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ANNUAL REPORT 2014

ANNUAL REPORT - FIU...2016/03/23  · FiU annUaL RePoRt 2014 5 Letter of transmittal The Honourable Sudarshan Bhadain Minister of Financial Services, Good Governance and Institutional

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Page 1: ANNUAL REPORT - FIU...2016/03/23  · FiU annUaL RePoRt 2014 5 Letter of transmittal The Honourable Sudarshan Bhadain Minister of Financial Services, Good Governance and Institutional

A N N U A L R E P O R T

2 0 1 4

Page 2: ANNUAL REPORT - FIU...2016/03/23  · FiU annUaL RePoRt 2014 5 Letter of transmittal The Honourable Sudarshan Bhadain Minister of Financial Services, Good Governance and Institutional
Page 3: ANNUAL REPORT - FIU...2016/03/23  · FiU annUaL RePoRt 2014 5 Letter of transmittal The Honourable Sudarshan Bhadain Minister of Financial Services, Good Governance and Institutional

Vision statementTo protect the integrity of our financial system and contribute to the safety of our citizens through deterrence of money laundering and terrorist financing.

mission statementTo be the leader in financial intelligence works in the region and be recognised worldwide as an FIU that adheres to international standards.

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FIU ANNUAL REPORT 2014 3

table of ContentsList of Acronyms 3Letter of Transmittal 5Chairman’s Message 6Director’s Message 72014 Highlights 8FIU Mauritius: Operations in 2014 9Regional Partnerships and Development in Africa 18International Partnerships and Developments 19Corporate Governance Report 23Unaudited Financial Statements 37

APPENDICES

I Board MembersII Organisation ChartIII Staff ListIV Overseas Missions, Conferences, Seminars, Training Courses of FIU Officers

in 2014V Updated List of MoUsVI Egmont MembershipVII Important Websites

LIST OF ACRONyMS

AML/CFT Anti-Money Laundering and Combating Financing of TerrorismAPG Asian Pacific GroupEG Egmont GroupESAAMLG Eastern and Southern Africa Anti-Money Laundering GroupFATF Financial Action Task ForceFIAMLA Financial Intelligence and Anti-Money Laundering ActFSC Financial Services CommissionFSRB FATF-Style Regional BodyFIU Financial Intelligence UnitGABAC Groupe d’Action Contre le Blanchiment d‘Argent en Afrique CentraleGIABA Groupe Intergouvernemental d’Action contre le Blanchiment d’Argent en

Afrique de l’OuestICAC Independent Commission Against CorruptionIMF International Monetary FundMENAFATF Middle East and North Africa Financial Action Task ForceML/TF Money laundering/ Terrorism FinancingML Money LaunderingMOFED Ministry of Finance and Economic DevelopmentMRA Mauritius Revenue AuthorityOECD Organisation for Economic Cooperation and DevelopmentRBA Risk Based ApproachROC Registrar of CompaniesSTRs Suspicious Transaction ReportsTF Terrorism FinancingUNODC United Nations Office on Drugs and Crimes

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FIU ANNUAL REPORT 2014 5

Letter of transmittal

The Honourable Sudarshan Bhadain Minister of Financial Services,Good Governance and Institutional Reforms7th floor, SICOM TowerEbène

Dear Sir,

Pursuant to Part VIA – Accounts, Audit and Annual Report of the Financial Intelligence and Anti-Money Laundering Act, 2002, I am pleased to present to you the Annual Report of the Financial Intelligence Unit for the year ended 31st December, 2014. This report consists of:

(a) a report on the activities of the FIU, its outcomes and outputs together with information on its key performance indicators, during the financial year;

(b) a Corporate Governance Report in accordance with the National Code of Corporate Governance; and

(c) the Audited Financial Statements in respect of the financial year, prepared in compliance with the International Public Sector Accounting Standards (IPSAS) issued by the International Federation of Accountants (IFAC).

yours sincerely,

Satyawan Kailash TrilochunChairmanFinancial Intelligence Unit, Mauritius27th November 2015

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FIU ANNUAL REPORT 20146

Chairman’s messageThe expectations on the FIU continue to increase as the new world becomes more complex and challenging to combat money laundering (ML), associated predicate offences, and terrorist financing (TF). Furthermore, the international AML/CFT policy-making body, the Financial Action Task Force (FATF), has raised the bar and has challenged jurisdictions to be more “effective.” One important aspect of an effective regime is the ability to collect a wide variety of financial intelligence and other relevant information, which can be used by competent authorities to investigate ML/TF offences. However, despite these challenges the FIU remained determined, as ever, to fulfill its obligations under the law.

Compared to the year 2013, the FIU has received a reduced number of case originators in 2014, that is 305 as compared to 578 in 2013. While this decrease may be linked to normal activity in 2014, as compared to 2013 when the Ponzi scheme came out to light, still it is felt that there is a poor reporting culture which may be due to lack of an effective AML/CFT programme among all reporting institutions.

With the support of the Government of Mauritius, the FIU has now deployed the UN goAML software. As at date, commercial banks duly licensed by the Bank of Mauritius, submit STRs exclusively via the goAML web platform. Other stakeholders are also expected to be connected to this system, mainly for exchange of information.

We, at the FIU, are always looking to the challenges we may confront in the future - particularly changes in emerging technologies and methods for conducting transactions. New payment systems can present opportunities for those who are seeking to avoid detection by converting the value of criminal assets in new ways. The attraction of criminals to these new technologies and services is a significant challenge. I strongly believe that, together, all AML/CFT partners, can improve detection and deterrence in the current financial system to overcome the challenges that we may confront in the future. In this vein, I believe that FIU’s achievements were realized through the joint efforts of all partners involved in the combat against ML/TF in 2014.

Finally, I wish to express my sincere gratitude to all our AML/CFT partners, both locally and abroad, for their continued support during the year and the FIU staff members for their efforts as well as their commitment in 2014.

L.C.L.K.S. Sam SoonChairman

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FIU ANNUAL REPORT 2014 7

As the newly appointed Director of the Financial Intelligence Unit since 18 February, 2015, I am pleased to present the report of the FIU’s activities for the year 2014. This Annual Report highlights the performance of the FIU in respect of its core and non-core functions in 2014.

As highlighted in the report the FIU has recruited five new Analysts (Operations) in the first quarter of 2014, one Financial Intelligence Analyst and a Head of Compliance in the second quarter of 2014 and a Legal Manager during the end of the year and the post of Assistant Director, which was vacant since 2008, has also been successfully filled.

The FIU also has a Compliance Department which became operational in late September 2014 following the recruitment of a Head of Compliance and has issued guidelines in the same month to assist Designated Non-financial Businesses and Professions (‘DNFBPs’) in complying with their obligations in relation to the prevention, detection and reporting of money laundering and financing of terrorism and pursuant to section 10(2) (ba) of the Financial Intelligence and Anti-Money Laundering Act (FIAMLA) 2002, as amended. In addition to its core intelligence receipt, analysis and dissemination functions, the FIU is now tasked to fulfil the non-core function of AML/CFT supervision for the jewelry and real estate sectors, which have long been susceptible of being targeted by money launderers.

The FIU has also implemented the goAML software developed by the United Nations Office on Drugs and Crime and optimized its use of sophisticated analytical capabilities to conduct both operational and strategic analysis. We are now receiving STRs from banking institutions directly through this software, saving all stakeholders much time and effort. The FIU is currently working on extending this online reporting capability to all non-banking financial institutions.

The local AML/CFT framework will undergo major changes in the near future. The FIU has now been brought under the aegis of a newly set up Ministry for Financial Services, Good Governance and Institutional Reforms. The Government has also announced the setting up of a new Financial Crime Commission (‘FCC’), which will act as an apex body to oversee the operations of the FIU, the ICAC, the Asset Recovery Unit and a new Anti-Fraud Unit.

The FCC will undoubtedly make our institutional framework more effective and efficient as it will bring greater cooperation and coordination between all stakeholders concerned with the fight against money laundering and financial crime by removing current barriers such as administrative delays in the communication of relevant information between institutions or incongruent confidentiality provisions preventing the effective sharing of data. In this context, the Government has decided that, pending the setting up of the FCC, the Asset Recovery Unit will be brought under the responsibility of the FIU as a temporary measure.

I take this opportunity to thank all domestic AML/CFT stakeholders and foreign partners for their support. Last but certainly not least, I would like to thank the Board of the FIU and all members of staff for their warm welcome and assistance.

Guillaume OllivryDirector

Director’s message

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FIU ANNUAL REPORT 20148

2014 HighlightsKEy FIGURES

2014 2013 2012

Number of Case Originators 305 578 378

- Number of STRs 173 354 226

Banks 128 313 193

Management Companies (Offshore) 37 25 19

Cash Dealers 6 15 11

Others 2 1 3

- Number of Non-STR Disclosures 132 224 152

Supervisory Bodies 10 22 2

Investigatory Bodies 63 79 80

Foreign FIUs (Spontaneous Disclosures) 8 66 41

Others 51 57 29

Total Number of Dissemination Reports 376 490 205

- Number of Dissemination Reports in 2014

Investigatory Bodies 115 209 95

Supervisory Bodies 43 166 12

Others 44 66 37

- Number of Dissemination Reports relating to cases prior to 2014 174 49 61

Information Exchange

- Number of Requests received from Overseas FIUs 44 66 41

- Number of Requests sent to Overseas FIUs 189 199 79

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FIU ANNUAL REPORT 2014 9

FiU mauritius: operations in 2014

implementation of goamL

As per Recommendation 29 of the Financial Action Task Force (FATF), which is the international standard-setter on AML/CFT, all countries ‘should establish a financial intelligence unit (FIU) that serves as a national centre for the receipt and analysis of: (a) suspicious transaction reports; and (b) other information relevant to money laundering, associated predicate offences and terrorist financing, and for the dissemination of the results of that analysis’. The FIU Mauritius is established under Section 9 of the Financial Intelligence and Anti-Money Laundering Act 2002. The functions of the FIU is set out under section 10 of the FIAMLA 2002 and includes; receipt of information concerning suspected proceeds of crime and alleged money laundering offence, i.e., Suspicious Transactions Reports (STRs) and non-STR disclosures; collection of information and

interpretation of information disclosed, i.e., carrying out financial investigative analysis and, where appropriate, making disseminations to investigatory authorities responsible for investigation and prosecution, where deemed appropriate. The products of the FIU are intelligence packages that constitute leads for use by investigators and regulators.

The FIU Mauritius has revamped its operational approach in 2014 with the recruitment of five new Analysts (Operations) in the first quarter of 2014, one Financial Intelligence Analyst and a Head of Compliance in the second quarter of 2014 and a Legal Manager during the end of the year. The post of Assistant Director, which was vacant since 2008, has also been successfully filled.

The FIU Mauritius has fully deployed the United Nations Office on Drugs and Crime (UNODC) goAML application on 21st January 2014. Being part of UNODC’s strategic response to crimes, particularly serious and organised crimes, the software is an intelligence analysis system to manage processes and analyze financial transactions. It is designed to fully automate data collection and dissemination.

As of that date, STRs are exclusively submitted via the goAML web platform to the FIU Mauritius by banks only. Furthermore, in view of making full use of this software, the Message Board, an important component of the goAML software, is used by the FIU Mauritius to securely exchange information with its end users, mainly commercial banks duly licensed by the Bank of Mauritius. More than 140 requests for information, under section 13 (2) and (3) of the Financial Intelligence and Anti-Money Laundering Act (FIAMLA) 2002, have been made via the Message Board in 2014 to the banks, which have been duly

registered on goAML. Replies are being provided by the banks via the Message Board within the time frame specified under section 13(4) of the FIAMLA.

The advantage of an internal communication channel like the goAML Message Board is obvious as it allows communication between parties from within the goAML system. Reporting entities and stakeholders are notified immediately and automatically if their reports submitted to the FIU are accepted or rejected, in line with R7 of the Financial Intelligence and Anti Money Laundering Regulations 2003.

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FIU ANNUAL REPORT 201410

The Customs and Excise Department of the Mauritius Revenue Authority (MRA) is now able to submit Cross Border Declarations (under section 131A of the Customs Act), via the goAML Web Portal. In the year 2015, the FIU will trigger action for the use of the goAML software for communicating with other AML/CFT stakeholders such as ICAC, Police and Enforcement Authority (Asset Recovery Unit), Bank of Mauritius and the Financial Services Commission. The ultimate objective of the FIU Mauritius is to connect all reporting institutions and AML/CFT stakeholders to the goAML application using the goAML Web Portal.

Key Performance indicators

statistical information on FiU mauritius Core Functions

The FIU Mauritius focuses on result-based management, aiming at efficiency and effectiveness to carry out its statutory functions and other responsibilities. A broad-based and comprehensive database is therefore

maintained to gauge progress, effectiveness and assessment of FIU’s efforts to contribute to Government’s AML/CFT strategy. The Key Performance Indicator (KPI) of the FIU for 2014 reached a figure of 73%.

