEY PERFORMANCE TARGETS FOR 2017-18 Financial resources / Key perormance targets In focussing on its key priorities the FIU will, amongst other things Ensure that its staff receive training from recognised experts, including financial intelligence officer training, anti-money laundering training and terrorist finance training. Develop a programme for increased liaison with industry, including speaking at forums/conferences and meeting with the regulators, industry bodies and industry members. Produce guidance for industry on the risk indicators for terrorist financing. Produce guidance for industry on the online reporting system (Themis) and on the SAR reporting regime. Produce an operational analysis handbook for use by FIU staff. Increase the dissemination of actionable intelligence to law enforcement agencies (including ICART) and regulatory bodies. Collect and analyse intelligence from mutual legal assistance requests received by H.M. Attorney General and provide meaningful intelligence packages for use by law enforcement agencies and regulatory bodies. Work closely with other Isle of Man authorities in relation to the delivery of the Island s Financial Crime Strategy.
PRIORITIES FOR 2017-18 As a result of the National Risk Assessment 2015 and the Moneyval 5th Round Mutual Evaluation Report the FIU has identified its key priorities for 2017/18 as: Continuing to develop and implement a training and development programme for its staff; Providing education, guidance and training for industry on suspicious activity reports (SARs), including publishing typologies from the analysis of SARs. Improving the level of analysis of SARs and undertaking regular strategic analysis of threats based upon intelligence received. Building strategic and productive relationships with the financial and nonfinancial sectors and law enforcement agencies both on and off the Island, including the newly created International Cooperation and Asset Recovery Team (ICART). Identifying, collecting and maintaining statistics and KPIs designed to demonstrate and improve the FIUs performance. Whilst the FIU started to address these priorities during 2016-17, the FIU will give further attention to these priorities during 2017-18 to ensure that it achieves excellence in the gathering, analysis and dissemination of intelligence. The Financial Intelligence Unit will give further attention to its priorities during 2017-18 to ensure it achieves excellence in the gathering, analysis and dissemination of intelligence. 7 Priorities
Cabinet Office Government Office Bucks Road Douglas IM1 3PN