Transcript Calvin Wilson, "AML/ CFT Pre

AML/CFT PRE CONFERENCE
TRAINING
2007 CAIB AGM
Calvin E J Wilson
Executive Director
Caribbean Financial Action
Task Force
1
INTERNATIONAL COOPERATION ON
ML/FT

MEMBER STATES AGREED TO JOIN WITH THE
INTERNATIONAL COMMUNITY TO FIGHT THE TWIN
EVILS OF MONEY LAUNDERING AND THE
FINANCING OF TERRORISM.

BIRTH OF THE CARIBBEAN FINANCIAL
ACTION TASK FORCE

THE MUTUAL EVALUATION PROGRAMME
2
AML/CFT BEAUTY PAGEANT

THE MUTUAL EVALUATION PROGRAMME AND THE
END RESULT THE MUTUAL EVALUATION REPORT
COULD BE DESCRIBED AS A

BEAUTY PAGEANT WHERE COUNTRIES IN THEIR
OWN BEST INTERESTS SHOULD PUT THEIR BEST
FOOT FORWARD

SOLID PARTNERS IN THE GLOBAL BATTLE AGAINST
TRANS NATIONAL ORGANISED CRIME
3
THE MUTUAL EVALUATION PROGRAMME

THE MUTUAL EVALUATION PROGRAMME IS A
CRUCIAL ASPECT OF THE WORK OF THE CFATF
AS IT IS ONE OF THE MECHANISMS BY WHICH
THE SECRETARIAT ENSURES THAT EACH
MEMBER STATE FULFILS THE OBLIGATIONS
UNDERTAKEN.

THROUGH THIS MONITORING MECHANISM THE
WIDER MEMBERSHIP IS KEPT INFORMED AS TO
WHAT IS HAPPENING ON THE GROUND IN EACH
MEMBER COUNTRY THAT HAS SIGNED THE
MEMORANDUM OF UNDERSTANDING.
4
THE MUTUAL EVALUATION PROGRAMME

FOR THE INDIVIDUAL MEMBER, THE MUTUAL
EVALUATION PROGRAMME PRESENTS A VALUABLE
OPPORTUNITY FOR AN OBJECTIVE ASSESSMENT BY A
TEAM OF EXPERTS OF THE ANTI MONEY LAUNDERING
AND COMBATING THE FINANCING OF TERRORISM
FRAMEWORK AS IT EXISTS AT THE TIME OF THE VISIT.

THE PROGRAMME SEEKS TO GIVE DUE RECOGNITION
WHERE THE STANDARD BENCHMARKS ARE MET, BUT
WITH A VIEW TO SECURING IMPROVEMENTS WHERE
NECESSARY, IDENTIFIES WEAKNESSES WHICH HAVE
BEEN DETECTED AND MAKE RECOMMENDATIONS
WHERE THEY ARE FOUND TO EXIST.
5
THE MUTUAL EVALUATION PROCESS



A MISSION TO EACH OF THE MEMBER COUNTRIES
BY A TEAM OF EXPERTS, ONE OR MORE IN THE
FIELD OF LAW, FINANCE AND LAW ENFORCEMENT
LED BY THE EXECUTIVE DIRECTOR, DEPUTY
EXECUTIVE DIRECTOR, ONE OF THE EXPERT
ADVISORS AT THE SECRETARIAT,
OR OTHER SUITABLY QUALIFIED AND
EXPERIENCED EXAMINERS WHO FOR THESE
PURPOSES WILL BE CONSIDERED A MEMBER OF
THE SECRETARIAT.
6
THE MUTUAL EVALUATION PROCESS

THROUGH A RANGE OF INTERVIEWS WITH OFFICIALS IN
BOTH THE PRIVATE AND PUBLIC SECTORS, THE TEAM
ATTEMPTS TO GLEAN A PRECISE PICTURE OF THE
COUNTRY’S ANTI MONEY LAUNDERING AND COMBATING
THE FINANCING OF TERRORISM FRAMEWORK .

