Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697786609647.pdf (Fiji)
F I J I F I N A N C I A L I N T E L L I G E N C E U N I T ANNUAL REPORT 2019 OUR VISION “Protecting Fiji from Money Laundering” OUR MISSION 1.

Strengthen our compliance with international Financial Intelligence Unit (FIU) and anti-money laundering and combating the financing of terrorism (AML/CFT) obligations; 2.

Implement AML/CFT policies to ensure the safety and integrity of Fiji’s financial system; 3.

Implement an effective intelligence management framework; 4.
Strengthen networking with our partners; and 5.

Enhance operational governance and communication.

OUR KEY STRATEGIC GOALS Our strategic goals for achieving the missions are: 1.

Regional FIU Leadership; 2.

Global and Best AML/CFT Practices; 3.

Risk-Based Approach to Implementation of AML/CFT Policies; 4.

Effective Compliance Regime for Financial Institutions; 5.

Effective Tactical and Strategic Analysis Processes; 6.

Information Technology Based Intelligence and Case Management; 7.
Engagement with our Partners; 8.

Information and Intelligence Networking; 9.

High Performance and Effective Team; and 10.

Governance and Proactive Communication.

Table of Contents 2019 ANNUAL REPORT FIJI FINANCIAL INTELLIGENCE UNIT 1.

FIU ROLE AND RESPONSIBILITIES 2.

DIRECTOR’S FOREWORD 3.

GOVERNANCE STRUCTURE 4.

EXPENDITURE STATEMENT & NOTES 5.

OUR ACHIEVEMENTS A.

Analysis of Financial Information Received B.


Dissemination of Financial Intelligence 2 3 6 8 10 10 13 C. Supporting and Supervising Financial Institutions’ Compliance 16 D. Domestic Coordination and Engagement E. International Engagement and Contribution 6.

OPERATIONAL GOVERNANCE AND COMMUNICATION 7.

NATIONAL ANTI-MONEY LAUNDERING COUNCIL 8.

APPENDICES 9.

SELECTED KEY STATISTICS 2015-2019 10.

SELECTED KEY EVENTS 2019 STRATEGIC ANALYSIS REPORT 2019 FIJI FINANCIAL INTELLIGENCE UNIT 1.
STRATEGIC ANALYSIS OVERVIEW 2.

SUMMARY OUTCOMES 3.

OUTCOMES - SUSPICIOUS TRANSACTION REPORTS 4.

OUTCOMES - CASH TRANSACTION REPORTS 5.

OUTCOMES - ELECTRONIC FUNDS TRANSFER REPORTS 6.

OUTCOMES - BORDER CURRENCY REPORTS 19 21 26 29 32 36 37 41 43 44 51 53 55 7.

EMERGING AND CONTINUING MONEY LAUNDERING TRENDS 59 8.

CASE STUDIES 9.

GLOSSARY 61 69 FIU ROLE AND RESPONSIBILITIES 1 The Financial Intelligence Unit (FIU) is established under the Financial Transactions Reporting (FTR) Act.
The role and functions of the FIU are provided under the FTR Act.

The FIU is one of the leading agencies in Fiji that is responsible for preventing and detecting money laundering and terrorist financing activities.

The FIU is also Fiji’s anti-money laundering (AML) and combating the financing of terrorism (CFT) regulator and the lead agency on AML/CFT policy formulation, compliance and enforcement.
The FTR Act and Regulations specifies a range of measures that financial institutions1 in Fiji must implement in order to prevent the use of Fiji’s financial system from money laundering, terrorist financing and other serious criminal activities.

The vision of the FIU is to protect Fiji from money laundering.
It achieves this vision through the following key functions: 1. receive financial transactions and other information from financial institutions; 2. gather additional information from financial institutions, government and other stakeholder agencies; 3. analyse information; 4. develop intelligence; 5. refer intelligence and information of possible money activities or other serious criminal activities to appropriate law enforcement and regulatory agencies; laundering 6. assist domestic and foreign law enforcement agencies in their investigation and prosecution of money laundering and other serious criminal activities; 7. develop AML/CFT policies, FIU enforceable guidelines and advisories under the FTR Act; 8. comply with international AML/CFT standards; 9. supervise financial institutions for compliance with the FTR Act; 10. take appropriate enforcement action in case of non-compliance; 11. provide education and training to its stakeholders; 12. lead and facilitate national coordination; and 13. maintain networking and information sharing with domestic and foreign partner stakeholders and agencies.
The FIU also plays an important role in international AML/CFT initiatives by contributing to global AML/CFT programmes, policy discussions and information exchange network.

The FIU is modelled as an “administrative FIU” that is currently administered by the Reserve Bank of Fiji.

The FIU does not have formal investigative powers to arrest and charge suspects or restrain properties.

The FIU does not have a prosecutorial role.


The FIU’s role as a financial intelligence body in Fiji has become an integral part and contributor in successfully investigating and prosecuting money laundering and other serious crimes.

The FIU also conducts periodic strategic analysis and its outcomes are used by FIU partners including the private sector financial institutions and designated non-financial businesses and professions (DNFBP).
The FIU shares its intelligence and information both spontaneously and upon request to various partner agencies, both domestic and foreign.

The National AML Council provides assistance to the FIU on broad AML policy and national coordination framework.

The RBF provides funding and general administrative support for the FIU’s operations.

The Fiji Police Force (FPF) and the Fiji Revenue and Customs Service (FRCS) provide additional staffing support to the FIU.
1 The definition of “financial institutions” under the FTR Act includes DNFBPs and other non- traditional financial institutions such as non- banks, mobile money remitters, lawyers, accountants and real estate agents.

2 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 DIRECTOR’S FOREWORD 2 I am pleased to present the 2019 Annual Report of the FIU.

This is the 14th Annual Report of the FIU.


As the lead agency in Fiji for managing the strategic risk of ML/TF, the FIU develops, implements and enforces AML/CFT preventive measures, financial intelligence management, information exchange, and creates awareness on ML and TF trends and typologies.

In the last 14 years of our existence we have seen the AML/CFT landscape evolve and become more challenging nationally, regionally and globally.
As a result of these challenges and changes we launched our first Case Management System (CMS) in 2019.

CMS is an online central database for all suspicious transaction reports and analysis.

The system can also automatically generate case dissemination reports and link charts.
The FIU continued to engage with the designated non-financial businesses and professions, such as, lawyers, accountants and the real estate agents while at the same time the FIU further strengthened its engagement with other industry stakeholders and enforcement and regulatory authorities to ensure that the requirements under the FTR Act and Regulations are effectively implemented.
The evolving nature of the AML/CFT landscape makes it more apparent that serious illicit financial transactions generates a shared risk which can be managed with effective coordination and collaboration with domestic and international partners.

In 2019, the FIU continued as the secretariat for the National AML Council and working groups.
We continued in our role as Fiji’s primary contact point for APG and I led the Fijian delegation to the APG plenary meeting in Canberra, Australia where Fiji’s third follow-up report was discussed and a compliance rating was upgraded.

The 2019 Annual Report is divided into two parts: • Annual Report section; and • Strategic Analysis section.

The Annual Report section highlights key functional and operational outputs while the Strategic Analysis section highlights the underlying patterns and trends.
The FIU finalized its 2020 – 2024 strategic plan in 2019 and will introduce it in 2020.

The new strategic plan will focus on the five pillars of: i.

Financial Intelligence; ii.

Preventive Measures; iii.

Technology Driven Processes; iv.

Partnerships; and v. Our People.


While we have retained our vision of “Protecting Fiji from Money Laundering”, the strategic plan will also reflect the environment in which the FIU will operate in the next five years, particularly, redefining and advancing our technology driven, data quality and intelligence data mining processes.
3 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 The FIU will continue to engage with its key partner agencies and reporting institutions in 2020 and collaborate with the National AML Council on the implementation of APG recommendations and the findings of the national risk assessment.

I would like to thank the Governor and the Board of the Reserve Bank of Fiji for providing financial and administrative support to the FIU in 2019.
I look forward to working more closely with our stakeholders in 2020 in achieving our vision of “Protecting Fiji from Money Laundering”.

I would like to also thank the Commissioner of Police and the Chief Executive Officer of the FRCS for seconding their officers to the FIU.
Razim Buksh Director Financial Intelligence Unit Foreign investors, local business people and ordinary Fijians are protected from illicit financial transactions Safety and integrity of Fiji’s financial system Contribute to the investigation and prosecution of fraud, corruption, tax evasion and other complex financial crimes Detection, reporting and investigation of suspicious transactions and clients FINANCIAL INTELLIGENCE UNIT Conduct background and due diligence checks National and international networking and information exchange Fiji’s compliance with international AML/CFT requirements Implement preventive customer due diligence measures 4 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 2019 AT A GLANCE Received Received Received 1,515,681 Electronic Fund Transfer Reports 622 Cash Transaction Reports 794,044 Suspicious Transaction Reports Handled 89 requests for due diligence on 99 entities and 162 individuals Disseminated Issued 84 Intelligence reports 56 Ad-hoc policy advisories Handled Managed More than Analysed 1,102 Border currency reports 141 Authorised users of the FIU’s online IT system 16 Million Financial transaction reports in our database 216 Suspicious transaction reports Handled 222 Requests for investigative assistance from law enforcement agencies Provided training to 79 officers of financial institutions and 152 officers of law enforcement agencies Made Managed network of Conducted Conducted 603 Enquiries to financial institutions 131 registered AML Compliance Officers of financial institutions (since 2006) 3 AML on-site compliance examinations of law firms 4 AML on-site compliance examinations of real estate agents 5 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 GOVERNANCE STRUCTURE 3 Statutory Agency The FIU is an independent and administrative statutory agency of the Fijian Government.
The powers, duties and functions of the FIU are clearly defined in the FTR Act.

The FIU was established in January 2006 under the FTR Act.

Minister for Justice The Minister for Justice is the line Minister responsible for the FTR Act.

Pursuant to section 23(3) of the FTR Act, the Minister is directly responsible for the performance of the Director FIU.

The Minister is also responsible for appointing the Directo FIU on the recommendation of the National AML Council.
Governor of the Reserve Bank of Fiji Pursuant to a ministerial delegation under the FTR Act, the Director FIU reports to the Governor of the RBF for the discharge of his powers, duties and functions provided under the FTR Act.

Subsequent to this delegation and on the recommendation of the Governor, the Board of Directors of the RBF approved the organisation structure and annual funding of the FIU.
Director of the FIU The Director FIU is responsible for exercising the powers, duties and functions of the FIU as specified in the FTR Act.

The Director FIU is responsible to the Minister for Justice or such other person as the Minister may appoint, in the performance of his duties.

Following the Minister’s delegation of his responsibility in 2005, the Director is now directly responsible to the Governor of the RBF in the performance of his duties.

Director FIU is a member of the National AML Council.
He is also the advisor to the Minister and the Governor on matters relating to combating money laundering, terrorist financing and related offences in Fiji.

Accountability to the Governor The FIU’s administrative processes and procedures are linked to that of the RBF.

Therefore, the FIU complies with the corporate planning, budgeting, human resources and other policies and processes of the RBF.
The FIU’s annual work plan and budget are presented to the Governor and the RBF Board for their approval before each new financial year.

The Director FIU provides monthly reports to the Governor of the RBF on the FIU’s performance and achievement of work plan targets.

The Director of the FIU also provides regular progress updates to the National AML Council, Governor and Board of the RBF on key FIU outputs and outcomes.
FIU GOVERNANCE AND ACCOUNTABILITY FRAMEWORK • Minister responsible for the FIU under the FTR Act.

• Delegated his responsibilities under the FTR Act to the Governor of the RBF in 2005.

• Responsible for the administration of the FIU under the delegation of powers from the Minister for Justice.

• Responsible for the approval of FIU annual work plan and budget.

Minister for Justice Governor and RBF Director FIU • Responsible for the powers, functions and duties of the FIU as specified in the FTR Act.
• Reports directly to the Governor of the RBF.

• Advisor to Government on matters relating to combating ML and TF.

National AML Council • Responsible for providing advice and assistance to the FIU on the prevention of money laundering and terrorist financing activities in Fiji.

• Provides recommendations to the Minister and Governor on the appointment of the Director.
6 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Reporting to the National AML Council The National AML Council is established under the FTR Act and its members, roles and functions are also provided under the FTR Act.

The Council provides broad policy advice, assistance and guidance to the FIU on the prevention of money laundering, terrorist financing and related activities in Fiji.
The Council is also responsible for making recommendations to the Minister on the appointment of the Director of the FIU.

The FIU provides regular reports and updates to the National AML Council.

Funding and Administration The FIU is fully funded by the RBF and is organised as a separate functional group within the RBF’s organisation structure.

The annual budget of the FIU is submitted for the approval by the Board of the RBF each year.
The FIU is accountable to the Governor and the Board for the use of funds allocated annually.
Operational Governance As a member of the Egmont Group of international FIUs, the Fiji FIU implements world class operating standards, protocols and procedures on the following key responsibilities: Egmont Group FIU Responsibilities 1 International cooperation and information exchange 2 Receipt of confidential and sensitive information 3 Analysis and intelligence development 4 Information Security 5 Compliance & enforcement 6 Operational independence and governance The FIU is administratively housed within the RBF.
The FIU is subject to all the administrative protocols, policies and procedures of the RBF.

the FATF The FIU also Recommendation 29 and its Interpretative Note on financial intelligence units.

complies with Due to the nature of its establishment as part of the RBF, the FIU does not prepare and publish annual financial statements on its operations.
The expenditure of the FIU is included in the financial statements of the RBF and is subject to the Bank’s internal and external audit (refer to the section on Expenditure Statement and Notes for more information).

Independence of the FIU While the FIU is administratively dependent on the RBF, the technical functions of the FIU are independent of the RBF.

The Director FIU is responsible and accountable for the decisions relating to the delivery of the FIU core outputs.
The functional and operational independence of the FIU is provided under Part 4 of the FTR Act.

The FIU also receives indirect financial support from the FPF and the FRCS through staff secondment to the FIU on a full-time basis.

The secondment arrangement is provided under MOAs the FIU has signed with the two agencies.

receive any The FIU does not currently supplementary funding support from the Fijian Government.
The FTR Act requires that the consideration for appointment of Director FIU by the Minister (Governor of the RBF under delegation of authority) is subject to the recommendation of the National AML Council.

To ensure that the functions of the FIU are not influenced by other parties, the Director of the FIU is solely vested with the powers to discharge the statutory and functional responsibilities of the FIU.
7 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 EXPENDITURE STATEMENT & NOTES 4 The RBF continued to fund the operations of the FIU in 2019.

The FIU’s total expenditure for 2019 was $878,000 compared to $882,000 in 2018.

