The Importance of Coordinated Effort in Combating Money Laundering, Terrorist Financing, and Proliferation Financing
The fight against money laundering, terrorist financing, and proliferation financing requires a coordinated effort from all agencies involved. Recent international experience has shown that leaving detection solely to financial institutions is not only ineffective but also risks diverting attention away from larger-scale money laundering towards small-scale, more obvious forms.
Detection: A Proactive Approach
Agencies of the task force will:
- Train staff to understand money laundering, terrorist financing, and proliferation financing
- Provide assistance to entities they regulate or engage with to detect ML/TF/PF
- Actively search their own data holdings for indicators of these offenses and either act unilaterally or share information with other agencies
Deterrence: A Genuine Perception of Risk
Deterrence requires a genuine perception of risk among offenders and would-be offenders that they will be identified, caught, and punished. Task force agencies will actively seek out and engage in activities that emphasize the robustness of Samoa’s AML/CTF system to ensure effectiveness.
A Co-operative System: Collaboration is Key
The fight against profit-driven crime can only be effective if agencies with different powers, information, and skills work closely together. Task force member agencies will share information and personnel freely in both formal and informal arrangements.
Focus on Facilitators: Targeting the Source of the Problem
In terms of financially motivated crime, it is significantly more cost-effective to change the behavior of facilitators of money laundering than it is to change the behavior of every predicate offender or would-be offender. Therefore, AML/CTF resources will be applied in a manner that has the greatest possible impact, with a focus on targeting facilitators and those who engage in the laundering of other people’s proceeds.
High-Risk Areas: Prioritizing Efforts
In accordance with current FATF standards, Samoa will routinely conduct an assessment of ML/TF/PF risks. However, it is acknowledged that certain money laundering activities will be a certainty rather than just a risk. Task force resources will therefore be applied to known money laundering activities before moving on to lower-order risks.
Conclusion: A Coordinated Effort is Crucial
The fight against money laundering, terrorist financing, and proliferation financing requires a coordinated effort from all agencies involved in the task force. By taking a proactive approach in detection, providing assistance to entities, sharing information, and focusing on facilitators, Samoa can ensure the effectiveness of its AML/CTF system.
List of Acronyms
- AML: Anti-Money Laundering
- CPF: Counter Proliferation Financing
- CTF: Counter Terrorist Financing
- FATF: Financial Action Task Force
- MLPA: Money Laundering Prevention Authority
- ML: Money Laundering
- NRA: National Risk Assessment 2014
- PF: Proliferation Financing
- SFIU: Samoa Financial Intelligence Unit
- STR: Suspicious Transaction Report
- TF: Terrorist Financing