| Foreward |
| Acknowledgments |
| 1. |
Introduction |
| 2. |
Establishing an FIU |
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Steps in Establishing an FIU |
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Key Decisions |
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Consultations with Private Sector |
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Financing an FIU |
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Types of FIUs |
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Administrative-type FIUs |
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Law-enforcement-type FIUs |
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Judicial or prosecutorial-type FIUs |
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“Hybrid” FIUs |
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International Considerations |
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The FATF Recommendations |
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International Conventions |
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Core Principles of Financial Sector Supervision |
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Model Laws |
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Institutional Autonomy and Accountability |
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Placement in Administration |
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Appointment and Dismissal of FIU Head |
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Reporting Arrangements |
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Organization and Staffing |
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Internal Organization |
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Staffing |
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Liability of Staff and Confidentiality of Information |
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Security Issues |
| 3. |
Core Functions of an FIU |
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Receiving Transaction Reports |
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Who Must Report? |
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Financial institutions |
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Banks and insurance and securities companies |
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Nonfinancial businesses and professions |
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Casinos |
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Real estate agents and dealers in precious metals and precious stones |
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Lawyers, notaries, other independent professionals, and accountants |
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Trust and company service providers |
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Others |
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What Is to Be Reported? |
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Suspicious Transaction Reports |
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What is a suspicion? |
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What is criminal activity for purposes of the reporting obligation? |
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Reports of Transactions Related to Terrorism Financing |
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Reports of Transactions Above a Specified Amount |
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Reports of Cross-Border Transportation of Currency and
Bearer Negotiable Instruments |
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Data from Other FIUs |
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Rules Related to Reporting Entities |
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Confidentiality of customer information |
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Rules against “tipping off’ |
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Immunity of reporting entity and its staff for reports made in good
faith |
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Form and Contents of Reports to FIU |
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Improving Flow and Quality of Reports |
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Outreach actions |
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Administrative sanctions |
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Criminal sanctions |
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Analyzing Reports |
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Tactical Analysis |
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The FIU’s own data |
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Publicly available sources |
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Government-held databases |
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Additional information from original reporting entities and other
entities |
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Other FIUs |
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Operational Analysis |
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Strategic Analysis |
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Disseminating Reports |
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Transmitting Reports for Investigation or Prosecution |
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Sharing Information with Other Domestic Agencies |
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International Information Sharing |
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Legal basis for exchanges of information between FIUs |
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Exchange of information |
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Special arrangements for terrorist financing cases |
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Egmont Group principles of information exchange in money-laundering
cases |
| 4. |
Other FIU Functions |
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Monitoring Compliance with AML/CFT Requirements |
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AML/CFT Supervision Arrangements |
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FIU as AML/CFT Supervisor |
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Information Exchange and Cooperation |
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Blocking Transactions and Freezing Accounts |
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Training for Staff of Reporting Institutions in Reporting
and Other Requirements |
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Conducting Research |
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Enhancing Public Awareness of AML/CFT Issues |
| 5. |
Enhancing the Effectiveness of FIUs |
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Collecting Relevant Data |
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Identifying Opportunities for Improvement |
| 6. |
International Assessments of FIUs |
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Standards Regarding FIUs |
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Assessing Compliance with FIU-Related Standards |
| 7. |
Conclusions |
| Appendixes |
| I. |
Statement of Purpose of the Egmont Group of Financial
Intelligence Units |
| II. |
Procedure for Being Recognized as an Egmont Group
Financial Intelligence Unit (FIU) |
| III. |
The Egmont Group: Operational Financial Intelligence
Units of the World |
| IV. |
Interpretive Note Concerning the Egmont Definition
of a Financial Intelligence Unit |
| V. |
Egmont Group: Principles for Information Exchange
Between Financial Intelligence Units for Money-Laundering Cases |
| VI. |
Egmont Group: Best Practices for the Improvement
of Exchange of Information Between Financial Intelligence Units |
| VII. |
FATF 40 Recommendations (2003) |
| VII. |
FATF Special Recommendations on Terrorist Financing |
| IX. |
International Convention for the Suppression of
the Financing of Terrorism |
| X. |
United Nations Convention Against Transnational Organized
Crime |
| XI. |
United Nations Convention Against Corruption |
| Bibliography |
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| Tables |
| 1. |
FIU Power to Block Transactions and Freeze Accounts
in Selected Countries |
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| Figures |
| 1. |
Typical FIU Information Flow |
| 2. |
Typical FIU Organization Chart |
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| Boxes |
| 1. |
Administrative-Type FIUs |
| 2. |
Example of an Administrative-Type FIU: Slovenia’s
Office for Money Laundering Prevention (OMLP) |
| 3. |
Law-Enforcement-Type FIUs |
| 4. |
Example of a Law-Enforcement-Type FIU: United Kingdom’s
National Criminal Intelligence Service (NCIS) |
| 5. |
Judicial or Prosecutorial-Type FIUs |
| 6. |
Egmont Group of Financial Intelligence Units |
| 7. |
Norms and Standards on FIUs in European Union |
| 8. |
FIUs in Very Small Developing Island Economies |
| 9. |
Sharing Information with Other Domestic Agencies |
| 10. |
Requesting Information from an FIU |
| 11. |
FIU.NET |