The main function of the FIU Mauritius is to receive, collect and request information, process, analyse the information gathered and disseminate financial intelligence on cases suspected of money laundering and financing of activities related to terrorism. The input of the FIU is made up of STRs received from reporting institutions under Section 14 of the FIAMLA and non-STR disclosures i.e. disclosures made by supervisory bodies (Bank of Mauritius, Financial Services Commission) and Regulatory Bodies, investigatory bodies (Police, Independent Commission Against Corruption, Mauritius Revenue Authority, Enforcement Authority), foreign FIUs, ‘other requests’ from Government bodies and anonymous letters.

The total number of case originators, which comprises both STRs and Non-STRs disclosures, has decreased by 47.2 % from 578 in 2013 to 305 in 2014.

Number of STRs

Number of Non-STRDisclosures

CASE ORIGINATORS

CHART I: NUMBER OF CASE ORINIGATORS IN 2014

20140

100

200

300

400

500

600

700

2013 2012 2011

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FIU ANNUAL REPORT 2014 11

During the year 2014, the FIU Mauritius received 173 STRs from reporting entities which have an obligation as per Section 14 of the FIAMLA to ‘as soon as practicable, but not later than 15 working days, make a report to the FIU of any transaction which the bank, financial institution, cash dealer or member of the relevant profession or occupation has reason to believe may be a suspicious transaction’. From the 173 STRs received in 2014, 73.9%

came from ‘Banks’ followed by ‘Management Companies’ (21.4%), ‘Cash Dealers’ (3.5%) and ‘Others’ (1.2%) which included reporting entities from a non-bank financial institution (NBFI) and ‘member of the relevant profession or occupation’. Out of these 173 STRs, 120 were electronically received via the goAML system (which is currently applicable for banks only).

2014 STRs Categorised by Reporting Entities

Banks

Management Companies(Offshore)

Cash Dealers

Others

CHART II : SUSPICIOUS TRANSACTIONS REPORTS RECEIVED IN 2014

1.2%3.5%

21.4%

73.9%

yEARLy COMPARISON

Reporting Entities 2014 2013

Banks 128 313

Management Companies (Offshore) 37 25

Cash Dealers 6 15

Others 2 1

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FIU ANNUAL REPORT 201412

The cases reported by ‘banks’ decreased from 313 in 2013 to 128 in 2014, reflecting an decrease of 59.1%. The higher number of STRs in 2013 may be linked to a higher number of STRs that were filed on transactions related to Ponzi schemes of 2013. The drop in the number of STRs in 2014 may also be linked to the poor reporting culture of banks or lack of proper systems, automated or otherwise, in place to monitor transactions, generate hits that need to be evaluated at the level of the reporting institutions and ultimately reported to the FIU. On the other hand, there has been an increase in the number of cases reported by ‘Management Companies’ from 25 in 2013 to 37 in 2014, meaning a rise of 48%. Despite this increase, it is felt that there is a poor reporting culture from this sector.

The total number of non-STR disclosures in 2014 amounts to 132 compared to 224 in 2013. Asillustrated in Chart III, the requests came mainly from ‘Investigatory Bodies’ followed by ‘Others’ which include anonymous letters, ‘Supervisory Bodies’ and ‘Foreign FIUs’.

2014 Non-STR Disclosures

10

OTHERS 51

FOREIGN FIUS(SPONTANEOUS

DISCLOSURE)8

SUPERVISORyBODIES

10

20 30 40 50 60 70

CHART III: BREAKDOWN OF NON-STR DISCLOSURES RECEIVED IN 2014

yEARLy COMPARISON

INVESTIGATORyBODIES

63

Number of Non-STR Disclosures 2014 2013

Supervisory Bodies 10 22

Investigatory Bodies 63 79

Foreign FIUs 8 66

Others 51 57

***

A yearly comparison shows that there has been a fall in the non-STR disclosures sent by non-reporting entities. Again, the higher number of non-STR disclosures in 2013 may be linked to a higher number of disclosures that were related to Ponzi schemes of 2013.

The total figure is made up of only spontaneous disclosures. The total figure includes spontaneous disclosures as well as requests for information.**

*

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FIU ANNUAL REPORT 2014 13

The FIU Mauritius disseminates the results of its analysis, through intelligence packages, to relevant authorities when there are grounds to suspect money laundering, predicate offences or activities related to financing of terrorism for investigation.

These intelligence packages may take the form of analytical Statutory Reports (SRs), Further Statutory Reports (FSRs) which contain additional information on SRs previously sent, and Intelligence Reports (IRs) based on analysis of STRs, research/analysis and other information sources to which the FIU has access.

For the year 2014, FIU Mauritius made 376 disseminations. A breakdown of dissemination reports connected to inputs received in the year 2014 has been provided in the table below:

Besides the above disseminations, FIU completed its analysis on inputs received prior to 2014. In this context, the FIU made 154 Intelligence Reports and 20 Statutory Disseminations on such inputs to investigatory and supervisory authorities.

In line with Recommendation 29 and 40 of the FATF, an FIU should also be able to engage independently with foreign counterparts on the exchange of information. Within the Egmont framework, international cooperation relates mainly to the exchange of information with foreign counterpart agencies freely, spontaneously and upon request, based on reciprocity according to Egmont Principles

of Exchange of Information. As per Section 20 of the FIAMLA (2002), the FIU Mauritius may exchange information in relation to money laundering and financial intelligence with foreign FIUs or comparable bodies. The number of requests for information received from overseas FIUs was 44 in 2014 while requests for information from FIU Mauritius to its foreign counterparts reached 189 .

Dissemination by FIU Mauritius

SR FSR IR Total

Investigatory Bodies

ICAC 15 1 18 34

Police 4 0 14 18

MRA 0 0 24 24

Enforcement Authority

5 0 34 39

SupervisoryBodies

FSC 0 0 18 18

BOM 0 0 24 24

GRA 0 0 1 1

Others Foreign FIUs 0 0 42 42

Others 0 0 2 2

Total 24 1 177 202

international exchange of information

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FIU ANNUAL REPORT 201414

non-Core functions of FiU mauritiusISSUANCE OF GUIDELINES TO DESIGNATED NON-FINANCIAL BUSINESSES AND PROFESSIONS (DNFBPS)

DNFBPs and the fight against Money Laundering and Financing of Terrorism

AML/CFT Obligations applicable to DNFBPs

AML/CFT Regulatory Bodies for the DNFBPs

The Designated Non-Financial Business Professions (DNFBPs), which cover casinos, real estate agents, dealers in precious metals and stones, lawyers, notaries, other independent legal professions, accountants, and trust and company service providers that pose a money laundering threat but which cannot be classified as financial institutions, are attractive venues for criminals and they are consistently targeted to facilitate money laundering.

In response to the money laundering and financing of terrorism risks facing these professions, FATF introduced in its Revised Recommendations of 2012, AML/CFT measures for DNFBPs. Recommendations 22, 23 and 28 of the FATF provide that DNFBPs should carry out customer due diligence and that DNFBPs should be subject to regulatory and supervisory regime. This will include at a minimum a proper licensing mechanism, and supervision for compliance with AML/CFT requirements; to have in place measures to prevent that the DNFBPs are not being used by criminals for ML activities, among others.

Generally, DNFBPs in Mauritius are catered for in FIAMLA 2002, under the term “member of a relevant profession or occupation”. Following the 2007/08 Mutual Evaluation Report (MER) where Mauritius was rated ‘Partially Compliant’ for AML/CFT preventive measures applicable to DNFBPs. Several amendments have been brought to the Mauritius AML/CFT legislative framework, to reflect the recommendations made by the team of assessors. e.g., (i) the obligation to report STRs, under Section 14, was extended to certain new members of the relevant professions or occupations; (ii) DNFBPs are now required to take all applicable measures to combat money laundering and financing of terrorism; (iii) there has been the establishment of AML/CFT regulatory bodies for the DNFBP sector; and (iv) the penalty for non-compliance with Guidelines issued by the FIU has been introduced.

In line with Recommendation 28 of the FATF and to respond to the ‘Non-Compliant’ rating of 2007/08 MER, any member of a relevant profession or occupation is now subject to regulatory and supervisory measures including the designation of an AML/CFT regulatory body for each sector intended for monitoring and ensuring compliance with applicable AML/CFT measures. In December 2012, the Economic and Financial Measures (Miscellaneous Provisions) Act amended the FIAMLA by including in Schedule 1 (Section 2) Part I, a list of members of the relevant professions or occupations and their associated AML/CFT regulatory body. The FIU Mauritius has been designated as the Regulatory Body for: (i) Dealers under the Jewellery Act, (ii) Agent in Land and/or Building or Estate Agency under the Local Government Act, (iii) Land Promoter and Property Developer under the Local Government Act in December 2012. See Box 1 for the list of the Regulatory Bodies.

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FIU ANNUAL REPORT 2014 15

Issuance of Guidelines to DNFBPs by the FIU

Prior to July 2011, the power of the FIU Mauritius to issue guidelines to reporting entities was limited to the manner in which a suspicious transaction report may be made under Section 14 of the FIAMLA 2002 and on the manner in which additional information may be supplied to the FIU, on a suspicious transaction, pursuant to a request made under Section 13 (2) of the FIAMLA.

In July 2011, the Economic and Financial Measures (Miscellaneous Provisions) Act amended the FIAMLA by inserting a new section 10 (2) (ba). This section empowers the FIU to ‘issue guidelines to members of a relevant profession or occupation on measures to combat money laundering or financing of terrorism that are in force in jurisdictions having standards comparable to Mauritius.’

Due to the changes brought to the then FATF 40+9 Rec in 2012, coupled with the fact that the FIAMLA had to be amended to reflect those changes brought to the FATF Recommendations,the FIU Mauritius then issued draft guidelines, in 2013, to all members of the relevant professions or occupations for their feedbacks and comments.

Member of a relevant profession or occupation

Regulatory body

1. Professional accountant, public accountant mauritius institute of Professional accountants and member firm under the Financial established under the Financial Reporting act Reporting act

mauritius institute of Professional accountants established under the Financial Reporting act Reporting act

2. Licensed auditor under the Financial Reporting act

Financial Reporting Council established under the Financial Reporting act

3. Law firm, foreign law firm, joint law venture, foreign lawyer under the Law Practitioners act

attorney-General

4. Barrister Bar Council established under the mauritius Bar association act

5. attorney mauritius Law society Council referred to in the mauritius Law society act

6. notary Chamber of notaries established under the notaries act

7. Person licensed to operate a casino, gaming house, gaming machine, totalisator, bookmaker and interactive gambling under the Gambling Regulatory authority act

Gambling Regulatory authority established under the Gambling Regulatory authority act

8. Dealer under the Jewellery act FiU

9. agent in Land and/or Building or estate agency under the Local Government act

FiU

10. Land Promoter and Property Developer under the Local Government act

FiU

BOX 1: REGULATORY BODIES FOR ANY MEMBER OF A RELEVANT PROFESSION OR OCCUPATION

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FIU ANNUAL REPORT 201416

In September 2014, the FIU Mauritius issued the final guidelines to members of the relevant professions or occupations comprising of accountants, auditors and member firm, law practitioners, gambling business, dealers under the Jewellery Act and Agents in Land and/or Building or Estate Agencies/Land Promoters and Property Developers. The guidelines, which reflect the revised FATF Recommendations 2012, provide measures to combat money laundering or financing of terrorism that are in force in jurisdictions having standards comparable to Mauritius. They include, inter alia, details about Mauritius AML/CFT Legislative Framework, the process of suspicious transaction reporting, the role of the FIU and protection of information by the FIU, the tipping off offence; effectively assessing and mitigating money laundering and financing of terrorism risks via the RBA. Measures to combat ML/TF include (i) having in place proper AML/CFT Programs, (ii) Identification and Verification Procedures, (iii) Verification of Source of Wealth, (iv) Suspicious Transaction Monitoring and Reporting, (v) Employee Screening, (vi) Records Keeping and (vii) Auditing of AML/CFT Program among others.

Furthermore, in the last quarter of 2014, the FIU Mauritius has organised meetings with the Director and representatives of the Assay Office and the Permanent Secretary and representatives of the different local authorities falling under the aegis of the Ministry of Local Government for the presentation of the compliance framework.

The Financial Action Task Force (FATF) revised its 40 recommendations in 2012, and has set out key requirements for the principle of a risk-based approach (RBA) to combating money laundering and terrorist financing (ML/TF) in its Recommendation 1. In that respect, interpretive note of Recommendation 1 clearly maintains that that countries should take appropriate steps to gain a common understanding among all relevant authorities and stakeholders on the level and nature of ML/TF risks faced by them. Accordingly, a risk-based approach means that countries identify, assess, and understand their money laundering and terrorist financing risks to which they are exposed. Once these risks are properly recognized appropriate and efficient AML/CFT measures can be taken to mitigate those identified risks. Hence, more resources will be allocated to areas of higher risks and simplified measures to areas of lower risks. Undeniably, a risk assessment is central to the effective implementation of the FATF Recommendations.