The expenditure of the FIU is incorporated into the financial statements of the RBF and is audited as part of its annual accounts.
The RBF also provided other administrative support services to the FIU in 2019 in the areas of human resource management, accounting, information technology services, security services and other general administrative services.
Financial Intelligence Unit Statement of Expenditure For the year ended 31 December 2019 Expenses Salaries & wages Meetings IT expense Consultancy Insurance Printing, publications & stationery Other expenses Total expenses Note 31 December 2019 31 December 2018 $ $ 748,000 738,000 73,000 16,000 22,000 10,000 5,000 4,000 77,000 15,000 24,000 8,000 17,000 3,000 878,000 882,000 The statement of expenditure has been audited up to 31 July 2019.
The figures from 1 August 2019 to 31 December 2019 will be audited as part of the financial statement of the RBF in 2020.

8 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Financial Intelligence Unit Notes For the year ended 31 December 2019 1.

Salaries & Wages The total salaries & wages expense amounts to $748,000 for the financial year ended 31 December 2019 (2018: $738,000).
These include all the payments related to salaries (FNPF, TPAF, acting allowance, bonus) paid to Director FIU, two Managers and six technical and support staff.

2.

Meetings Overseas Local 31 December 2019 $ 31 December 2018 $ 67,000 6,000 73,000 72,000 5,000 77,000 This cost encompasses local and overseas meetings including the Egmont Plenary and APG Annual Meeting, congresses, conferences, conventions, seminars, attachments, external and in-house training.

3.
3.

IT Expense Oracle Database Maintenance Internet 31 December 2019 $ 31 December 2018 $ 12,000 4,000 16,000 11,000 4,000 15,000 The computer cost is related to the database maintenance, licence and internet expense for the year.

4.

Consultancy The consultancy expense amounts to $22,000 for the financial year ended 31 December 2019 (2018: $24,000).

The cost includes the subscription of databases for intelligence gathering and Egmont Group membership fees.

5.
5.

Insurance The insurance expenditure is related to the term life insurance scheme that is provided to all staff.

This amounts to $10,000 for the financial year ended 31 December 2019 (2018: $8,000).

6.

Printing, Publications & Stationery Printing Publication 31 December 2019 $ 31 December 2018 $ 1,000 4,000 - 17,000 17,000 The above expense included the cost for printing and publication of the annual report, border currency reports and other relevant publications.

5,000 7.
5,000 7.

Other Expenses Vodafone Advertising General Expense 31 December 2019 $ 31 December 2018 $ 2,000 1,000 1,000 4,000 1,000 1,000 1,000 3,000 9 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 OUR ACHIEVEMENTS 5 A.

Analysis of Financial Information Received A key function of the FIU is to analyse suspicious transaction reports and other financial transaction reports that it receives from financial institutions2, members of the public and other agencies in Fiji.
Highlights of financial transaction reports received by the FIU in 2019 are provided below.

The FIU also conducts strategic analysis of financial transaction reports received which is provided in the strategic analysis section of this Annual Report.

In 2019, the FIU received a total of 2,311,449 financial transaction and other reports.

These reports consisted of suspicious transaction reports (STR); cash transaction reports (CTR); electronic fund transfer reports (EFTR) and border currency reports (BCR).
Financial Transaction Reports Received 2015-2019 Year STR CTR 2015 2016 2017 2018 2019 516 579 650 632 622 579,849 591,636 623,213 968,693 794,044 EFTR 1,029,993 1,148,711 1,220,602 1,357,246 1,515,681 BCR 491 547 792 969 1,102 TOTAL 1,610,849 1,741,473 1,845,257 2,327,540 2,311,449 Monthly Total Average Source: Fiji FIU 134,237 145,123 153,771 193,962 192,621 Financial Transaction Reports Received 2000-2019 EFTR 10,725,275 Part D Continued Part D Continued FIJI CUSTOMS / IMMIGRATION USE ONLY 23 Residential Address (Cannot be a PO Box) 23 Residential Address (Cannot be a PO Box) Country: Phone: Country: Phone: 24 Occupation, Business or Principal Activity of this Person, Business or Organisation 24 Occupation, Business or Principal Activity of this Person, Business or Organisation SIGNATURE OF PERSON CARRYING CURRENCY SIGNATURE OF PERSON CARRYING CURRENCY 25 This Statement is Made Pursuant to the Requirement for Currency Reporting at the Border Under FTR Act and the Regulations.
Sign Here X Sign Here X Date: Date: / / / M M / D D Y Y Y Y D D M M Y Y Y Y Complete this Report and Give to: Complete this Report and Give to: Customs Officer at the Port of Arrival / Departure Customs Officer at the Port of Arrival / Departure For Assistance Contact: For Assistance Contact: Financial Intelligence Unit Financial Intelligence Unit Phone: (+679) 322 3333 Fax: (+679) 331 6454 Email: info@fijifiu.gov.fj Phone: (+679) 322 3333 Fax: (+679) 331 6454 Email: info@fijifiu.gov.fj Fiji Islands Revenue & Customs Authority Phone: (+679) 330 2322 Fax: (+679) 330 5138 Email: info@frca.org.fj Fiji Islands Revenue & Customs Authority Phone: (+679) 330 2322 Fax: (+679) 330 5138 Email: info@frca.org.fj YES NO 1 Verify: Name: Date of Birth: Country of Birth: Passport Number: 2 Currency Verified: 3 Officers Name Comments: 4 Name and Type of Port - (e.g.
Airport, Avatui Harbour) 5 Date and Signature: / / D D M M Y Y Y Y 6 Fiji Customs / Immigration Reference Number : Stamp Here: FIJI FINANCIAL INTELLIGENCE UNIT USE ONLY Report Number: Authorisation: Comments: BORDER CURRENCY REPORT (BCR) $10,000 OR MORE Complete this form if you are carrying $10,000 or more in Currency Currency Reporting at the Border is required under section 32 (1) of the Financial Transactions Reporting Act 2004 and Part 6 of the FTR Regulations 2007.
Complete this form if you are carrying currency or negotiable bearer instruments with a combined value of FJD10,000 or more or its equivalent in foreign currency.

"Currency" means the cash of the Fiji Islands or of another country that is designated as legal tender and which is customarily used and accepted as a medium of exchange in the country of issue.
"Negotiable Bearer Instrument" means a document representing ownership of debts or obligations, including bills o exchange, promissory notes, or certificates of deposit, whether made payable to the bearer or not.

The term "currency" is used throughout this form and includes cash and negotiable bearer instruments.

Criminal and civil penalties will apply under the Financial Transactions Reporting laws for failure to declare currency or for providing false or misleading information.
Page 5 of 6 Page 5 of 6 Form: BCR 4 - Schedule 1, FTR Regulation 39.

[Jan 2008] Form: BCR 4 - Schedule 1, FTR Regulation 39.

[Jan 2008] Page 6 of 6 Form: BCR 4 - Schedule 1, FTR Regulation 39.

[Jan 2008] Page 1 of 6 Form: BCR 4 - Schedule 1, FTR Regulation 39.

[Jan 2008] No: 0001 Suspicious Transaction Reports The FIU received 622 STRs3 in 2019 or an average of 52 STRs per month compared to 632 STRs reported in 2018.

Suspicious Transactions Reported 2015-2019 No.


of STRs 700 650 632 622 579 516 600 500 400 300 200 100 0 CTR STR BCR 5,628,119 8,571 6,751 Total 16,368,716 2015 2016 2018 2019 2017 Years Source: Fiji FIU Financial institutions are required under section 14 of the FTR Act and regulation 24 of the FTR Regulations to report suspicious transactions to the FIU.
A suspicious transaction is a transaction or attempted transaction which a financial institution has reasonable grounds to suspect may be related to a “serious offence, a money laundering offence or an offence of the financing of terrorism”.

2 Financial institutions include designated non-financial businesses and professions.

3 The number of STRs reported and the funds that are involved in suspicious transactions do not necessarily indicate the size of money laundering activity in Fiji.
However, these transactions have been subject to a greater level of scrutiny by reporting financial institutions and have been flagged and reported as questionable, unusual and suspicious transactions.

The figure suggests money laundering symptoms, risk and vulnerabilities in Fiji.

10 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Electronic Fund Transfer Reports The FIU received 1,515,681 EFTRs in 2019 or an average of around 126,307 per month.
This is an increase of 12 percent compared to 1,357,246 EFTRs reported in 2018.

Electronic Fund Transfers Reported 2015-2019 No.


of EFTRs 1,600,000 1,400,000 1,200,000 1,00,000 800,000 600,000 400,000 200,000 0 1,515,681 1,220,602 1,357,246 1,029,993 1,148,711 2015 2016 2017 2018 2019 Years Source: Fiji FIU remittance service Commercial banks and providers (including mobile phone money remitters) are required under section 13(2) of the FTR Act and regulation 26 of the FTR Regulations to report to the FIU all international electronic fund transfer transactions.
There is no monetary threshold for EFTRs.

Border Currency Reports In 2019, the FIU received 1,102 BCRs.

This is an increase of 14 percent compared to 969 BCRs received in 2018.

There were more declarations made by outbound travellers compared to inbound travellers.

Border Currency Declarations 2015-2019 No.
of BCRs 1200 1000 800 600 400 200 0 1,102 969 792 491 547 2015 2016 2017 2018 2019 Years Source: Fiji FIU BCR Declarations by Direction of Travel 2015-2019 Persons Declaring Declarations made by inbound travellers Declarations made by outbound travellers 2015 2016 2017 2018 2019 187 265 375 434 436 304 282 417 535 666 TOTAL 491 547 792 969 1,102 Source: Fiji FIU FIUs Reporting and Intelligence Development As required under section 25(1) of the FTR Act, the FIU is required to analyse and assess all reports and information that it receives including information that is received from members of the public.
The FIU uses tactical analysis procedures as set out in its standard operating manual to analyse all STRs and develop intelligence of possible money laundering or other serious offences.

Other reports received by the FIU such as the CTRs and EFTRs while not analysed in detail, provide critical information which is used to analyse STRs.
During 2019, the FIU continued to use FFIMSO in 11 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 its intelligence processes.

The FIU uses its Alert and Monitoring System (AMS) which monitors all financial transaction reports maintained on the FFIMSO database for identifying suspicious transactions.
The FIU also continued to use a Data Mining System (DMS) to analyse financial transaction data captured in the FFIMSO database.

The DMS identifies links, relationships and patterns of suspicious financial activities.

The AMS and DMS proactively identifies suspicious transactions and reports this weekly to FIU analysts for their further analysis.

The FIU launched its Case Management System (CMS) on 7 February 2019.

The system centrally stores all STR cases, analysis and reports.
The case system also automatically generates dissemination reports, link charts, and queries resulting in more streamlined processes.

BCRs are collected by FRCS and sent to the FIU for data mining and analysis for possible currency smuggling, tax evasion, money laundering and related criminal offences.

FIU Enquiries with Financial Institutions As part of its analysis process, the FIU makes enquiries with financial institutions.
The queries are aimed at developing further intelligence on information already provided on the STRs.

FIU queries may also be in relation to an ongoing investigation of money laundering offence or proceeds of crime case.

The FIU has powers to obtain information from relevant financial institutions under sections 14(3), 25(1)(c), 25(1)(h) and 28 of the FTR Act.

Monthly FIU Queries to Financial Institutions 2019 Commercial Banks Other Financial Institutions No.
of Queries 120 100 80 60 40 20 0 J F M A M J J A S O N D Months Source: Fiji FIU FIU Queries to Financial Institutions (Excluding Commercial Banks) 2019 No.
of Queries 30 25 20 15 10 5 0 Insurance & Superannuation Finance Companies Money Remittance Service Providers Law Firms Others Financial Institutions (excluding commercial banks) Source: Fiji FIU The queries sent to financial institutions included requests for: In 2019, 603 queries for further information were made by FIU to commercial banks (90 percent) and other financial institutions (10 percent).

i. customer transaction history; ii.

customer identification details; iii.


customer account details; 12 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 iv.

copies of documents such as identification documents; v. customer transaction queries; vi.

follow ups and clarifications; vii.

originator information enquiries; viii.

payment instrument (cheque) details; and ix.

customer payment and asset details.


In 2019, the majority of the queries sent to financial institutions were for customer transaction history (i), customer identification details (ii) and customer account details (iii).

B.

Dissemination Of Financial Intelligence Intelligence Reports to Law Enforcement Agencies law Disseminating financial enforcement agencies is a core function of the FIU.
Financial intelligence enables our law enforcement partners to investigate predicate crimes, money laundering and terrorist financing activities.

intelligence to The FIU’s intelligence reports also provide profiling of suspected proceeds of crime and proceeds linked to tax evasion.

The FIU analyses suspicious transaction and other financial transaction information to develop intelligence.
The results of the FIU’s analysis of STRs are disseminated to relevant law enforcement agencies in a case dissemination report (CDR).

In 2019, 84 CDRs were referred to law enforcement agencies compared to 321 CDRs in 20184.

The CDRs were developed from reports of suspicious transactions received in 2019 and prior to 2019.

Case Dissemination Reports 2015-2019 No.


of CDRs 500 450 400 350 300 250 200 150 100 50 0 448 321 258 195 84 2015 2016 2017 Years 2018 2019 Source: Fiji FIU Case Dissemination Reports to Law Enforcement Agencies 2015-2019 Law Enforcement Agency and Reason for Dissemination FRCS - Inland Revenue Services Possible violations under the Income Tax Act and VAT Decree.

FPF* Possible violations under the Proceeds of Crime Act and serious offences under the Crimes Decree.
Immigration Department Possible violations under the Immigration Act and Passport Act.

2015 2016 2017 2018 2019 166 83 310 193 44 66 58 84 62 8 1 5 2 8 0 4 Due to strict confidentiality requirements, this annual report does not discuss details of cases currently being investigated as a result of the FIU’s intelligence.
Cases that involved proceeds of crime that were subject to monitoring, restraining, confiscation or forfeiture orders as a result of FIU’s intelligence are also not mentioned in this report.

Convictions of money laundering and proceeds of crime cases have been published as case studies and have been included in the FIU Strategic Analysis Report.
13 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 2015 2016 2017 2018 2019 Due to the sensitivity and confidentiality of the Alert & Instruction Notice, financial institutions are advised to circulate the Alert & Instruction Notices internally with caution.

5 12 7 14 7 There were nine Alert & Instruction Notices issued by the FIU in 2019.

Law Enforcement Agency and Reason for Dissemination FRCS - Customs Division Possible violations under the Customs Act.
Others5 20 37 45 44 TOTAL 258 195 448 321 25 84 Alert & Instruction Notices Issued 2019 Date Alert Notice Number Issued To Details Source: Fiji FIU In 2019, 61 percent of the CDRs were disseminated to FRCS while ten percent of CDRs were disseminated to the FPF.

