Samoa’s Fight Against Money Laundering, Terrorist Financing and Proliferation Financing: A High-Stakes Battle
The Costly and Complex Endeavor
The battle against money laundering, terrorist financing, and proliferation financing is a costly and complex endeavor for financial institutions in Samoa. Not only do they face significant resource costs to detect and report suspicious transactions, but they also risk losing profits by turning away lucrative business opportunities to prevent these illicit activities.
The Role of the Samoa Financial Intelligence Unit (SFIU)
To combat this issue, the SFIU will be training its staff to understand the complexities of money laundering, terrorist financing, and proliferation financing. The SFIU will also provide assistance to regulated entities to help them detect and prevent these illicit activities. Periodically, the agency will audit the processes used by financial institutions to ensure they are effective in identifying and reporting suspicious transactions.
Deterrence: A Key Component
Deterrence is a crucial component of the fight against money laundering, terrorist financing, and proliferation financing. To achieve this, Task Force agencies will actively seek out and engage in activities that emphasize the robustness of Samoa’s AML/CTF/CPF systems to enhance the perception that those who engage in these criminal activities have a high risk of being detected and punished.
Disruption: A Multi-Faceted Approach
The intentional disruption of money laundering, terrorist financing, and proliferation financing will take various forms, including:
- Prosecution of offenders
- Confiscation of illicit assets
- Use of other legal and ethical means to reduce harm caused by these activities
- Regular review of intelligence on offending and consideration of practical measures to target syndicates and entities involved in these criminal activities
Prevention: A Proactive Approach
Prevention involves developing strategies to stop others from following in the footsteps of previous offenders. The Task Force will regularly review intelligence on money laundering, terrorist financing, and proliferation financing and formulate strategies to prevent repetition of these crimes or similar offenses.
Testing the System
The Authority and the Task Force acknowledge the importance of testing AML/CTF/CPF systems to ensure they are functioning as intended. This includes regular testing procedures with corrective actions put in place to correct identified deficiencies. The results of follow-up testing will be documented to ensure effectiveness.
Cooperation Among Agencies
The fight against profit-driven crime requires cooperation among agencies with different powers, information, and skills. Task Force member agencies will share information and personnel freely in both formal and informal arrangements.
Focus on Facilitators
Changing the behavior of facilitators of money laundering is significantly more cost-effective than changing the behavior of every predicate offender or would-be offender. The focus of AML/CTF law enforcement and regulatory action should be targeted towards facilitators and those who engage in laundering the proceeds of multiple predicate offenses.
High-Risk Areas
The Task Force will conduct regular assessments of ML/TF/PF risks and apply resources to known money laundering activities before moving on to lower-order risks.