The National Risk Assessment (NRA) is also an initial basis used by Mutual Evaluation assessors for understanding the risks specific to a country. The Mutual Evaluation for Mauritius is scheduled in 2016 and it is therefore essential to bring in all domestic AML/CFT stakeholders to prepare a National AML/CFT Risk Assessment for Mauritius. In this context, in late 2014, the Ministry of Finance and Economic Development agreed for the FIU Mauritius to undertake and to lead the first National Risk Assessment with the support of all members of the National Committee on AML/CFT. Some of the FIU Mauritius staff have received training to undertake this project and a small unit has been set up to drive this project.

national Risk assessment

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FIU ANNUAL REPORT 2014 17

The FIU Mauritius continues its commitment to Africa by hosting training sessions for visiting delegations. In 2014, eight members of the Kenya Financial Reporting Centre (14- 17 April 2014), the Director and the Head of Compliance of Gambia Financial Intelligence Unit (27-30 October 2014) and four members from the Financial Intelligence Center of Ethiopia (16 -18 December 2014) have visited the FIU Mauritius for a knowledge sharing and on-site training session.

In the past, such training has been attended by representatives of FIUs from Nigeria, Zimbabwe, Senegal, Niger, Botswana, Lesotho, the Seychelles, Madagascar, Malawi, Ghana, Ethiopia, Gabon, Comoros, Burkina Faso and Zambia.

training for Visiting Delegations

The Director and the Head of Compliance of the Gambia Financial Intelligence Unit and the FIU Mauritius staff

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FIU ANNUAL REPORT 201418

Regional Partnerships and Development in africa

PARTNERSHIPS OF FIU MAURITIUS

ESAAMLG AND THE FIU FORUM

MAJOR ACTIVITIES OF ESAAMLG IN 2014

The FIU Mauritius continued its involvement in regional AML/CFT developments, mostly through training support to emerging FIUs in the region. The FIU Mauritius continues its commitment to Africa by hosting training sessions for visiting delegations. In 2014, Kenya Financial Reporting Centre, the Gambia Financial Intelligence Unit and the Financial Intelligence Center of Ethiopia have visited the FIU Mauritius for a knowledge sharing and on-site training session.

The Director of SAMFIN Madagascar who visited the FIU in May 2014, requested for a training programme in IT and Analysis field. In view of FIU’s regional commitments at the Egmont Group level and the position of the Mauritian Government in assisting Africa, the Director accepted his request and two officers were called upon to provide training to SAMFIN Madagascar in the above fields.

The Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) was launched in 1999 at a meeting of eastern and southern African ministers in order to develop a regional mechanism to cooperate in the implementation of AML programmes. The ESAAMLG has the responsibility of coordinating its fight against money laundering with other international organisations, studying regional typologies, developing institutional and human resource capacities relating to these issues and coordinating technical assistance where needed.

Towards the end of the period under review, ESAAMLG also considered a proposal made by Namibia and the ESAAMLG Secretariat to undertake a Special Typologies project on Poaching and Illicit Trade in Wildlife Products. Preliminary work, in particular conceptualization of the project, has been undertaken by a Project Team. It was noted that the majority of ESAAMLG member countries have vast resources in wildlife which, during the last few years, have seen unprecedented targeting by both individuals and syndicates involved in poaching and other illegal wildlife activities. This typology project therefore focuses on poaching and illegal trade in wildlife and wildlife products and associated money laundering in the ESAAMLG Region. Certain shortcomings have been identified by ESAAMLG in the project to include lack of data on (a) quantitative records of wildlife, (b) the methods used to channel funds related to the poaching activities, (c) the information on potential persons involved in the activities, among others.

ESAAMLG developed an Outreach Program for countries in the region to join the ESAAMLG. This organization recognizes that money laundering and terrorist financing crimes are transnational problems, which require unified and concerted efforts by all countries in the region to deal with. It therefore embarked on an outreach program with Burundi, Democratic Republic of Congo, Ethiopia and Rwanda.

Special Typologies Project on Poaching and Illicit Trade in Wildlife Products

Expansion of ESAAMLG membership

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international Partnerships and Developments

THE EGMONT GROUP OF FINANCIAL INTELLIGENCE UNITSRecognizing the importance of international cooperation in the fight against money laundering and financing of terrorism, a group of Financial Intelligence Units (FIUs) met at the Egmont Arenberg Palace in Brussels, Belgium, and decided to establish an international informal network of FIUs for the stimulation of international co-operation since 1995. Known as the Egmont Group of Financial Intelligence Units, it is a non-political, international forum of operational Financial Intelligence Units (FIUs) which exchange information to follow the suspected proceeds of crime when funds are located in different jurisdictions. Egmont Group of FIUs are required to be operationally independent. This independence allows them to effectively examine potential criminal proceeds regardless of the underlying offence and the organisation that takes the investigative lead. The members of the Egmont Group meet on a regular basis to find ways to promote the development of FIUs and to cooperate, particularly in the areas of information exchange, training and the sharing of expertise.

Egmont member FIUs operate within the context of their national legislation and framework for combating money laundering and terrorist financing. They play a vital role in the detection, identification, investigation, prosecution, and confiscation of the proceeds of crime.

Over the years, the Egmont Group has evolved and is presently comprised of 147 member FIUs. The new members are UIF Angola, FIE-AMBD Brunei Darussalam, NAFI Chad, FIC Ghana, FID Jamaica, FIC Namibia, MOT Saint Maarten, and FIU Tanzania. Indeed, the Egmont network of FIUs is likely to expand further in the coming years since Recommendation 29 of FATF requires all FIUs to be a member of the Egmont Group.

The FIU Forum was set up in September 2011 in Mauritius and the first Chairman of that Forum was Mauritius, under the chairmanship of Mr S D Bikoo. The Terms of Reference of the Chairmanship and Deputy Chairmanship, makes reference to a rotation of these positions. In this context, the FIU Forum which met in September 2014, thanked Mr Bikoo for having steered the activities of the FIU Forum since its inception in September 2011. The new Chairperson and Deputy Chairperson of the FIU Forum are South Africa and Malawi respectively.

The international nature of money laundering and financing of terrorism is a compelling reason to develop international cooperation and coordination because these phenomena not only jeopardise international security but also the world’s economic prosperity. The present section shows how international institutions such as the Egmont Group and the Financial Action Task Force have been intensifying their efforts to combat money laundering and terrorist financing in 2014.

The FIU Forum

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EGMONT PLENARy MEETING

MAJOR ACTIVITIES OF THE EGMONT GROUP IN 2014

EGMONT COMMITTEE REGIONAL REPRESENTATION

The Egmont Plenary took place in Lima, Peru between 1 and 6 June 2014. It was attended by almost 320 participants representing 115 FIUs from jurisdictions and 15 international organizations to discuss the challenges faced by FIUs in combating money laundering, associated predicate offences and terrorist financing, especially in the areas of international cooperation, information sharing and the improved development of financial intelligence.

During this meeting, five FIUs from the African continent namely Angola, Namibia, Tanzania, Chad and Ghana were admitted to the Egmont

Group. The FIU Mauritius was the lead sponsor for Namibia’s admission and provided training in Mauritius to the management of the Ghana Financial Intelligence Centre (FIC). As at date, there are 21 FIUs from African Region. Furthermore, it is also important to note that the Heads of FIUs have approved, with effect from January 2015, that Africa will be represented in the Egmont Committee by three FIUs, one for Eastern and Southern Africa, one for Central and Western Africa and one for Middle East and Northern Africa.

The Heads of Financial Intelligence Units (HoFIUs) adopted the Egmont Group Strategic Plan 2014-2017 and the new Egmont Group Regional Footprint, both of which set out the future objectives and approach for the organisation. The Strategic Plan outlines the Egmont Group’s key strategies and sharpens the organisation’s focus on enhancing the effective exchange of information between FIUs, the facilitation of adherence to international standards, and the development and sharing of expertise among FIUs. The HoFIUs also agreed that cooperation with international partner organisations and an effective and sustainable Egmont Group infrastructure, to include a properly resourced Secretariat, are critical components towards the implementation of the Strategic Plan.

The Egmont Group Secretariat has discussed on a new regional representation formula consisting of eight-regional configuration. Each region shall have at least one representative, while regions with 20 or more members will have two regional representatives, and those with 40 or more members will have three representatives.

The new Global Footprint is an undertaking by the HoFIUs, recognising that the growth of the organisation requires a more focused regional approach. The Global Footprint, with an amended configuration methodology, involves designating members to new regions that are aligned more with Egmont Group Observers like the FATF Style Regional Bodies (FSRBs).

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EGMONT GROUP STRATEGIC PLAN 2014-2017

FINANCIAL ACTION TASK FORCE (FATF)

HIGH-RISK AND NON-COOPERATIVE JURISDICTIONS (ICRG)

The Egmont Group Strategic Plan 2014-2017, approved by the HoFIUs in June 2014 provides a focus for the organisation to better serve its members and to collaborate with Observers and International AML/CFT Partners. The Egmont Group’s two Key Result Areas (KRAs) are Enhancing Effective Information Exchange between FIUs and Facilitating Adherence to International Standards, Developing and Sharing Expertise of FIUs.

The Financial Action Task Force (FATF) was established in 1989 by the G7 countries. It is an intergovernmental body whose purpose is to set standards and promote effective implementation of legal, regulatory and operational measures for combating money laundering, financing of terrorism and other related threats to the integrity of the international financial system. The FATF standards are reflected in its 40 Recommendations issued in February 2012. These are universally recognized international standards for anti-money laundering and countering financing of terrorism.

A key objective of the FATF is to identify which jurisdictions have strategic weaknesses in their national AML/CFT regimes and later works with them to determine an action plan to tackle these weaknesses. Through the Improving Global AML/CFT Compliance Process, it monitors their progress in implementing the components of the action plan. The FATF publicly identifies these jurisdictions to raise global awareness about the risks for the financial system emanating from them.

In 2014, while Algeria has taken steps towards improving its AML/CFT regime and has made commitment to work with FATF and MENAFATF to address its strategic AML/CFT deficiencies, the country did not make sufficient progress in implementing its action plan. The country remains therefore on the list of High-Risk and Non-Cooperative Jurisdictions.

Concerning Angola, Iraq, Sudan and Uganda, steps have been taken towards improving their AML/CFT regimes but strategic AML/CFT deficiencies still exist. They remain as such on the FATF public document, “Improving Global AML/CFT Compliance: On-going Process” and must continue to work on implementing their action plans to address these deficiencies.

Kuwait, Namibia and Zimbabwe have made significant progress to improve their AML/CFT regimes and have substantially addressed their action plans at a technical level. The FATF will undertake on-site visits to confirm whether the process of implementing the required reforms and actions is underway. Although, Syria and yemen have also significantly addressed their action plans at a technical level, on-site visits could not be conducted due to the security situation in these two countries. The FATF will however continue to monitor the situation.

Jurisdictions no longer subject to the FATF’s on-going Global AML/CFT Compliance Process

Following significant progress made in improving their AML/CFT framework, Kenya, Tanzania and Ethiopia are no longer subject to FATF’s monitoring process under its on-going global AML/CFT compliance process.

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PUBLICATIONS

The guidance outlines the principles involved in applying a risk-based approach to AML/CFT as well as assists countries, competent authorities and banks in the design and implementation of a risk-based approach to AML/CFT through general guidelines and practical examples. The document will also support the effective implementation and supervision of national AML/CFT measures, by focusing on risks and on mitigation measures, but also support the development of a common understanding of what the risk-based approach to AML/CFT entails. This document targeting countries and their competent authorities, as well as practitioners in the banking sector.

This typologies report examines in detail, how and where NPOs are at risk of terrorist abuse. The report uses case studies as well as input collected from law enforcement, other government actors and NPOs themselves to increase awareness of the methods and risk of abuse for terrorism of the NPO sector, both domestically and internationally.

As decentralised, math-based virtual currencies—particularly Bitcoin—have garnered increasing attention, two popular narratives have emerged: (1) virtual currencies are the wave of the future for payment systems; and (2) virtual currencies provide a powerful new tool for criminals, terrorist financiers and other sanctions evaders to move and store illicit funds, out of the reach of law enforcement and other authorities. Against this backdrop, the report builds on the 2013 New Payment Products and Services (NPPS) Guidance (FATF, 2013) by suggesting a conceptual framework for understanding and addressing the anti-money laundering / countering the financing of terrorism risks associated with one kind of internet-based payment system: virtual currencies.

The report, inter alia, identifies (i) how and where ML/TF from Afghan drug production and trafficking is occurring based on case studies, existing literature and other data,(ii) possible “red flag” indicators that could assist financial and non-financial institutions in developing mechanisms to detect and report financial transactions, financial flows and ML/TF activities resulting from Afghan drug production and trafficking, assists jurisdictions and FSRBs in knowledge-building and recognition of the negative impact and effects to the integrity of the world financial system associated with the illicit production and trafficking in opiates and enhance FATF efforts in tackling illicit financial flows and prevention of ML/TF activities resulting from Afghan drug production and trafficking.

