Transcript ND Presentation

AML Seminar to Accountants - JFIU
4 March 2010
Stewart McGlynn
Chief Inspector of Police
Joint Financial Intelligence Unit
JOINT FINANCIAL INTELLIGENCE UNIT
STR Filing

Suggested format & content
detailed in JFIU website
 Email
 Fax
 Post
 Verbal (urgency - follow-up by
hardcopy)
JOINT FINANCIAL INTELLIGENCE UNIT
Concerns

Urgency

Confidentiality

Tipping Off

Crime Report Vs STR
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Feedback


Acknowledgement of Receipt
 File Ref.
 Contact Person Details
Consent / No Consent Letter

Arrest / Prosecutions / Convictions

STR Quarterly Analysis Report
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Case Example 1
US$10M pledge
US$9.7M loan
Mr. X, Chairman of
Board of Directors
for ABC Company
Sole Owner of XYZ
company is Mr. X
XYZ company
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Learning Points
Effective CDD / KYC
Good quality STR, allowing JFIU
to perform its function
Protection
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Case Example 2 – Good Auditing Practice
Winding-up
Company X
Audit
Fraud and
False Accounting
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Learning Points
Reported knowledge of Crime
Proceeds – Fraud
Crime report could have been
made but STR acceptable in this
case
Urgency? Unsure? Contact JFIU
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Case Example 3 – Good KYC / CDD
Frequent substantial
withdrawals
from Bank account of
Company X
in Hong Kong
KYC /
CDD
By Accountant
for Company X
Discovery
Director of
Company X
wanted in Japan
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Learning Points
Common sense, proportionate
approach to KYC and CDD
If it looks like a duck……….
No risk of prosecution
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Think About This
Poor / Negligible CDD / KYC
Absence of risk based approach
Sub Standard STR
JFIU unable to make assessment
What would you Think?
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Country Comparison
STR filed by Accountants
Country
2005
2006
2007
Employment in
Accountancy in
2008
Singapore
0/2,076
(0%)
2/3,290
(0.06%)
2/7,621
(0.03%)
875
UK
14,567/
195,702
(7.44%)
9,896/
213,202
(4.64%)
8,110/
220,484
(3.68%)
N/A
HK
0/13,505
(0%)
0/14,557
(0%)
3/15,457
(0.02%)
3715
JOINT FINANCIAL INTELLIGENCE UNIT
STR filed by Accountants
2005
2006
2007
2008
2009
No. of STR
Received
13,505
14,557
15,457
14,838
16,062
Filed by
Accountant
0
0
3
6
11
Percentage
(%)
0.00%
0.00%
0.02%
0.04%
0.07%
JOINT FINANCIAL INTELLIGENCE UNIT
Some Final Thoughts
JFIU understands the burden that
CDD and KYC entails
Law / International Standards
Increase in quality STRs from the
sector desirable – intelligence is our
business
JFIU is here to help – Contact us
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Contact JFIU
Telephone:2866 3366
Fax :2529 4013
Email:[email protected]
Mail:GPO Box 6555 Hong Kong
[email protected]
Telephone:2860 3547
JOINT FINANCIAL INTELLIGENCE UNIT