Financial Intelligence Agency...Financial Intelligence Agency Annual Report 2018/19 Letter from Director to H.E. The Governor FINANCIAL INTELLIGENCE AGENCY TURKS AND CAICOS ISLANDS

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Financial Intelligence Agency Annual Report 2018/19

Financial Intelligence Agency - Annual Report 2018-19

Annual Report

2018/19

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Financial Intelligence Agency 201 Cabot House, Leeward Highway | Providenciales

Turks and Caicos Islands | TKCA1ZZ Office: (649) 941-7691/3692/8429 | Fax: (649) 941-7440

www.fia.tc | [email protected]

http://www.fia.tc/http://www.fia.tc/mailto:[email protected]:[email protected]

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Table of Contents Mission and Vision ....................................................................................................................................... 4

Letter from Director to H.E. The Governor .................................................................................................. 6

Message from the Chairperson of the Board of Directors .......................................................................... 7

Director’s Message ....................................................................................................................................... 8

Suspicious Activity/Suspicious Transaction Reports (SARs/STRs) .............................................................. 9

FIs and DNFBPs Yearly Comparison ........................................................................................................... 10

Customs Declarations ................................................................................................................................. 13

Disposition of SARs/STRs ........................................................................................................................... 14

Domestic and International Requests for information (Incoming and Outgoing) ................................... 14

Requests for Information by the FIA ......................................................................................................... 19

Monetary Value of SARs/STRs ................................................................................................................... 20

SARs/STRs by Customer ............................................................................................................................. 22

Occupation or Business Activity ............................................................................................................ 22

Nationality of subjects in SARs/STRs ..................................................................................................... 23

Reason for Reporting (Indicators).............................................................................................................. 25

Customer Profile ..................................................................................................................................... 26

Source of Funds ....................................................................................................................................... 27

Adverse Media Report ............................................................................................................................ 27

Declined Business ................................................................................................................................... 27

Email/System Compromise/Wire Fraud ................................................................................................. 28

Blackmail ................................................................................................................................................. 28

Cheque Fraud .......................................................................................................................................... 28

Cheque Kiting .......................................................................................................................................... 28

Concealing Criminal Property ................................................................................................................. 29

Consent SAR ............................................................................................................................................ 29

Emergency Fraud Scam ........................................................................................................................... 29

High Risk Jurisdiction .............................................................................................................................. 29

Identification Documents ....................................................................................................................... 30

Structuring .............................................................................................................................................. 30

Suspicious Activity ................................................................................................................................... 30

Suspicious Document-............................................................................................................................. 30

Trends and Typologies ............................................................................................................................... 31

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Email Fraud/Compromise ....................................................................................................................... 31

Cheque Kiting .......................................................................................................................................... 31

FIA Activities ............................................................................................................................................... 32

FIA Commences Strategic Assessment of Human Smuggling/Trafficking in the TCI .............................. 32

Staff Development and Training ............................................................................................................. 32

CFATF Mutual Evaluation ........................................................................................................................ 32

Outreach and Awareness ........................................................................................................................ 32

16th August 2018 ................................................................................................................................. 32

April 2018 ............................................................................................................................................ 33

December 2018 ................................................................................................................................... 33

Conclusion .................................................................................................................................................. 34

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Mission and Vision

To identify perpetrators of money laundering, terrorist financing and connected

crimes through the receipt of suspicious activity reports and requests that are

analysed for dissemination to relevant authorities for further investigation to

reduce the harm that these activities can cause to our people, financial stability

and security.

That where it occurs, perpetrators of money laundering,

terrorist financing and connected crimes are detected and

brought to justice ultimately becoming a deterrent to the

commission of these offences in the Turks and Caicos Islands.

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List of Abbreviations AG - Attorney General AGC - Attorney General’s Chambers AML - Anti-Money Laundering AMLC - Anti-Money Laundering Committee CFATF - Caribbean Financial Action Task Force CFT - Combating the Financing of Terrorism CO - Compliance Officer CSP - Company Services Provider DNFBP - Designated Non-Financial Businesses and Professions FATF - Financial Action Task Force FCU - Financial Crime Unit FIA - Financial Intelligence Agency FIs - Financial Institutions FIU - Financial Intelligence Unit FFIU - Foreign Financial Intelligence Unit FLEA - Foreign Law Enforcement Agency

FSC - Financial Services Commission LEA - Law Enforcement Agency LGA - Local Government Agency ML - Money Laundering MLCO - Money Laundering Compliance Officer MLRO - Money Laundering Reporting Officer MOU - Memorandum of Understanding MSB - Money Services Business POCO - Proceeds of Crime Ordinance PF - Proliferation Financing RTCIPF - Royal Turks and Caicos Islands Police Force SAR - Suspicious Activity Report STR - Suspicious Transaction Report TCI - Turks and Caicos Islands TF - Terrorist Financing

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Letter from Director to H.E. The Governor

FINANCIAL INTELLIGENCE AGENCY TURKS AND CAICOS ISLANDS

201 Cabot House, Graceway Plaza Leeward Highway, Providenciales Turks and Caicos Islands TKCA1ZZ

Tel: 649 941 7691/3692/8429 Fax: 649 941 7470

Email: [email protected] |www.fia.tc

26th September 2019

His Excellency Mr. Nigel Dakin Governor of the Turks and Caicos Islands Waterloo Grand Turk Your Excellency. In accordance with s.29 of the Financial Intelligence Agency Ordinance, I hereby submit the

report of the Financial Agency’s operations for the financial year 2017/18.

Sincerely, ____________________ Dwayne BAKER, CAMS Director FIA – TCI Encls. FIA 2018/19 Annual report

mailto:[email protected]://www.fia.tc/

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Message from the Chairperson of

the Board of Directors

On behalf of the

members of the

Board of the

Financial

Intelligence Agency

(FIA) which consists

of the Chair of the

Anti-Money

Laundering

Committee (AMLC): The Honourable Mrs.

Rhondalee BRAITHWAITE-KNOWLES OBE,

Attorney General of the Turks and Caicos Islands,

Commissioner of Police Mr. Trevor BOTTING,

Director of Public Prosecutions, Mr. Eugene

OTOUNYE and appointed member Mr. Willin

BELLIARD, I wish to congratulate the staff of the

FIA for once again producing this very

comprehensive and informative report.