• Risk-Based Approach guidance for the Banking Sector (October 2014)

• Risk of terrorist abuse in non-profit organisations (June 2014)

• Virtual Currencies: Key Definitions and Potential AML/CFT Risks (June 2014)

• Financial flows linked to the illicit production and trafficking of afghan opiates and associated ML/TF activities (June 2014)

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Corporate Governance ReportCompliance to the Code of Corporate Governance

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Corporate Governance ReportCOMPLIANCE TO THE CODE OF CORPORATE GOVERNANCE

The Director and the Board of the FIU fully recognise that good governance should be the driving force behind each decision made at the FIU. The need for good governance is all the more important given the nature of FIU’s activities and its role as an important stakeholder involved in combating money laundering and terrorist financing (AML/CFT). As expected in those instances where FIU could not comply with the Code of Corporate Governance because of certain constraints, disclosures have been made in this report.

The FIU performs core and non-core functions to achieve its objectives as defined in the Financial Intelligence and Anti-Money Laundering Act, 2002. In the performance of both core and non-core functions, the FIU is guided by its values, namely Professionalism, Integrity, Respect, Discretion and Innovation.

ADOPTION OF A STRATEGIC PLANIn 2014, the FIU continued with the implementation of the revised 2012-2014 Strategic Plan which focused on strategic goals and strategies as highlighted below

Strategic Goals Strategies

1. to have a modern information system for effective data collection, storage, retrieval, management and financial investigative analysis.

acquiring a modern integrated information system specially designed for FiUs i.e. Un goamL system.

2. to have a strong culture of reporting of money laundering and terrorist financing in mauritius and increase amL/CFt awareness across mauritius.

Develop better communication with reporting institutions, amL/CFt stakeholders and the media in mauritius, the region and worldwide.

3. to be at the vanguard of research, training and dissemination of financial intelligence and analytical report in mauritius and promote action under Revised FatF Recommendation issued in February, 2012 e.g. strategic analysis and national Risk and threat assessment for mauritius.

Consolidate the Financial investigative skills with focus both on tactical and strategic analysis. improve the effectiveness of the supervision of DnFBPs for which FiU is a regulator, namely the Jewellery, Real estate, Land Promoters and Property Developers.

4. to promote productivity, efficiency and commitment of staff.

adapting organisation structure and duties of individual staff. integrating an efficient and constructive performance management system through which staff are motivated and development encouraged.

5. enhance credibility of mauritius as a jurisdiction adhering to international amL/CFt norms.

Participating in high profile domestic, regional and international events to promote the adoption of amL/CFt standards of mauritius and co-operate effectively with all domestic amL/CFt stakeholders.

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INTERNAL CONTROL SySTEMS OF THE FIUThe Board has the financial management responsibility of the FIU and as such it ensures that the FIU complies with its systems of internal control. One of the main components of internal control is that all payments are authorised by the Chairman of the FIU Board. Consequently, all such expenses are subject to the scrutiny of the Chairman. In addition, the Board also reviews the FIU accounts which are submitted to them prior to submission to the auditors. The Board thus has the opportunity to control and question the use of public funds by FIU and to ensure that all expenses are made in accordance with FIU’s policies and procedures.

Tender CommitteeFor transparency, the Board of the FIU has approved the setting up of a Tender Committee since 2004 and the latter reports directly to the Board. In 2008, the composition of the independent Tender Committee was reviewed and now comprises of a Chairperson, two members and one secretary. Furthermore, the Chairmanship is rotated among members.

The Tender Committee has a set of procedures compliant with the requirements of the Public Procurement Act, 2006 and Regulations, 2008. The Tender Committee normally sits whenever there is a need to procure single items exceeding Rs 100,000.

(1) Approval of expenses The Board of the FIU has approved that any expenses above Rs 100,000 needs its approval.

All purchases below Rs 5, 000 need to be approved by the Director after which quotations are sought from three suppliers. After analysis, the most competitive supplier is retained and a purchase order is sent to confirm the order.

Audit, Risk, Remuneration, Nomination and Corporate Governance CommitteesGiven the small size of the institution, the FIU has not yet set up committees such as audit, risk, remuneration, nomination and corporate governance. The Director and the Accounting Technician work together on the audit of the FIU and the Director endeavours to flag any concerns to Board. External ControlAdditionally, the service of the National Audit Office is retained each year for the audit of FIU’s Financial Statements. Any weakness identified by the external auditors is brought to the attention of the Board and remedial action is taken as soon as possible. As regards matters pertaining to remuneration, nomination and risk, they are brought for discussion and approval at Board level. It is to be noted that since 1st January 2013 the FIU is under the purview of the Pay Research Bureau which sets up the terms and conditions of employment of the staff. The PRB recommendations have now replaced the FIU terms and conditions. The Terms and Conditions of Employment of the Director and Board members are set up by Government.

There is no specific internal audit function at the FIU in view of its limited resources and financial constraints. While the Board had agreed in early 2012 that as from the year 2013, key senior officers with recognised accounting professional qualifications will assist in internal audit, this has unfortunately not been implemented yet.

COMMITTEES

INTERNAL AUDIT

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The Board of the FIU has approved a Code of Ethics for staff of the FIU. It is clearly specified in the Code of Ethics that employees of the FIU should avoid other activity, whether remunerated or not, that could reasonably be perceived as a conflict of interest. Additionally, in order to ensure that conflict of interests do not interfere with the work of the FIU, all officers of the FIU are required to declare their interest to the Director with a view to guaranteeing public confidence in the impartiality of the FIU. Furthermore, staff of the FIU are required to inform the Director, of any potential conflict of interest, or anything that may appear to be a conflict of interest that arises in the course of their duties.

The FIAMLA, 2002 makes provision for the appointment of Board members only. The Board, on its part, appoints the Secretary. Currently, this role is being fulfilled by FIU’s Accounting Technician.

The Financial Intelligence Unit (FIU) was established in August 2002, under the Financial Intelligence Unit and Anti-Money Laundering Act, 2002 (FIAMLA). There FIAMLA has been amended by the Economic and Financial Measures (Miscellaneous Provisions) Act 2013 on 21st December, 2013 and the new functions of the FIU are stipulated in section 10 of the Act which now reads as follows:

(1) The FIU shall be the central agency in Mauritius responsible for receiving, requesting, analysing and disseminating to the investigatory and supervisory authorities disclosures of information - (a) concerning suspected proceeds of crime and alleged money laundering

offences; (b) required by or under any enactment in order to counter money laundering;

or (c) concerning the financing of any activities or transactions related to

terrorism.

(2) For the purposes of subsection (1), the FIU shall - (a) collect, process, analyse and interpret all information disclosed to it and

obtained by it under the relevant enactments; (b) inform, advise and co-operate with the Enforcement Authority and the

investigatory and supervisory authorities;(ba) issue guidelines to members of a relevant profession or occupation on

measures to combat money laundering or financing of terrorism that are in force in jurisdictions having standards comparable to Mauritius;

(c) issue guidelines to banks, financial institutions, cash dealers and members of a relevant profession or occupation on the manner in which (i) a report under section 14 shall be made; and (ii) additional information may be supplied to the FIU, on a suspicious

transaction, pursuant to a request made under section 13(2);(f) exchange information with overseas financial intelligence units and

comparable Bodies;(g) undertake, and assist in, research projects in order to identify the causes of

money laundering and terrorist financing and its consequences.

CONFLICTS OF INTEREST

COMPANy SECRETARy

FUNCTIONS OF THE FINANCIAL INTELLIGENCE UNIT

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As per Section 12 of the Financial Intelligence and Anti-Money Laundering Act, 2002, there is set up for the purposes of this Act a Board which shall consist of –

(a) a Chairperson, who shall be a person who has - (i) served as a Judge of the Supreme Court; or (ii) served as a Magistrate, or been a law officer or practised as a barrister, in Mauritius

for at least 10 years; (b) 2 other members of high repute, of whom one shall be a person with substantial experience in the legal profession and the other shall be a person with substantial

experience in the financial services industry. (2) The Chairperson and members of the Board shall be appointed by the President on

the recommendation of the Prime Minister made in consultation with the Leader of the Opposition.

(3) The appointment of the Chairperson and each member of the Board shall be on such terms as may be specified in the instrument of appointment of the Chairperson and each such member.

(4) The Board may act notwithstanding the absence of one of its members.

BOARD OF THE FINANCIAL INTELLIGENCE UNIT

(3) Any institution to which, or person to whom, guidelines are issued under subsection (2) (ba) or (c) shall comply with those guidelines.

(4) Where an institution or a person fails to comply with guidelines issued under subsection (3), the institution or person shall be liable to pay a penalty not exceeding 50,000 rupees for each day on which such breach occurs as from the date on which the breach is notified or otherwise comes to the attention of the FIU and such penalty may be recovered by the Director as if it were a civil debt.

(5) Any penalty collected by the Director under subsection (4) shall, as soon as practicable, be paid into the Consolidated Fund.

(6) For the purposes of section 18(3A), a regulatory body which exercises control over members of a relevant profession or occupation may require any member of the relevant profession or occupation to furnish it with such information and produce such record or document at such time and place as may be required in writing by the regulatory body.

(7) Any member of a relevant profession or occupation who fails to furnish the information or produce the record or document required under subsection (6) shall commit an offence and shall, on conviction, be liable to a fine not exceeding 500,000 rupees and to imprisonment for a term not exceeding 5 years.

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Members of the Board are Mr. Louis Clency L.K.S. Sam Soon (Chairperson), Mr. Gunness Ramdewar SA OSK and Mr. Percy Pascal.

Mr. L.C.L.K.S. Sam Soon, Chairman, holds a B.A degree in Law & Economics from the University of Keele, UK. He completed his Bar Finals at the Inns of Court School of Law, London and was called to the Bar at Lincoln’s Inn, London in 1977.

Mr. G. Ramdewar SA OSK has a long and substantial experience in the legal profession and he was a Principal State Attorney from 1978 to 1996.

Mr. P. Pascal has significant experience in the financial services industry. He has been in the banking business for thirty seven years and held the position of Risk Management Director in a commercial bank for seven years prior to his retirement.

The new functions of the Board of the FIU following amendment in the Economic and Financial Measures (Miscellaneous Provisions) Act 2013 on 21st December, 2013 reads as follows:

12. The Board

(5) The functions of the Board shall be to –

(a) keep under overall review the manner in which the FIU discharges its functions under this Act and to formulate the necessary policies for implementation by the Director with a view to achieving the objects of the FIU;

(b) review and approve the budgetary estimates of the FIU;

(c) issue such instructions as it considers appropriate with regard to the financial management of the FIU;

(d) advise the Director on matters relating to the discharge by the FIU of its functions; and

(e) consider the annual report of the FIU and report to the Minister on any matter appearing in or arising out of such report.

(6) The Board shall not have the power to consider, discuss or deliberate on any matter relating to the lodging, analysing, reporting, requesting or disseminating of information in respect of any suspicious transaction report, nor will it have access to information concerning any suspicious transaction report.

(7) Subject to subsections (4) to (6), the Board shall determine its own procedure.

FUNCTIONS OF THE BOARD OF THE FINANCIAL INTELLIGENCE UNIT

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Section 12 (3) of the Financial Intelligence and Anti-Money Laundering Act, 2002 provides that the appointment of the Chairperson and each member of the Board shall be on such terms as may be specified in the instrument of appointment of the Chairperson and each such member.

The Board endeavours to meet at least once a month and during the year 2014 fourteen meetings were held for each. Section 12 (4) of the Financial Intelligence and Anti-Money Laundering Act, 2002 provides that the Board may act notwithstanding the absence of one of its members.

Section 9 (2) and (3) of the Financial Intelligence and Anti-Money Laundering Act, 2002 as amended by the Economic and Financial Measures (Miscellaneous Provisions) Act 2012 provides that the Head of the FIU shall be the Director who shall be a person of high repute with substantial experience in the financial services industry or law enforcement and experience in management and accounting and appointed by the President on the recommendation of the Prime Minister made in consultation with the Leader of the Opposition, on such terms and conditions as may be determined by the Prime Minister. The Director shall be responsible for the administration and management of the FIU and shall be assisted by such persons as may be appointed by the Director to assist him. Head of FIU – DirectorFor the period 2014, the Director of the FIU was Mr Satyadev Deonarain Bikoo whose appointment was made by the President on the recommendation of the Prime Minister made in consultation with the Leader of the Opposition as per section 9(2) of the Financial Intelligence and Anti-Money Laundering Act, 2002. The Director was appointed on a fixed term contract and his last re-appointment became effective from 9th August, 2013 until the termination of his contract on 30 January, 2015.

The fixed yearly fees paid to the Chairperson and Board members in 2014 were as follows:Chairperson Rs 655,200Board Members Rs 780,000

REMUNERATION OF BOARD

BOARD MEETINGS ATTENDANCE

STAFF OF THE FINANCIAL INTELLIGENCE UNIT

Members Board Meeting (14 meetings)

Mr. L.C.L.K.S. Sam SoonChairman

14

Mr. G. Ramdewar SA, OSKMember

14

Mr. P. PascalMember

14

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Mr. S.D. Bikoo is a former Director of the Mauritius Offshore Business Activity Authority (1996-2001), Assistant Director of Research at the Bank of Mauritius (1988-1992) and Senior Adviser at the Ministry of Economic Development, Financial Services and Corporate Affairs of Mauritius (2001-2002). He has also been active in AML/CFT and FIU development in Africa, having been twice Chairman of the Task Force of Senior Officials of ESAAMLG as well as regional representative of Africa on the Egmont Committee since July, 2003.

