Introduc)on to the Joint Money Laundering Intelligence Taskforce (JMLIT Toolkit)

Transcription

1 Introduc)on to the Joint Money Laundering Intelligence Taskforce (JMLIT Toolkit) 1

2 Why launch the JMLIT? Ini$a$ve driven by UK banks and LEAs with full support of HM Government and Home Secretary. Project sits under Home Office led Financial Sector Forum (FSF) Collabora$ve response to ensure the cleanliness of UK financial markets - we know criminals target them to launder proceeds of crime and to enhance UK s interna$onal reputa$on for tackling economic crime effec$vely Vision: provide an environment for the financial sector and government to exchange and analyse intelligence to detect, prevent and disrupt money laundering and wider economic crime threats against the UK 2

3 What does it do? JMLIT s three primary objec)ves: Opera)onally enhance collec$ve an$ money laundering detec$on capability and generate increased preven$on and disrup$on opportuni$es rela$ng to money laundering ac$vity in the UK Strategically increase the UK s public and private sectors resilience to economic crime and developing our reputa$on in this regard Developmentally create a more sophis$cated, collec$ve UK response to money laundering, driven by beuer informed and capable law enforcement agency and bank staff 3

4 Governance SOC FINANCIAL SECTOR FORUM (HO, NCA, BBA) PRIORITY JURISDICTIONS CRIMINAL FINANCES INFORMATION SHARING JMLIT Management Board (NCA) Ad hoc meetings (HO) Priority Jurisdictions Working Group (HO) JMLIT Strategic Group (Lloyds / NCA) JMLIT Operations Group (NCA) Confiscation Orders (NCA) BBA s Financial Crime Alerts Service 4

5 What does it look like? Name Purpose Members (Banks) Timeline Strategic group Provide strategic direction to JMLIT operational group and promote wider info sharing on AML risks, typologies and methodologies Circa 25 UK and foreign banks, NCA, Home Office, Financial Conduct Authority and HM Treasury as appropriate. Started in Oct 2014, meets quarterly Operations group Alerts function Tactical intelligence and data sharing in physically co-located hub. Operational focus Circulate assessments, trend reports and non-sensitive intelligence and strategic and operations groups NCA, CoLP, HM Revenue and Customs, Financial Fraud Action Uk, Cifas and 10 banks - other members as appropriate All BBA members, particularly focused on smaller banks and building societies Started in Feb 15 pilot running for a year (1-2 days per week) Started in April

6 JMLIT Opera)ons Group: Why? Assists banks and law enforcement to fill intelligence gaps where suspected money laundering crosses mul$ple financial ins$tu$ons Secure environment for in-depth briefings on suspected money laundering all staff are veued Environment to agree priori$es and speed up enquiries (access to up to 10 banks at the same $me) Underpinned by clear legal framework (provisions of sec$on 7 of the Crime and Courts Act) and formal Informa$on Sharing Agreement 6

7 JMLIT Opera)ons Group: Who, when, where? Opera$onal team staffed by ten banks (all veued), law enforcement and industry bodies Pilot started February 2015 for one year Two days a week at secure premises in the City provided by the Corpora$on of London Dedicated SARs glossary code (if needed) - XXJMLXX 7

8 JMLIT Strategic Group Why? To share knowledge of current and emerging strategic money laundering risks across public and private sector Who, what? Co-chaired by NCA and Lloyds Banking Group, with law enforcement and circa 25 banks represented To inform alerts, assessments, typologies, trend reports and other non-sensi$ve intelligence products to inform the wider banking community and public authori$es of current and emerging strategic money laundering risks Four key strategic risks that have and con$nue to be examined: trade based money laundering, money laundering linked to human trafficking/organised immigra$on crime corrup$on and terrorist financing. 8

9 How can you help? 1. If you iden$fy money laundering with a UK angle in inves$ga$ons, flag this to JMLIT 2. Determine partners appe$te for informa$on sharing and sharing money laundering typologies 3. Offer interna$onal partners the concept and help us establish informa$on sharing gateways 9

10 Who can you call? JMLIT is a developing concept and we welcome your feedback For referrals to the JMLIT Strategic Group and/or queries about membership please the BBA For referrals to the JMLIT Opera$ons Group and/or general enquiries about JMLIT Ops please 10

11 Findings: 6 Month Review ToR Asssess whether Objec$ves have been met 6 months into 12 month Pilot and make recommenda$ons for change Specifically consider RISK 1 FAILS TOP ACHIEVE CORE OBJECTIVE TO PREVENT DETECT AND DISRUPT MONEY LAUNDERING RISK 2 CONCERNS ABOUT THE USE OF s7 AS THE LEGAL GATEWAY DETER ITS USE BY BANKS RISK 6 INDIVIDUALS INVOLVED IN JMLIT DO NOT HAVE NECESSARY CAACITY OR CAPABILITY TO DRIVE THE TASK FORCE TO DELIVER 11

12 Findings: 6 Month Review Quan)ta)ve LEA Cases 22 referred Private Sector 4 cases referred S7 responses 108 SARS responses 7 Remedial ac$on resul$ng from beuer profiling and monitoring Why disparity between LEA and Private Sector? Concerns over effec$veness of s7 in providing safe harbour? 12

13 Findings: 6 Month Review Qualita)ve Overview Banks, BBA HMRC and FCA asked to score effec)veness of progress to date on a scale of 1-10 All came out in range

14 Findings: 6 Month Review Is providing evidence base of issues and difficul$es to inform SARS review Use of SARS to report and use s7 Gateway to follow up has been novel and helped beuer banking /LEA understanding Concept emerging of super SARS and super pre order enquiry types of approach using S 7 gateway Banks apprecia$ve of the means of developing much beuer understanding of typologies, improving profiling and developing proac$ve monitoring controls creates hos$le AML environment Lessons being shared more widely by BBA with non par$cipa$ng banks 14

15 Findings: 6 Month Review Banks expec$ng some Pursue outcomes from JMLIT None yet apparent Measurability the so whats? Ini$al measurable outputs What / How do we measure outcomes from this? What measurable difference has it made to banks/leas / the vic$m of predicate offence» Point raised by Home Office Variability of Support / Responses From Banks Why? We need to understand concerns be`er. 15

16 Findings: 6 Month Review Awareness and Alignment with Other AML Ini)a)ves RART/ROCU Pilots North East and North West» To avoid Londoncentric percep)ons Need through BBA to communicate outputs with smaller and non- par)cipa)ng banks» To avoid percep)ons of select club of banks 16

17 Findings: 6 Month Review ToR Assess whether Objec$ves have been met 6 months into 12 month Pilot and make recommenda$ons for change Specifically consider RISK 1 FAILS TO ACHIEVE CORE OBJECTIVE TO PREVENT DETECT AND DISRUPT MONEY LAUNDERING RISK 2 CONCERNS ABOUT THE USE OF s7 AS THE LEGAL GATEWAY DETER ITS USE BY BANKS RISK 6 INDIVIDUALS INVOLVED IN JMLIT DO NOT HAVE NECESSARY CAPACITY OR CAPABILITY TO DRIVE THE TASK FORCE TO DELIVER 17