MONITORING COMPLIANCE WITH THE FATF 40
RECOMMENDATIONS AND THE NINE SPECIAL
RECOMMENDATIONS AGAINST THE FINANCING OF
TERRORISM
7
THE MUTUAL EVALUATION PROCESS

CRUCIAL TO THIS UNDERTAKING IS THE NEED FOR A
NATIONAL AGENCY WITHIN THE MEMBER STATE,
HEADED BY A CO-ORDINATOR, WHO COULD BE A
LEGAL OFFICER WITH NO MINISTERIAL
RESPONSIBILITY, WHO WILL BE RESPONSIBLE FOR THE
CO-ORDINATION OF THE MUTUAL EVALUATION
PROCESS.

IT IS NECESSARY FOR ALL GOVERNMENT
DEPARTMENTS AND AGENCIES AS WELL AS THOSE
PRIVATE SECTOR ORGANISATIONS THAT WILL BE
CALLED UPON TO PARTICIPATE IN THE EVALUATION
TO INFORM ALL RELATED OFFICIALS OF THE NATURE,
RATIONALE AND IMPORTANCE OF THE EXERCISE.
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THE MUTUAL EVALUATION PROCESS
THE NATIONAL ANTI MONEY
LAUNDERING COMMITTEE.
 BUILDING RELATIONSHIPS
BETWEEN ALL NATIONAL
STAKEHOLDERS
 SERVING THE BEST INTERSTS OF
THE NATION

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THE NATIONAL ANTI MONEY LAUNDERING
COMMITTEE

THE AML/CFT METHODOLOGY, THE TOOL BY WHICH
AML/CFT REGIMES ARE ASSESSDED FOR COMPLIANCE.

COMPLEX AND INTRICATE

THE EVOLVING OPINIONS ON THE ESSENTIAL CRITERIA
AGAINST WHICH THE RECOMMENDATIONS ARE RATED.

THE EXTENT AND NATURE OF THE SUPPORTING
ANALYTICAL DATA TO BE INCLUDED IN THE REPORT
10
THE NATIONAL ANTI MONEY LAUNDERING
COMMITTEE

THE THRUST OF THE CURRENT ROUND OF ASSESSMENTS
GLOBALLY IS EFFECTIVE IMPLEMENTATION.

UNCERTAINTY AS TO HOW THIS IMPORTANT FACTOR IS TO
BE ADDRESSED.

CURRENT WORK OF THE FATF WORKING GROUP TO DEVISE
GUIDELINES FOR ASSESSORS IN THIS AREA.
11
THE NATIONAL ANTI MONEY LAUNDERING
COMMITTEE

CRTICAL TO THE EFEECTIVENESS CONSIDERATIONS IS
THE COLLATING OF STATISTICS ON THE OPERATION OF
THE AML/CFT SYSTEM.

COUNTRIES SHOULD DEVISE A NATIONAL PLAN TO
COLLATE STATISTICS BY ALL MEMBERS OF THE DOMESTIC
AML/CFT COMMUNITY.

EMBARKING ON SUCH AN EXERCISE IS A MAJOR
UNDERTAKING AND RESOURCE INTENSIVE.

FEW COUNTRIES HAVE MOVED IN THIS DIRECTION.
12
THE NATIONAL ANTI MONEY LAUNDERING
COMMITTEE

ASSESSING EFFECTIVENESS AND ASSIGNING RATINGS TO
THE RECOMMENDATIONS IS PROVING TO BE QUITE A
CHALLENGE FOR EXAMINERS GLOBALLY.

THIS IS REFLECTED IN PROTRACTED AND INTENSE
PLENARY DISCUSSIONS ON THE REPORTS.

SOME AREAS OF CONTENTION
POLITICALLY EXPOSED PERSONS
THIRD PARTY INTRODUCERS
CRIMINALISING ALL THE AREAS COVERED BY THE FATF
LIST OF PREDICATE OFFENCES



13
THE NATIONAL ANTI MONEY LAUNDERING
COMMITTEE

THE ONUS IS ON THE COUNTRY TO BE EXAMINED TO
DEMOSTRATE THE NATURE AND EFFECTIVENESS OF ITS
AML/CFT INFRASTRUCTURE.


A MAJOR DIFFICULTY HERE IS COMPLETING THE MUTUAL
EVALUATION QUESTIONNAIRE

RECENT CFATF TRAINING SEMINAR FOR COUNTRIES THAT
ARE BEING ASSESSED 2007/EARLY 2008 .