Mr. S.D. Bikoo is an Economist by profession, holding an MSc (Econ) from the London School of Economics and an M.Phil from the University of Southampton, UK.

Mr. Guillaume Ollivry is the current Director of the FIU and he assumed his duties on 18 February 2015. Mr. G. Ollivry holds a LLB (Hons) from the University of Kent, Canterbury. He has a background in legal research and investigation of human rights abuses and financial crime. He is also on the roster of experts of the AML/CFT Project in the Greater Horn of Africa region.

Key StaffKey officers of the FIU are comprised of an Assistant Director, a Senior Financial Intelligence Analyst, five Financial Intelligence Analysts and a team of three Managers (Data Intelligence, Corporate Affairs and Legal). The post of Assistant Director which was vacant since 2008 has been filled in September, 2014.

The Assistant Director is Mr. Mahendrasingh Ramdhary who joined the FIU Mauritius in January, 2004 as Financial Intelligence Analyst. In January, 2010 he was promoted to the position of Senior Financial Intelligence Analyst. He holds a BA (Hons) degree in Law and Management and is a Certified Anti-Money Laundering specialist since 2011.

StaffingThe organisation structure of the FIU is shown in Appendix II of the Annual Report 2014. As regards to the various grades and posts, the table below lists the job positions as at 31st December, 2014.

Grade No. of Post Grade No. of Post

Director 1 analyst / traineeanalyst (operations)

82 on leave

without payassistant Director 1

senior Financial intelligence analyst

vacant intelligence officer 4

Financial intelligence analyst 5 accounting technician 1

Head of Compliance 1 Data intelligence assistant 1

Legal manager 1 office secretary2

1 on leavewithout pay

Data intelligence manager 1 Data Processing assistant 1

Corporate affairs manager 1 assistant office secretary 1

senior intelligence officer 1 Driver / General assistant 3

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Remuneration and Allowances to Staff of the FIU

Staff of the FIU are under the purview of the Pay Research Bureau with effect from 1st January, 2013 and are paid accordingly. Board voted a resolution on 12th December, 2012 to allow for staff in employment as at 31st December, 2012 to enjoy certain benefits that they were enjoying under FIU’s “Pay and Grading Structure and Conditions of Employment” as listed below:

(i) The Financial Intelligence Unit will maintain the Group Personal Accident Insurance Policy (for security reasons and the nature of our work)

(ii) The Financial Intelligence Unit will maintain the Medical Insurance Policy for all its employees. (This was introduced in June 2005 as an incentive to attract and retain staff)

(iii) The Financial Intelligence Unit will maintain the provision of parking facility or a parking fee of Rs 2000 a month to confirmed employees drawing salary in a scale the maximum of which is not less than Rs 53000 and above as at 31st December, 2012. (An incentive to retain senior staff and given the exigencies and nature of our work)

(iv) The FIU will maintain travel grant to its existing employees drawing salary in a scale the maximum of which is not less than Rs 53000 as at 31st December, 2012. (An incentive to motivate and retain staff in senior position)

(v) The FIU will maintain the grant of duty free benefits to its existing employees drawing salary in a scale the maximum of which is not less than Rs 53000 as at 31st December, 2012. (An incentive to motivate and retain staff in senior position)

(vi) The Financial Intelligence Unit will maintain the passage benefits granted to all its employees in employment as at 31st December, 2012.

(vii) The Financial Intelligence Unit will maintain the Code of Ethics as specified in the current Terms and Conditions of Employment for all officers of the FIU. (To comply mainly with section 30 of the Financial Intelligence and Anti-Money Laundering Act, 2002)

Performance Appraisal of Staff of the FIU

FIU has a transparent way of assessing performance of the employees. They are given the opportunity to express their opinions on the assessment conducted by their immediate supervisors, on the environment in which they are working and on their aspirations. The Director then assesses each employee in a face to face meeting and discusses any contested issue with the immediate supervisor in the presence of the officer being appraised. FIU is always striving to improve the performance appraisal system so that the organization and the staff can derive the most benefit from it.

STAFF MATTERS

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FIU ANNUAL REPORT 201432

FUNDS OF THE FIU

ACCOUNTABILITy

As per section 33 of the Financial Intelligence and Anti-Money Laundering Act, 2002, the expenses of the FIU shall be met out of (a) money appropriated annually by Parliament for the purposes of the FIU; and (b) any government grants made to it. Section 33 (2) provides that with the consent of the Minister, the FIU may accept donations and that Article 910 of the Code Civil Mauricien shall not apply to a donation to the FIU. The Ministry may also request the Director to attend meetings related to FIU or general AML/CFT matters on its behalf. Funds for such overseas missions are either drawn from the FIU’s budget or specifically provided by Government.

Statutory Bodies Pension Funds Act, 1978

There is established in respect of the FIU a pension fund which shall be administered by the SICOM Limited, a company incorporated and registered under the Companies Act 1984. The FIU makes a contribution to the Fund in respect of persons in the permanent and full time employment of the FIU until they cease to be employed by the FIU.

Data Protection Act, 2004

The Data Protection Act provides for the protection of the privacy rights of individuals in view of the developments in the techniques used to capture, transmit, manipulate, record or store data relating to individuals. The FIU has been registered as a Data Controller and has complied with the provisions of the Act in so far as they apply to the FIU.

Public Procurement Act, 2006

The Public Procurement Act (2006) and its accompanying 2008 Regulations provide for the simplification of procurement procedures and ensure that public funds are spent in a transparent, efficient and fair manner. The FIU has ensured that the provisions of the Public Procurement Act and Public Procurement Regulations are complied with in the procurement of goods and services. Illustratively, the methods of procurement set out in the above legislation have been strictly observed in the procurement of goods and services by the FIU.

Employment Rights Act, 2008

The Employment Rights Act is partly applicable to the FIU e.g PART VIII of the Act which concerns ‘Termination of Agreement’. Whenever there has been a termination of agreement by the FIU, the provisions of the Act has been strictly observed. The Employment Rights Act 2008 also prohibits discrimination at work with regard to age, race, colour, caste, creed, sex, sexual orientation, HIV status, religion, political opinion, place of origin, national extraction or social origin (section 4.(5) (a) of the Employment Rights Act 2008). The FIU is an equal opportunity employer and does not make any discrimination among its employees or in the recruitment of its employees.

As a public body, the FIU needs to comply with various legislations in place. A few of these acts are indicated below.

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FIU ANNUAL REPORT 2014 33

INTEGRATED SUSTAINABILITy REPORTING

RISK MANAGEMENT

Health and Safety Policies

The FIU is committed in providing and maintaining a healthy, safe and secure working environment. It has thus developed and implemented safety, health and environment policies and practices to comply with existing legislative and regulatory frameworks.

Ethics

In view of the sensitive nature of the operations of the FIU, all staff of FIU must comply with FIU’s Code of Ethics.

An oath of confidentiality is taken by all members of the Board, Director and staff of the FIU.

Environment

The FIU has a disposal policy which has been approved by its Board with regards to safe disposal of electronic equipment and minimisation of the utilisation of printing paper.

Social

Given its limited resources and its functions, the FIU is not involved in any Corporate Social Responsibility programmes.

As part of its risk management policies, the Board regularly review the potential risks, from both internal and external sources to which the FIU is exposed to. The Board is of opinion that there is no material risk that may adversely affect the operation of the FIU. Other risks exposures have been addressed as follows:

Physical

FIU’s Terms and Conditions of Employment stipulate that all employees are covered by a medical and such other schemes covering job risks. Staff of the FIU in employment as at 31st December, 2012 are under a 24-hr Group Personal Accident insurance policy which covers mainly bodily injury following accident.

All assets of the FIU including office equipment, computers, furniture etc are covered under an insurance policy. Moreover, the premises of the FIU are under security control of the syndic where our office is located.

Equal Opportunities Act, 2008

The FIU complies with the Equal Opportunities Act and, as per section 9 of the Act which provides that every employer needs to draw up and apply an equal opportunity policy of work with a view to mitigating risks of discrimination and promoting recruitment, training, selection and employment on the basis of merit. The FIU has developed an Equal Opportunity Policy.

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FIU ANNUAL REPORT 201434

Operational

Operational risks at the FIU are minimal. This results from established procedures, provisions in the Financial Intelligence and Anti-Money Laundering Act, 2002 and the adopted Code of Ethics.

Staff Turnover

In the past years, the rate of staff turnover at the FIU was deemed to be high. However, as from the year 2013 the turnover rate has drastically decreased and only one staff resigned from the FIU. There was no resignation at the Financial Intelligence Unit in the year 2014.

Information Security

Information security at the FIU is embodied in an architecture made up of various policies and procedures in place. The Board members, Director and staff must comply with section 30 of the Financial Intelligence and Anti-Money Laundering Act, 2002 on confidentiality. The FIU has a well-established security and data protection architecture comprising of protection under the provisions of existing legislation, measures approved by Board, environmental and physical security measures and on-going monitoring & “Break the Glass” access for audit trail purposes. Financial

The Ministry of Finance and Economic Development (MOFED) provides a grant to the FIU to meet its expenditure after the FIU has submitted its annual budget estimates to MOFED. Monthly reports are submitted in the form of Request for Release of Funds to the Ministry of Finance to ensure that funds disbursed are used as per approved budget.Given the small size of the organization and its relatively small annual budget, the FIU has not identified any material financial risk. The Accounting Technician of the FIU works in the Corporate Affairs Division and keeps proper records of all transactions. The Director oversees all payments of the FIU which are counter-checked and signed by the Chairman of the Board. Reputational

The breach of confidentiality is an omnipresent risk and provision has been made in section 30 of the Financial Intelligence and Anti-Money Laundering Act, 2002 on Confidentiality as follows “The Director, every officer of the FIU, and the Chairperson and members of the Board shall – before they begin to perform any duties under this Act, take an oath of confidentiality in the form set out in the Second Schedule; and maintain during and after their relationship with the FIU the confidentiality of any matter relating to the relevant enactments”.

Additionally, as per section 31 of the Financial Intelligence and Anti-Money Laundering Act, 2002 the Director, every officer of the FlU, and the Chairperson and members of the Board shall file with the Independent Commission Against Corruption a declaration of his assets and liabilities in the form specified in the Third Schedule (a) not later than 30 days after his appointment; and (b) on the termination of his appointment. As from 22nd December, 2012, the new section 31 (2) of FIAMLA, 2002 provides that every person referred to in subsection (1) shall make a fresh declaration of his assets and liabilities, every year, and also on the expiry of his employment or termination of his employment on any ground.

The Board of the FIU has also established specific procedures for recruitment. This includes tests, interviews and pre-employment screening.

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FIU ANNUAL REPORT 2014 35

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FIU ANNUAL REPORT 201436

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FIU ANNUAL REPORT 2014 37

Financial statements for the Year ended31 December 2014

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FIU ANNUAL REPORT 201438

Board’s Reportfor the year ended 31 December 2014The Board of the Financial Intelligence Unit (FIU) presents its thirteenth report and the audited financial statements of the organisation for the year ended 31 December, 2014.

FUNCTIONS OF THE FIU

The FIU was established under Section 9 of the Financial Intelligence and Anti-Money Laundering Act 2002. The FIU is the central agency in Mauritius responsible for receiving, requesting, analysing and disseminating to the investigatory and supervisory authorities’ disclosures of financial information concerning suspected proceeds of crime and alleged money laundering offences and the financing of any activities or transactions related to terrorism.

STATEMENT OF THE BOARD’S RESPONSIBILITIES IN RESPECT OF THE FINANCIAL STATEMENTS

The Board of the FIU is responsible for the preparation of the financial statements for each financial year, which gives a true and fair view of the Statement of Financial Position, Statement of Financial Performance, and Statement of Cash Flows for that period.

In preparing those financial statements, the Board is required to:

• selectsuitableaccountingpoliciesandthenapplythemconsistently;• makejudgementsandestimatesthatarereasonableandprudent;• state whether applicable accounting standards have been followed, subject to any

material departures and explained in the financial statements; and• preparethefinancialstatementsonthegoingconcernbasisunlessitisinappropriateto

presume that the organisation will continue in business;• preparethefinancialstatementsinaccordancewiththeFinancialIntelligenceandAnti-

Money Laundering Act 2002 (Part VIA – Accounts and Audit).

The Board is responsible for keeping proper accounting records, which disclose with reasonable accuracy at any time the financial position of the FIU. They are also responsible for safeguarding the assets of the FIU, designing, implementing and maintaining effective internal controls relevant for the preparation and presentation of financial statements that are free from material misstatements.

The Board confirms that the Board has complied with the above requirements and the relevant statutes in so far as they relate to the preparation of the financial statements.

