Financial Crime World

Anguilla’s Financial Intelligence Unit: A New Hybrid Model to Combat Financial Crimes

Anguilla’s Financial Intelligence Unit (FIU), established in 2000, has recently undergone significant transformation with the enactment of the Financial Intelligence Unit Act, 2020. This legislation formalized the FIU as a Department of the Anguillan Government, tasked with the investigation, detection, prevention, and control of financial crimes.

A Hybrid Model for Efficient Financial Crimes Combat

The Anguillan FIU adopted the Hybrid Model, a unique combination of the judicial, law enforcement, and administrative FinCEN-style models. This model aims to create an efficient disclosure intermediary while maintaining the essential links between the judicial and law enforcement sectors.

The Law Enforcement Model

The Law Enforcement Model is a critical component of this hybrid setup. It enforces anti-money laundering regulations alongside existing law enforcement systems. By supporting various law enforcement or judicial authorities, it enhances their capabilities to combat money laundering effectively, particularly when dealing with competing or concurrent jurisdictions.

The Administrative Model

The Administrative Model functions as a centralized, independent authority. It collects information from the financial sector and shares disclosures with judicial or law enforcement agencies for subsequent prosecution. This model acts as an essential buffer between the financial sector and the law enforcement community.

post-Hybrid Model Implementation

Following the implementation of the hybrid model, the Anguillan FIU now operates with two distinct divisions:

  1. Financial Intelligence Unit – Intelligence Division: This division is at the forefront of gathering, analyzing, and disseminating intelligence to support investigations.

  2. Financial Intelligence Unit – Investigations Division: The primary focus of this division is on the in-depth investigation of serious financial crimes, such as money laundering, terrorist financing, asset recovery, cash seizure, and forfeiture. Additionally, it handles mutual legal requests concerning money laundering and terrorist financing.

Essential Coordination and Oversight

Both FIU divisions are overseen by the Director of the Financial Intelligence Unit, Anguilla, providing essential coordination and oversight in Anguilla’s efforts to combat financial crimes.