Intelligence that is developed from a single STR is sent in some instances to more than one law enforcement agency as it may involve suspected violations of different laws.
After detailed analysis, the FIU also, filed away 132 STRs during 2019 compared to 248 STRs in 2018.

STRs are filed away for future intelligence references and analysis, if after analysis and intelligence gathering, the FIU is able to reasonably conclude that the transaction or information does not involve a money laundering offence or other serious offence.
Alert & Instruction Notices to Financial Institutions From time to time, the FIU may need to disseminate alerts or directives to financial institutions in relation to information it has received under the FTR Act.

The FIU issues Alert & Instruction Notices to financial institutions, in order to protect the financial system from being used by adversely reported individuals and business entities.
An Alert & Instruction Notice contains information on adversely reported individuals and/or business entities that require enhanced due diligence and scrutiny by financial institutions.
6 February 1/2019 Commercial banks 20 February 2/2019 BSP Bank (all branches) Request For Pre- Authentication EFTPOS Machine Enhanced Account Scrutiny 15 April 3/2019 16 May 4/2019 5 July 5/2019 All Commercial Banks and Money Remittance Service Providers All Commercial Banks and Money Remittance Service Providers Commercial banks and money remittance service providers Possible Advance Fee Fraud Possible Advance Fee Fraud Possible Advance Fee Fraud 10 July 6/2019 ANZ & BOB (all branches) 7 October 7/2019 Westpac Bank (all branches) Enhanced Account Scrutiny Enhanced Account Scrutiny 23 October 8/2019 25 December 9/2019 Source: Fiji FIU All Commercial Banks and Money Remittance Service Providers Possible Investment Scam BSP and Westpac Bank (all branches) Possible Advance Fee Fraud Directives to Financial Institutions The FIU has powers under section 25(1)(h) of the FTR Act to issue enforceable directives to financial institutions to take appropriate steps in relation to any information or report received by the FIU and 5 Other law enforcement agencies include FICAC, RBF and other foreign law enforcement agencies.
14 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 to enforce compliance with the FTR Act or facilitate any investigation anticipated by the FIU or a law enforcement agency.

activities and other predicate offences such as forgery and fraud, drug trafficking/dealing, human trafficking, obtaining money by false pretences, larceny and corruption.

The FIU issued three such directives in 2019 to commercial banks.
The directives issued were in relation to the following: i. undertaking enhanced due diligence on customers; ii.

establishing source of funds; iii.

ascertaining the ultimate destination of any subsequent withdrawal transaction(s); iv.

identifying any third party transaction(s); v. seeking approval in writing from the FIU before proceeding with any transaction(s).

In 2019, the FIU cancelled one directive that was previously issued due to successful investigations by a law enforcement agency.
The FIU also uses directives to temporarily suspend a transaction until the customer provides all necessary information to the financial institution as stipulated in the directive, consistent with the customer due diligence requirements under the FTR Act and FTR Regulations.

Section 7 of the FTR Act and regulation 19(3)(c) of the FTR Regulations requires financial institutions to not proceed any further with a transaction unless directed to do so in writing by the FIU.
The Alert & Instruction Notices and directives are enforceable instructions of the FIU and must be implemented by the financial institutions as directed.

Investigative Assistance Provided to Law Enforcement Agencies The FIU also provides assistance to law enforcement agencies upon request.
The request for assistance from the law enforcement agencies are related to investigations of suspected money laundering The requests may also be related to investigations initiated by a CDR that was disseminated to a law enforcement agency.

The FIU received 222 requests in 2019 compared to 260 requests in 2018 from local law enforcement agencies such as the FPF, FICAC, Department of Immigration and FRCS.
Requests for Investigative Assistance 2019 Requesting Agency Number of Requests FICAC Fiji Police Force FRCS Immigration Others TOTAL Source: Fiji FIU 30 85 97 8 2 222 Number of Checks on Individuals 34 Number of Checks on Entities 9 177 73 26 8 318 18 31 8 1 67 The FIU also assists law enforcement agencies in their investigations by facilitating the process to trace and temporarily suspend suspected proceeds of crime and criminal funds that is suspected to be transacted or held within financial institutions and to also ensure that the funds are immediately secured while the formal investigations into the suspected criminal activity is underway.
Dissemination of Information to Foreign FIUs The FIU receives requests for information from foreign FIUs.

In 2019, the FIU received 12 requests for information from foreign FIUs through the Egmont Secure Web (ESW) and other formal communication compared to 13 requests received in 2018.

The FIU also sent five requests for information to foreign FIUs through the ESW in 2019.
15 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Information Exchanges with Other FIUs 2015-2019 2015 2016 2017 2018 2019 22 6 11 7 25 10 13 10 12 5 Number of requests made to Fiji FIU Number of requests made by Fiji FIU Source: Fiji FIU Due Diligence The FIU provides assistance to conduct background and due diligence checks on individuals and entities upon a request made in writing from a Government department or authority.
Requesting agencies are required to fill out the FIU request form and provide relevant details on the individuals and businesses that are under scrutiny.

In 2019, the FIU received 89 requests for background and credibility checks compared to 118 requests in 2018.

The checks were conducted on 162 individuals and 99 entities.
Requests for Background Checks 2019 Requesting Agency Office of the Prime Minister Office of the Attorney General Supreme Court of Fiji Investment Fiji Fiji Pharmaceutical and Biomedical Services Ministry of Civil Service Ministry of Economy Ministry of Industry, Trade & Tourism Water Authority of Fiji Fijian Competition & Consumer Commission FRCS - Policy REALB South Pacific Stock Exchange RBF TOTAL Source: Fiji FIU Number of Requests Number of Checks on Individuals Number of Checks on Entities C. Supporting And Supervising Financial Institutions The FIU promotes a “risk-based” approach to implementing the FTR Act and provides guidance to financial institutions to comply through issuance of policies and provision of training.
The requirements in the FTR Act, commonly referred to as “preventive measures” are based on international AML/CFT standards, the Financial Action Task Force (FATF) Recommendations.
Entities and businesses that are required to comply with the requirements of the FTR Act include: i. financial institutions such as, commercial banks, intermediaries, insurance companies and finance companies, money remitters, money changers, investment advisors, brokers and dealers, unit trust or managed funds, mobile phone banking service providers; and ii.

other DNFBPs, such as, accounting firms, law firms, real estate agents or businesses.
All entities and businesses that are covered by the FTR Act are referred to as “financial institutions” under the law.
Real Estate Agents Commercial Banks Finance & Credit Companies Lawyers Insurers and Insurance Brokers Accountants Financial Institutions Superannuation Fund Mobile Phone Banking Money Remitters Stock Exchange Investment Advisers, Brokers and Dealers, Investment Fund Money Changers 16 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 AML Guidelines and Policy Advisories In 2019, the FIU continued to provide financial institutions with advice and guidance on the requirements under the FTR Act and Regulations.
The FIU provides advisories and guidelines aimed at helping financial institutions gain a better understanding of their obligations under the laws.

During 2019, the FIU issued one Enforceable Guideline.

Enforceable Guideline Issued by FIU in 2019 Guideline Title Date Issued Purpose of Guideline Appendix 2 lists the Policy Advisories issued to date by the FIU.

These Policy Advisories address very specific issues relating to the FTR Act.
The FIU also provides policy advice on an ad- hoc basis, as and when requested by financial institutions.

In 2019, the FIU issued 56 ad-hoc policy advisories explaining various requirements of the FTR Act and Regulations.

To ensure consistent application and understanding of FTR requirements across all the covered financial institutions, the FIU disseminates its policy advisories to all the institutions.
AML Compliance Obligations of Real Estate Agents and Businesses (FIU Enforceable Guideline #8) 1 October 2019 Source: Fiji FIU provides real estate guidance To to agents and businesses on their obligations under the FTR Act and Regulations.

This Guideline may also be used by real estate agents and businesses as a basis for developing internal policies, procedures, systems and controls on AML/CFT.

their The FIU also issued one Policy Advisory in 2019.
Policy Advisory Issued by FIU in 2019 Policy Advisory Title Establishing Source of Funds Source: Fiji FIU Date Issued Purpose of Guideline 20 September 2019 To provide further guidance and on clarification establishing a customer’s source of funds.

Appendix 1 lists the Enforceable Guidelines issued by the FIU and RBF to date.
The Enforceable Guidelines provide detailed guidance on the requirements under the FTR Act relating to suspicious transaction reporting, cash transaction reporting and customer identification and verification.
Ad-hoc Policy Advisories Issued by FIU in 2019 Nature of Advisory Number of Ad-hoc Advisories Issued Customer Due Diligence Requirements Transaction Reporting Requirements Other Issues (FIU Alert Notices, role of compliance officer, AML developments) TOTAL Source: Fiji FIU 27 21 8 56 The FIU continued to engage with the AML Compliance Officers of the various financial institutions during the year.

The FIU held two interactive forums for AML Compliance Officers during the year.
The sectors covered in these forums included banks, finance companies, restricted foreign exchange dealers, real estate agents, lawyers and insurance companies and brokers.

These forums provided a platform for the FIU to update the AML Compliance Officers on new regulatory developments and money laundering trends and to clarify policy requirements.

During 2019, the FIU continued its engagement with the real estate and legal sector to enhance industry level awareness and compliance.
The 17 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 engagement was through one-on-one meetings and forums with AML Compliance Officers.

RBF on the AML/CFT section of the on-site examinations of RBF licensed financial institutions.

Supervision of Financial Institutions for Compliance with the FTR Act The FIU and RBF are required under the FTR Act to supervise and ensure that financial institutions comply with the FTR Act and Regulations.
The FIU conducted on-site compliance visits of three law firms and four real estate agents to assess these businesses’ compliance with the FTR Act and Regulations.
Key findings from the FIU on- site examination of the law firms and real estate agents included: • no written AML policies or procedures in place; • most of the firms were not fully aware of their reporting obligations under the FTR Act, thus, failed to report CTRs and STRs; • • staff were not provided with AML training; and there was lack of monitoring of client’s engagements or transactions for any complex, unusual or large transactions.
The results of the assessments were shared with the management of the respective businesses with recommendations for further improvements in internal processes.

The FIU also continued with its off-site assessment and review of transaction reporting and record keeping obligations of financial institutions in Fiji.

The FIU relied on the on-site supervision programme of the RBF to assess the compliance of RBF licensed financial institutions with the FTR Act and Regulations.
The FIU provided policy advice to RBF supervisors as and when needed on the AML/CFT compliance issues.

The FIU also provided assistance to the In 2019, the FIU and RBF conducted joint on- site AML/CFT compliance examinations of seven restricted foreign exchange dealers.

AML/CFT Supervision Supervisor of Financial Institutions and Designated Non- Financial Businesses and Professions RBF FIU Finanial Institutions licensed by RBF under the following laws: 1.

Banking Act 2.

Exchange Control Act 3.


Companies Act 4.

Insurance Act Other financial institutions not under the supervision of the RBF: 1.

Accountants 2.

Lawyers 3.

Real Estate Agents 4.

Other Financial Institutions Training and Awareness Programme for Financial Institutions In 2019, the FIU provided training and awareness presentations institutions which were attended by a total of 79 employees.

The training covered the financial institutions’ obligations under the FTR Act and Regulations.
to various financial Training to Financial Institutions 2019 Sector Number of Employees Accounting Firms Real Estate Agents Commercial Banks TOTAL Source: Fiji FIU 30 13 36 79 18 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 D. Domestic Coordination and Engagement National AML Council The FIU continued to provide secretarial support for the National AML Council and its three AML Working Groups (Legal Working Group; Supervisors and Regulators Working Group; and Law Enforcement Working Group).
As part of these MOA arrangements, authorised officers from the FPF, FRCS and FICAC continued to have direct access to the FIU database.

In 2019, there were 28 officers who had this direct access to the FIU database.

The officers used this arrangement to obtain intelligence on persons or entities of interest who are subject to their investigations.

There were two meetings of the National AML Council in 2019.

It continued to progress key national outputs during the year.
Its work was also supported by the three AML Working Groups (Refer to section on National AML Council for more information).

The Director FIU is a member of the National AML Council and participated in the Council’s activities for 2019.

Other FIU staff also actively contributed to the work of the AML Working Groups.

The FIU provided high level updates to the Council on key issues such as the FIU’s membership in the G7 24/7 Network, and updates on Fiji’s compliance with the FATF Recommendations.
During 2019, the FIU also provided advice to the Council on measures needed to address the deficiencies raised in Fiji’s 2016 mutual evaluation report (MER) relating to transparency of companies’ beneficial owners, review of the non-profit organisation sector and financial sanctions relating to terrorist financing and proliferation financing.

Engagement and Exchange of Information with Partner Agencies The FTR Act provides the FIU with the mandate to enter into MOAs with other agencies.
The MOAs allow the FIU to exchange information and enhance networking and cooperation with domestic partner agencies.

The FIU has signed MOAs with 12 local partner agencies to date.

The FIU continued to engage with these partner agencies during 2019.

Officers from FRCS and the FPF continued to be seconded to the FIU in 2019 as provided under the MOA arrangement.

One of the seconded officers was from FRCS and one officer was from the FPF.
Secondment Officers for 2019 from left: Sunita Segran (FRCS) and PC Hanisi Semisi (FPF) MOAs with Domestic Partner Agencies Agency Immigration Department FRCS Fiji Police Force Date MOA Signed Type of MOA 12 July 2007 Information exchange 28 November 2007 Information exchange and secondment of two staff with the FIU 12 September 2014 (amendment) Direct access to FIU database 24 January 2008 Information exchange and secondment of a staff with the FIU 11 December 2014 (amendment) Direct access to FIU database Investment Fiji 13 June 2008 Information exchange Ministry of Justice 3 July 2008 Information exchange 19 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Agency Land Transport Authority FICAC Joint Taskforce RBF/ FRCS/FIU Maritime Safety Authority of Fiji Date MOA Signed Type of MOA 5 October 2009 Information exchange 3 November 2009 Information exchange 14 April 2010 Information exchange 16 August 2012 Information exchange RBF 17 April 2014 Information exchange Fijian Elections Office Real Estate Agents Licensing Board Source: Fiji FIU 11 August 2016 Information exchange 24 April 2017 Information exchange NCLASA The Director of the FIU is a member of the National Combined Law and Security Agencies (NCLASA) Committee.
NCLASA is Fiji’s national information sharing framework on security issues comprising approximately 38 agencies.

The NCLASA framework is to create an environment for information sharing and co- operation between members.

Unexplained Wealth Taskforce The FIU contributed to the work of the Taskforce is made up of during 2019.

The Taskforce representatives from the FIU, FPF, FRCS and FICAC.
The objective of the Taskforce is to enable member agencies to network and collaborate on cases of unexplained wealth.