The Board acknowledges the outstanding work

of the Director and his staff, especially during

this financial year 2018/19 which saw the FIA

being the subject of an Onsite Mutual Evaluation

process by the CFATF during this period. The FIA

has also undergone Audits by the National Audit

Office and the Internal Audit Department of the

Turks and Caicos Islands Government of TCIG. It

has also reviewed and approved policies

important to the continued growth and

development of the FIA

As the FIA continues to progress, it has increased

its technical capacity through the acquisition and

implementation of a case management database

which enables the storage, access and analysis of

data held by the FIA in a secure manner and

making more efficient the Agency’s capacity to

perform its core functions related to the Anti

Money Laundering and Countering the Financing

of Terrorism (AML/CFT) regime in the Turks and

Caicos Islands.

In its effort to increase efficiency, the

recruitment process has started based on the

Staffing Plan which had been previously

approved by the Board. This increase in staff will

enable more efficient analysis of SARs/STRs,

processing of requests, and conducting outreach

and awareness programs.

The Board’s structure saw some changes during

the period, as we welcomed the new

Commissioner of Police and bade farewell to

outgoing CoP Mr. James Smith in August 2018,

and also welcomed Mr. Eugene Otuonye QC as

the DPP replacing Ms. Jillian Williams. There is

also the addition of a newly appointed member

Mr. Willin Belliard, who brings to the Board a

wealth of knowledge and experience in

AML/CFT.

I am grateful for the opportunity to serve as the

Chair of the Board of the FIA, and proud of the

Agency’s accomplishments during this period.

Edith COX, Chair

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Director’s Message 2018/2019

continued to

be a

demanding

year for the

FIA. During

that period we

participated in

the Caribbean

Financial

Action Task Force (CFATF) mutual evaluation

of the Turks and Caicos Islands. The

assessment was based on the Financial

Action Task Force (FATF) 40

recommendations regarding combating

money laundering, the finacing of terrorism

and proliferation of weapons of masss

destruction(AML/CFT/PF). The mutual

evaluation exercise is an all encompossing

assessment of a jurisdictions effectivemness

of its AML/CFT/PF systems against the

FATF’s global standards involving various

stakeholders in the public and private

sectors. The process engaged a lot of the

FIA’s resources during the period. It is

anticipated that the TCI’s final report will be

presented at the November 2019 CFATF

Plenary to be held in Antigua and Barbuda.

It is anticipated that within the next fiscal

year the FIA will receive funding for the

hiring of permanent staff. The staff

compliment remains three persons

consisting of officers on secondment from

the Royal Turks and Caicos Islands Polcie

Force. The RTCIPF support of the FIA

throughout its transition since becoming an

independent Agency in October 2014 is

lauded as it facilitated the transfer of skills

and knowledge by staff who operated within

the former Fiancial Intelligence Unit within

the RTCIPF.

In November 2018 the FIA launched its new

data management software called IBM

iBase. This software improves on the existing

software for the storage, management,

analysis and security of information the the

FIA recevies such as Suspicious Acticity

Reports (SARs), local and international

requests and intelligence; and the

preparation of reports following analysis.

Suspicious Acticity Reports (SAR) saw an

increase over of 47% over the previous

period. This was dominated by reports from

the Financial sector specifically banks and

money services businesses (MSBs).

2019/2020 is expected to be yet another major year for the FIA as it grows from strenght to stength. Increased technical staff will help to increase our capacity and meet ever growing performanc targets. The start of the formal implementation of the recommendations of the mutual evaluation exercise is also expected to commence during that period following the publication of the TCI’s mutual evaluation report which is which is anticipated sometime within Q4 (Jan-March) 2019/2020. Dwayne Baker CAMS, Director

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Suspicious Activity/Suspicious

Transaction Reports (SARs/STRs) This statistical report covers the fiscal year

2018/2019 which began 1st April 2018 and ended

31st March 2019.

During the period under review 2018/19, the FIA

received a total of 78 SARs/STRs; this represents

a significant increase of 25 or 47% when

compared to the previous year 2017/18 (53

SARs/STRs) and a marginal decrease of 1 or 1%

when compared to the same period in 2016/17

(79 SARs/STRs)

Commercial Banks (CBs) continue to be the main

contributor of the SARs/STRs submitted. This

followed a similar trend when compared to the

previous year. CBs accounted for 44 or 56% of

the submissions during the period. Money

Service Businesses (MSBs) accounted for 14 or

24% and private banks (PBs) accounted for 4 or

5%. CBs, PBs and MSBs under the category of

financial institutions accounted for 63 or 81% of

the total SARs/STRs submitted during the period.

This made Financial Institutions the main

reporting sector over the period. The remainder

of the SARs came from the Designated Non-

Financial Businesses and Professions (DNFBPs)

sector; namely Company Services Providers

(CSPs) (7) and Law Firms/ Attorneys (8).

There was an increase of reports made by

reporting entities (REs) as a result of adverse

media regarding an ongoing investigation into

corruption in another country namely the

“Argentine Notebook case”1 and the alleged

involvement of attorneys in the TCI. These

reports were not related to any suspicious

activity or transactions; however, the REs made

the submissions out of an abundance of caution.

1 https://www.bbc.com/news/world-latin-america-45049064

Commercial Banks have continued to be the

main reporters of SARs/STRs over the MSBs that

used to hold such position. This trend has been

maintained since the fiscal year 17/18.

Law firms/Attorneys increased their reporting by

4 or 100% when compared to the previous fiscal

year (17/18 = 4 SARs/STRs); an increase of 5 or

167% when compared to the same period in

2016/17. The increase is attributed to adverse

media reports related to the previously

mentioned ongoing investigation into corruption

in Argentina.

Overall, the Designated Non-Financial

Businesses and Professions (DNFBPs) continue

to submit less SAR/STR reports as a sector when

compared to FIs.

Table 1 below shows SARs/STRs received by the FIA by

Fiscal Year and Sector for the period 2016/17 to

2018/19.

Reporting Entity/Sector 18/19 17/18 16/17

Financial Institutions 63 41 64

Commercial Banks 44 26 25

Private Banks 4 0 0

Money Service Businesses (MSBs)

15 15 39

DNFBPs 15 12 15

Casinos 0 4 0

Company Service Providers (CSPs)

7 0 7

Insurance Agent/Brokers/Managers

0 1 1

Law Firms/Attorneys 8 4 3

Real Estate Agency/Agent 0 2 1

Trust Companies 0 1 3

Grand Total 78 53 79 Table 1 – Source: FIA-TCI

https://www.bbc.com/news/world-latin-america-45049064https://www.bbc.com/news/world-latin-america-45049064

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Chart 2 – Source: FIA-TCI

Chart 1 above shows a comparison of SARs/STRs disclosed to the FIA by category of reporting entities

between the periods 2016/17 to 2018/19. As seen in the chart above, Commercial banks and Money

Service Businesses account for the majority of the reports; both categories submitted a combined total of

59 or 76% SARs/STRs during the period.

