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International Organised Crime Groups Use Samoa as Transit Point
Samoa, a Pacific island nation known for its tourism industry, has emerged as a preferred transit point for international organised crime groups (IOCGs). The country’s geographic location, stable economy, and advanced banking system make it an attractive hub for illegal activities.
Attracting IOCGs
According to sources, IOCGs are drawn to Samoa due to its reputation as a secrecy haven with low capacity law enforcement. This allows them to operate undetected, moving goods and money without fear of being caught.
Effective AML/CFT System
However, experts say that an effective Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) system can reduce the attractiveness of Samoa for IOCGs. By preventing the movement of funds for illegal activities, a robust AML/CFT system can make it more difficult for these groups to operate.
Samoan Authorities’ Response
The Samoan authorities have acknowledged an intelligence gap regarding the activities of IOCGs and are working to identify sources of intelligence to fill these gaps. In response, they will commence engagement with international agencies and other stakeholders to better understand the nature and extent of IOCGs operating in Samoa. They will also formulate steps to reduce the country’s attractiveness as a place for IOCGs to do business.
Assessing Risks and Applying a Risk-Based Approach
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The Money Laundering Prevention (MLP) Act 2007 and MLP Regulations 2009, which govern AML/CFT in Samoa, have been criticized for not considering the types or volume of threats associated with predicate offences. The regulations also do not provide for a comprehensive risk-based approach to allocating resources and implementing measures to prevent or mitigate money laundering/terrorist financing.
Strengthening the Legal Framework
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The National Risk Assessment (NRA) 2014 and APG/FATF Mutual Evaluation have identified areas in Samoa’s legislation that can be tightened to improve the robustness of its AML/CFT system. These include the lack of legislation supporting targeted financial sanctions relating to terrorism and weapons proliferation financing.
Action Items
- Samoan authorities will commence engagement with international agencies and other stakeholders to better understand the nature and extent of IOCGs operating in Samoa.
- The authorities will formulate steps to reduce the country’s attractiveness as a place for IOCGs to do business.
- Future NRAs will consider the types or volume of threats associated with predicate offences.
- Feedback on findings from NRAs will be provided to financial institutions and designated non-financial businesses and professions.
- A comprehensive risk-based approach will be implemented to allocate resources and prevent or mitigate money laundering/terrorist financing.
- Existing laws will be amended to address technical deficiencies.
- The range of sanctions applicable to financial institutions and designated non-financial businesses and professions will be reviewed.
Conclusion
By strengthening its AML/CFT system and addressing the weaknesses in its legal framework, Samoa can reduce the attractiveness of its territory to IOCGs and prevent illegal activities from occurring.