THIS INITIATIVE WILL HAVE TO BE INSTITUTIONALISED
14
THE NATIONAL ANTI MONEY LAUNDERING
COMMITTEE

COUNTRIES ARE NOW ALLOWED TO IMPLEMENT THE FATF
RECOMMENDATIONS DEPENDING ON THE LEVEL OF RISKS
IN ANY GIVEN AREA.

COUNTRIES MUST BE ABLE TO OUTLINE HOW THIS
DETERMINATION WAS MADE.

VERY FEW COUNTRIES HAVE EMBARKED UPON THE
ASSESSMENT OF AML/CFT RISKS AT A NATIONAL LEVEL.

FSRBS SHOULD ARRANGE TECHNICAL ASSISTANCE AND
TRAINING FOR THOSE COUNTRIES WHICH NEED
ASSISTANCE
15
THE NATIONAL ANTI MONEY LAUNDERING
COMMITTEE

PLACING TERRORIST FINANCING LEGISLATION
ON THE STATUTE BOOKS.

THE INTRODUCTION OF SUPERVISORY REGIMES
FOR DESIGNATED NON FINANCIAL BUSINESSES
AND PROFESSIONS.

THE ALLOCATION OF ADEQUATE RESOURCES TO
ALL AML/CFT STAKEHOLDERS AND PROVIDING
TRAINING ON AN ONGOING BASIS
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THE NATIONAL ANTI MONEY LAUNDERING
COMMITTEE

EDUCATION FOR OFFICIALS AT THE HIGHEST
ECHELONS OF THE POLITICAL DIRECTORATE ON
THE EXTENT AND SERIOUSNESS OF THE
OBLIGATIONS UNDERTAKEN WITH THE
INTERNATIONAL COMMUNITY AND THE
IMPLICATIONS FOR NON COMPLIANCE.

IMPACT OF THE PUBLICATION OF THE MUTUAL
EVALUATION REPORTS

RESPONSE OF THE INTERNATIONAL MARKETS
AND INVESTMENT COMMUNITY
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THE NATIONAL ANTI MONEY LAUNDERING
COMMITTEE






MINISTRY OF JUSTICE
ATTORNEY GENERAL –CENTARL AUTHORITY
MINISTRY OF NATIONAL SECURITY-FINANCIAL INTELLIGENCE
UNIT POLICE-CUSTOMS-IMMIGRATION- COAST GUARD-ARMY
MINISTRY OF FINANCE-CENTRAL BANK-SECURITIES
EXCHANGE COMMISSION-SUPERVISOR OF INSURANCESUPERVISORS FOR CREDIT UNIONS- REGULATORS FOR TRUST
AND COMPANY SERVICE PROVIDERS
SELF REGULATORY ORGANISATIONS-ATTORNEYSACCOUNTANTS- REAL ESTATE AGENTS,
REGULATORY BODIES –DEALERS IN PRECIOUS
METALS/PRECIOUS STONES, CASINOS - MONEY SERVICE
BUSINESSES -BUREAUX DE CHANGE
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THE NATIONAL ANTI MONEY LAUNDERING
COMMITTEE

FOCUS OF ALL THESE ENTITIES

ENGENDERING A STRONG CULTURE OF
COMPLIANCE IN THE JURISDICTION

REPUTATION
REPUTATION
REPUTATION


19
THE MUTUAL EVALUATION PROCESS

THE MUTUAL EVALUATION EXERCISE IS NOT A TRIAL, IT IS A
CONSTRUCTIVE CONSULTATIVE DIALOGUE BETWEEN
PROFESSIONALS, BE THEY BANK
SUPERVISORS/REGULATORS, LEGAL OFFICERS OR MEMBERS
OF THE DEFENCE FORCE, POLICE AND CUSTOMS
DEPARTMENTS, REPRESENTATIVES OF THE PRIVATE SECTOR

THE AIM IS TO ASSIST THE MEMBER STATE TO IMPROVE ITS
ANTI MONEY LAUNDERING AND COMBATING THE
FINANCING OF TERRORISM FRAMEWORK SO THAT THE
LEGISLATION, REGULATIONS, ADMINISTRATIVE
PROCEDURES, PROGRAMMES AND POLICIES ARE IN
COMPLIANCE WITH THE 40 FATF AND 9 SPECIAL
RECOMMENDATIONS.
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THE DOCUMENTS FOR THE MUTUAL
EVALUATION MISSION