FIs and DNFBPs Yearly

Comparison FIs accounted for 63 or 80% of the SARs/STRs

reported to the FIA during the period.

Commercial banks accounted for 44 or 70%,

Private banks reported 4 or 6% and the

remaining 14 or 22% came from MSBs. These

figures represent an increase of 22 or 54% from

the previous fiscal year (FY17/18 FIs = 41

SARs/STRs) and a decrease of 1 or 2% when

compared to FY 16/17 (FY16/17 FIs = 64

SARs/STRs). Of note, during and prior to

FY16/17, MSBs were the main reporting

category within the FIs sector; however, CBs,

since, have been the main contributors.

Submissions made by DNFBPs increased slightly

during the period when compared to the

previous FY. Submissions from the DNFBP sector

increased by 3 or 25% when compared to the

previous fiscal year (FY17/18 DNFBPs = 12

SARs/STRs). There was no change when

compared to the same period in the fiscal year

16/17 (FY16/17 DNFBPs – 15 SARs/STRs).

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Chart 2 SARs/STRs submitted by sector during the fiscal years 2018/19 vs 2017/18 and 2016/17.

As seen, Financial Institutions consistently submit the most reports.


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Chart 3. SARs/STRs reported to the FIA by DNFBPs for the period 2018/19 vs 2017/18 and 2016/17.

An increase of 4 or 100% is noted by the Law Firms/Attorney’s which represents an increase partly attributed to

adverse media reports related to the ongoing investigation of a corruption case in Argentina.



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Customs Declarations The FIA received a total of 73 customs declarations from the Customs Department. The collection and

recording of declarations fulfil the Financial Action Task Force (FATF) Recommendation 32 which

stipulates that countries put measures in place for all persons to make declarations of currencies or Bearer

Negotiable Instruments (BNIs) over a threshold amount. The sharing of the declarations with the FIA is

tied to Recommendation 29 regarding the ability of the FIA to have as broad a range of access to

information to allow it to conduct its analysis. USD10,000.00, is the threshold amount for outward and

inward declarations in the Turks and Caicos Islands. The FIA commenced receiving these declarations from

the Customs Department in 2018.

During the period 2018/19 the FIA received from HM Customs Department, a total of 73 Cash Declarations

with a total value of USD38,395,003.37. Incoming – USD91,600.00; and Outgoing – USD38,303,403.37. 70

or 96% of the cash declarations were outgoing declarations mostly from Money Service Businesses

(MSBs). The remaining 03 or 4% were related to incoming cash declarations from individuals. The de-

risking by some banking institutions of MSBs has limited their access to banking services. This has resulted

in the physical transportation of cash for remittance settlements in other countries. It is anticipated that

this phenomenon will draw the attention of competent authorities regarding risk and other attending

issues that may be faced by the MSBs in having to adopt this approach for settlements as part of their

operations.

The recipient countries to which the funds were mostly transported, include the Bahamas, Barbados,

Haiti, Jamaica and USA. Jamaica and Haiti were the major recipient of the funds transported overseas and

accounted for USD37,943,352.26 or 99% of the funds transported. Where there was suspicion concerning

the in or outbound movement of funds the FIA conducted the relevant analysis and cooperated with our

counterparts.


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The Chart below shows the value of the cash declarations (inwards and outwards) reported to the FIA by TCI’s Customs

Department between the period 1st April 2018 to 31st March 2019. As shown in the chart below, Jamaica and Haiti were the

main destinations for the majority of the funds transported. Jamaica and Haiti accounted for USD37,943,352.26 or 99% of the

funds transported.


Disposition of SARs/STRs During the period under review, the FIA analysed

75 SARs/STRs. The FIA disseminated 6

intelligence products to foreign and local

counterparts namely Foreign Financial

Intelligence Units (FFIUs) = 4 and Local Law

Enforcement Agencies (LLEAs) = 2.

The intelligence reports disseminated were

related to suspected frauds.

Domestic and International

Requests for information

(Incoming and Outgoing) The FIA assists and shares information with

domestic and international counterparts related

to AML/CFT. Information sharing through

requests or spontaneous disseminations with

other FIUs is done through the EGMONT7 Secure

Web (ESW) and information to FLEAs, LLEAs and

is done directly through the use of secure email

communications.


received a total of 30 requests from LGAs, LLEAs,

and FFIUS (22 Local and 8 International). The FIA

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also received 9 Intelligence reports from LLEAs,

LGAs and FFIUs (6 Local and 3 International).

The majority of requests received by the FIA

were domestic. Requests from Domestic

counterparts accounted for 22 or 73% of the

requests made to the FIA during the period of

which requests from LLEAs accounted for the

majority. The remaining 8 or 27% came from

international counterparts, all of which were

FFIUs.

Domestic requests came from the following

entities; Integrity Commission, RTCIPF-Financial

Crime Unit2, RTCIPF-Criminal Investigations

Department, FSC3 and the Gaming Inspectorate.

International requests came from the following

countries: Argentina, Bahamas, Bermuda,

Guatemala, Trinidad and Tobago, USA and

Venezuela.

There was a reduction of 8 or 21% in requests

made to the FIA when compared to the previous

period 2017/18 = 39 Requests (22 Domestic and

17 International); and a significant decrease of

30 or 50% when compared to the same period in

2016/17 = 60 Requests (25 Domestic and 35

International).

Table 4. Requests made to the FIA by jurisdiction and

type of entity between from 2016/17 to 2018/19.

Jurisdiction/Type of Entity

2018/19 2017/18 2016/17

International 8 17 35

FFIUs 8 14 30

FLEAs 0 3 5

Domestic 22 21 25

LLEAs 16 15 17

LGAs 6 6 8

Grand Total 30 38 60 Table 4 – Source: FIA-TCI

Chart 7. Requests received from international and domestic counterparts 2018/19, 2017/18 and 2016/17.


2 Royal Turks and Caicos Islands Police Force – www.tcipolice.tc

3 Financial Services Commission – www.tcifsc.tc

http://www.tcipolice.tc/http://www.tcifsc.tc/

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Chart 9. Countries from which requests from counterparts were received. As can be seen Domestic requests accounted for the

majority of the requests made to the FIA during the period under review.


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The FIA made a total of 53 requests to Domestic

counterparts. There were no requests made to

international counterparts during the period.

The majority of the domestic requests were

made to LGAs which accounted for 34 or 64% of

the requests and the remaining 19 or 36% were

made to LLEAs. Information requested by the FIA

mostly included details on entities/companies;

asset tracing and data on travel history.