Approved by the Board on 26 October, 2015.

Signed on behalf of the FIU Board

Mr Satyawan Kailash Trilochun Chairman

Mr Rishinand BhoobunBoard Member

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FIU ANNUAL REPORT 2014 39

statement of Financial Positionas at 31 December 2014

Mr Satyawan Kailash Trilochun Chairman

Mr Rishinand BhoobunBoard Member

FINANCIAL INTELLIGENCE UNIT

Notes Year 2014 Year 2013Rs Rs

ASSETS

Current AssetsCash and cash equivalents 6 2,283,958 1,503,561Receivables 7 1,012,230 634,577Total Current Assets 3,296,188 2,138,138

Non-Current AssetsRetirement benefit asset 12 5,494,418 4,705,213Property, plant and equipment 8 7,152,007 7,219,236Intangible Assets 9 3,555,246 5,455,194Total Non-Current Assets 16,201,671 17,379,643

Total Assets 19,497,859 19,517,781

LIABILITIES

Current LiabilitiesPayables 10 791,668 408,776Provision for passage benefits 11 974,102 874,603Provision for leave refund 11 607,175 111,881Total Current Liabilities 2,372,945 1,395,260

Non-Current LiabilitiesProvision for leave refund 11 2,924,361 2,430,850 Total Non-Current Liabilities 2,924,361 2,430,850

Total Liabilities 5,297,306 3,826,110

Net Assets 14,200,553 15,691,671

NET ASSETS/ EQUITYGeneral Fund 2,591,825 2,247,953Capital Fund 11,608,728 13,443,718Total Net Assets/ Equity 14,200,553 15,691,671

Approved by the Board on 26 October, 2015

The notes to the accounts on pages 45 to 59 form part of the financial statements.

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FIU ANNUAL REPORT 201440

Notes Year 2014 Year 2013Rs Rs

RevenueGovernment grant 13 33,218,454 28,381,333Deferred income 4,408,536 2,218,612Other income 14 84,804 440,130Total Revenue 37,711,794 31,040,075

ExpensesSalaries and Allowances 15/16 22,916,184 20,736,864Training and Seminars 17 757,350 1,065,264Rent and Utilities 18 4,597,316 3,755,635Office and Administrative expenses 19 4,688,536 2,175,755Depreciation and Amortisation 4,408,536 2,218,612Total Expenses 37,367,922 29,952,130

Surplus/(Deficit) for the year 343,872 1,087,946

statement of Financial Performancefor the year ended 31 December 2014

FINANCIAL INTELLIGENCE UNIT

The notes to the accounts on pages 45 to 59 form part of the financial statements.

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FIU ANNUAL REPORT 2014 41

Capital Fund General Fund TotalRs Rs Rs

Balance as at 01 Jan 2014 13,443,718 2,247,953 15,691,671

Grant received during the year 2,573,546 - 2,573,546

Deferred Grant released to Statement of Financial Performance

(4,408,536) - (4,408,536)

Surplus/(Deficit) for the year - 343,872 343,872

Closing balance 11,608,728 2,591,825 14,200,553

statement of Changes in General and Capital Fundsfor the year ended 31 December 2014

FINANCIAL INTELLIGENCE UNIT

The notes to the accounts on pages 45 to 59 form part of the financial statements.

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FIU ANNUAL REPORT 201442

statement of Cash Flowsfor the year ended 31 December 2014

FINANCIAL INTELLIGENCE UNIT

Year 2014 Year 2013

Rs Rs

Cash flows from operating activities

Surplus/(Deficit) for the year 343,872 1,087,946

Adjustment for:

Interest income (76,529) (63,273)

Depreciation and Amortisation 4,408,536 2,731,042

Unrealised income – Increase in Pension Asset (789,205) (997,447)

Deferred capital grant for the year (4,408,536) (2,218,612)

(521,862) 539,656

Changes in Working capital:

(Increase)/Decrease in receivables (377,653) (182,725)

Decrease/(Increase) in other financial assets - 52,703

(Decrease)/Increase in loan from Government - (52,703)

Increase/(Decrease) in provision for passage benefits 99,499 225,718

(Decrease)/Increase in provision for leave refund 988,805 615,109

(Decrease)/Increase in payables 382,892 (1,348,495)

1,093,543 (690,393)

Net cash flows from operating activities 571,681 (150,737)

Cash flow from investing activities

Acquisition of Property, Plant and Equipment (2,441,359) (3,432,677)

Acquisition of intangible assets – goAML project - (5,699,844)

Interest received 76,529 63,273

Net cash used in investing activities (2,364,830) (9,069,248)

Cash flow from financing activities

Grant used for capital expenditure 2,573,546 9,702,804

Net cash used in financing activities 2,573,546 9,702,804

Net increase in cash and cash equivalents 780,397 482,819

Cash and cash equivalents at 01 January 2014/2013 1,503,561 1,020,742

Cash and Cash equivalent at 31 December 2014/2013 2,283,958 1,503,561

The notes to the accounts on pages 45 to 59 form part of the financial statements.

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FIU ANNUAL REPORT 2014 43

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FIU ANNUAL REPORT 201444

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FIU ANNUAL REPORT 2014 45

Note 1: Reporting entity

The Financial Intelligence Unit (FIU) is a public office established by the Financial Intelligence and Anti-Money Laundering Act, 2002 which was passed by the National Assembly in 2002 and proclaimed on 10 June 2002. The objective of the Financial Intelligence Unit is to combat money laundering, terrorist financing and other financial crimes.

The registered office address of the FIU is at 7th Floor Ebène Heights, 35 Ebène Cybercity, Ebène.

The financial statements of the Financial Intelligence Unit have been prepared in a spirit of adherence to the good governance principles of accountability and transparency.

Note 2: Basis of preparation

The financial statements of the FIU have been prepared in accordance with the International Public Sector Accounting Standards (IPSAS) issued by International Public Sector Accounting Board (IPSASB) which is a Board of the International Federation of Accountants Committee (IFAC).

The financial statements have been prepared on a going-concern basis and the accounting policies have been applied consistently throughout the period. They have been prepared on the historical cost basis.

The preparation of financial statements in conformity with IPSAS and generally accepted accounting practices requires the use of estimates and assumptions that affect the reported amounts of assets and liabilities at the date of the financial statements and the reported amounts of revenue and expenses during the reporting period.

In the application of the FIU’s accounting policies, which are described in Note 5, management is required to make judgements, estimates and assumptions about the carrying amounts of assets and liabilities that are not readily apparent from other sources. The estimates and associated assumptions are based on historical experience and other factors that are considered to be relevant. Actual results may differ from these estimates. The estimates and underlying assumptions are reviewed on an on-going basis. Revisions to accounting estimates are recognised in the period in which the estimate is revised if the estimate affects only that period or in the period of the revision and future periods if the revision affects both current and future periods. Estimates include, but are not limited to fair valuation of accounts receivables, contingent assets and liabilities, and degree of impairment of property, plant and equipment.

The financial statements are presented in Mauritian Rupees.

notes to the accounts for the year ended 31 December 2014

FINANCIAL INTELLIGENCE UNIT

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notes to the accounts for the year ended 31 December 2014 (Cont’d)

FINANCIAL INTELLIGENCE UNIT

Note 3: Accounting Standards - IPSAS

The FIU has adopted the International Public Sector Accounting Standards (IPSAS) since 01 January 2011.

At the date of authorisation of the financial statements, the Accounting Standard referred below was not relevant to the FIU’s operations. It did not have any material effect on the accounting policies and disclosures and hence has not been adopted.

• IPSAS32ServiceConcessionArrangements:Grantor(effectivedate:01January2014)

Note 4: Measurement Base

The accounting principles recognised as appropriate for the measurement and reporting of the financial performance, cash flows, and financial position on an accrual basis using historical cost are followed in the preparation of the financial statements.

Note 5: Accounting Policies

The following specific accounting policies that materially affect the measurement of financial performance and the financial position are applied:

(a) Revenue Recognition

IncomeIncome is measured at the fair value of the consideration received. Government GrantThe revenue necessary to finance the expenditure of FIU is derived from the National Assembly by means of the Annual Estimates (Program Based Budget) and the corresponding Appropriation Act. Government recurrent grant is recognised to the extent that the grant has been received.

Government grant used to finance expenditure on the property, plant and equipment and intangible assets are transferred from government grant received to capital grant in the Statement of Financial Position and is released to the Statement of Performance over the life of the assets.

Income from seminars and workshopsThe FIU may also generate income from fees charged to participants in seminars and workshops organised by the FIU.

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notes to the accounts for the year ended 31 December 2014 (Cont’d)

(b) Accrual accountingAccrual accounting under IPSAS does not require the matching of revenue to related expenses. The cash flows arising from contributions and the related expenses take place in current and future accounting periods.

(c) Other ReceivablesAccounts receivable are recorded at their estimated realisable value after providing for doubtful and uncollectible debts.

(d) LeaseThe FIU has an operating lease but does not have any finance lease.

(e) Foreign currency transactionsTransactions in foreign currencies are translated to Mauritian rupee at the exchange rate ruling at the date of transaction.

(f) Employee EntitlementsEmployee entitlements to salaries, pension costs, and other benefits are recognised when they are earned.

Sick LeavesEmployees are allowed to accumulate sick leaves not taken at the end of each calendar year up to a maximum of 110 days, in a sick leave bank as at 31 December 2014.The balance of bank sick leave is valued at the end of the financial year and is recognised as both short term and long term payables. Beyond this ceiling of 110 days, officers are refunded part of the annual entitlement of sick leaves not taken at the end of every calendar year and is expensed to the Statement of Financial Performance.

Passage BenefitsA provision is made for the estimated liability for passage benefits. The balance of passage benefits accrued to each staff are valued at year end. The annual increase in passage benefits is expensed to the Statement of Financial Performance.

Gratuity and Annual LeaveEmployees employed on contract are paid gratuity, any annual leaves not taken and the passage benefits, when due. These costs are expensed to the Statement of Financial Performance.

Other Post-Employment BenefitsProvision for accrued Vacation LeavesNo provision is made for the estimated liability for vacation leave as employee benefits for accumulated vacation leave can only be cashed in extremely rare cases.

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Retirement benefitsProvisions for retirement benefits for pensionable officers of the FIU are made in accordance with the Statutory Bodies Pension Act 1978 as amended. The State Insurance Company of Mauritius (SICOM) manages the Pension and Family Protection Schemes in favour of the officers of the FIU. These schemes are contributory both by the FIU and the officers.

The FIU has a Defined Benefit Pension scheme for which the Retirement benefit asset is valued at each year end by the actuary. Any pension assets or liabilities are shown in the Statement of Financial Position. Any difference arising in actuarial valuation is recognised in the Statement of Financial Performance in the same period.

The FIU also has a Defined Contribution Pension scheme. All pension payments are expensed to the Statement of Financial Performance.

(g) Property, plant and equipment (PPE)

Recognition and measurementProperty, plant and equipment are stated at historical cost or revalued amount less accumulated depreciation and any impairment losses. PPE are depreciated (as outlined below) at rates estimated to recognise the consumption of economic benefits of the PPE over their useful lives.

Where the carrying amount of an asset is greater than its estimated recoverable service amount, it is written down to its recoverable amount. An impairment loss is recognised for the amount by which the carrying amount of the asset exceeds its recoverable amount which is the higher of an asset’s net selling price or its value in use.

Gains and losses on disposal are determined by comparing proceeds with carrying amounts and are included in the Statement of Financial Performance.

Impairment reviews are undertaken annually for all assets that, in our opinion, need to be revalued.

DepreciationDepreciation is calculated either on the straight-line or reducing balance method so as to write off the cost of each asset to their residual value over their estimate useful life. The annual depreciation rates used and basis of depreciation are as follows:

% Computer equipment 33 1/3 Straight LineOffice Equipment 20 Straight LineFurniture and Fittings 20 Straight LineMotor vehicle 20 Reducing balanceLeasehold Improvement 20 Straight Line

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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Cost of software for operating system and office tools when acquired with computers are included in the hardware costs and depreciated as for any computer equipment. Capital Expenditure costing less than Rs 5,000 is expensed to the statement of financial performance.

(h) Intangible AssetsIntangible Assets are recognised only if:• It isprobablethat futureeconomicbenefitsthatareattributabletotheassetswill

flow to the organisation; and• Thecostofassetscanbemeasuresreliably.

Cost of acquired computer software are amortised using the straight-line basis over the estimated period of utilisation not exceeding three years. The amortisation expense on intangible assets is recognised in the Statement of Financial Performance in the expense category consistent with the function of the intangible assets.

(i) Financial InstrumentsFinancial instruments are recognised when the FIU becomes a party to the contractual provisions of the instrument until such time when the rights to receive cash flows from those assets have expired or have been transferred and the FIU has transferred substantially all the risks and rewards of ownership.

FIU uses only non-derivative financial instruments as part of its normal operations. These financial instruments include accounts receivable and accounts payable.

All financial instruments are recognised in the statement of financial position at their fair values.