In 2019 the National AML Council approved the Unexplained Wealth Taskforce Standard Operating Procedure.

Cyber Security Working Group The FIU is part of Fiji’s national cyber security working group on technical, legal and security issues.

The FIU contributed to the discussions of the Working Group during 2019.
Counter Terrorism Officials Working Group The FIU is a member of the Counter Terrorism Officials Working Group (CTOG), a national Working Group which is responsible for developing and implementing Fiji’s counter terrorism strategy.

During 2019, the FIU continued to contribute to the meetings, policy discussions and work of CTOG.
Fijian National Identity Card (FNIC) Taskforce The FNIC Taskforce was endorsed by cabinet in October 2019 to provide input for the review of the Fijian national identification (ID) management strategy, requirements for a national ID and possible solutions.

The FIU was invited to contribute to the Taskforce and attended two meetings in 2019.

The FIU advised the Taskforce on the identification and verification requirements under the FTR Act.
The FIU will continue to contribute to the work of the FNIC Taskforce in 2020.

Training and Awareness Programs for Law Enforcement Agencies The FIU continued to provide training and awareness briefings to law enforcement agencies during the year on money laundering and the role and functions of the FIU.

A total of 152 law enforcement officials attended these training sessions.
FIU Training Provided to Law Enforcement Agencies and Prosecutors 2019 Date Particulars of Training Participating Agencies Number of Participants 20 June Role of the FIU FPF 26 November Role of the FIU FICAC 25 67 20 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Number of Participants Fiji submitted its first and second Follow-Up Report (FUR) in January 2017 and 2018.

Its third FUR was submitted in January 2019.


Date Particulars of Training 29 November Terrorist Financing 26 November Role of the FIU TOTAL Source: Fiji FIU Participating Agencies FPF, Ministry of Defence, FRCS, Immigration Department FPF, Ministry of Defence, Immigration 40 20 152 E. International Engagement And Contribution Fiji Mutual Evaluation - Progress Update Fiji’s mutual evaluation report (MER) was tabled at the 2016 APG Annual Meeting and identified key gaps and deficiencies for Fiji to address.
The MER noted that Fiji had 23 non-compliant/ partially compliant ratings with the FATF 40 Recommendations and 11 low or moderate levels of effectiveness on the 11 Immediate Outcomes on effectiveness.

The key findings of Fiji’s third FUR noted that Fiji has made good progress in addressing the technical compliance with the implementation of processes to collect and maintain relevant statistics.
Therefore, the APG upgraded Fiji’s technical compliance ratings for one FATF Recommendation (which was previously rated partially compliant in the 2016 MER) to compliant.
FATF Rec Description Rating 2016 MER Rating After 2019 Plenary Meeting R.33 Statistics Partially Compliant Compliant Since submissions of the three FURs (2017, 2018 and 2019), the APG has upgraded Fiji’s compliance ratings for 17 FATF Recommendations to a “largely compliant” or “compliant” ratings (from either a non-compliant or partially compliant rating).

Fiji’s Compliance Ratings and Upgrades Rec.
Description Rating MER 2016 1 Assessing Risks & Applying a Risk Based Approach 2 National Co-operation & Co-ordination 3 ML Offence 4 Confiscation & Provisional Measures 5 6 7 Terrorist Financing Offence Targeted Financial Sanctions related to Terrorist Financing Targeted Financial Sanctions related to Proliferation Financing 8 Non Profit Organisations 9 Financial Institutions Secrecy Laws 10 Customer Due Diligence 11 Record Keeping 12 Politically Exposed Persons 13 Correspondent Banking 14 Money or Value Transfer Services 15 New Technologies PC PC LC C PC NC NC PC C PC PC PC C C PC Ratings Upgraded in 2017 LC Ratings Upgraded in 2018 Ratings Upgraded in 2019 Current Rating as end 2019 LC C PC PC LC C LC C C LC LC C C PC PC PC C LC C C C C C 21 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Rec.
Description Rating MER 2016 16 Wire Transfers 17 Reliance on Third Parties 18 Internal Controls 19 High Risk Countries 20 Reporting of Suspicious Transactions 21 Tipping Off and Confidentiality 22 Designated Non-Financial Businesses and Professions (DNFBP) 23 DNFBP- Other Measures 24 25 Transparency and Beneficial Ownership of Legal Persons Transparency and Beneficial Ownership of Legal Arrangements 26 Regulation and Supervision of Financial Institutions 27 Powers of Supervisors 28 Regulation and Supervision of DNFPBs 29 FIU 30 31 Responsibilities of Law Enforcement & Investigative Authorities Powers of Law Enforcement & Investigative Authorities 32 Cash Couriers 33 Statistics 34 Guidance and Feedback 35 Sanctions 36 International Instruments 37 Mutual Legal Assistance 38 Mutual Legal Assistance Freezing and Confiscation 39 Extradition 40 Other Forms of International Cooperation PC PC PC NC LC LC NC PC PC PC LC LC PC C C LC LC PC LC PC PC LC C PC LC Ratings Upgraded in 2017 LC LC LC LC Immediate Outcomes IO - 1 Risk, policy and coordination IO - 2 International cooperation IO - 3 Supervision IO - 4 Preventive measures IO - 5 Legal persons and arrangements IO - 6 Financial intelligence IO - 7 ML investigation & prosecution IO - 8 Confiscation IO - 9 TF investigation & prosecution Ratings Upgraded in 2018 Ratings Upgraded in 2019 Current Rating as end 2019 LC C LC LC LC LC C LC LC C LC LC LC LC PC PC LC LC LC C C LC LC C LC LC LC LC C PC LC Rating MER 2016 Moderate Moderate Moderate Moderate Low Moderate Moderate Low Low Low Low IO - 10 TF preventive measures & financial sanctions IO - 11 PF financial sanctions Key: C: Compliant LC: Largely Compliant PC: Partially Compliant NC: Not Compliant IO is achieved to a very large extent; Minor improvements needed High level: Substantial level: IO is achieved to a large extent; Moderate improvements needed Moderate level: IO is achieved to a large extent; Moderate improvements needed Low level: IO is not achieved or achieved to a negligible extent; Fundamental improvements
 needed 22 Source: Fiji FIU FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Memorandum of Agreements with Foreign FIUs The FIU may enter into MOAs with foreign FIUs or law enforcement agencies for the exchange of information relevant to the investigation or prosecution of a money laundering offence, terrorist financing offence or any other serious offence.
The FIU has signed MOAs with 29 foreign FIUs to date.
MOA with Foreign FIUs Agency Name of FIU Date Australia Australian Transactions Reports and Analysis Centre 19 May 2011 Bangladesh Financial Intelligence Unit 9 June 2015 Belgium Financial Intelligence Unit 3 September 2012 Brazil Council for Financial Activities Control 3 July 2013 Cambodia Cambodia FIU 5 December 2017 Canada Financial Transactions and Reports Analysis Centre of Canada 12 July 2011 Cook Islands Cook Islands FIU 21 July 2011 France The Unit for Intelligence Processing and Action Against Illicit Financial Networks 12 July 2011 India India FIU 5 June 2014 Indonesia Israel Japan Korea Indonesian Financial Transaction Reports and Analysis Center Israel Money Laundering Prohibition Authority Financial Intelligence Centre 10 July 2009 6 February 2013 9 June 2015 Korea FIU 6 May 2011 Lebanon Special Investigation Commission Macau SAR China Financial Intelligence Office 5 June 2014 6 and 13 March 2012 Malaysia Papua New Guinea Philippines Unit Perisikan Kewangan, Bank Negara Malaysia 3 February 2010 Papua New Guinea FIU 29 January 2018 The Anti-Money Laundering Council, The Financial Intelligence Unit of the Republic of the Philippines 13 July 2011 Samoa Samoa FIU 8 March 2013 Solomon Islands Solomon Islands FIU 12 July 2011 Agency Name of FIU Date South Africa Financial Intelligence Centre 11 July 2012 Sri Lanka Republic of China (Taiwan) Republic of Marshall Islands Russia Thailand United Kingdom Financial Intelligence Unit of Central Bank of Sri Lanka Anti-Money Laundering Division, Investigation Bureau, Ministry of Justice 21 July 2011 10 July 2012 Banking Commission- Financial Intelligence Unit 24 July 2017 Federal Financial Monitoring Service (Russian Federation) The AML Office of the Kingdom of Thailand The Serious Organised Crime Agency United Kingdom FIU 28 June 2013 25 October 2011 12 July 2011 5 June 2014 (Amendment) 12 July 2011 United States of America The Financial Crimes Enforcement Network Vanuatu Vanuatu FIU 8 March 2013 Association of Pacific Island FIUs The FIU is a member of the
 Association of Pacific Island FIUs (APIFIU).
APIFIU was established in 2011 and currently has 12 FIUs as its members namely the FIUs of Cook Islands, Fiji, Nauru, Niue, Palau, Papua New Guinea, Republic of Marshall Islands, Samoa, Solomon Islands, Tonga, Vanuatu and Kiribati.

The FIU served as the APIFIU Secretariat in 2019 and participated in its meeting during the year.

The FIU also provided advice during the year to regional FIUs on various aspects of Fiji’s AML/ CFT framework.
Asia Pacific Group on Money Laundering Fiji is a member of the APG, an autonomous and collaborative international organisation currently comprising of 41 member countries.

The FIU, as the designated lead agency for Fiji, liaised closely with the APG in 2019 on various 23 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 national outputs, APG governance and other policy and mutual evaluation matters including the submission of the 3rd Follow Up Report.
Egmont Group During 2019, the FIU participated in the following key APG activities: i. liaised with APG on Terms of Reference for APG technical assistance on NPO Sector Review; ii.

contributed to the discussions of the Governance Committee; iii.

contributed to the APG mutual evaluation programme by reviewing the MERs of other APG members; iv.

attended the APG Annual Plenary Meeting held in Canberra, Australia; and v. participated in various APG surveys and contributed to discussion papers.
The FIU also prepared and submitted Fiji’s country report and technical assistance report for the 2019 APG Annual Plenary Meeting.

The FIU continued to liaise with the APG on various AML/CFT issues relevant to Fiji during the year.

The FIU is a member of the Egmont Group of FIUs.

The FIU continued to participate in the activities of the Egmont Group during 2019.
This included contributing to Egmont surveys conducted during the year, reviewing and providing comments on Egmont governance papers, projects and questionnaires.

As a member of the Egmont Group of FIUs, the Fiji FIU is committed to sharing information with other Egmont Group members.

During 2019, the FIU continued to provide assistance and information to other Egmont Group members upon request via the ESW.

The FIU fully complies with the Egmont Group key governance instruments, namely the: 1.
Egmont Charter; 2.

Operational Guidance; 3.

Principles of Information Exchange; and 4.

Support and Compliance Process; (FRCS); Loraini Seru The Fijian delegation to the APG Annual Meeting 2019.

Back from left to right: Muni Ratna (FPF); Jayneeta Prasad (ODPP); Sophina Ali (Ministry of Justice); Mohammed Ali (FICAC); Seated front from left to right: Sam Savumiramira (FICAC); Christopher Pryde (ODPP); Razim Buksh (FIU) head of Fijian delegation.
24 Source: Egmont Group FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Alliance for Financial Inclusion The FIU is a member of the Alliance for Financial Inclusion (AFI) Global Standards Proportionality Working Group (GSPWG).
The aim of GSPWG is to provide a platform to facilitate peer learning on issues policymakers and regulators face in achieving a balance between financial inclusion, integrity and stability, and to examine the proportionate implementation of the standards set by global standard setting bodies.

The FIU participated in the meetings of the GSPWG which were held in Egypt and Rwanda during the year.
25 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 OPERATIONAL GOVERNANCE AND COMMUNICATION 6 Professional Development of Staff During the year FIU staff attended various workshops, technical forums and meetings.

The FIU also provided on-the-job training to new secondment staff from FRCS and the FPF who joined the FIU during the year as part of the secondment rotation programme.
Month Course Venue Organiser Pacific Workshop on Targeted Financial Sanctions Related to Terrorism Financing and Proliferation Suva, Fiji PIFS/APG Trainings, Meetings and Conventions 2019 Month Course Venue Organiser July January Egmont Group Meeting Jakarta, Indonesia Egmont Group FATF Standards Training Course Auckland, New Zealand FATF TREIN/APG OCO National Workshop on Criminal Business Entities AFI 10th Global Standards Proportionality Working Group Meeting Suva, Fiji OCO Cairo Egypt AFI September March April April May FATF Assessor Training Auckland, New Zealand APG United Nations Convention on Transnational Organized Crime Suva, Fiji MDNS Intelligence Training Suva, Fiji Recall of 2017 Intelligence Training Suva, Fiji Office of the Attorney General/ UNODC Ministry of Defence & AFP Ministry of Defence & AFP Pacific Roundtable on Correspondent Banking Relations Workshop Auckland, New Zealand IMF Women Against ML Conference Canberra, Australia Australian Department of Home Affairs Egmont Plenary Meeting The Hague, Netherlands Egmont Group Cash Courier Workshop Rarotonga, Cook Islands APG August 22nd APG Annual Meeting and Technical Assistance Forum 2019 Canberra, Australia APG Joint FATF/APG Assessor Training Workshop Bandung, Indonesia FATF/APG 11th Global Policy Forum (GPF) Kigali, Rwanda AFI NZ FIU Annual Conference Wellington, New Zealand NZ FIU October Workshop on Drafting and Application of Cybercrime Legislation Suva, Fiji Council of Europe November Workshop on Intelligence Support to Policy Makers and Framework for SPID Cooperation Brisbane, Australia SPID Counter Terrorism Workshop Nadi, Fiji Ministry of Defence December Proliferation Financing Workshop Nadi, Fiji US Embassy June IMF STI Course on Correspondent Banking Singapore IMF AG’s Conference Natadola, Fiji Office of the AG Source: Fiji FIU 26 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Governance The FIU continued to provide monthly reports on its operations to the Governor of the RBF and the Chairman of the National AML Council.
The FIU also provided regular updates to the National AML Council on key AML/CFT national initiatives and projects.

Communication The FIU uses the media and its website to communicate key AML/CFT initiatives to the general public.

In 2019, the FIU issued two press releases on the 2017 and 2018 FIU Annual Report (Refer to Appendix 3).

The FIU also used media interviews to provide awareness to the public on AML/CFT issues and money laundering risks.
Staffing As at the end of 2019, the FIU had nine permanent staff and two officers on secondment from partner agencies (one FPF officer and one FRCS officer).

The FIU engaged two project officers to assist in the FIU data migration project.