The number of requests made by the FIA during

the period under review decreased slightly by 8

or 13% when compared to the previous period

under review 2017/18 = 61 Requests (7

International and 55 Domestic) and a significant

decrease of 59 or 53% when compared to the

same period in 2016/17 = 112 Requests (8

International and 104 Domestic).

Jurisdiction/ Type of Entity

2018/19 2017/18 2016/17

International 0 7 8

FFIUs 0 6 5

FLEAs 0 1 3

Domestic 53 54 104

LGAs 34 25 73

LLEAs 19 29 31

Total 53 61 112 Table 5 – Source: FIA-TCI

4 https://gov.tc/landregistry/

The significant decrease when compared to

2016/17 was as a result of the number of

matters which required multiple requests to

different entities or in some cases the same

entity. This occurs when the FIA, pursues as

many lines of inquiry to get the best picture of

the matter to arrive at an informed decision.

Additionally, the FIA conducts further checks in

the case where information is discovered but

creates other leads for its intelligence officers

and analysts.

The FIA requested information from LGAs

namely the FSC, Land Registry4 and the Road

Safety Department. The LLEAs from which the

FIA requested information included the

Immigration Department, RTCIPF – National

Criminal Intelligence Bureau (NCIB) and Customs

Department.

https://gov.tc/landregistry/

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The chart below depicts requests made by the FIA to International and Domestic stakeholders; these counterparts include

FFIUs, FLEAs, LGAs and LLEAs which are of a governmental nature.


Chart 8. Requests made by the FIA to international and domestic counterparts.

As shown in the chart, during the period under review, the FIA made the majority of its requests to LGAs


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Requests for Information by the FIA In an effort to get the best picture of matters

analysed; the FIA make requests to Reporting

Entities (REs), LGAs, LLEAs, FLEAs, FFIUs and

other individuals/agencies from which useful

information can be obtained to assist in the

execution of its statutory requirements related

to AML/CFT.

The FIA has access to a broad range of

information sources which enables the proper

analysis of reports or requests it receives. Types

of information requested by the FIA include but

are not limited to: financial, administrative, law

enforcement data, migratory data and any other

information necessary to conduct analytical

tasks and to facilitate decision making in

disclosures that may reveal ML/TF or related

predicate offences.


made a total of 246 requests for information

under section 30 of the Financial Intelligence

Agency Ordinance (FIAO).

51 or 21% of the requests were connected to

SARs, 96 or 39% were connected to international

requests; 13 or 5% were related to proactive

investigations; 82 or 33% were related to local

requests and the remaining 4 or 2% were as a

result of cash declarations submitted by the

Customs Department.

There was an increase of 34 or 16% when

compared to the previous fiscal year 2017/18 =

212 requests and a decrease of 219 or 27% when

compared to the same period in 2016/17 = 465

requests.

Type of Entity 18/19 17/18 16/17

Commercial Banks 157 119 245

Company Service Providers (CSPs)

4 2 10

Law Firms and Attorneys 5 2 2

LGAs 34 25 73

Local Law Enforcement Agencies (LLEAs)

19 29 31

Money Service Businesses (MSBs)

19 25 17

Other 0 0 2

Private Banks 4 2 27

Real Estate Agent/Broker/Agency

0 1 0

Trust Companies 4 7 58

Total 246 212 465 Table 6 – Source: FIA-TCI

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Monetary Value of SARs/STRs The analysis of the 78 SARs/STRs received during

the period under review identified that a total

monetary value (attempted or actual) in the

amount USD1,030,032,107.47. This amount is

inflated by 1 SAR/STR which involved a bond

suspected to be fictitious in the amount of 1

Billion US Dollars.5 The remaining 77 SARs/STRs

had a monetary value of approximately

USD30,032,107.47.

13 or 17% of the submissions did not have a

value associated with them. The remaining 65 or

83% accounted for the remaining amount. The

amounts expressed were under suspicion and

are not necessarily linked to actual crimes

committed.

Excluding the SAR/STR with a purported value of

USD1 Billion from a DNFBP (real estate agency),

commercial banks accounted for

USD18,800,104.15 or 63% of the value of

SARs/STRs reported. Law Firms and Attorney

accounted for USD9,533,227.28 or 32%. CSPs

accounted for USD1,377,724.27 or 5%. MSBs

accounted for USD216,149.84 or 1% and Private

banks accounted for less than 1%.

Indicator TOTAL

Fraudulent Disposition US$ 355,545.35

Adverse Media Report US$ 8,100,000.00

Email/System Compromise/Wire fraud

US$ 325,734.28

ATM advance Fraud US$ -

Blackmail US$ 100.00

Cheque Fraud US$ 199,950.00

Cheque Kiting US$ 12,110.00

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Concealing Criminal Property

US$ 49,242.00

Consent SAR US$ 798,134.77

Customer Profile US$ 14,110,560.30

Declined Business US$ -

Emergency Fraud Scam US$ 4,660.00

High Risk Jurisdiction US$ 17,445.27

High Volume of Transactions

US$ -

Identification Documents US$ 194,100.00

Source of Funds US$ 863,113.24

Structuring US$ 9,127.15

Suspicious Activity US$ 1,004,507,169.23

Suspicious Documents US$ -

Third Party Remittances US$ 3,458.00

Theft Related Offences US$ 73,580.00

Grand Total US$ 1,029,624,029.59

Table 7 – Source: FIA-TCI

Chart 10. SARs/STRs reported to the FIA by sector.

As can be seen, the Real Estate Agency/Agent sector reported the majority of the value during the period under review.6


6 Attributed to 1 report.

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Chart 11 below depicts SARs/STRs submitted to the FIA by indicator during the period under review; Suspicious

activity accounted for the major reason for reporting (indicator).


SARs/STRs by Customer (Natural and Legal Persons)

Of the 78 SARs the FIA received during the period

under review; 49 or 88% involved natural

persons and the remaining 7 or 13% were legal

persons7. Please note that some SARs/STRs may

have more than one legal or natural person

connected to them.

7 Legal Person – May be a company or other entity

Occupation or Business Activity The occupation or business activity (in the case

of legal entities) varied during the period under

review; there was no significant concentration of

suspicious activity around any particular

occupation or business activity as shown in the

table below however, of note the majority of the

SARs/STRs reported were made against natural

persons as opposed to legal persons.

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Table 8 below list the declared profession of the subjects

of SARs/STRs and whether they were Legal or Natural

persons.

Note: Where it says unknown, either the profession was not

declared or there was insufficient information to determine

if the subject was a legal or natural person.

