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Money Laundering, Terrorism Funding, and Proliferation Financing: A Private Enterprise Focus
In a bold move to combat financial crimes, the Samoan government has announced that it will be leaving the detection of money laundering, terrorist financing, and proliferation financing solely in the hands of private enterprise.
Background
According to industry experts, recent international experience has shown that relying on financial institutions alone is not only ineffective but also risks diverting attention away from larger-scale money laundering schemes. This approach can result in significant costs for financial institutions, including resource expenditures and lost profits.
The Task Force’s Approach
In a statement, officials from the Money Laundering Prevention Authority (MLPA) acknowledged that while financial institutions play a crucial role in detecting these crimes, they cannot be left solely to them. Instead, agencies of the Task Force will:
- Train their staff to understand money laundering, terrorist financing, and proliferation financing
- Provide assistance to regulated entities
- Actively search its own data holdings for indicators of these crimes and share information with other agencies to facilitate disruption, deterrence, and prevention
- Conduct periodic audits of financial institutions’ processes and effectiveness to ensure that efforts are being undertaken in the spirit of the law
Deterrence
To effectively deter money laundering, terrorist financing, and proliferation financing, it is essential to create a perception of risk among offenders and would-be offenders. The Task Force will focus on targeting facilitators of these crimes, who can have a significant impact on the overall effectiveness of anti-money laundering efforts.
Cooperation
The fight against profit-driven crime requires collaboration between agencies with different powers, information, and skills. The Task Force has established formal and informal arrangements for sharing information and personnel to ensure a coordinated approach to combating financial crimes.
Focus on Facilitators
In terms of financially motivated crime, it is more cost-effective to change the behavior of facilitators than individual predicate offenders. The Task Force will apply its resources in a manner that has the greatest possible impact, targeting facilitators and those who engage in laundering other people’s proceeds.
High-Risk Areas
The Task Force will conduct routine assessments of money laundering, terrorist financing, and proliferation financing risks and focus on known high-risk areas before moving on to lower-order risks. This approach ensures that resources are applied where they can have the greatest impact.
Conclusion
By leaving detection to private enterprise, the Samoan government is taking a bold step towards combating financial crimes. The Task Force’s focus on facilitators, cooperation between agencies, and targeting high-risk areas will help ensure that these efforts are effective and impactful. As the global fight against money laundering, terrorist financing, and proliferation financing continues, it remains essential to adapt and evolve our approaches to stay ahead of these evolving threats.