The FIU also engaged a temporary worker as part of the RBF’s and National Employment Centre attachment programme.
Governance Structure 2019 Attorney General & Minister for Justice Governance Director Financial Intelligence Unit Functional Operations Governor Reserve Bank of Fiji Governance Financial Intelligence Unit Board Reserve Bank of Fiji Budget National AML Council Advisory FIU Organisation Structure 2019 Manager Intelligence Management Intelligence Analyst.

Seconded from FPF Intelligence Analysts.
Seconded from FRCS (Customs and Tax) Intelligence Analyst Intelligence Analyst Policy & Compliance Analyst Intelligence Management Division Manager Policy & Compliance Policy & Compliance Division Manager IT Management (vacant) Director FIU IT Management Division Administration Senior Systems Analyst Systems Analyst Senior Secretary HR and Other Support (Provided by RBF) 27 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Other Assistance Provided to the FIU The FIU received indirect funding assistance from FRCS and the FPF through the secondment of their staff with the FIU in 2019.
The salaries of the seconded officers were fully funded by their respective agencies.

In 2019, the FIU also received assistance from various organisations to fund staff attendance at technical AML/CFT trainings, conventions and meetings.

These included the APG, AFI, NZFIU and the IMF.

Fiji FIU’s Information Management System Online [FFIMSO] FFIMSO consists of two online web application systems, namely Online Data Delivery System (ODDS) and Transaction Query System (TRAQ).
ODDS is used by financial institutions to securely report financial transaction reports online.

TRAQ is used by FIU staff and direct data access (DDA) officers for search, analysis and profiling purposes.
Sector No of Reporting Entities Registered for Online Reporting to the FIU Finance Companies Law Firms Insurance & Superannuation Accounting Firms Securities and Brokers Real Estates Money Lenders Others TOTAL Source: Fiji FIU 11 48 12 10 3 25 1 10 138 FFIMSO received an average of 192,529 financial transaction reports per month in 2019.
As at the end of 2019, the FFIMSO database had received over 16 million financial transaction reports from financial reporting institutions since on-line commenced in 2008.

Financial institutions continued to use ODDS to report their transactions (STR; CTR; EFTR) electronically to the FIU.

As at the end of 2019, there were 141 authorised users of FFIMSO.

As at the end of 2019, 138 financial institutions had registered on FFIMSO.
FFIMSO Registration Sector No of Reporting Entities Registered for Online Reporting to the FIU ODDS was accessed by 111 authorised users, 8,321 times during 2019.

TRAQ was accessed by 13 FIU officers, 1,327 times and 17 direct database access officers, 209 times during 2019.
Commercial Banks Foreign Exchange Dealers & Money Remitters Mobile Phone Money Remitters 6 10 2 28 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 NATIONAL AML COUNCIL 7 The National AML Council is established under Section 35 of the FTR Act and is Fiji’s national AML/CFT coordination committee.
The vision of the National AML Council is “an effective and efficient legal system and institutions to prevent and detect money laundering, terrorist financing and other serious financial crimes in Fiji.” The Council’s missions are to: i. provide sound and timely advice to the Minister and other relevant stakeholders on the prevention of money laundering and terrorism financing; ii.

promote a strong legal and institutional AML/ CFT framework; and v. Chief Executive Officer of the FRCS; and vi.
Director of the FIU.

The Council may invite other persons to attend the Council meetings.

There are five invited members of the Council.

These are: • Director, Immigration Department; • Permanent Secretary, Ministry of Economy; • Permanent Secretary, Ministry of Defence, National Security and Immigration; • Permanent Secretary, Ministry of Foreign Affairs; and • Deputy Commissioner, FICAC.

The FIU is the secretariat to the Council.

iii.


facilitate networking and cooperation amongst NATIONAL AML COUNCIL MEMBERS 2019 NATIONAL AML COUNCIL INVITED MEMBERS 2019 relevant stakeholders.

The Council seeks to achieve these missions by: i. providing sound and timely advice to the Minister and other government agencies on policy and regulatory AML/CFT matters; ii.

promoting a strong legal, policy and institutional framework to comply with international AML/ CFT standards and best practices; iii.
supporting institutions in their efforts to combat money laundering and terrorist financing; iv.

encouraging and facilitating networking and cooperation between agencies; and v. providing advice to the FIU on AML/CFT issues.

The members of the National AML Council are: i.

Permanent Secretary for the Ministry for Justice, as Chairperson; ii.

Director of the ODPP; iii.

Commissioner of Police; iv.
Governor of the RBF; Sharvada Sharma Solicitor-General and Acting Permanent Secretary for Justice Manasa Lesuma Permanent Secretary Ministry of Defence and National Security Ariff Ali Governor Reserve Bank of Fiji Makereta Konrote Permanent Secretary Ministry of Economy Yogesh Karan Acting Permanent Secretary Ministry of Foreign Affairs Litia Saumaka Acting Director Immigration Department Rashmi Aslam Deputy Commissioner Fiji Independent Commission Against Corruption Fane Vave Acting Chief Executive Officer Fiji Revenue and Customs Service Christopher Pryde Director Office of the Director of Public Prosecutions Sitiveni Qiliho Commissioner Fiji Police Force Razim Buksh Director Financial Intelligence Unit 29 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Functions of the Council The functions of the Council are provided for in section 35(5) of the FTR Act and are: 1. to advise the FIU and the Minister on any matters relating to the prevention of money laundering or the financing of terrorism; 2. to make recommendations to the Unit and the Minister on any matter relating to the the prevention of money financing of terrorism; laundering or 3. to assist the FIU and the Minister in the formulation of policies or strategies relating to the prevention of money laundering or the financing of terrorism; and 4. to assist the FIU in coordination between various Government departments and with statutory corporations.
Council Working Groups The National AML Council is supported in its work by three working groups, namely: i.

Legal Working Group; ii.

Supervisors and Regulators Working Group; and iii.

Law Enforcement Working Group; The terms of reference of each Working Group is determined by the Council.

The Working Groups provide updates at the National AML Council meetings on its achievements.
Terms of Reference of AML Working Groups AML Legal Working Groups AML Supervisors & Regulators Working Group AML Law Enforcement Working Group • To facilitate the review of relevant legislations to ensure that Fiji has an effective and globally acceptable legislative framework for combating money laundering and other related offences.

• To facilitate the ratification of relevant international conventions.

• To administer the forfeiture asset fund.


• To facilitate matters relating to international assistance and extradition.

• To facilitate networking and sharing of information amongst regulators regarding the supervision of financial institutions for compliance with the FTR Act.

• To facilitate networking amongst law enforcement agencies to enable: a) better sharing of information amongst agencies; • To conduct joint AML compliance programmes.
• To advise the Council on financial institutions compliance with legislative AML requirements.

b)the effective investigation and prosecution of money laundering and other related financial offences; and c) sharing of technical expertise and resources • To advise the Council on issues relating to investigation and prosecution of money laundering and other related offenses.

from the Working Groups are The members of representatives relevant agencies who contribute towards Fiji’s AML/CFT initiatives.
The chairpersons of the Working Groups are elected by the members of the Working Group.

The FIU is a member and provides the secretariat of the three Working Groups.
30 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 National AML Council and Working Groups National AML Council Secretariat-FIU AML Legal Working Group AML Supervisors & Regulators Working Group AML Law Enforcement Working Group ODPP (Chairperson) RBF (Chairperson) FICAC (Chairperson) Fiji Police Force FIU (member secretariat) Fiji Police Force Ministry of Justice Ministry of Economy Ministry of Foreign Affairs Office of the Solicitor-General FIU (member/ secretariat) FRCS ODPP FIU Immigration Department Investment Fiji Fiji Transnational Crime Unit Ministry of Defence ii.
the Council endorsed the Unexplained Wealth Taskforce Standard Operating Procedure.

iii.

the Council proposed technical assistance for Targeted Financial Sanctions legislations and implementation.

iv.

NPO Sector Review was provided by APG.

v. Amendment of the Companies Act to include beneficial ownership details.

vi.

representatives of the Council attended the APG annual plenary meeting held in Australia.

vii.

APG Ministerial letter of endorsement of the APG Mandate was issued.

viii.
viii.

supported Fiji’s capacity building and skills enhancement opportunities by participating in the following programmes: • Pacific Workshop on Targeted Financial Sanctions Related to Terrorism Financing and Proliferation.

• APG/FATF Assessor Training Workshops.

ix.

ongoing support and contribution to APG work, namely, Fiji’s contribution to the APG mutual evaluation programme, APG mandate paper and other governance issues.
Number of Working Group Meetings 2015-2019 Council’s Activities in 2019 Key outputs driven by the National AML Council in 2019 were as follows: Working Group Legal i. submission of Fiji’s 3rd progress report to the APG on 31 January 2019.

The report outlined measures Fiji had taken since 2016 to implement the recommendations of the mutual evaluation report.
Law Enforcement Supervisors and Regulators Source: Fiji FIU 2015 2016 2017 2018 2019 5 2 1 1 Ad-hoc meeting Ad-hoc meeting 1 2 1 2 3 1 1 2 Ad-hoc meeting 31 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 8 APPENDICES APPENDIX 1: ENFORCEABLE GUIDELINES ISSUED BY THE FIU Guideline Reference Title Guideline 1 Suspicious Transactions Guideline 2 Reporting a Suspicious Transaction by Paper Guideline 3 Reporting Cash Transactions of $10,000 or above by Paper Date Issued 26 October 2007 26 October 2007 Purpose of Guideline To provide guidance on how to identify suspicious transactions and report these suspicious transactions.
To provide guidance to financial institutions on how to complete a “suspicious transaction report” form.

22 May 2009 To provide guidance to financial institutions on how to report cash transactions of $10,000 and above using the paper report forms.

Guideline 4 Customer Identification and Verification 20 August 2009 To explain the customer identification and verification requirements of the FTR Act and Regulations and provide practical guidance on how to apply these customer verification requirements.
Guideline 5 Risk Assessment of New Products, New Business Practices and Technologies 31 January 2018 Requires financial institutions to identify and assess the money laundering, terrorist financing and proliferation financing risks that may arise in relation to the development of new products and new business practices, including new delivery mechanisms.
Guideline 6 Dealing with Higher Risk Countries 31 January 2018 Outlines further requirements relating to dealing with higher risk countries and countries that have been identified as having inadequate systems in place to detect or prevent money laundering, terrorist financing and proliferation financing risks emanating from these countries.
Guideline 7 Politically Exposed Persons 27 March 2018 Outlines requirements for dealing with domestic politically exposed persons and international organisation politically exposed persons.

Guideline 8 AML Compliance Obligations of Real Estate Agents and Businesses Guidelines Issued by the RBF 1 October 2019 Provides guidance to real estate agents and businesses on their obligations under the FTR Act and Regulations.
Minimum Requirements for Licensed Financial Institutions for the Management of Money Laundering and Terrorist Financing Risk November 2014 The Policy sets out the minimum requirements on establishing a risk management framework comprising of systems, structures, processes and people within which licensed financial institutions identifies, assesses, mitigates and monitors money laundering and terrorist financing risk.
Minimum Requirements for the Management of Money Laundering and Terrorist Financing Risk October 2018 The Policy sets out the minimum requirements for foreign exchange dealers and money changers in establishing a risk management framework comprising of systems, structures, processes and people within which a licensed entity identifies, assesses, mitigates and monitors money laundering and terrorist financing risk.

Banking Supervision Policy No.
6 Restricted Foreign Exchange Dealers and Money Changers Supervision Policy Statement No: 4 Insurance Supervision Policy Statement No:13 Minimum Requirements for the Management of Money Laundering and Terrorist Financing Risk November 2018 The Policy sets out minimum requirements for insurance companies and brokers on establishing a risk management framework, comprising of systems, structures, processes and people within which the institution identifies, assesses, mitigates and monitors money laundering and terrorist financing risk.
Source: Fiji FIU and RBF 32 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 APPENDIX 2: POLICY ADVISORIES ISSUED BY THE FIU Reference Subject Purpose of Advisory Issue Date 1/2007 Customer Due Diligence of Existing Customers’ Accounts To explain how and when due diligence is to be applied to existing customers of financial institutions 15 March 2007 2/2007 Customer Due Diligence of Customers Who Have Insufficient or No Official Identification Documents To provide further guidance on how due diligence is to be applied to new customers who have insufficient or no official identification documents 11 April 2007 3/2007 Identification and Verification of a Customer’s Signature To provide further guidance on how to identify and verify a customer’s signature 26 April 2007 4/2007 Identification and Verification of Occasional Customers To provide further guidance on how to identify and verify occasional customers 14 June 2007 5/2007 Risk Based Approach To provide guidance on how to apply the FTR Act and Regulations on a risk based approach 22 June 2007 6/2007 Application of Exemption Provisions for Reporting of Cash Transactions To provide guidance on how to apply the exemption provisions relating to cash transaction reporting requirements 9 July 2007 7/2007 Record Keeping To provide further guidance on the record keeping requirements of the FTR Act 11 July 2007 1/2008 Identification and Verification of Customers of Insurance Providers 2/2008 Identification and Verification of Clients and Beneficiaries of Employer Funded Group Life Insurance Policies 1/2010 Identification and Verification of a Customer's Signature 2/2010 Use of Referee Letter to Verify a Customer's Identity 3/2010 Refugee Identity Card 4/2010 Identification of Customers of Telephone Financial Services 1/2012 Subsequent Reporting of Suspicious Transactions 2/2012 Voter Identification Card To provide further guidance to insurance companies, brokers and agents on their obligations to identify and verify their customers’ identity.
23 January 2008 To provide guidance on how insurance companies and intermediaries can apply the identification requirements to clients of employer funded group life insurance policies.

24 November 2008 To provide guidance on how to identify and verify a customer’s signature.

This Advisory supersedes and replaces Policy Advisory 3/2007 of 26 April 2007.
Pursuant to Section 4(4)(a )of the FTR Act, to allow financial institutions to rely solely on a letter from a suitable referee to verify a low risk customer who does not have or is unable to provide any formal identification documents.

To advise financial institutions of the identification documents pertaining to customers who have been granted Asylum Seeker and Refugee status by the Fiji Government.
To provide guidance to telephone service providers that provide financial services to customers on the customer identification requirements under the FTR Act and how it relates to the Decree on Compulsory Registration of Customers for Telephone Services (2010).
To provide clarification on the need for continuous reporting of customers who have been previously reported to the FIU as engaging in suspicious transactions To advise financial institutions of the inclusion of the Fiji Voter Identification Card for identification and verification of certain customers and clients.
11 August 2010 27 August 2010 17 September 2010 17 September 2010 28 March 2012 22 August 2012 1/2013 FNPF/FRCS Joint Identification Card 1/2018 Parenthood Assistance Payment Programme 2/2018 Change in Account Name for Existing Private Companies To advise financial institutions of the inclusion of the FNPF/FRCS Joint Identification card for identification and verification of their customers and clients.
15 November 2013 To provide clarification on the application of CDD requirements on bank account opening for recipients of the Parenthood Assistance Payment Programme.