Occupation Legal Natural Un-known

Grand Total

Accountant

1

1

Attorney

4

4

Bank Teller

1

1

Beautician

1

1

Business Person

7

7

Civil Servant

2

2

Cleaner

1

1

Consulting Company

1

1

Domestic Worker

1

1

Engineer

1

1

Exempted Company

1

1

Financial Trader

2

2

Fuel Station 1

1

Heavy Machinery Operator

1

1

House Keeper

1

1

House Wife

1

1

Investment Holding Company

3 1

4

Labourer

1

1

Law Firm 2

2

Maintenance Person

1

1

Manager

2

2

Mechanic

1

1

Metal Working

1

1

Night Auditor

1

1

Office Administrator

1

1

Oil Trader

1

1

Physician

1

1

Police Officer

4

4

Project Manager

1

1

Property Holding Company

1

1

Property Manager

2

2

Real Estate Agent

1

1

Retired

5

5

Sales Clerk

1

1

Self Employed

2

2

Site Supervisor

1

1

Student

1

1

Supply Manager

2

2

Trust Company

1

1

Unemployed

3

3

Unknown 3 8 3 14

Villa Rental Company

1

1

Grand Total 15 65 3 83 Table 8 – Source: FIA-TCI

Nationality of subjects in SARs/STRs During the period under review, the nationality

of 83 natural and legal persons was identified.

The nationality of 8 persons (legal and natural)

could not be determined. The Turks and Caicos

Islands accounted for the largest number for

both legal and natural persons accounting for 35

or 42% of nationalities (11 Legal and 24 Natural)

reported during the period.

The United Kingdom, Canada and Haiti had the

same amount of nationalities reported and were

the second largest amount following TCI; 6

reported (0 Legal and 6 natural persons) who

were subjects of submissions made to the FIA;

collectively, these 3 nationalities accounted for

18 or 22% of the nationalities reported. The

other nationalities identified are shown in the

table below which gives a detailed breakdown of

the reported nationalities and the category of

persons.

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Note: When the nationality of a legal person is

indicated; it means that it has been registered in that

jurisdiction.

Country of Nationality

Legal Natural Unknown Grand Total

Australia 0 4 0 4

Bahamas 0 1 0 1

BVI 1

0 1

Canada 0 6 0 6

Dominican Republic

0 1 0 1

Germany 0 1 0 1

Guyana 0 1 0 1

Haiti 0 6 0 6

India 0 2 0 2

Jamaica 0 1 0 1

Nigeria 0 1 0 1

Philippines 0 1 0 1

Russian 0 2 0 2

Spain 0 1 0 1

St. Lucia 0 1 0 1

TCI 11 24 0 35

Turkey 0 1 0 1

United Kingdom

0 6 0 6

Unknown 2 3 3 8

USA 0 1 0 1

Venezuela 0 1 0 1

Zambia 1 0 0 1

Grand Total

15 65 3 83


Chart 12 Nationality of subjects related to SARs/STRs.

As shown in the chart below, the TCI accounts for the majority of the nationalities declared for both legal and

natural persons.

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Reason for Reporting (Indicators) All reporting entities within the Turks and Caicos

Islands are legally obligated to have a Money

Laundering Reporting Officer (MLRO). MLROs

play a crucial role in identifying suspicious

activity by their clients/customers and those

they interact with in the conduct of their

business activities.

Entities are required by law under the AML/CFT

regime to have mechanisms and procedures in

place to identify suspicious activity. The Money

Laundering Compliance Officer (MLCO) has a

role to play in this exercise. Together the MLRO

and MLCO help to create an environment within

their respective organisations to deter the

occurrence of Money Laundering or Terrorist

Financing. The front-line staff (where the

structure permits) in line with their training

submit internal reports to the MLROs who then

apply scrutiny on a risk-based approach aligned

to company policies and procedures; laws and

regulations. Where the matter reaches a

threshold in which the MLRO has reasonable

grounds to believe that the matter being

reviewed is of a suspicious nature, a SAR/STR

would be filed with the FIA.

During the period under review 2018/19, the

main reason for reporting SARs/STRs to the FIA

was due to the occurrence of activities or

transactions not corresponding with the

customer’s profile. This may occur when the

activity of a customer is outside of their normal

patterns or inconsistent with their customer

profile as recorded by the entity or simply that

the person who is conducting the transaction is

not known to be able to carry out a specific

activity/transaction. The FIA submits that

sometimes these unusual behaviours and

patterns are not always related to criminal

activity or to ML/TF, but the REs takes the

necessary action by reporting such matters for

further review and scrutiny by the FIA which is

able to apply the use of its legislative powers and

resources to conduct further inquiries.

14 or 20% of reports were related to

inconsistencies in customer’s profile. Source of

funds information was another major reason for

reporting, accounting for 12 or 15% of the

submissions made and adverse media reports

accounted for 10 or 13%. Together, these 3

reasons for reporting also referred to as

‘indicators’, accounted for 36 or 46% of the

indicators reported during the period under

review.

Indicator TOTAL

Adverse Media Report 10

Email/System Compromise/Wire fraud 11

Blackmail 1

Cheque Fraud 2

Cheque Kiting 1

Concealing Criminal Property 3

Consent SAR 4

Customer Profile 14

Declined Business 1

Emergency Fraud Scam 2

High Risk Jurisdiction 1

Identification Documents 2

Source of Funds 12

Structuring 2

Suspicious Activity 7

Suspicious Documents 1

Third Party Remittances 1

Theft Related Offences 3

Grand Total 78


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Chart 13. Reasons for reporting (indicators) 2018/19.

As illustrated below Customer Profile (14), Source of Funds (12) and Adverse Media Reports (10) accounted for

the main reasons for reporting to the FIA.

Chart 13 – Source: FIA -TCI

Customer Profile At the commencement of any business

relationship, during the period also referred to

as onboarding of customers. FIs and DNFBPs

conduct know your customer (KYC) and

customer due diligence (CDD) procedures.

During that period entities may request from

their prospective customers/clients, whether

legal or natural persons, different pieces of

information which geared at assisting the entity

to assess the risk associated with the customer

before onboarding (entering into a business

relation) and, or the continuation of an existing

relationship. Information obtained on natural

and legal persons during this process mostly

depends on different factors and the

information may include, but is not limited to

details such as: source of Income, place of

employment, current address, expected account

activity, nature and country of expected

business, instruments of deposits, etc. During

the period under review the FIA received a

number of reports related to suspicions

surrounding customer activity and transactions

which the reporting entities deemed to be

inconsistent to the normal customer activities

and profile. For example: a customer visits an

MSB to remit funds of a substantial amount

overseas however, based on the customer’s

employment history the entity identified the

amount the subject remitted as inconsistent

with the income from their employment and did

not coincide with the expected activity and

historical transaction pattern by the subject.