THE MUTUAL EVALUATION QUESTIONAIRE
THE AML/CFT METHODOLOGY
THE CFATF MUTUAL EVALUATION PROCEDURES
THE 40 FATF RECOMMENDATIONS ON MONEY
LAUNDERING
THE NINE SPECIAL RECOMMENDATIONS TO
COMBAT THE FINANCING OF TERRORISM
THE VIENNA CONVENTION-DRUG TRAFFICKING
THE PALERMO CONVENTION-ORGANISED CRIME
UN CONVENTION FOR THE SUPPRESSION OF THE
FINANCING OF TERRORISM
UN SECURITY COUNCIL RESOLOUTIONS 1267 AND
1373
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THE MUTUAL EVALUATION PROCESS
1.
2.
3.
4.
5.
RECEIVE ME RESPONSE 2 MONTHS
BEFORE ON-SITE
SECRETARIAT TO PREPARE PARTIAL
DRAFT IN ADVANCE OF ON-SITE
ON-SITE: 8 DAYS OF MEETINGS
LAST 2 DAYS – TEAM LOOKS AT EACH
RECOMMENDATION TO AGREE RATINGS
1ST DRAFT MER – 8-10 WEEKS AFTER
ONSITE
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THE MUTUAL EVALUATION PROCESS
6.
7.
8.
9.
10.
11.
12.
INITIAL FULL REVIEW BY COUNTRY AND
SUBMISSION OF COMMENTS
POSSIBLE 2ND FACE TO FACE MEETING
DRAFT MER TO PLENARY 1 MONTH
BEFORE MEETING
IFI PRO-FORMA REVIEW PRIOR TO
PLENARY
ERG PROCESS AT BEGINNING OF
PLENARY
PLENARY DISCUSSION
PUBLICATION OF REPORT
23
THE MUTUAL EVALUATION REPORT
PUBLICATION ON THE CFATF WEBSITE




SCRUTINY FROM REGIONAL AND
INTERNATIONAL PARTNERS
ACCOLADES AND EMULATION
CENSURE AND SANCTIONS
INDEED THE CFATF EXPERIENCE HAS BEEN
THAT MEMBERS, BY VIRTUE OF THE MUTUAL
EVALUATION REPORT HAVE BEEN ABLE TO
IMPLEMENT IMPROVEMENTS IN THEIR
LEGISLATIVE FRAMEWORK THROUGH THE
RECOMMENDATIONS OF THE EXAMINERS
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THE MUTUAL EVALUATION REPORT

MONITORING ROLE OF THE NATIONAL ANTI
MONEY LAUNDERING COMMITTEE PIVOTAL
-

RECTIFICATION OF IDENTIFIED DEFICIENCIESRECOMMENDATIONS OF EXAMINERS
DELIVERY OF TECHNICAL ASSISTANCE AND
TRAINING
BUILDING DOMESTIC CAPACITY
WORKING WITH INTERNATIONAL DONOR
COMMUNITY



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THE MUTUAL EVALUATION REPORT






CFATF SECRETARIAT –REGIONAL CO-ORDINATOR
FOR DONOR ASSISTANCE
GROUP OF COOPERATING AND SUPPORTING
NATIONS-CANADA,FRANCE, NETHERLANDS,MEXICO,
SPAIN, UNITED KINGDON, UNITED STATES OF
AMERICA
INTERNATIONAL MONETARY FUND
WORLD BANK
FATF SECRETARIAT
UNITED NATIONS
26
FATF NON COPERATIVE COUNTRIES
AND TERRITORIES EXERCISE 1999-2005


DESIGNED TO COMBAT NATIONAL
AND INTERNATIONAL THREATS
MAINTAIN THE SAFETY AND SECURITY
OF THE INTERNATIONAL FINANCIAL
SYSTEM
27
STATEMENTS BY THE
INTERNATIONAL COMMUNITY






UNITED NATIONS RESOLUTIONS
COMMONWEALTH -HEADS OF
GOVERNMENTS
INTERNATIONAL MONETARY FUND
G7 FINANCE MINISTERS
ORGANISATION FOR ECONOMIC
COOPERATION AND DEVELOPMENT
FINANCIAL STABILTIY FORUM
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SPIRIT OF THE STATEMENTS