To provide clarification on the customer due diligence (CDD) requirements under the Financial Transactions Reporting (FTR) Act and how it aligns to the requirements under the Companies Act on changes to names of existing Private Companies.
8 August 2018 23 November 2018 1/2019 Establishing Source of Funds To provide further guidance and clarification on establishing a customer’s source of funds.

20 September 2019 Source: Fiji FIU 33 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 APPENDIX 3: PRESS RELEASES PRESS RELEASE Press Release No.
: 16/2019 Date: 12 February 2019 FIU Telephone: (679) 331 3611/322 3333 FIU Facsimile: (679) 330 2094/331 6454 Email: info@rbf.gov.fj or info@fijifiu.gov.fj FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2017 The Financial Intelligence Unit (FIU) Annual Report for 2017 was tabled in Parliament yesterday, 11 February 2019 by the Honourable Attorney- General and Minister for Justice, Mr Aiyaz Sayed-Khaiyum.

The report provides information on key achievements and performance of the FIU for 2017.
The FIU is responsible for implementing and enforcing the Financial Transactions Reporting (FTR) Act, a legislation aimed at preventing and detecting money laundering and other proceeds generating criminal activities in Fiji.

The Director of the FIU, Mr Razim Buksh said that the FIU, in partnership with key government agencies and the private sector financial institutions, continued to implement important anti-money laundering (AML) and combating financing of terrorism (CFT) initiatives during 2017.
In 2017, the FIU received and analysed 650 suspicious transaction reports and disseminated 448 intelligence reports to law enforcement agencies for further investigation of possible tax evasion, money laundering and other serious offences.

The total value of funds that were identified by the FIU as possible tainted proceeds in the 448 intelligence reports was approximately $241.3million.
There were four successful money laundering convictions, 46 border currency smuggling cases, and several successful tax evasion and predicate crime investigations in 2017.

In 2017, the FIU provided 205 investigative assistance and 75 due diligence assistance on 836 entities and 783 individuals to law enforcement and other Government relating to ongoing criminal investigations and background checks.
In carrying out its “functions, duties and powers” in 2017, the FIU continued to: • Ensure the safety and integrity of Fiji’s financial system from financial crimes and money laundering activities; • Ensure that local businesses, ordinary Fijians and foreign investors are protected from illicit financial transactions and they conduct their trade and personal financial transactions in a secure environment; • Contribute to the investigation and prosecution of fraud, corruption, tax evasion and other complex financial crimes by providing timely and credible financial intelligence and information to law enforcement authorities, such as, Fiji Police Force, FRCS and FICAC; • Conduct background and due diligence checks on individuals and entities for the Fijian Government and statutory agencies; • Ensure that financial institutions (including lawyers, accountants and reals estate agents) implement preventative customer due diligence measures and report suspicious and other transactions to the FIU; • Ensure that Fiji complies with international requirements on AML and CFT; and • Contribute to national and inter-agency coordination and international networking, particularly on transnational crimes such as human and drug trafficking cases, currency smuggling and cyber fraud.
Mr Buksh said that the achievements of the FIU in 2017 were only possible through the tremendous support and contributions of its staff, law enforcement and regulatory partners, and the financial institutions and businesses that are covered under the FTR Act.

RESERVE BANK OF FIJI 34 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 PRESS RELEASE Press Release No.
: 16/2019 Date: 3 September 2019 FIU Telephone: (679) 331 3611/322 3333 FIU Facsimile: (679) 330 2094/331 6454 Email: info@rbf.gov.fj or info@fijifiu.gov.fj FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2018 The Financial Intelligence Unit (FIU) Annual Report for 2018 was tabled in Parliament yesterday, 02 September 2019 by the Honourable Attorney- General and Minister for Justice, Mr Aiyaz Sayed-Khaiyum.

The report provides information on key achievements and the performance of the FIU for 2018.
The FIU is responsible for implementing and enforcing the Financial Transactions Reporting (FTR) Act.

Director of the FIU, Mr Razim Buksh said that the FIU is the lead agency in Fiji that is tasked to prevent and detect money laundering and related predicate criminal activities.

“We ensure the safety and integrity of Fiji’s financial system by implementing important anti-money laundering (AML) and combating financing of terrorism (CFT) initiatives.” Mr Buksh said.
Mr Buksh said that FIU’s intelligence products have supported and contributed to significant positive outcomes of its partner agencies, such as the Fiji Police Force, Fiji Revenue and Customs Service and Fiji Independent Commission Against Corruption.

“Investigation and prosecution of complex financial crimes, such as fraud, drug trafficking, corruption, tax evasion and cybercrime requires a concerted effort.
The FIU provides timely and credible financial intelligence and information to its partner agencies,” Mr Buksh said.

In 2018, the FIU received and analysed 632 suspicious transaction reports and disseminated 321 intelligence reports to law enforcement agencies for further investigation of possible tax evasion, money laundering and other serious offences.

The total value of funds that were identified by the FIU as possible tainted proceeds in the 321 intelligence reports was approximately $175million.
There were six successful money laundering convictions, 50 border currency smuggling cases, and several successful tax evasion and predicate crime investigations in 2018.

During the year, the FIU provided 260 investigative assistance and 118 due diligence assistance on 1,172 entities and 1,500 individuals to law enforcement and other Government agencies relating to ongoing criminal investigations and background checks.
In undertaking its regulatory function in 2018, the FIU conducted industry specific outreach and training, issued AML/CFT guidelines and policy advisories, and conducted on-site compliance examination of law firms and real estate agents.

The FIU also contributed towards improving Fiji’s compliance ratings with the international AML/CFT standards.
Mr Buksh said that the FIU continued to contribute to national and inter-agency coordination and international networking, particularly on transnational crimes such as drug trafficking cases.

Mr Buksh further said that the achievements of the FIU in 2018 were only possible through the support and contributions of its staff, law enforcement and regulatory partners, and the financial institutions and businesses that are covered under the FTR Act.
RESERVE BANK OF FIJI 35 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 SELECTED KEY STATISTICS 2015-2019 9 SELECTED KEY STATISTICS 2015-2019 Year 2015 2016 2017 2018 2019 Suspicious Transaction Reports 516 579 650 632 622 Cash Transaction Reports 579,849 590,385 623,213 968,693 794,044 Transaction and Currency Reports Received by FIU Electronic Fund Transfer Transaction Reports 1,029,993 1,148,711 1,220,602 1,357,246 1,515,681 Border Currency Reports 491 547 792 969 1,102 Year 2015 2016 2017 2018 2019 Suspicious Transaction Reports Filed Away for future intelligence and analysis Case Dissemination Reports Information Dissemination Reports Intelligence and Information Reports to Stakeholders Due Diligence Reports Notices to Financial Institutions Alert Notices Directives Queries Request for further information from financial institutions 667 464 502 446 603 Year 2015 2016 2017 2018 2019 Number of employees of Financial Institution 270 320 202 376 Education and Awareness Number of Financial Institutions Employees of Law Enforcement Agencies 3 84 6 67 8 80 5 65 Source: Fiji FIU 79 1 152 36 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 SELECTED KEY EVENTS 2019 10 JANUARY 9 28-31 31 FEBRUARY 1 7 12 MARCH 11-15 APRIL 11 MAY 21 JUNE 17-19 JULY 1-5 AUGUST 14 16 Meeting of the National AML Council Egmont Committee Meeting, Indonesia Fiji’s Follow Up Report to APG AML Law Enforcement Working Group Meeting Case Management System (CMS) launched AML Legal Working Group Meeting FIU Press Release – Financial Intelligence Annual Report 2017 AFI Global Standards Proportionality Working Group Meeting, Egypt New AML Compliance Officers Induction AML Forum for Real Estate Agents Pacific Workshop on Targeted Financial Sanctions relating to Terrorist Financing & Proliferation Financing Egmont Group Plenary Meeting, Netherlands AML Law Enforcement Working Group Meeting Aidong Zhang convicted of money laundering offence 18-23
 APG Annual Meeting and Forum on Technical Assistance and Training, Australia SEPTEMBER 3 11-13 20 27 OCTOBER 1 17 31 DECEMBER 5 5 FIU Press Release – Financial Intelligence Annual Report 2018 AFI 11th Global Policy Forum, Rwanda Policy Advisory 1/2019: Source of Funds Aidong Zhang returned $1 million to Mr Yong Chen as per High Court Direction Guideline 8: AML Compliance Obligations of Real Estate Agents and Businesses FNIC Taskforce Meeting Aidong Zhang sentenced to 3 years imprisonment, suspended for 18 months Nousheen Mezabeen Nisha convicted of money laundering offence FNIC Taskforce Meeting 37 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 38 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 STRATEGIC ANALYSIS REPORT 2019 39 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 STRATEGIC ANALYSIS REPORT 2019 FIJI FINANCIAL INTELLIGENCE UNIT 1.
STRATEGIC ANALYSIS OVERVIEW 2.

SUMMARY OUTCOMES 3.

OUTCOMES - SUSPICIOUS TRANSACTION REPORTS 4.

OUTCOMES - CASH TRANSACTION REPORTS 5.

OUTCOMES - ELECTRONIC FUNDS TRANSFER REPORTS 6.

OUTCOMES - BORDER CURRENCY REPORTS 41 43 44 51 53 55 7.

EMERGING AND CONTINUING MONEY LAUNDERING TRENDS 59 8.

CASE STUDIES 9.
CASE STUDIES 9.

GLOSSARY 61 69 40 40 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 STRATEGIC ANALYSIS OVERVIEW 1 Overview The Fiji FIU undertakes detailed analysis of financial transaction information and converts it into meaningful outputs.

This is called Strategic Analysis.

This Report provides the key outcomes of Strategic Analysis on the various categories of reports that the FIU receives as well as a summary of the trends and case studies identified in 2019.
Strategic analysis outcomes enable the FIU and its stakeholders to understand the patterns and trends on money laundering and related issues.

It also enables the FIU to draw conclusions for the strategic prevention of money laundering and the financing of terrorism in Fiji, to provide input for policy formulation and for setting operational priorities.
Strategic Analysis also assists the FIU to develop knowledge (strategic intelligence) relating to money laundering, the financing of terrorism and other threats to the security of Fiji’s financial systems.

FIU analysis should add value to the information received and held by the FIU.
While all the information should be considered, the analysis may focus either on each single disclosure received or on appropriate selected information, depending on the type and volume of the disclosure received, and on the expected use after dissemination.

FIUs should be encouraged to use analytical software to process information more efficiently and assist in establishing relevant links.

However, such tools cannot fully replace the human judgement element of analysis.
FIUs should conduct the following types of analysis: • Operational analysis uses available and obtainable information to identify specific targets (e.g.

persons, assets, criminal networks and associations), to follow the trail of particular activities or transactions, and to determine links between those targets and possible proceeds of crime, money laundering, predicate offences or terrorist financing.
• Strategic analysis uses available and obtainable information, including data that may be provided by other competent authorities, to identify money laundering and terrorist financing related trends and patterns.

This information is then also used by the FIU or other state entities in order to determine money laundering and terrorist financing related threats vulnerabilities.
Strategic analysis may also help establish policies and goals for the FIU, or more broadly for other entities within the AML/ CFT regime.

and Source: FATF Recommendation 29, Interpretive Note Paragraph 3 Strategic analysis aims to decipher the underlying patterns and trends that would enable an FIU to draw conclusions for the strategic prevention of money laundering and the financing of terrorism, and to provide input for policy formulation and for setting operational priorities.
In FIU context, this (strategic intelligence) as it relates to money laundering, the financing of terrorism and other threats to the security of a country’s financial systems.
Some components of strategic analysis include: implies developing knowledge • examining data for patterns and similar concepts; • developing a working hypothesis that addresses the “who”, “what”, “when”, “where”, “how”, and “why” of the activity; • collecting, evaluating and collating further information as required; • identifying connections or links between pieces of information, also used to support an inference; 41 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 an indicator or model for predicting future behaviour.
• Synthesis - This includes identifying connections that identify break-through ideas and opportunities in the detection of money laundering or the financing of terrorism.

• Geographical/regional analysis - This shows the area of influence or location of the phenomenon.

• Behavioural analysis - This shows the type of operations, institutions and products used by the group.

• Activity analysis - This focuses on identifying weaknesses of an economic sector or activity.
• Advanced - These intelligence products may include vulnerability assessments, risk assessments and significant event assessments.

Source: Egmont Group of Financial Intelligence Units Operational Guidance for FIU Activities and the Exchange of Information • developing inferences (an inference is the best estimate of the truth that can be drawn from facts, opinions or other inferences); and • constructing the argument, that is the logical flow of elements leading to the inference.
The sophistication of Strategic Analysis may vary based on the capacity and resources of the FIU.

Product ranges of Strategic Analysis may include: • Typologies and trends - this is a systematic classification of a number of schemes that appear to be constructed in a similar fashion.

These are built on a series of indicators that show how money was laundered, which in turn increases general understanding of an issue or method of money laundering or the financing of terrorism.
When a typology occurs for any given event over a period of time, this can be classed as a trend.

Changes in crime types or the way in which money is moved are examples of trends.
• Patterns - this is a recurring characteristic or trait that helps in the identification of a phenomenon/problem and that serves as 42 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 SUMMARY OUTCOMES 2 Suspicious Transaction Reports primary Instrument Type - Cash Cash Transaction Reports Electronic Fund Transfer Reports Border Currency Reports Managed from commercial banks 74% 141 from MRSPs22% current authorised users of the FIU’s online IT system Total value $57.4 Million from $78.8 million in 2018 Top two grounds of Managed suspicion STRs 141 current authorised 1) unusual account activity users of the FIU’s online 2) advanced fee fraud IT system Fijian currency93% 78% 33 years of age 57% from Central/ Eastern Division 99% from commercial banks 43% between $10,001 and $20,000 72% from the Money Remittance Service Providers 79% inward remittance transactions Total value Received 794,044 Received 1,515,681 Received 1,102 from 969 BCRs in 2018 More outbound declarations $63.6 Million compared to $62.7 million in 2018 43 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 OUTCOMES - SUSPICIOUS TRANSACTION REPORTS 3 Reporting Financial Institutions STRs were reported to the FIU by various financial institutions including members of the public.
The majority of the STRs continue to be reported by commercial banks (2019: 74 percent; 2018: 62 percent) followed by the money remittance service providers (2019: 22 percent; 2018: 29 percent).