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Other reports pertained to additional

inconsistencies regarding customer’s income

and higher deposited amounts outside of the

usual activity.

Source of Funds Entities must assess the risk of the transactions

carried out by the customers to minimize the

use of their services for money laundering,

terrorist financing or other criminal conduct.

Transactions by customers involving large cash

deposits or wire transfers over the entity’s

threshold or outside of the customer(s) usual

transactional pattern(s) could trigger scrutiny

by reporting entities. For the period, the FIA

received several submissions regarding

suspicion surrounding the source of funds of

deposits. The reports pointed to the failure of

customers to provide to entities sufficient

information to verify the legitimacy and source

of the funds involved in the specific

transactions. Inconsistencies in the documents

or explanation a customer provided or

reluctance/avoidance to answer to queries

from an entity regarding a customer’s source

of funds may create a level of suspicion about

the true nature of activity being carried out by

a customer.

Adverse Media Report Entities are required to conduct due diligence

on their clients and customers and the level of

such may depend on different factors based on

the type of business, the customer, products,

services and location. Additionally, the risk

associated to these factors helps to direct

initial customer due diligence, ongoing

customer due diligence or enhanced due

diligence. Entities may use different sources to

conduct their due diligence one of which

includes open source information. Open

source information may be obtained from

sources such as online search engines and

social media, which are useful tools for

gathering information. As such, open source

searches can reveal details of court cases or

investigations against clients, customers or an

entity. Analysis of such cases received by the

FIA during the reviewed period revealed that

entities submitted reports out of an

abundance of caution as their clients/

customers were featured adversely in open

source searches. However, the reports did not

identify any suspicion on the part of the

subjects. Example: An entity while conducting

its ongoing due diligence discovers that one of

its clients is the subject of an ongoing criminal

proceeding and reports to the FIA that they

have an ongoing business relationship with

the client, however, the entity indicated they

have no suspicion in relation to the services

utilised by the customer nor their activities.

Declined Business Sometimes businesses exercising their discretion

may or may not accept business from a

prospective customer or existing customer

depending on the circumstances of the activity

or the proposed transaction. In the case of

onboarding a customer, the entity may discover

adverse information and may determine that the

customer’s business or activities may be too

risky for the entity to establish a relationship and

may decline to conduct a transaction or establish

a business relationship. In another situations,

the customer may be an existing client and the

entity might decline to handle a specific

transaction(s) because of an inherent risk to do

so and to protect the reputation of their

business. Example: A customer attempts to

establish an additional business relationship for

different services with an entity, however, such

request was declined on discovery of ongoing

criminal proceedings against the customer.

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Email/System Compromise/Wire Fraud Several reports received involved cyber fraud utilizing emails. Some reporting entities received emails from email addresses which appeared to be that of their clients with instructions for wire transfers of funds which upon verification were discovered to be fraudulent. All SARs/STRs related to email fraud were listed as attempted fraud. The reporting entities due to their verification processes regarding wire transfers were able to contact their clients who denied initiating such requests and advised of possible compromise of their email account, or the requests were identified as fraudulent upon their receipt. One report of this nature resulted in loss to the victim of USD22,900.00 which was wired to South Africa. The FI was unsuccessful with the recall of the funds wire transferred.

Blackmail The FIA received a SAR/STR from a reporting

entity concerning a customer under the age of

18 who was attempting to remit funds

overseas to an individual in the Ivory Coast to

avoid the publication of nude photos on social

media. Apparently, the customer was told by

the fraudster, that they obtained access to the

victim’s phone and all photos and demanded

that if a certain amount of money wasn’t paid

the photos would be published over the

internet. The matter was reported to the

RTCIPF by the entity.

Cheque Fraud The use of fraudulent cheques is a recurring

methodology in several internet-initiated

frauds. Several entities could be the target of

such fraud. One such report involved a

prospective client who engaged a local law

8 in financial terms, the float is money within the banking system that is briefly counted twice due

firm to retain their services to recover on their

behalf a debt owed from a domestic company.

The perpetrator later sent to the law firm a

cheque purported to have come from the

debtor for the funds owed. The entity

identified discrepancies in the cheque and

requested further information from the

prospective client, but the information was

never provided which created further

suspicion of the cheque. The modus operandi

of such fraud is to give the impression that a

targeted entity in the same jurisdiction of the

law firm is owing money. The perpetrators

send a cheque as though it came from the

debtor with the intention that the law firm will

deposit the cheque. Once the entity received

the cheque, the perpetrator requests that the

entity take out their retainer fee and wire

transfer the balance. The perpetrator(s) knows

the cheque is fraudulent and hopes the law

firm would forgo the bank’s clearing cycle and

remit the funds. Once the funds are sent and

the cheque returned as worthless, the firm

would incur a loss of the retainer and wired

amount. This type of fraud has been

previously observed and analysis indicates

that law firms have been the primary targets

of such activity. All entities are encouraged to

exercise caution when unsolicited or

payments in excess of the value or a service or

requires settlement is received followed by a

rapid request to “return” excess amounts.

Cheque Kiting This type of fraud involves taking advantage of

the bank’s float8 to make use of non-existent

funds in another account thereby making the

cheques become a form of unauthorized credit

as opposed to being used as a negotiable

instrument. Example: The FIA received a

to time gaps in the registering of a deposit or withdrawal, usually due to the delay in processing paper checks.

29 | P a g e


SAR/STR from a commercial bank indicating

that one of its customers was using the cash

back facility offered by the bank by depositing

cheques that did not have enough funds and

withdrawing funds beyond available balances.

Concealing Criminal Property The FIA received reports regarding several

clients of a bank who appeared to have been

complicit with one of the bank’s employees in

transferring funds from the accounts of

customers of the bank without their authority.

The report was in the realm of a criminal

conduct namely, the ‘Theft of a Chose in

Action’ which was referred to the RTCIPF-FCU

by the reporting entity. From time to time, the

FIA receives such reports which the entity has

also submitted to police for investigations.

Consent SAR The FIA received a SAR from an entity seeking

consent to proceed with a proposed

transaction for the purchase of real estate in

the Turks and Caicos Islands. The funds

involved for the proposed purchase were

derived from a lawful source in another

jurisdiction. However, under the laws of the

Turks and Caicos Islands, the funds would have

been deemed as criminal property as it derived

from a conduct which is deemed unlawful in

the TCI despite being lawful in the overseas

jurisdiction. The FIA denied the consent for the

use of the funds use as requested.