TO COMBAT TRANSNATIONAL ORGANISED
CRIME
TO IMPROVE REGULATION OF OFFSHORE
FINANCIAL CENTRES
MEASURES NECESSARY TO DETER MONEY
LAUNDERING
MAINTAIN THE CREDIBILITY AND
INTEGRITY OF THE GLOBAL FINANCIAL
SYSTEM
29
TWENTY FIVE POINT
CRITERIA




LOOPHOLES IN FINANCIAL
REGULATIONS 1-11
OBSTACLES RAISED BY OTHER
REGULATORY REQUIREMENTS 12-14
OBSTACLES TO INTERNATIONAL
COOPERATION 15-22
INADEQUATE RESOURCES FOR
PREVENTING AND DETECTING MONEY
LAUNDERING ACTIVITIES 23-25
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SOURCES OF INFORMATION FOR
EXAMINATION OF POTENTIAL TARGET
COUNTRIES



OPEN SOURCE DATA
RESTRICTED-INFORMATION-MUTUAL
EVALUATION REPORTS
DIRECT EXPERIENCES IDENTIFYING
PROBLEMS OF COOPERATION
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GUIDING FEATURES TO EXAMINE
JURISDICTIONS

LOOPHOLES IN LAWS

SHORTCOMINGS IN THE ACTIVITIES OF
FINANCIAL CENTRES

PRACTICAL OR OPERATIONAL
IMPEDIMENTS TO COOPERATION
32
CFATF COUNTRIES REVIEWED AS A
PRIORITY











ANTIGUA AND BARBUDA
THE BAHAMAS
BELIZE
BERMUDA
BRITISH VIRGIN ISLANDS
CAYMAN ISLANDS
DOMINICA
PANAMA
ST. LUCIA
ST. KITTS AND NEVIS
ST. VINCENT AND THE GRENADINES
33
CFATF COUNTRIES THAT WERE
LISTED








THE BAHAMAS
CAYMAN ISLANDS
DOMINICA
PANAMA
ST. KITTS AND NEVIS
ST. VINCENT AND THE GRENADINES
GRENADA
GUATEMALA
34
SOME FACTORS THAT LED TO LISTING




INADEQUATE CONTROL AND SUPERVISION
OF THE OFFSHORE SECTOR
NEGATIVE RESPONSES TO ENQUIRIES ON
IDENTIFICATION OF SHAREHOLDERS
OBSTACLES TO IDENTIFICATION OF
BENEFICIAL OWNERS OF COMPANIES
REFUSAL TO PROVIDE RECORDS IN PURE
CRIMINAL TAX MATTERS
35
LEGISLATIVE SHORTCOMINGS

FAILURE TO CRIMINALIZE MONEY
LAUNDERING BEYOND DRUGS

NO MANDATORY SYSTEM FOR
REPORTING SUSPICIOUS
TRANSACTIONS

EXCESSIVE SECRECY PROVISIONS
36
EFFECTS OF LISTINGS

ADVERSE ECONOMIC IMPLICATIONS

LOSS OF BUSINESSES, JOBS AND INVESTMENTS

FEELINGS OF HELPLESSNESS AND VULNERABILITY

DIVERSION OF SIGNIFICANT HUMAN AND
FINANCIAL RESOURCES TO RESPOND TO THE
INITIATIVES
37
SUCCESSOR TO THE FATF NCCT
EXRCISE

THE FATF REMAINS VIGILANT ON INTERNATIONAL
COOPERATION ISSUES AND WILL NOT HESITATE TO
ACT IF A COUNTRY POSES A SERIOUS THREAT TO
THE INTERNATIONAL EFFORT TO COMBAT MONEY
LAUNDERING AND TERRORIST FINANCING.

INTERNATIONAL COOPERATION REVIEW GROUP

REVIEW OF COUNTRIES THAT POSE THREATS TO
EXPEDITIOUS AND EFFECTIVE COOPERATION
BETWEEN STATES ON AML/CFT ISSUES.
38
CRITERIA FOR PRORITISING
COUNTRIES OR REVIEW




