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Private Enterprise and Financial Institutions Under Scrutiny in Samoa’s Anti-Money Laundering Efforts

In an effort to strengthen its fight against money laundering, terrorist financing, and proliferation financing, the government of Samoa has introduced a new national policy. This policy shifts the focus from solely relying on financial institutions to detect these offenses.

New Policy Aims to Enhance Anti-Money Laundering Efforts

The policy aims to enhance the effectiveness of anti-money laundering (AML), counter-terrorism financing (CTF), and counter-proliferation financing (CPF) measures. It acknowledges that detection of these offenses cannot be left solely to private enterprise and financial institutions.

Key Features of the Policy

• Agencies under the Money Laundering Prevention Task Force will actively engage in detecting and disrupting money laundering activities.
• The task force agencies will provide assistance to entities they regulate or engage with to detect ML/TF/PF offenses.
• Periodic audits of financial institutions’ processes will be conducted to ensure that they are being carried out effectively.

Emphasis on Perception of Risk

The policy emphasizes the need for a robust perception of risk among offenders and would-be offenders. It highlights the effectiveness of Samoa’s AML/CTF/CPF systems to deter money laundering activities.

• The task force agencies will engage in activities that demonstrate the severity of consequences for those who engage in such offenses.
• This includes sharing information and personnel freely with other member agencies to disrupt money laundering networks.

Focus on Disruption and Prevention

The policy also focuses on disruption and prevention. It aims to target facilitators of money laundering activities, who are often more cost-effective to change than individual predicate offenders.

• AML/CTF resources will be applied in a manner that has the greatest possible impact.
• The focus will be on those who assist in the formation of companies or launder proceeds from multiple predicate offenses.

Prioritizing Known Risks

In recognition of the high-risk nature of some money laundering activities, the task force agencies will prioritize known risks before moving on to lower-order risks.

Regular Testing and Corrective Actions

The policy emphasizes the need for regular testing and corrective actions to ensure that AML/CTF systems are functioning effectively.

Conclusion

Overall, Samoa’s new national policy aims to strengthen its anti-money laundering efforts by shifting the focus from solely relying on financial institutions to a more comprehensive approach that involves detection, deterrence, disruption, and prevention.