Emergency Fraud Scam Perpetrators of different internet frauds

befriend others on social media – a method

easily used to conduct fraudulent activities

such as emergency fraud scams. Once the

fraudster/s starts to communicate with the

individuals they befriend, their main aim is to

gain the trust of the person(s) and to give the

impression that their friendship is genuine.

The fraudsters target men and women alike,

and having gained their trust, they create

different stories to impress upon the

unsuspecting persons that they are in urgent

need of medical support, facing a family crisis

or in need of food appealing to the goodwill of

individuals who in turn give up their money.

This often occurs over a period whereby the

victim continuously surrenders their money to

‘help’ the perpetrator of the fraud.

High Risk Jurisdiction Entities can determine a jurisdiction to be high

risk for several reasons. Some rely on

categorisations by international bodies such as

the Financial Action Task Force (FATF) and the

United Nations; and individual country lists or a

combination. Countries could be rated as high-

risk for different reasons. For example,

deficiencies in their AML/CFT framework and

lack of implementation of the FATF

Recommendations. When some countries are

listed as high risk, entities must apply further

scrutiny in the form of Enhanced Due Diligence

(EDD) when dealing with customers; or

prospecting customers; or the undertaken of

transactions by their clients/customers; or the

customers of their customers pertaining to

such jurisdiction(s). Reports of the type are not

always an indication that the person(s) is/ are

involved in unlawful conduct. Example: An

entity submitted a report to the FIA as a result

of a customer’s transmission of funds to

several countries including one listed as a high-

risk jurisdiction based on a Financial Action

Task Force (FATF) ongoing compliance process

for the country. Conducting business with a

high-risk jurisdiction does not necessarily

mean that the transactions is illicit, however it

would require further scrutiny by the RE.

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Identification Documents Entities from time to time may come across

different identification documents that appear

suspicious to the frontline staff and would

require further scrutiny to determine the

authenticity of the documents. There are many

individuals of various nationalities living and

working in the Turks and Caicos Islands. It can be

an arduous task for several of the reporting

entities to ascertain the authenticity of the

different forms of identification presented by

the different nationals. These matters do not

always result in wrongdoing as it can just be a

case that staff members are unfamiliar with the

identification type or the date format of one ID

presented when compared to another.

Structuring Some customers who conduct multiple

financial transactions over a short period, in

high volumes or even using multiple branches

of the same entity can be viewed as engaging

in the structuring of transactions or funds. In

such matters reported to the FIA, most of the

transactions had the appearance of

structuring which gave the impression that the

customers were attempting to avoid reporting

requirements such as thresholds for

transactions over a specified amount. In most

instances, while some transactions might have

indications of structuring, upon conducting

inquiries and analysis, the FIA identified that

some of the customers were remitting funds

to their family members or assisted by sending

funds to the families of their work colleagues

or housemates.

Suspicious Activity The FIA received SARs/STRs related to general

suspicion of transactions which were

conducted by customers of the entities. REs

tend to report matters which appear to be out

of the usual and not necessarily that they

suspect the client has committed any

particular offence/crime but would rather err

on the side of caution and make a report.

These occur especially where a customer may

give explanations which do not sound

reasonable.

Suspicious Document- Customers are sometimes required to produce

additional documents to the business which they

are attempting to commence a business

relationship with or are trying to conduct some

transaction. Entities also apply scrutiny to these

documents which are sometimes issued by in

other countries or even locally. Example: A

customer produced a bank reference letter

which appeared suspicious to the business and

as a result a verification process occurred which

resulted in confirming that the document was in

fact fraudulent.

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Trends and Typologies During the period under review 2018/19,

analysis of reports showed a continuation of the

prior trends with slightly varying typologies.

Additionally, The FIA recorded an increase in

email-based frauds.

Email Fraud/Compromise During the reviewed period, The FIA received a

total of 9 reports which involved the

compromising of a system to conduct fraud.

Example:

Financial Institution (A) received an email

purported to have come from a known customer

requesting a wire transfer of funds to an

account in the name of another individual in

another jurisdiction. (A) identified the

inconsistencies in the request and proceeded to

verify the request by contacting their customer

who advised that they did not make the request

and had seen the said the email in the deleted

folder of their email inbox. (A) submitted a

SAR/STR to the FIA indicating the suspicion that

their customer’s email or computer system may

have been compromised; hence the

unauthorized email.

The financial institution had policies in place

pertaining to certain transactions and ensured

that emailed requests for transfers are clarified

with customers via means other than emails. The

clarification with the customer added an extra

safeguard against unauthorised request and

protection from losses to the customer.

These sorts of breaches occur quite frequently.

They can be caused by lapses in security such as

responding to a suspicious email or clicking on a

link within an email which may have malicious

code embedded. This allows the hacker to gain

access to the device either through the

monitoring of the screen or key strokes

(Keylogger) to determine the subject’s sensitive

passwords to different sites.

Users should exercise caution when opening

emails from unknown persons and even from

known persons whose email appear inconsistent

with normal activity.

Indicators:

• Email received from authentic email

address, but the request may not be

consistent with historical correspondence or

is unusual when compared to normal

activity;

• Customer denies making the request;

• The perpetrator or hacker sent request to

bank then deleted same from the main inbox

so that the email account holder (customer)

would not identify that an email was sent to

the FI;

• Customer identifies emailed request in the

trash folder (Indicates email compromise).

Cheque Kiting This type of fraud involves taking advantage of

the bank’s float to make use of non-existent

funds in another account thereby using the

cheques as a form of unauthorized credit rather

than being used as a negotiable instrument.

Example:

Financial Institution (A) receives a returned

cheque for a certain amount from another

Financial Institution (B) concerning a customer

(X) of both institutions. Investigations by (A)

identified that (X) has a historical pattern of

writing cheques beyond the available credit on

their bank account at (A) and deposited to the

account held with (B). (A) then debits the funds

from (X’s) account creating a negative balance

due to the cheques written above the amount

available on the account. (A) removed the cash

back feature to prevent (X) from perpetuating

the kiting scheme.

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Indicators:

• The subject writes a cheque from one

account with insufficient funds held with one

institution and deposits it to another

account held with another bank to inflate

the deposits on that account;

• The subject’s account on which the cheques

were drawn had insufficient funds;

• The cheques were deposited via the ATM to

take advantage of the bank’s cash back

feature -which allows for the withdrawal of

a portion of the cheque amount deposited.