Gains or losses arising from changes in the fair value of financial instruments are included within the statement of financial performance in the period in which they arise.

(j) TaxationNo provision has been made in the financial statements for income tax and value added tax, on the basis that the FIU, as a government statutory body, is exempted.

(k) Provisions and Contingent LiabilitiesProvisions are made for future liabilities and charges where FIU has a present legal or constructive obligation as a result of past events and it is probable that FIU will be required to settle the obligation.

Provisions are measured at management’s best estimate of the expenditure required to settle the obligation at the date of the Statement of Financial Position.

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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Other commitments, which do not meet the recognition criteria for liabilities, are disclosed in the notes to the financial statements as contingent liabilities when their existence will be confirmed only by the occurrence or non-occurrence of one or more uncertain future events which are not wholly within the control of FIU.

As at the reporting date of 31 December 2014, the FIU was not involved in any litigation, claim judgment, settlements, or any transactions or charges.

(l) Risk ManagementFinancial risksThe FIU, as a public sector entity, is not much exposed to financial risks.The FIU does not use any derivative financial instruments to hedge risk exposures.

Credit riskThe FIU is not much exposed to credit risk.

Currency riskFIU is not exposed to any currency risk.

Interest rate riskFIU is not exposed to any interest rate risk.

(m) Events after statement of Financial Performance dateThe FIU’s office will be relocated to another building. The tenant has claimed an amount of Rs. 4,452,479 excluding VAT for fit-out works done for part of the building that would have been rented for 5 years since November 2014. This matter is under consideration.

Apart from the above, there were no major events after the Statement of Financial Performance date.

(n) Employee DisclosureAs at 31st December, 2014, the FIU had 33 employees on establishment.

(o) Key Management PersonnelThe aggregate remuneration of key management personnel was Rs 10,845,863 for the fiscal year 2014 and Rs 9,660,160 for the fiscal year 2013.

Year 2014 Year 2013

Rs Rs

Key Management Personnel: Director 3,502,960 3,497,560

Key Management Personnel: Others 7,342,903 6,162,600

10,845,863 9,660,160

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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FINANCIAL INTELLIGENCE UNIT

(p) Related PartiesFor the purposes of these financial statements, parties who are considered to be related to the FIU are Government ministries/departments if they have the ability, directly or indirectly, to control the FIU or exercise significant influence over the financial and operating decision making, or vice versa. Related parties may be individuals or other entities. Related party transactions were carried out at commercial terms and conditions.

Note 6: Cash and Cash Equivalents

Note 7: Receivables

Receivables represent prepayments at the date of the statement of financial position.

Year 2014 Year 2013

Rs Rs

Cash in hand 4,337 5,000

Cash at bank 2,279,621 1,498,561

2,283,958 1,503,561

Year 2014 Year 2013

Rs Rs

Other prepayments 1,012,230 634,577

1,012,230 634,577

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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Note 8: Property, Plant and Equipment

Note 9: Intangible AssetsIntangible assets consist solely of software

ComputerEquipment

Office Equipment

Furniture &Fittings

Motor Vehicle

LeaseholdImprovement Total

Rs Rs Rs Rs Rs Rs

COSTAt 01.01.2014 13,692,162 1,072,613 1,637,030 2,579,999 572,729 19,554,533Additions 297,405 185,889 753,848 1,130,000 74,217 2,441,359At 31.12.2014 13,989,567 1,258,502 2,390,878 3,709,999 646,946 21,995,892

DEPRECIATION

At 01.01.2014 9,500,257 812,882 1,048,476 733,000 240,682 12,335,297Charge for the year

1,657,512 102,850 237,036 396,644 114,546 2,508,588

At 31.12.2014 11,157,769 915,732 1,285,512 1,129,644 355,228 14,843,885

NET BOOK VALUE

At 31.12.2014 2,831,798 342,770 1,105,366 2,580,355 291,718 7,152,007

At 31.12.2013 4,191,905 259,731 588,554 1,846,999 332,047 7,219,236

Year 2014 Year 2013

Rs Rs

COST

At 01.01.2014 5,699,844 2,468,000

Additions - 3,231,844

At 31.12.2014 5,699,844 5,699,844

AMORTISATION

At 01.01.2014 244,650 -

Charge for the year 1,899,948 244,650

At 31.12.2014 2,144,598 244,650

NET BOOK VALUE

At 31.12.2014 3,555,246 5,455,194

The cost of the fully depreciated assets amounts to Rs. 10,788,363.

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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FINANCIAL INTELLIGENCE UNIT

Note 10: Payables

Payables include invoices received from suppliers not yet settled and obligations to suppliers for services performed not yet invoiced. Accruals have also been made for staff costs.

Note 11: Provision for Passage Benefits and Leave Refund

Provisions made for passage benefits and leave refund represent cumulative amount of passage benefits and leave refund earned by staff at the end of the year. The provision for leave refund amounted to Rs 3,531,536 out of which Rs 607,175 was transferred to short term liabilities. The provision for passage benefits totalled Rs 974,102 at 31 December 2014.

Note 12: Retirement Benefits Obligations

A defined benefit asset of Rs 5,494,418 was calculated and recognised for the year ending 31 December 2014, together with a resulting unrealised income of Rs 789,205.

During the year ending 31 December 2014, the FIU has contributed an amount of Rs 791,968 to the FIU Pension Fund under the Defined Benefit Scheme and an amount of Rs. 268,409 under the Defined Contribution Scheme.

Year 2014 Year 2013

Rs Rs

Payables 691,668 119,680

Audit fees 100,000 100,000

Provision for gratuity to officers on contract - 189,096

791,668 408,776

Year 2014 Year 2013

Rs Rs

Provision for leave refund 3,531,536 2,542,731

Provision for passage benefits 974,102 874,603

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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The actuarial valuation at year ending 31 December 2014 of the Retirement Benefits Obligations managed by State Insurance Company of Mauritius Ltd is as follows:

Year 2014 Year 2013Rs Rs

Amounts recognised in statement of financial position at end of year:

Present value of funded obligation 7,437,742 5,864,687(Fair value of plan assets) (10,569,209) (8,961,450)

(3,131,467) (3,096,763)Present value of unfunded obligation - -Unrecognised actuarial (loss) (2,362,951) (1,608,450)

Liability recognised in statement of financial position at end of year (5,494,418) (4,705,213)

Amounts recognised in statement of financial performance:

Current service cost 772,293 711,117(Employee contributions) (527,979) (563,355)Fund expenses 26,399 28,219Interest cost 469,175 277,824(Expected return on plan assets) (760,103) (603,670)Actuarial loss/(gain) recognised 22,978 -Past service cost recognised - -Total, included in staff costs 2,763 (149,865)

Movements in liability recognised in statement of financial position

At start of year (4,705,213) (3,707,766)Total staff cost as above 2,763 (149,865)(Contributions paid by employer) (791,968) (847,582)At end of year (5,494,418) (4,705,213)

Actual return on plan assets: 528,095 748,593

Main actuarial assumptions at end of year:

Discount rate 8.0% 8.0%

Expected rate of return on plan assets 8.0% 8.0%

Future salary increases 5.5% 5.5%

Future pension increases 3.5% 3.5%

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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FINANCIAL INTELLIGENCE UNIT

The assets of the plan are invested in funds managed by State Insurance Company of MauritiusLtd. The discount rate is determined by reference to market yield on bonds.

Year 2014 Year 2013Rs Rs

Reconciliation of the present value of the defined benefit obligationPresent value of obligation at start period 5,864,687 3,472,806Current service cost 772,293 711,117Interest cost 469,175 277,824(Benefits paid) (213,884) (48,754)Liability (gain)/loss 545,471 1,451,694Present value of obligation at end of period 7,437,742 5,864,687

Reconciliation of fair value of plan assetsFair value of plan assets at start of period 8,961,450 6,878,892Expected return on plan assets 760,103 603,670Employer contributions 791,968 847,582Employee contributions 527,979 563,355(Benefits paid + other outgo) (240,283) (76,973)Assets (loss) (232,008) 144,924Fair value of plan assets at end of period 10,569,209 8,961,450

Distributions of plan assets at end of period

Percentage of assets at end of yearGovernment securities and cash 57.1% 59.1%Loans 4.1% 4.9%Local equities 21.1% 21.9%Overseas bonds and equities 17.0% 13.4%Property 0.7% 0.7%Total 100% 100%

Additional disclosures on assets issued or used by the reporting entityPercentage of assets at end of year % %Assets held in the entity’s own financial instruments 0 0Property occupied by the entity 0 0Other assets held by the entity 0 0

History of obligations, assets and experience adjustmentsYearCurrency Rs RsFair value of plan assets 10,569,209 8,961,450(Present value of defined benefit obligation) (7,437,742) (5,864,687)Surplus 3,131,467 3,096,763

Asset experience (loss) during the period (232,008) 144,924Liability experience gain/(loss) during the period (545,471) (1,451,694)

Year 2015Expected employer contribution 829,089

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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Note 13: Government Grant

Note 14: Other Income

Year 2014 Year 2013

Rs Rs

Amount received during the year 35,792,000 38,084,138

Amount devoted to capital expenditure (2,573,546) (9,702,805)

33,218,454 28,381,333

Year 2014 Year 2013

Rs Rs

Interest Income 76,529 63,273

Unrealised Income – Pension Assets - 216,942

Stale Cheques 8,275 147,915

Insurance Claim Settlement - 12,000

84,804 440,130

Year 2014 Year 2013

Rs Rs

Remuneration to Chairman and Board members 1,435,200 1,449,000

Total Salaries and Allowances (Note 15 & 16) 22,916,184 20,736,864

Year 2014 Year 2013

Rs Rs

Salaries and Wages 18,709,269 16,511,954

Contribution to FIU Pension Fund 271,172 66,065

Contribution to FPS, Medical Scheme & NPF 473,425 424,883

Passage Benefits 640,896 575,966

Gratuity & Annual leave refund 426,918 788,112

Leave Refund 959,304 920,884

21,480,984 19,287,864

Note 15: Salaries and Allowances

The monthly average salary, bonus and allowances for the year ended 31 December 2014 amounted to Rs 1,559,106 compared to Rs 1,365,308 for the year ended 31 December 2013.

Note 16: Remuneration of Board Members

The monthly average remuneration to Chairman and Board members for the year ended 31December 2014 and year ended 31 December 2013 amounted to Rs 119,600.

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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Note 17: Training and Seminars

Year 2014 Year 2013

Rs Rs

Local & Overseas Training 137,772 176,525

Overseas missions 594,604 852,856

Overseas visitors 24,974 35,883

757,350 1,065,264

Year 2014 Year 2013

Rs Rs

Rent 3,107,436 2,612,844

Utilities 1,489,880 1,142,791

4,597,316 3,755,635

Year 2014 Year 2013

Rs Rs

Subscription fees 104,838 132,408

Motor vehicle running expenses 346,108 294,743

Printing, postage and stationery 224,737 283,831

Advertisement 157,516 205,148

IT-related expenses 2,867,265 657,261

General Expenses 375,111 283,454

Staff welfare Development 14,882 12,465

Bank Charges 7,529 6,285

Professional fees 590,550 300,160

4,688,536 2,175,755

Note 18: Rent and Utilities

Rent for 2014 has increased as the FIU has occupied additional floor space of 6,400 sq ft in the same building at the monthly rate of Rs 247,296 since November 2014. The contract has not yet been finalised with the NPF. Based on claim received, we have expensed some Rs 494,592 for the year 2014 for the additional space. The FIU has already shown its interest to the present lessor (NPF) that it would be relocating to another building.

Note 19: Office and Administrative Expenses

The IT-related expenses comprises of the annual support fee amounting to Rs 2,167,532 paid for the goAML software. Professional fees include payment made to FIU’s Legal Advisor and Communication Consultant.

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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Note 20: Reconciliation of Original Budget, Revised Budget and Actual Revenue/Expenses

Funds for expenditure by the FIU are approved in annual Government Estimates under Ministry of Finance and Economic Development (MOFED) for year 2014) as a one-line budget item. The original budget for the fiscal year 2014 amounted to Rs 40 million and Rs 35,8 million was released by MOFED during the fiscal year.

The Statement of Comparison of Budgeted and Actual Amounts shows the budgetary resultsreconciled with the results after IPSAS adjustments for the period as reported in the financial statements. IPSAS adjustments are accounting entries required to conform to IPSAS and are not Part of the FIU’s budgetary reporting. These adjustments principally concern accrual accounting relating to expenses and revenues, property, plant and equipment and related amortization, depreciation and impairment together with provisions deemed necessary.

In order to reconcile the budget results to the results after IPSAS adjustments for the period, differences between budget accounting and accrual accounting need to be taken into account. The most significant of these differences are the following:

a) In budget accounting, revenue is required to cover all committed expenditures. In accrualaccounting, revenue and expenses only includes amounts corresponding to amounts accruing to the period. The difference is treated as deferred revenue or expenses in accrual accounting.

b) In budget accounting, capital expenditures are recorded as current year expenses. In accrual accounting this expense is capitalised and depreciated over the useful lives of the assets. These capital expenditures and associated depreciation are recorded at their net value as assets in the Statement of Financial Position. Depreciation expense is recorded in the Statement of Financial Performance.

c) In budget accounting, expenditure for employee benefits is accounted for on a pay as you go basis as is the case for payments of pensions on retirement. In accrual accounting, the expense is estimated by an actuary in accordance with a methodology set out in accounting standards. Basically, the pension and post-employment benefits obligation is to be reported in theStatement of Financial Position.