Summary of Reporting Financial Institutions Financial Institutions and Persons Reporting Number of Financial Institutions Registered with FIU No.
of STRs Received 2015 2016 2017 2018 2019 Commercial Banks Money Remittance Service Providers Finance Companies Members of the Public Regulatory Authorities Law Firms Accounting Firms Insurance Companies and Superannuation Fund Securities, Unit Trusts Real Estate Businesses Others6 TOTAL Source: Fiji FIU 6 397 367 407 391 459 12 10 - - 41 17 13 4 29 - Summary of Reporting Financial Institutions Other Financial Institutions Banks Banks to Total Number of STRs Money Remittance Service Providers to Total Number of STRs No.
of STRs 500 % Change 90 450 400 350 300 250 200 150 100 50 0 80 70 60 50 40 30 20 10 0 2015 2016 2017 Years 2018 2019 Source: Fiji FIU Value of Transactions Reported as Suspicious The total value of suspicious transactions that were reported in 2019 decreased to $57.4 million from $78.8 million in 2018.

There has been an increase in the number of low value suspicious transactions reported to the FIU in 2019 and a decrease in the number of high value suspicious transactions reported in the same period.
The average value of a transaction reported in 2019 as suspicious was $92,283 compared to $124,684 in 2018.

Total Value of Transactions Reported as Suspicious 2015 2016 2017 2018 2019 82.7 74.7 49.1 78.8 57.4 516 579 650 632 622 160,373 128,968 75,503 124,684 92,283 Total Value ($ million) Number of STRs Average Value reported ($ per STR) Source: Fiji FIU 6 “Others” include STRs filed by foreign FIU’s.
44 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Total Value of Transactions Reported as Suspicious $m No.

of STRs 100 80 60 40 20 0 Number of STRs Total Value of STR 700 600 500 400 300 200 100 0 2015 2016 2017 2018 2019 Years Source: Fiji FIU Grounds for Suspicion on STRs Received 2019 “Grounds for Suspicion” in Suspicious Transaction Reports In 2019, majority of the STRs were reported on the grounds of suspected unusual account activity and advance fee fraud & other scams.
Grounds of suspicion relating to unusual account activity included “rapid movement of funds”, “sudden change in banking behaviour where large cash deposits take place which were not previously observed”, “significant withdrawals not aligned to customer’s employment status”, and “making payments in different currencies through an account without any logical sense”, etc.
Grounds for Suspicion Use Of Minors Account Unusually large foreign exchange Possible unexplained wealth Violation of EC requirements Counterfeit financial instruments FIU/Other Watchlist Third Party Transaction Unusually Large Transfer Unusually Large Cash Transaction Other (One Off Large Transaction) Inconsistent with Customer Profile Suspicious Behaviour Avoiding Reporting Obligations Unusual Use/Exchange Of Cash Fraud Or Other Serious Offence Tax Evasion Advance Fee Fraud & Other Scams Unusual Account Activity 0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 Number of STRs Source: Fiji FIU 45 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Suspicious Transactions by Transaction Value There is no monetary threshold under the FTR Act for reporting suspicious transactions.
Thus, any suspicious transaction must be reported to the FIU regardless of the amount involved in the transaction, including the reporting of attempted transactions.

Previous trends indicate that suspicious transactions do not always involve substantial dollar amounts.

The majority (52 percent) of the STRs submitted by financial institutions in 2019 were reported on transactions valued below $5,000.
STRs involving large value transactions of more than $0.5 million accounted for 3 percent of total STRs reported in 2019 compared to 5 percent in 2018.

Suspicious Transactions by Instrument Type ‘Cash’ continued to be the primary financial instrument type that is reflected in the STRs reported to the FIU in 2019.

Out of the 622 transactions reported as suspicious in 2019, 286 (46 percent) involved cash transactions.

The types of financial instruments involved in STRs include: 1.
Cash (local and foreign currency); 2.

Cheque (bank cheques/drafts, personal and company cheques); 3.

Remittances; and 4.

Other instruments (account-to-account transfers, credit cards and travellers cheques).
Suspicious Transactions by Transaction Value 6% 2% 1% 7% 7% 10% 15% 52% Suspicious Transactions by Instrument Type Year Cash Cheque Remittances Others Total 2015 2016 2017 2018 2019 285 398 409 343 286 Source: Fiji FIU 55 40 67 62 90 125 93 113 186 193 51 48 61 41 53 516 579 650 632 622 Suspicious Transactions by Instrument Type Cash Cheque Remittances Others $0-$5,000.00 $5,000.01-$10,000.00 No.
of STRs $10,000.01-$20,000.00 $20,000.01-$50,000.00 $50,000.01-$100,000.00 $100,000.01-$500,000.00 $500,000.01-$2,000,000.00 $2,000,000.01 & above Source: Fiji FIU 398 409 450 400 350 300 285 Suspicious Transactions by Transaction Value Transaction Value Number of STRs Percentage of STRs $0 - $5,000.00 327 $5,000.01 - $10,000.00 $10,000.01 - $20,000.00 $20,000.01 - $50,000.00 $50,000.01 - $100,000.00 $100,000.01 - $500,000.00 $500,000.01 - $2,000,000.00 $2,000,000.01 & above 91 64 44 45 37 10 4 52 15 10 7 7 6 2 1 250 200 150 100 50 0 Total 622 100 Source: Fiji FIU 46 343 286 186 193 125 55 51 113 93 48 40 67 61 62 41 90 53 2015 2016 2017 Years 2018 2019 Source: Fiji FIU FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Suspicious Transactions by Currency Type The majority (93 percent) of the STRs reported in 2019 involved Fijian currency.
The suspicious transactions that involved foreign currency decreased to 7 percent of total STRs in 2019 compared to 25 percent in 2018.

Suspicious Transaction Reports by Customer Age 55 percent of STRs on individuals were reported on customers between the age of 26 and 46 years.

Age not stated decreased from 20 in 2018 to 3 in 2019 due to an improvement in the quality of reports.

Suspicious Transactions by Currency Type Fijian Currency Fijian Currency % Change No.
of STRs 700 Foreign Currency Foreign Currency % Change % Change 100 577 515 472 384 358 185 132 133 160 45 600 500 400 300 200 100 0 80 60 40 20 0 Suspicious Transaction Reports by Customer Age Year 2yrs – 18yrs 19yrs - 25yrs 26yrs - 32yrs 33yrs - 39yrs 40yrs - 46yrs 47yrs - 54yrs 55yrs and over Not Stated7 TOTAL Source: Fiji FIU 2015 2016 2017 Years 2018 2019 Suspicious Transaction Reports by Customer Age Source: Fiji FIU 80, 19% 86, 20% Suspicious Transaction Reports by Customer Type There were 923 (84 percent) personal customers reported in STRs compared to 180 (16 percent) reports on corporate and business entities in 2019.
The proportion of STRs reported in 2019 on increased by 74 percent when individuals compared to 2018.

This increase was caused by multiple individuals being reported on in a single STR.

Suspicious Transaction Reports by Customer Type No.
of STRs Legal Entities Individual 95, 23% 68, 16% 3, 1% 7, 2% 26, 6% 53, 13% 2 yrs - 18 yrs 19 yrs - 25 yrs 26 yrs - 32 yrs 33 yrs - 39 yrs 40 yrs - 46 yrs 47 yrs - 54 yrs 55 yrs and over Not Stated Source: Fiji FIU 1000 900 800 700 600 500 400 300 200 100 0 923 447 503 542 529 69 69 108 103 180 2015 2016 2017 Years 2018 2019 Source: Fiji FIU 7 Date of birth is not usually provided in STRs where the person reported is a beneficiary of advance fee fraud.
47 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Age of Convicted Money Launderers Analysis of money laundering and proceeds of crime conviction cases showed the following in relation to the age bracket of the persons involved.
Age of Convicted Money Launderers Name of Individual Year STR was Reported Age at the time of the offence Year Convicted Manoj Khera 2004 31 years old 2014 Timothy Aaron O’Keefe 2005 25 years old 2005 Monika Arora 2007 28 years old 2011 Salendra Sen Sinha 2008 30 years old 2010 Anand Kumar Prasad 2008 28 years old 2011 Deo Narayan Singh 2008 40 years old 2011 Atisma Kirti Singh 2008 23 years old 2011 Name of Individual Other ML Investigations Age at the time of the offence Year Convicted Deepak Rajneel Kapoor Robin Surya Subha Shyam Faiyaz Khan Savita Singh 25 years old 2012 38 years old 2013 38 years old 2013 32 years old 2015 Chris Ronil Singh 38 years old 2015 Mukeshwar Narayan Singh 21 years old 2016 Sakiusa Vakarewa 31 years old 2016 Josefa Saqanavere 41 years old 2016 Savenaca Batibawa 47 years old 2016 Katarine Gounden Fiu 31 years old 2016 Vika Sadrau 34 years old 2018 Rahul Rajan Naidu 28 years old 2018 Johnny Albert Stephen 2009 39 years old 2012 Avenai Danford 29 years old 2018 Doreen Singh 2009 31 years old 2013 Rimakshni Ranigal 30 years old 2018 Kapil Kushant Samy 2010 24 years old 2012 Nitesh Kumar Nirmala Devi Natasha Nilma Singh Vikash Mehta Tuimoala Raogo Fazeel Razid Ali Manjeet Singh Rajneel Chaudary Preetika Anuwesh Lata 2016 2011 23 years old 2016 46 years old 2012 2012 20 years old 2014 2013 2013 2015 2014 2014 29 years old 2015 41 years old 2016 27 years old 2016 22 years old 2017 23 years old 2017 2014 27 years old 2017 Prashil Prakash 2012 28 years old 2017 Aidong Zhang 2014 & 2016 51 years old 2019 Rosheen Praveena Raj 42 years old 2018 Rine Munivai Sorby 54 years old 2018 Nousheen Mezbeen Hussain Source: Fiji FIU 25 years old 2019 Suspicious Transaction Reports by Geographical Location of Reporting Institutions The FIU receives STRs from various commercial centres in Fiji.
Majority of the STRs continue to be received from financial institutions based in the Central/Eastern Division due to concentration of economic and commercial activities in this division.

In 2019, STRs from the Northern Division increased to 72 from 68 STRs received in 2018.
48 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Suspicious Transaction Reports by Geographical Location of Reporting Institutions Examples of Reasons for Reporting Transactions as Suspicious Western Central/Eastern Northern Commercial Banks No.
of STRs 400 350 300 250 200 150 100 50 0 352 349 353 286 273287 245 202 213 197 28 17 41 68 72 2015 2016 2017 2018 2019 Years Source: Fiji FIU Reasons for Suspicious Reporting A financial institution’s decision to report a transaction as suspicious to the FIU is based on a number of factors, such as, the: i. customer’s usual occupation or business activity; ii.

customer’s transaction history; iii.

income level and source of income of the customer; and iv.
the complexity, frequency and size of transactions; customer’s general background and profile (such as age, citizenship, etc.).

These factors individually may seem insignificant but when considered together may raise questions on appropriateness and normality of customer’s transaction(s).

The above-mentioned indicators can also be based on known money laundering typologies.
Financial institutions are required under the FTR Act to know their customers in order to identify transactions that may be unusual, suspicious or questionable individual customer or a type or category of customer.

for an 1.

2.

3.

4.

5.

6.

7.

8.

9.

$220,800 was received and was subsequently withdrawn after four days.

A sudden change in banking behaviour wherein large credit was not previously observed.
Customer made a cash deposit of $10,000 and when the teller asked about the source of funds she was hesitant to reply and did not disclose anything.

Alert was created for external foreign bank account due to two transfers made to two beneficiaries in high terrorist financing risk countries totalling $3,600.

Customer visited bank branch to check on an inward telegraphic transfer from Australia.

He provided copy of a remittance advice which appeared to be fraudulent.
Customer made a $300 cash deposit to another customer’s account based on a promise on social media that she will get a huge catering contract.

She did not hear from the other customer again.

Multiple cash deposits for wages from a local restaurant made into numerous accounts of employees.

The restaurant has been operating in Fiji for nearly two years without any local bank account.

Customer received a large cheque deposit of $68,000 made by the wife.
The wife advised that the cheque was his salary, however on the bank’s records, he is listed as a retiree.

Rapid movement of funds whereby $132,000 was withdrawn in cash a day after $133,000 was received from an unknown source.

The true origin and legitimacy of these funds were not verified.

A sudden change in account behaviour wherein large credit was not previously observed.

The customer deposited $28,000 into his account with funds sourced from his company account.
Possible case of tax evasion and money laundering possibly by the company utilising the individual’s account.

Money Remittance Service Providers 10.

Customer who was an Asian national was not willing to provide further details when conducting enhanced due diligence.

11.

Invalid ticket was provided when wanting to exchange funds.

12.

Customer’s occupation is domestic duties who receives money frequently sent by Person A overseas.
The relationship mentioned by the customer differs from “husband” to “family friend”.

The customer receives cash nearly every day and gives the purpose as building the house.

49 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Finance Companies Insurance Companies and Superannuation Fund 13.

14.

Client is a farmer who has been making additional payments monthly and conducted a large sum payment of $22,500.00 which was deemed suspicious.
Client was reluctant to provide source of funds and initially said that the money was from his bank account and then stated that it was kept at home.

Members of the Public 15.

A couple is allegedly living in a home in Nadi which belongs to a foreigner, however the local couple managed to transfer the home to them through gift, love and affection.

Law Firms 16.

As per court order, funds were supposed to be paid to Law Firm A’s trust account by Law Firm B’s client.
Law Firm B was informed by their client that Law Firm A had taken the funds into the trust account which was not notified to them and has not been refunded till date.

Law Firm B was informed that the trust account money in favour of the plaintiff was used by Law Firm A for some other purpose and was only paid out to the plaintiff later in the year.

17.

Individual has deposited over $2 million over the course of 4 years.

18.
18.

Individual is observed to be making split deposits between first few months of 2019 totalling up to $38,600.00.

It appears that individual who is also a business owner, may be avoiding the reporting threshold of $10,000.00.

19.

Transactions are suspicious on the grounds that inconsistent pattern was noted.

Securities & Unit Trusts 20.

Customer came in with $50,000.00 cash in $100 dollar bills and advised that the cash was from his salary and bonus from his employer and some are from his savings.
However, he was not able to provide a bank statement for all the cash.

The above are extracts from actual STRs reported to the FIU in 2019.

Source: Fiji FIU 50 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 OUTCOMES - CASH TRANSACTION REPORTS 4 Financial institutions are required under section 13(1) of the FTR Act and regulation 25 of the FTR Regulations to report to the FIU any cash transaction of $10,000 and above or its equivalent in foreign currency.
Cash includes coin or paper money, bank drafts, bank cheques, bearer bonds, travelers cheques, postal notes and money orders.

For ease of reporting, some financial institutions report all cheque transactions of $10,000 and above.