SEVERE DEFICIENCIES IN IMPLEMENTING
THE AML/CFT STANDARDS(EG LACK OF
CRIMINALISATION OF ML/FT, LACK OF
PREVENTIVE MEASURES,LACK OF FIU
CONCRETE CASES OF NOT ADEQUATELY
RESPONDING TO REQUESTS FOR
INTERNATIONAL COOPERATION
SIZE OF FINANCIAL SECTOR AND
INTEGRATION INTO WORLD MARKETS
ACTUAL ML/FT THREATS.
39
WHERE ARE WE AT NOW
THE HEADS OF CFATF FINANCIAL INTELLIGENCE UNITS
FORUM
ENHANCING INTERNATIONAL COOPERATION ON JUDICIAL,
REGULATORY AND LAW ENFORCEMENT ISSUES IN THE FIGHT
AGAINST TRANS-NATIONAL ORGANISED CRIME AND THE
FINANCING OF TERRORISM.
FACILITATING THE SIGNING OF MEMORANDA OF
UNDERSTANDING BETWEEN FIUS IN THE REGION AND
ALSO WITH FIUS IN OTHER PARTS OF THE WORLD
FACILITATING CFATF MEMBERS TO BECOME MEMBERS OF
EGMONT
40
WHERE ARE WE NOW

ENCOURAGE MEMBERS IN THE REGIONS

TO FOLLOW EXISTING CENTRES OF EXCELLENCE AND
BEST PRACTICES

WITHIN THE CFATF REGION FACILITIES EXIST FOR
ELECTRONIC OR PAPERLESS TRIALS, COMPUTERSISED CASE
MANAGEMENT AND PLANS FOR THE E-FILING OF
DOCUMENTS TO INITIATE NEW CASES OR ADVANCE
EXISTING ONES.
OFFICIALS IN THIS JURISDICTION ARE WILLING TO
ACCOMMODATE SHORT VISITS OR PERIODS OF
SECONDMENT BY OFFICALS FROM THE WIDER CFATF
MEMBERSHIP. SUCH EXAMPLES OF BEST PRACTICE MUST
BE EMULATED.

41
WHERE ARE WE NOW

TO DEVELOP AND SUSTAIN A STRONG, NATIONWIDE CULTURE OF
COMPLIANCE WITH INTERNATIONAL BENCHMARKS AGAINST
TRANS NATIONAL ORGANISED CRIME IN ALL ITS FORMS BECAUSE
OF THE ATTENDANT REPUTATIONAL RISKS WHERE A
JURISDICTION IS SEEN OR PERCEIVED AS HAVING DEFENSIVE
MECHANISMS WHICH ARE LESS THAN SATISFACTORY.

PROVIDE ONGOING TRAINING FOR ALL CRIMINAL JUSTICE
OFFICIALS IN AREAS SUCH AS BASIC AND ADVANCED FINANCIAL
CRIME INVESTIGATIONS, CORRUPTION, AND CONSPIRACY TO
DERAUD, ASSET SEIZURE, FREEZING AND CONFISCATION.

THIS COULD ENTAIL DRAWING ON THE BROADRER EXPERIENCES
AND EXPERTISE OF THE AGENCIES LIKE THE ASSET FORFEITURE
AND RECOVERY UNIT IN DEVELOPED COUNTRIES FOR TRAINING
IN MONEY LAUNDERING/ ASSET FORFEITURES AND
CONFISCATION PROSECUTIONS AND THE OPERATIONS OF A
CIVIL FORFEITURE SCHEME
42
WHERE ARE WE NOW

TRUMPETING REGIONAL ACCOMPLISHEMNTS TO THE INTERNATIONAL
COMMUNITY

IN SOME INSTANCES IN THE CARIBEAN BASIN REGION SUCH A
POSITION HAS LED TO JURISDICTIONS BEING AHEAD OF
INTERNATIONAL STANDARDS ON CERTAIN MATTERS,


THE COVERAGE OF ‘GATEKEEPERS’ SUCH AS LAWYERS AND REAL
ESTATE AGENTS

THE ABOLISHING OR IMMOBILIZATION OF BEARER SHARES;

THE UNDERTAKING OF RETROSPECTIVE DUE DILIGENCE ON ALL
EXISTING CLIENTS IN KEEPING WITH MODERN KNOW YOUR
CUSTOMER PRINCIPLES;
43
WHERE ARE WE NOW

ENTRENCHED REGIONAL PARTICIPATION IN
THE FATF WORKING GROUPS

REGIONAL VOICE/REGIONAL INTERESTS COULD
BE INSTRUMENTAL IN FRAMING THE AML/CFT
BENCHMARKS

MORE CFATF MEMBERS SHOULD GRASP THE
OPPORTUNITY-FOLLOW THE LEAD OF THE
BRITSH VIRGIN ISLANDS/CAYMAN ISLANDS/THE
BAHAMAS.
44
FUTURE FOCUS FOR CFATF MEMBERS