FINANCIAL INTELLIGENCE UNIT

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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statement showing Reconciliation of actual Cash Flows with Financial statements for the year ended 31 December 2014

FINANCIAL INTELLIGENCE UNIT

Year Ended 2014

Rs

Actual Income as presented in the Statement of Budgets, Actual Cash 35,876,804

and Accrual Based Amounts

Basis Differences:

Capital grant received (2,573,546)

Deferred income 4,408,536

Actual amount as per Statement of Financial Performance 37,711,794

Payments

Actual Expenditure as presented in the Statement of Budgets, Actual 35,098,101

Cash and Accrual Based Amounts

Basis Differences:

Staff Costs 107,647

Operational Costs 194,998

Acquisition of Non-Current Assets (2,441,360)

Depreciation 4,408,536

Actual amount as per Statement of Financial Performance 37,367,922

notes to the accounts for the year ended 31 December 2014 (Cont’d)

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appendicesAppendix I

Board members

Appendix II

organisation Chart

Appendix III

staff List

Appendix IV

overseas missions, Conferences, seminars, training Courses of FiU officers in 2014

Appendix V

Updated List of moUs

Appendix VI

egmont membership

Appendix VII

important Websites

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appendix iBoard members

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Board membersFINANCIAL INTELLIGENCE UNIT

Chairperson

L.C.L.K.S Sam SoonBA Hons (Law and Economics) Keele,Barrister-at-Law

Members

Gunness Ramdewar, SA, OSK

Percy PascalFormer Risk Management Director of a commercial bank

The Chairman, Board members and the Director of the FIU Mauritius are appointed by the President of the Republic of Mauritius on the recommendation of the Prime Minister made in consultation with the Leader of the Opposition as laid down under Sections 12(2) and 9(2) of the Financial Intelligence and Anti- Money Laundering Act, 2002 and Section 12 of the Anti-Money Laundering (Miscellaneous Provisions) Act, 2003.

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appendix iiorganisation Chart

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FIU ANNUAL REPORT 2014 65

appendix iiistaff List

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staff List as at 31st march 2015FINANCIAL INTELLIGENCE UNIT

Grade No. of Officers

1 Director 1

2 Assistant Director 1

3 Senior Financial Intelligence Analyst 1 vacant

4 Head of Compliance 1

5 Financial Intelligence Analyst 5

6 Legal Manager 1

7 Data Intelligence Manager 1

8 Analyst Operations 8

9 Senior Intelligence Officer 1

10 Intelligence Officer 4

11 Data Intelligence Assistant 1

12 Data Processing Assistant 1

13 Corporate Affairs Manager 1

14 Accounting Technician 1

15 Office Secretary 2

16 Assistant Office Secretary 1 vacant

17 Driver / General Assistant 3

Human Resources of FIU Mauritius

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appendix iVoverseasmissions,Conferences, seminars,trainingCourses of FiU officersin 2014

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overseas missions, Conferences, seminars,training Courses of FiU officers in 2014

FINANCIAL INTELLIGENCE UNIT

Participants Training/Workshop/Conference Organizer Country Dates

Mr. M. Ramdhary

ESAAMLG’s SecondRound of MutualEvaluation Training for Assessors

ESAAMLGWindhoek,Namibia

27 - 31January,2014

Mr D. BikooESAAMLG 27th TaskForce of SeniorOfficials Meetings

ESAAMLGArusha,Tanzania

31 March -04 April,2014

Ms. K. Char Sit yee

ESAAMLG’s SecondRound of MutualEvaluation Training for Assessors

ESAAMLGVictoria Falls,Zimbabwe

27 April - 02 May,2014

Mr. M. Ramdhary

Combatingtransnational organized crime at sea - following the money trail and pursuing networks and organizers of maritime crime

EU-INTERPOL Brussels20 - 21May,2014

Mr D. Bikoo22nd Egmont PlenaryMeetings

Egmont GroupLima,Peru

01 - 06June,2014

Ms. K. Char Sit yee

Training on NationalRisk AssessmentNRA) and Risk BasedApproach (RBA)

ESAAMLGPretoria,South Africa

30 June - 04 July,2014

Ms B. MigaleDevelop CapacityBuilding Action Plan for Financial Intelligence Units

COMESAMahé,Seychelles

26 - 28November,2014

Mr. K. Ramdhary & Mrs. V. Dhunnoo

Training Visit toSAMIFIN

FIU Mauritius Madagascar12 - 16December,2014

Overseas

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Participants Training / Workshop /Seminar Organizer Venue Dates

Mr N. HeerasingWorkshop on “DataProtection - A Must for Today’s Business”

MicrosoftCorporation incollaboration withData ProtectionOffice Mauritius

Maritim Hotel,Balaclava

19February,2014

Ms. A. Heera and Mr N. Padaruth

Workshop onCybercrime

Office of theDirector of PublicProsecutions incollaboration withthe EuropeanUnion

Rajsoomer Lal-lah Lecture Hall, Garden Tower,Port Louis

26 & 28February,2014

Mr. C. KokilNational Cyber Securi-ty Strategy Validation Workshop

NationalComputer Board

Conference HallA.Cyber Tower1, Ebène

24March,2014

Mr. K. Ramdhary,Mr. C. Kokil

Global Action onCybercrime(GLACy) Project

Ministry ofInformation andCommunicationTechnology

Ministry ofInformation and CommunicationTechnology

04April,2014

Ms Z. Hossenally

Workshop on Training and Employment of Disabled Persons Act (amended 2012) and its applications

Training andEmployment ofDisabled PersonsBoard

Training Unit, Ministry of social Security N.S & R.I

22May,2014

Mr N. Padaruth,Mr. L. Tulsi,Mr. N.S. Dabee

Fraud Prevention and Detection Workshop

PricewaterhouseCoopers Ltd

Hennessy ParkHotel, Ebène

11 - 12August,2014

Mr. C. KokilCybercrime Capacity Building in Mauritius

Ministry ofInformation andCommunicationTechnology incollaboration withEU and Council ofEurope

Intercontinental Resort, Balaclava

11 - 12August,2014

Mr. K. Ramdhary,Mr. N. Heerasing

AML/CFT in InsuranceSector

BLC ChambersHennessy ParkHotel, Ebène

27August,2014

Ms. V Seeruttun,Mrs. V. Dhunnoo,Mrs y. Isseljee-Furreed, Mr L.Tulsi

Workshop on BidEvaluation

ProcurementPolicy Office

Conference Room

09 October,2014

Ms. P. Ramen CPE Training Course

Port LouisChapter of theAssociation ofCertified FraudExaminers

Le Meridien Hotel,Pointe auxPiments

19 - 20November,2014

Mr. C. KokilCyber SecurityConference

NationalComputer Board

SVICC, Pailles28November,2014

Local

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appendix VUpdated Listof moUs

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Updated List of moUsFINANCIAL INTELLIGENCE UNIT

Organisations Date of Signature

1 Financial Services Commission (FSC) June, 2004

2 Registrar of Companies (ROC) July, 2006

3 Mauritius Revenue Authority-Customs March, 2007

4 Bank of Mauritius (BOM) November, 2009

5 Enforcement Authority March, 2013

Jurisdiction Foreign FIUs Date of Signature

1 South Africa Financial Intelligence Centre (FIC) August, 2003

2 AustraliaAustralian Transaction Reports & Analysis

Centre (AUSTRAC)October, 2003

3 Principality of MonacoService d’Information et de Contrôle sur les

Circuits Financiers (SICCFIN)June, 2004

4 Kingdom of Thailand Anti- Money Laundering Office (AMLO) October, 2004

5 BelgiumFinancial Intelligence Processing Unit (CTIF-

CFI)November, 2005

6 CanadaFinancial Transactions and Reports Analysis

Centre (FINTRAC)June, 2006

7 FranceTraitement du Renseignement et Action

contre les Circuits Financiers Clandestins (Tracfin)

October, 2006

8 Cayman Islands Financial Reporting Authority (CAyFIN) December, 2006

9 United Kingdom Serious Organised Crime Agency (SOCA) May, 2007

10 Netherlands AntillesMeldpunt OngebruikelijkeTransacties Van de Nederlandse Antillen/ FIU Netherlands

AntillesMay, 2007

11 Republic of IndonesiaIndonesian Financial Transaction Reports

and Analysis CentreMay, 2007

12 India Financial Intelligence Unit- India (FIU- IND) February, 2008

13 Nigeria Nigerian Financial Intelligence Unit (NFIU) October, 2009

14 SenegalCellule Nationale de Traitement des

Informations FinancièresOctober, 2009

15 MalaysiaUnit Perisikan Kewangan, Bank Negara

Malaysia (UPWBNM)October, 2009

16 EgyptEgyptian Money Laundering Combating

Unit (EMLCU)March, 2010

17 Qatar Qatar Financial Information Unit (QFIU) June, 2010

18 Luxembourg Financial Intelligence Unit Luxembourg March, 2011

19 USAFinancial Crimes Enforcement Network

(FinCEN)March, 2011

20 Bermuda Financial Intelligence Agency Bermuda March, 2011

21 Malawi Financial Intelligence Unit Malawi April, 2012

22 Seychelles Financial Intelligence Unit September, 2013

MoUs signed with Domestic Organisations

MoUs signed with Foreign FIUs

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appendix Viegmontmembership

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egmont membershipList of african egmont FiUs

FINANCIAL INTELLIGENCE UNIT

Name of FIU JurisdictionDate joined

Egmont

Financial Intelligence Unit (FIU) Mauritius July 2003

Financial Intelligence Centre (FIC)South Africa

July 2003

Egyptian Money Laundering Combating Unit (EMLCU) Egypt June 2004

Nigerian Financial Intelligence Unit (NFIU) Nigeria May 2007

Financial Intelligence Unit (FIU-Malawi) Malawi May 2009

Cellule Nationale de Traitement des Informations Financières/National Financial Intelligence Processing Unit (CENTIF-SENEGAL)

Senegal May 2009

Cellule Nationale de Traitement des Informations Financières de Côte d’Ivoire (CENTIF-CI)/National Unit for the Processing of Financial Information in Côte d’Ivoire

Côte d’Ivoire

June 2010

Agence Nationale d’Investigation Financière (ANIF)/National Agency for Financial Investigation (NAFI)

Cameroon June 2010

Cellule Nationale de Traitement des Informations Financières (CENTIF-Mali)

Mali June 2011

Financial Information Processing Unit of Morocco Morocco June 2011

National Agency for Financial Investigation (NAFI) Gabon July 2012

Tunisian Financial Analysis Committee (CTAF) Tunisia July 2012

CTRF Algeria Algeria July 2013

CENTIF-Burkina FasoBurkina Faso

July 2013

Seychelles FIU Seychelles July 2013

CENTIF-Togo Togo July 2013

Kitengo cha Kudhibiti Biashara ya Fedha Haramu / Financial Intelligence Unit (FIU)

Tanzania June 2014

Unidade de Informação Financeira (UIF) / Financial Intelligence Unit (FIU)

Angola June 2014

Financial Intelligence Unit (FIC) Namibia June 2014

Agence Nationale d’Investigation Financière du Tchad (ANIF) / National Agency for Financial Investigation (NAFI)

Chad June 2014

Financial Intelligence Centre (FIC) Ghana June 2014

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appendix ViiimportantWebsites

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important WebsitesFINANCIAL INTELLIGENCE UNIT

FIU Mauritius’ AML/CFT Partners Websites

Local

Independent Commission Against Corruption http://www.icac.mu

Police http://police.govmu.org

MRA- Customs http://www.mra.mu

Bank of Mauritius https://www.bom.mu

Financial Services Commission http://www.fscmauritius.org

Registrar of Companies http://companies.govmu.org

Africa

Eastern and Southern Africa Anti Money Laundering Group http://www.esaamlg.orgGroupe Intergouvernemental d’Action contre le Blanchiment d’Argent en Afrique de l’Ouest

http://web.giaba.org

Middle East and North Africa Financial Action Task Force http://www.menafatf.org

International

Financial Action Task Force http://www.fatf- ‐gafi.org

Egmont Group http://www.egmontgroup.org

International Monetary Fund http://www.imf.org

World Bank http://www.worldbank.org

International Money Laundering Information Network http://www.imolin.org

United Nations Office on Drugs and Crime http://www.unodc.org

International Criminal Police Organisation http://www.interpol.int

General Information on Mauritius Websites

Government of Mauritius http://www.govmu.org

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7th Floor, Ebène Heights34, Ebène Cybercity, EbèneRepublic of MauritiusT (230) 454 1423F (230) 466 2431email: [email protected]: www.fiumauritius.org