FIA Activities

FIA Commences Strategic Assessment of

Human Smuggling/Trafficking in the TCI The FIA commenced its strategic assessment project on 20th June 2018 to identify trends, typologies and perpetrators of Human smuggling and Trafficking in the TCI. Initial requests for information have been sent out to Government Departments and agencies for details which could be beneficial to conducting the analysis.

Staff Development and Training In May 2018, 2 FIA staff completed part two of

their Analyst training in Open Source

Investigations (OSINT). That training was

facilitated by the Caribbean Financial Action

Task Force. It was conducted over two days in

Jamaica and designed for both analysts and

financial investigators of Financial

Intelligence/Investigations Units in the region.

The aim of the training was to develop a cadre

of suitably qualified analysts in the region who

to be accredited under the CFATF, European

Union sponsored training and accreditation

project. It is anticipated that with this training

there will be an improvement in the FIA’s

analytical capacity and the quality of analytical

products produced.

CFATF Mutual Evaluation Q2 2018/19 was an intense period for the Agency. During September 2018, the FIA hosted the CFATF Mutual Evaluation Assessment team comprising of 6 experts in the fields of Law, Law Enforcement and Financial regulation from throughout the region. The Agency played an integral role in the facilitation of the Assessors who used its facilities as their base for interviews and meetings with persons from various Government bodies and Private sector agencies. The FIA also worked tirelessly to provide significant volumes of data and documents as requested from the assessment team in the lead up to and during the assessment.

Outreach and Awareness

16th August 2018 On 16th August 2018 The FIA participated in an

AML Risk Management Seminar hosted by the

Financial Services Commission (FSC) at the

Atrium in Providenciales TCI. The seminar was

aimed at an audience of Managers, Money

Laundering Reporting Officers (MLROs) and

Compliance Officers in the Financial, DNFBP and

NPO sectors to review the TCI’s preparation for

the CFATF assessment of the jurisdiction in

September 2018. Topics Covered included:

CFATF Peer Review, FSC On-site Examinations

common Control Failures seen, Preparation of

Businesses’ Risk Assessments, SAR/STR

reporting and the Application of Financial

Sanctions in the TCI.

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April 2018

In April 2018 the FIA participated in a joint presentation with the Financial Crimes Unit (FCU) of the RT&CIPF to 20 Police officers. The FIA presented on its role, functions and the assistance that it can provide to investigators relating to Money Laundering and Terrorist Financing offences. Topics covered by the other presenters representing the DPPs Office and the RT&CIPF included requirements under the Proceeds of Crime Ordinance and Cash seizure and confiscation.

December 2018

The FIA participated in outreach and awareness geared towards persons in Insurance, Company Services, Real Estate, the Legal profession and Gaming sectors as part of their annual AML/CFT training requirements. Topics covered were: ML & TF, SAR/STR reporting, KYC, Legislative Requirements (SAR reporting); and Banking and Compliance. There were 18 participants at that event.

Local Capacity Building The FIA engaged with interested persons from

the Financial Services industry seeking to

regroup the TCI Compliance Association. The

TCI Compliance Association is a private,

independent organization that aims to build

capacity among its members in AML/CFT

requirements. The organization had been

dormant in recent years and the FIA welcomed

efforts to ensure a vibrant and active

association in the TCI, since its work

complements the efforts of local competent

authorities. The FIA will support the activities

of the association once rejuvenated as part of

its outreach and awareness activities.

Regional Assistance As part of the commitment to our region and

specifically the CFATF’s call for assistance in

building capacity among its members in various

aspects of the AML/CFT/PF field, the FIA was

able to provide a trainer to train persons in the

application and techniques in the use of Open

Source Intelligence as part of the CFATF/

European Union funded regional analyst training

program. To this end a FIA trained analyst,

trained as a trainer, participated in the conduct

of training of prospective analysts in July 2018 in

Antigua and Barbuda.

Following a request from the CFATF to the Prime Contact for AML/CFT matters in the TCI – the Chair of the Anti-Money Laundering Committee (AMLC), the FIA provided a law Enforcement assessor for the CFATF mutual evaluation of Bermuda. Such specific requests speak to the capacity of persons within the TCI with the capabilities to conduct such assessments and by extension provide vital assistance to support regional efforts in the AML/CFT field.

Events and Training In October the Director visited Bermuda where he was part of the Caribbean Financial Action Task Force (CFATF) assessment team for the Mutual Evaluation of its compliance and effectiveness with the Financial Acton Task Force (FATF) 40 recommendations against Money Laundering, Terrorist Financing and Proliferation. During the 4th week of November as part of the TCI delegation, the Director attended the CFATF XLVIII Plenary in Barbados where among other AML/CFT related matters and meetings, the Mutual Evaluation report of the Cayman Islands was discussed and debated. In November, two FIA intelligence officers/analysts completed Open Source Investigations Training (OSINT) in Jamaica. Participation in that course was funded by the CFATF/ EU and the FIA. The purpose of the training was to further develop suitably qualified analysts to be accredited under a CFATF/

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European Union sponsored, Training and Accreditation Project.

In December one intelligence officer/ analyst

completed an Intelligence Gathering and

Analysis course at REDTRAC in Jamaica.

CFT and Investigative Techniques Training During the period, one of the FIA’s analysts attended a Basic Combating the Financing of Terrorism Investigative Techniques training. The training was conducted locally by attendees of the World Bank course on the same topic conducted in November 2018 in Barbados. The training was designed to provide intelligence/investigative officers with knowledge of the FATF standards for CFT, how to apply relevant legislation and how it could be applied to the Turks and Caicos Islands. It also addressed methods and techniques that should be utilized when conducting Investigations/Inquiries into CFT matters. The FIA also continued its active engagement

in the work related to the CFATF 4th round

mutual evaluation of the TCI against the FATF

global AML/CFT standards by attending

several working group meetings and Anti

Money Laundering Committee meetings.

Conclusion The FIA witnessed the strengthening of

technical skills during FY2018/19 that will

enhance its work in the future. The area of SAR

reporting shows that there is a need for

increased efforts to bring those entities with

low reporting numbers fully on board in the

AML/CFT efforts.

While reports have shown that activities

warranting entities suspicion is occurring, for

the most part activities remain consistent with

prior periods. The FIA will continue to execute

its legislative mandate to receive, analyse and

disseminate information related to national

and global efforts to combat money

laundering, the financing of terrorism and

proliferation of weapons of mass destruction.

We seek all persons to unite in this effort

whether competent authorities, financial and

other institutions and persons as the effect of

such activity has the capacity to impact upon

us all.

*****************ENDS****************