STRIVING FOR FULL COMPLIANCE WITH THE INTERNATIONAL
BENCHMARKS

TIMELY ADHERENCE WITH THE CFATF MUTUAL EVALUATION
PROCEDURES

ACTIVE PARTICIPATION IN THE PLENARY DISCUSSIONS OF THE
MUTUAL EVALUATION REPORTS

PARTICIPATION AS EXAMINERS IN CFATF/FATF/FSRBS/IMF/WB
MUTUAL EVALUATION MISSIONS

ACTIVE PARTICIPATION IN THE CFATF WORKING GROUPS ON
LEGAL, FINANCIAL AND LAW ENFORCEMENT
45
FUTURE FOCUS FOR CFTAF MEMBERS

ADVERSERIAL STANCE OF THE PAST IS TO BE
REPLACED WITH FULL ENGAGEMENT IN THE
GLOBAL AML/CFT DIALOGUE WITH ALL
INTERNATIONAL PARTNERS

PROVIDING FEEDBACK TO THE SECRETARIAT ON
FATF PAPERS AND INITIATIVES

PARTICIPATING WHERE APPLICABLE IN FATF
WORKING GROUP MEETINGS AS CFATF
REPRESENTATIVES
46
THE WAY AHEAD

IN RECENT YEARS AS THE RISKS OF TRANS NATIONAL
CRIMINALS ORGANISATIONS HAVE INCREASED, THE
INTERNATIONAL STANDARDS TO COMBAT THEM HAVE
EXPANDED IN TANDEM, WITH SIGNIFICANT COST
IMPLICATIONS FOR THE GLOBAL COMMUNITY.


THIS IS OCCURING IN A CLIMATE WHERE, THERE HAS
BEEN IN REAL TERMS, REDUCTIONS IN AID AND
INVESTMMENT AND UNFAVOURABLE POLICY DECISIONS
BY INTERNATIONAL ORGANISATIONS ON TRADE ISSUES.

GIVEN THESE CIRCUMSTANCES THE CHALLENGES POSED
FOR MACRO ECONOMIC POLICYMAKERS, PARTICULARLY IN
SMALL COUNTRIES ARE INDEED FORMIDABLE AS THE
NEED TO ADHERE TO EVER CHANGING INTERNATIONAL
STANDARDS DEMAND THE RE-ALLOCATION OF SCARCE
RESOURCES.
47
THE WAY AHEAD

REGIONAL BODIES SHOULD

ADVOCATE FOR A GLOBAL ASSESSMENT OF ALL THE
IMPLICATIONS OF FULL ADHERENCE TO THE
INTERNATIONAL AML/CFT STANDARDS

ADVOCATE FOR A DIALOGUE AT THE HIGHEST POLITICAL
LEVELS INTERNATIONALLY AS TO THE TRUE COSTS OF
PROTECTING THE INTERNATIONAL FINANCIAL SYSTEM
AGAINST MONEY LAUNDERS.

ADVOCATE FOR A MECHANISM SO THAT THESE COSTS
COULD BE MORE EQUITABLY SHARED BY ALL STATES.
48
THE WAY AHEAD

THE RESULT

THE ENHANCEMENT OF GLOBAL
CAPACITY, PARTICULARLY OF COUNTRIES
IN THE REGIONS, TO BUILD DOMESTIC
INFRATSTRUCTURE THAT WOULD
EFFECTIVELY AND SUCCESSFULLY
PURSUE TRANS- NATIONAL CRIMINAL
ORGANISATIONS AND THOSE WHO
FINANCE TERRRORISM
49
FUTURE FOCUS FOR CFTAF MEMBERS




STRENGTHENING REGIONAL AML/CFT CAPACITY
PUBLIC AND PRIVATE SECTOR DIALOGUE AND
PARTNERSHIP
CONTINUOUS TRAINING INITIATIVES
SPREADING THE MESSAGE THATALL
THIS WORK IS TO BE LOOKED AT IN
TERMS OF PROTECTING OUR
NATIONAL AND REGIONAL
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THE END

THANK YOU VERY MUCH INDEED
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