Financial Crime World

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Financial Crime Investigation Procedures in Senegal: A Comprehensive Guide

Creating a Subject Profile

In all financial crime investigations, creating a subject profile is a crucial initial step. This involves collecting and recording basic information related to the target within the case folder and ensuring it is regularly updated. In multijurisdictional cases, this information will help establish links to foreign jurisdictions and be shared with counterpart agencies.

Information Collection

Practitioners should collect and maintain various information during the early stages of an asset recovery investigation in Senegal. This includes:

  • Personal Information:
    • Name (including aliases), date, and place of birth of target; copies of birth certificates; passports and national identity cards
    • Names (including aliases) and dates and places of birth of spouses, children, parents, new partners (if divorced or separated), siblings, spouses of siblings, immediate relatives (uncles, aunts, cousins, grandparents, grandchildren), and spouses’ relatives
  • Contact Information:
    • Relevant telephone numbers (business, home, mobile), email addresses, and other contact details
  • Recent Documents:
    • Recent photographs of all targets and associates (including government-issued identification)
    • A fingerprint card
    • Results of a criminal record search
  • Additional Information:
    • Academic records, employment history, and association memberships
    • Results of public-source searches on targets, associates, and affiliated companies using internet search engines, social media sites, local and international media reports, and libraries
    • Information from government agencies
    • Salary statements of the subject from a relevant government employer (if applicable)
    • Real estate records including purchase agreements, mortgages, loan applications, and appraisals
    • Information identifying banks or bank accounts and other entities that may hold business records

Collecting Financial Data & Other Evidence Sources

Financial data may include all assets and liabilities, income, and expenses of the targets and their businesses. Documents and other leads should be gathered from various sources, including:

  • Government Agencies
  • Financial Institutions (including e-banking facilities)
  • Money Service Providers
  • Law and Accounting Firms
  • Trust and Company Service Providers
  • Real Estate Agents
  • Art Dealers
  • Insurance Companies
  • Business Competitors
  • Travel and Other Reward Programs
  • ** Businesses, Relatives, Employees, and Associates of the Targets**
  • The Targets Themselves

Open-Source Investigations

Open-source information is publicly available data that can be gathered by any legal means, including information available through social media or the internet for free, for a fee, or by subscription. This information can reveal assets held by targets, their families and associates, and associated businesses.

In Senegal, open-source information is used throughout the investigation, from helping to assess the credibility of allegations to submitting admissible evidence at trial. It can assist in developing leads or identifying domestic or foreign assets held by targets, their families and associates, and associated businesses, as well as identifying associates and potential witnesses and compiling subject profiles.

Categories of Open-Source Information

  • Official Public Records (domestic and foreign): records of incorporation or birth, death, marriage, real property
  • Private, Commercial, or Law Enforcement Databases: property and credit reports; due diligence or know your customer (KYC) databases
  • Civil Litigation, Divorce, and Probate Proceedings (if available)
  • Corporate Registrations and Corporate Filings (including financial statements)
  • Patent and Trademark Applications
  • Nonprofit Organization Registrations
  • Tax Filings or Retirement Plan Information (if available)
  • Moveable-Asset Tracking Sites: regarding movement of aircraft, marine vessels, and motor vehicles
  • Social Media Postings
  • News Media (including newspapers, trade journals, society or gossip tabloids, or websites)
  • Educational Records, publications of alumni organizations
  • Information Describing the Confiscation by Legal Authorities and relevant information from other countries through:
    • Financial Action Task Force (FATF) reports
    • Informational country reports: for example, reports available on the US Department of Justice website
    • Asset Recovery Guides
    • Beneficial Ownership Guides

Additional Sources of Open-Source Information

  • Investigative Reporting and nongovernmental organization (NGO) reports are also important sources of open-source information, including:
    • International Consortium of Investigative Journalists (ICIJ)
    • Global Witness
    • Global Financial Integrity
    • Public Eye