Chapter 4 - Reporting Suspicious Activity

Question 1

Financial Intelligence Cycle

Answer 1

Characterized by banks and financial institutions reporting Suspicious Transaction Reports/Suspicious Activity Reports (STR/SAR) to a national financial intelligence unit (FUI)

Question 2

Triggers for opening an Investigation

Answer 2

1. Internal watchlists
2. Adverse media or seizure reports
3. Data from external organizations - what does this mean? Other financial institutions? Other law enforcement agencies or academic studies?
4. Requests from law enforcement

Question 3

5 Ws

Answer 3

Who's involved?
What instruments r mechanisms were being used?
Where did the suspicious activity occur?
When did the suspicious activity occur?
How did the suspicious activity occur?

Question 4

Conducting the investigation - Step 1

Answer 4

1. Conduct a review of the Customer Due Diligence profile.
   Start publicly
   Look at involved parties, to whom the money is going to, research them and an suspicious connections, then research them

Question 5

Conducting the investagation - Step 2

Answer 5

External Databases

• Check names against existing databases
• –law enforcement for records/offences

Question 6

Conducting the Investigation - Step 3

Answer 6

Conduct a transaction review
look at who they’re transacting with - then run their names
also check their rep on social media

Question 7

Things you should mention

Answer 7

• Web presence or lack thereof - website, owner public profile

Question 8

Look for

Answer 8

Look at the geographies that the transactions are related to -
- dude who took out a lot of cash in a casino close to game lands
Look at transactions involving species protected from commercial trade through an international treat (aka CITES)
Look for transactions to actors in high-risk industries

Question 9

Good Investigation

Answer 9

Gives as much detail as possible - the 5 Ys

Question 10

Role Banks and Financial Institutions can play

Answer 10

• “following the money”
• monitor the media
• work with counterparts in other countries
• lead and participate in regular PPP forums
• share patterns and trends on investigations completed for the IWT
• create internal watchlists and share with existing Environmental Crime watchlists
• Join coalitions

Question 11

Look for

Answer 11

• geography - towns or villages NEAR national parks

- connected to national park employees and officials

Question 12

Look for (Public Private Intelligence sharing)

Answer 12

law enforcement requests sensitive info that they then share with United for Wildlife via Basel Institute on governance
- robust study because of the coordination between federal/state actors, private org, and academic institution

Question 13

Examples of good public-private collaborative efforts or taskforces

Answer 13

1 - UK’s Joint Money Laundering Intelligence Taskforce (JMLIT)
2 - South African Anti-money laundering Integrated Taskforce (SAMLIT)
- both bring together the three - state law enforcement, private sector, and experts in the trade
- use existing laws to provide pathways to share information
- the ability to know who to call in each agency has sped up a number of financial investigations in Africa