Chasing the Shadow: A National Effort to Combat Money Laundering, Terrorist Financing and Proliferation Financing
In a bold move to tackle the scourge of money laundering, terrorist financing and proliferation financing, Samoa’s authorities have launched a comprehensive national policy aimed at detecting, deterring, disrupting and preventing these criminal activities.
Detection: A Proactive Approach
The government has recognized that detection of these offences cannot be left solely to financial institutions. Instead, all agencies of the Money Laundering Prevention Task Force will work together to identify and report suspicious transactions and activities.
- Recent international experience has shown that relying solely on financial institutions can lead to ineffective and haphazard detection, diverting attention away from larger-scale money laundering schemes.
- A proactive approach is necessary to stay ahead of criminal activity and prevent damage to Samoa’s financial system and reputation.
Deterrence: A Strong Message
To deter offenders, the authorities will emphasize the robustness of Samoa’s anti-money laundering, counter-terrorist financing and proliferation financing systems. This will enhance the perception that those who engage in such activities have a high risk of being detected and punished.
- The strength of Samoa’s AML/CTF systems will serve as a deterrent to would-be offenders, making it more difficult for them to operate with impunity.
- A strong message is essential to prevent criminal activity and protect the country’s financial system.
Disruption: Targeted Action
The Task Force agencies will regularly review intelligence on offending and consider practical measures to target syndicates and entities involved in money laundering, terrorist financing and proliferation financing. This may include prosecution of offenders, confiscation of illicit assets and other legal measures.
- Targeted action is necessary to disrupt criminal activity and prevent further harm to Samoa’s financial system.
- A focused approach will help to dismantle criminal networks and bring perpetrators to justice.
Regular Testing and Improvement
To ensure the effectiveness of Samoa’s anti-money laundering, counter-terrorist financing and proliferation financing systems, regular testing procedures will be implemented. Deficiencies identified through these tests will be addressed through corrective actions, which will be documented along with the results of follow-up testing.
- Regular testing is essential to identify weaknesses in Samoa’s AML/CTF systems and prevent exploitation by criminal actors.
- Continuous improvement is necessary to ensure the effectiveness and efficiency of Samoa’s anti-money laundering efforts.
A Co-operative System
The fight against profit-driven crime requires close cooperation among agencies with different powers, information and skills. Task Force member agencies will share information and personnel freely in formal and informal arrangements to achieve this goal.
- Close collaboration is necessary to share intelligence, coordinate efforts and prevent duplication of effort.
- A co-operative system will help to ensure that Samoa’s anti-money laundering efforts are effective and efficient.
A Focus on Facilitators
Changing the behavior of facilitators of money laundering is a more cost-effective approach than targeting individual predicate offenders. Therefore, Samoa’s AML/CTF resources will be applied in a manner that has the greatest possible impact, focusing on those who assist through the formation of companies and other entities.
- Focusing on facilitators is essential to disrupt criminal activity and prevent further harm to Samoa’s financial system.
- A targeted approach will help to reduce the risk of money laundering and terrorist financing.
High-Risk Areas
In accordance with current FATF standards, Samoa will conduct regular assessments of ML/TF/PF risks. However, certain money laundering activities will not just be a “risk” but a “certainty”. Task Force resources will therefore be applied to known money laundering activities before moving on to lower-order risks.
- High-risk areas will receive priority attention to prevent further harm and ensure the effectiveness of Samoa’s anti-money laundering efforts.
- A risk-based approach is necessary to allocate resources effectively and maximize the impact of Samoa’s AML/CTF efforts.
By adopting this national policy, Samoa is sending a strong message that it is committed to combating money laundering, terrorist financing and proliferation financing. The government’s proactive approach will help to protect the country’s financial system and reputation, while also contributing to international efforts to combat these global threats.