Transcript Agency Financial Investigators

ARO Seminar
Ankara
[email protected]
What is financial crime?
• The handling of the proceeds of crime
(drug dealing, theft, smuggling, trading
counterfeit goods)
• Market manipulation (insider trading)
• Tax evasion
• Fraud
What is money laundering?
• The handling of the proceeds of predicate
crimes (drug dealing, theft, smuggling,
trading counterfeit goods)
Tackling crime
Money
Laundering
Proceeds
of Crime
Crime
What is financial investigation?
• The covert mapping of criminals and their
assets before arrest
• The intrusive use of financial intelligence,
multiple databases, analysis, mixed with
traditional surveillance, human sources
and other field intelligence
Speakers
• Tristram Hicks, Detective Superintendent
Scotland Yard
• Head of Financial Intelligence
• Recipient of all London STRs
• Head of London Asset Recovery Team
• Police rep on National Strategic
Committees
Speakers
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Cedric Woodhall
Senior Officer UK Customs
Head of
Set up UK Asset Recovery Office
Speakers
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Lawrie Day
Scotland Yard Detective
Accredited Financial Investigator
International AML adviser (Kosovo,
Croatia, Albania, northern Cyprus)
Speakers
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Jill Thomas
Europol AML specialist
Secretary of CARIN
Secretary of ARO Platform
Speakers
• Nottenboom
• Netherlands specialist prosecutor
• Founder of ARO
ARO Seminar
Ankara
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ARO Seminar
Ankara
UK experience
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UK Value 1970 - 2000
UK Value 1970 - 2010
Volume of POC 2002 - 2010
Key tools
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Find bank accounts
Access to SARs
Seize cash
Freeze accounts & assets
Incentive money for agencies
Incentive money for agencies
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50% to Ministry of Interior
18.75% Police
18.75% Prosecution
12.5% Courts administration
Incentive money for agencies
Pros
• Helps senior
management
• Helps middle
management
• Helps shop floor
• Helps government
Cons
• Changes focus from good
policing to revenue
• Perverted ‘cost/benefit
analysis
• ‘Better, quicker, cheaper’
investigations ignored
• ‘Incentive’ time limited
Incentive money for agencies
• Perceptions
• Police allow drug dealers to carry on until
car is worth seizing (moral hazard)
• Prosecutors change indictment/ bring case
to get the money (Judicial disapproval)
• Police/prosecutors working for themselves
not the public (public distrust)
Standard Intelligence Unit
Operational
Heads
Researcher
Briefing
Manager
Analyst
F.I.O.
Officer
Acquis and
FATF compliant
A Working AML Regime
Outputs:
Increased State
revenue
Prosecutions &
Confiscation
Outcomes
Police
Deters &
disables
organised crime
Suspicious
activity
Intervention
Prosecutors
Local
crime
Strategic
Group
Customs
Tax
Other
crime
Social welfare
SARs
FIC
Receiving
Analysis
Dissemination
Feedback to
Sectors
Tax evasion
Financial
sector
Awareness
Trust
Feedback
Financial Investigators 2000 to date
Agency
Police
Financial
Investigators
1417
London Police
496
SOCA
Tax & Customs
Local Gov
246
270
105
Social Welfare
Serious Fraud
24
16
Financial Services
11
Other Gov
Total
37
2622
Financial
investigators
UK only
Training History
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Fraud Training
Fraud and Confiscation Training
Confiscation Training
Intelligence then Investigation then
Confiscation Training
UK training is EU recommended
• Council of the EU, Evaluation of Financial
Crime and Financial Investigation, Report
on the UK.
• UK powers and training systems should be
presented to the EU, its Members and
Agencies
Intelligence
Investigation
Confiscation
Enhanced
Intelligence
Managers’
Course
Cash Seizure
Financial
Investigator
Internet
Research
Money
Laundering
F.I. Tutor
Course Format
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Pre-read
5 day course
Allocation of Tutor
Creation of Professional Development
Portfolio
• Regular Continuous PD
Course style
• Interactive problem solving
• Main Courses follow one case
Key lessons from UK
• Beware! Cultural resistance of senior
police managers, prosecutors, judges
• Emphasise operational efficiency: better,
quicker, cheaper investigations
• Seize and freeze first, ask questions later
• Importance of cash seizure
• Collect statistics now!
• Beware recycling the money to agencies
Money Laundering
& Proceeds of
Crime (ML & POC)
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