The FIU received 794,044 CTRs in 2019 or an average of around 66,170 CTRs per month.

This is a decrease of 18 percent compared to 968,693 CTRs received in 2018.
Cash Transactions Reported Year 2015 2016 2017 2018 2019 Source: Fiji FIU Total CTRs Monthly Average CTRs 579,849 591,636 623,213 968,693 794,044 48,321 49,303 51,934 80,7248 66,170 Monthly Cash Transaction Reports 2015 2016 2017 2018 2019 CTRs Received by Sector The majority (99 percent) of the CTRs received during 2019 was reported by commercial banks.

There is a gradual increase in CTRs reported by law firms due to the FIU’s AML/CFT compliance and outreach initiatives.
Cash Transactions Reported by Sector Sector 2015 2016 2017 2018 2019 Commercial Banks Foreign Exchange Dealers and Money Remitters Finance Companies Insurance and Superannuation Fund Law Firms Securities/ Brokers/ Advisors Accountants Statutory Authority Real Estate TOTAL Source: Fiji FIU CTRs by Direction of Cash Payment The CTRs received in 2019 consisted of 61 percent inwards (IN) and 39 percent outward (OUT) CTRs.
Inward CTRs refer to cash transactions received by a financial institution.

Outward CTRs refer to cash transactions paid out by a financial institution.

CTRs by Direction of Cash Payment 2019 90,000 85,000 80,000 75,000 70,000 65,000 60,000 55,000 50,000 45,000 40,000 30,000 30,000 25,000 20,000 J F M A M J J A S O N D Months Source: Fiji FIU 307,959 39% 486,085 61% 8 In 2018 one reporting institution reported backdated CTRs totalling 249,114 in October 2018.
This is also not reflected in the Monthly Cash Transaction Reports graphs for 2018.

Out In Source: Fiji FIU 51 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 CTRs by Value of Transactions The majority (43 percent) of CTRs received by the FIU in 2019 were for cash transactions between $10,001 and $20,000.

Approximately 73 percent of CTRs reported are for cash transactions between $10,001 and $50,000.
CTRs by Value of Transactions 2019 90,535 11% 39,415 5% 84,909 11% 240,439 30% 338,746 43% Exactly $10,000 $50,001 to $100,000 $10,001 to $20,000 More than $100,000 $20,001 to $50,000 Source: Fiji FIU 52 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 OUTCOMES - ELECTRONIC FUND TRANSFER REPORTS 5 Commercial banks and remittance service providers are required under section 13(2) of the FTR Act and regulation 26 of the FTR Regulations to report to the FIU all international electronic fund transfer transactions.
There is no monetary threshold for EFTRs.

Currently, 6 commercial banks, 12 MRSPs, and 2 mobile phone operators are subject to EFTR reporting.

The FIU received 1,515,681 EFTRs in 2019 or an average of around 126,307 EFTRs per month.

This is an increase of 12 percent compared to 1,357,246 EFTRs received in 2018.

Electronic Funds Transfer Transactions Reported EFTRs Received by Sector Majority (72 percent) of EFTRs were received from the MRSPs.
There was a notable increase of 56 percent in the number of EFTRs received from the mobile phone money remittance sector in 2019 due to a new remittance platform partnership arrangement with a mobile phone company.

Mobile phone operators are currently authorized to only conduct inward remittance transactions.
EFTRs Received by Sector 2019 66,794 4% Year 2015 2016 2017 2018 2019 Source: Fiji FIU Total EFTRs Monthly Average EFTRs 360,595 24% 1,029,993 1,148,711 1,220,602 1,357,246 1,515,681 85,833 95,726 101,717 113,104 126,307 1,088,292 72% Monthly Electronic Funds Transfer Reports 2018 2017 2016 2015 Money Remittance Service Providers Commercial Banks Mobile Phone Money Remitters 2019 Source: Fiji FIU EFTRs Received by Sector Sector 2015 2016 2017 2018 2019 Money Remittance Service Providers Commercial Banks Mobile Phone Money Remitters 697,676 793,837 869,363 968,016 1,088,292 324,604 333,746 319,640 346,282 360,595 7,713 21,128 31,599 42,948 66,794 160,000 150,000 140,000 130,000 120,000 110,000 100,000 90,000 80,000 70,000 60,000 50,000 J F M A M J J A S O N D Total 1,029,993 1,148,711 1,220,602 1,357,246 1,515,681 Months Source: Fiji FIU Source: Fiji FIU 53 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 EFTRs by Direction of Remittances EFTRs may involve remittances into Fiji (inward) or remittances out of Fiji (outward).
Majority (79 percent) of EFTRs received during 2019 were for inward remittances.
EFTRs by Direction of Remittances 2019 316,776 21% 1,198,905 79% Out In Source: Fiji FIU EFTRs by Direction of Remittances 2015 2016 2017 2018 2019 Inwards 773,264 879,644 958,090 1,053,266 1,198,905 Outwards 256,729 269,067 262,512 303,980 316,776 Total 1,029,993 1,148,711 1,220,602 1,357,246 1,515,681 Source: Fiji FIU remittance international EFTRs by Sending and Receiving Country transactions Inward reported to the FIU were conducted from the following ten major countries: Australia, United States of America, New Zealand, United Kingdom, Canada, Solomon Islands, Vanuatu, Cook Islands, Tonga and Papua New Guinea.
54 EFTRs: Top 10 Countries Conducting Inward Remittances to Fiji 335,743 28% 8,882 1% 8,379 1% 222,913 18% 10,137 1% 11,967 1% 12,155 1% 38,894 3% 80,939 7% 216,906 18% 251,990 21% Australia United Kingdom Cook Islands United States of America Canada Tonga Solomon Islands Papua New Guinea New Zealand Vanuatu Others Source: Fiji FIU remittance international Outward transactions reported to the FIU were made to the following ten major countries: Australia, New Zealand, United States of America, India, Philippines, China, Solomon Islands, Hong Kong, Vanuatu and Singapore.
EFTRs: Top 10 Countries Involved in Outward Remittances from Fiji 49,524 16% 156,999 49% 40,116 13% 3,752 1% 4,113 1% 15,865 5% 15,389 5% 11,975 4% 5,749 2% 8,260 3% 5,034 1% Australia India Hong Kong New Zealand Philippines Vanuatu United States of America China Singapore Solomon Islands Others Source: Fiji FIU FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 OUTCOMES - BORDER CURRENCY REPORTS 6 All travellers coming into Fiji or going out of Fiji are required to declare if they are carrying currency or negotiable bearer instruments of $10,000 or more (or its equivalent in foreign currency).
Travellers are required to make a declaration in the first instance on the arrival or departure cards and then fill out a BCR form which is available at all ports of entry and exit in Fiji.

The completed BCRs are collected by Customs FRCS officials at the ports and submitted to the FIU for central recording, analysis and for its intelligence purpose.

In 2019, 1,102 BCRs were submitted to the FIU compared to 969 BCRs in 2018.
BCRs by Direction of Travel There were more declarations made by outbound travellers compared to inbound travellers in 2019.

BCR Declarations by Direction of Travel 2015-2019 Persons Declaring Declarations made by inbound travellers Declarations made by outbound travellers 2015 2016 2017 2018 2019 187 265 375 434 436 304 282 417 535 666 Total 491 547 792 969 1,102 Source: Fiji FIU The FIU has noted an increase in declarations made by outbound travellers.
In 2019, 60 percent of declarations were made by outbound travellers while 40 percent of declarations were made by inbound travellers.

Comparison of Declaration made by Travellers by Month No.
of BCR’s Outbound Inbound 100 80 60 40 20 0 J F M A M J J A S O N D Months Source: Fiji FIU BCR Declarations: Reason for Travel outbound) 2019 (inbound and 24% 20% 3% 4% 2% 2% 18% Business Migration Holiday Visiting Friends/ Relatives Convention/ Conference Medical 27% Education/ Training Other Source: Fiji FIU 55 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 BCRs by Transaction Values: Outbound 2019 38,6% 38, 6% We have observed that 65% of travellers stated their reason for travel both in and out of Fiji was for holiday/business/visiting friends and relatives.
The majority of BCRs declared by inbound and outbound travellers ranged in the value of FJ$10,001 - FJ$100,000.

329, 49% BCRs by Value of Currency Declared The total value of currency declared by travellers in the BCRs in 2019 was $63.6 million compared to $62.7 million in 2018.
261, 39% $10,000 $100,001 - $500,000 $10,001 - $100,000 $500,001 and above Source: Fiji FIU BCR by Transaction Values: Inbound 2019 Value of Border Currency Reports Received 2015-2019 Persons Declaring Travellers Arriving in Fiji Travelers Departing Fiji Value of Currency Declared ($million) 2015 2016 2017 2018 2019 11.0 13.1 21.4 22.6 19.3 20.9 17.1 28.5 40.1 44.3 41, 9% 4, 1%% 21, 5% Total 31.9 30.2 49.9 62.7 63.6 Source: FRCS & Fiji FIU Failure to Declare Currency Failure to declare currency at the border is an offence under the FTR Act.
If convicted, a person is liable to a fine of up to $60,000 or imprisonment of a maximum of 10 years or both.

In 2019, there were 19 reported cases of BCR non-declaration compared to 50 cases of persons failing to declare currency in 2018.

Most of the cases were detected at Nadi International Airport and the remainder were detected at the Nausori Airport and sea ports.
370, 85% $10,000 $100,001 - $500,000 $10,001 - $100,000 $500,001 and above Source: Fiji FIU 56 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Failure to Declare Currency Cases in 2019 Date Of Detection DETAILS 1.

9 January Passenger departed for New Zealand from Nausori AMOUNT FAILED TO DECLARE FJD 340 NZD 305 USD 4,634 FJD EQUIVALENT DATE OF CONVICTION JUDGMENT IN COURT $10,618.00 7 February Warning letter issued 2.
8 February Passenger arrived from New Zealand NZD 16,110 $21,935.00 N/A NZD 16,110.00 to be forfeited to state 3.

4.

5.

6.

1 March Passenger departed for Korea from Nadi 11 March Passenger arrived from high seas 6 April Passenger arrived from Honolulu 8 May Passenger arrived from Seoul 7.

12 May Passenger arrived from Singapore 8.

9.

27 May Passenger arrived from Apia 30 May Passenger arrived from Auckland 10.

24 June Imported currency through the air mail PNDE # 28345 11.
22 August Passenger departed for Brisbane USD 15,556 FJD 85 INR 15,890 USD 2,400 JPY 27,009 $31,648.80 28 March Passenger fined $1,000.00 $12,207.54 9 April Passenger fined $500.00 USD 8,972 $20,355.00 8 April Passenger fined $1,000.00 HKD 16,260 RMB 4,500 AUD 5,000 USD 9,253 INR 12,120 GEL 125 COM 73,540 AED 485 KGS 851,000 USD 10,850 IDR 5,000 USD 12,460 NZD 35 FJD 90 $12,091.49 8 May Passenger fined $500.00 $18,531.95 13 May Passenger fined $1,000.00 $23,384.67 27 May Passenger fined $1,000.00 $25,870.00 13 June Passenger fined $1,000.00 USD 10,920 $23,387.10 16 July Passenger fined $1,000.00 AUD 10,875 USD 870 FJD 1,220 GBP 10 $17,058.00 22 August Passenger fined $1,000.00 12.
13.

7 September Passenger arrived from Honolulu USD 11,700 $26,171.73 07 September Warning letter issued 15 September Passenger departed from Melbourne AUD 95 USD 6,094 $12,801.49 23 September Passenger fined $4,750.00 57 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Date Of Detection DETAILS 14.

15.

22 September Passenger arrived from Singapore 24 September Passenger arrived from Singapore 16.

2 October Passenger arrived from Vanuatu 17.

11 October 18.

11 October 19.
11 October Source: FRCS & Fiji FIU Passenger arrived from Hong Kong Passenger arrived from Hong Kong Passenger arrived from Hong Kong AMOUNT FAILED TO DECLARE USD 562 EUR 20,000 RMB 11,000 THB 360 USD 18,905 JPY 16,200 CNY 20 USD 11,529 WST 400 NZD 65 AUD 10 RMB 300 TOP 57 HKD 60 FJD 55 RMB 15,500 NZD 9,295 RMB 20,721 NZD 9,630 RMB 20,721 NZD 9,630 FJD EQUIVALENT DATE OF CONVICTION JUDGMENT IN COURT $48,406.48 23 September Passenger fined $2,500.00 $43,004.00 29 September Passenger fined $2,500.00 $24,217.81 29 September Passenger fined $2,500.00 $18,079.00 3 October Passenger fined $2,500.00 $20,502.00 11 October Passenger fined $2,500.00 $20,502.00 11 October Passenger fined $2,500.00 58 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 EMERGING AND CONTINUING MONEY LAUNDERING TRENDS 7 Emerging Trend Mingling (business investment) and tax evasion The FIU noted an increase in individuals using personal bank accounts to conduct business- like transactions.
It was also noted that business account signatories were using business bank accounts for personal use.

Combining business proceeds with personal accounts tends to obscure the source of funds and actual tax liabilities of individuals and businesses.
Structuring of transactions to avoid threshold reporting (smurfing) The FIU received numerous STRs relating to individuals conducting high volumes of small value transactions through various accounts to avoid detection of threshold reporting requirements of $10,000.00.

Transactions involved cash or cheque deposits, withdrawals and transfers.
Continuing Trend Business Email Compromise Scam / Cyber Fraud The FIU observed a continued occurrence of entities falling victim to business email compromise scams in 2019.

Hackers usually intercept a normal local business email conversation between entities and foreign counterparts or suppliers and unexpectedly change the payment instruction.

BEC hackers utilize social engineering tactics to trick unsuspecting employees and executives.
Hackers will often the usual counterpart contact person for conducting import trade transactions or wire transfers and obscure the payment instructions (usually by manipulating invoices) at the last minute.

impersonate Businesses and individuals must exercise caution when conducting overseas trade transactions or large personal remittances while commercial banks and remittance providers should continue to conduct enhanced due diligence for suspicious payment instructions.
Declining Trends The FIU has noted a decline in the following trends: a) Use of false identification and documents; b) ATM skimming; and c) Internet banking fraud.

Evasion Structuring Cyber Crime Indicators: • frequent cash payments to loan accounts.

• frequent/large transfers and deposits of business funds into personal accounts.

Indicators: • multiple deposits conducted below the reporting thresholds.

• deposits conducted at different branches in the same day.
Indicators: • use of social media and electronic communication to facilitate fraudulent activities.

• sudden internet banking transfers for large sums to a third party.
59 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Business Email Compromise (BEC) 2016 - 2019 29 STRs totalling $5,853,690.59 • $1,882,322.03 recovered • $3,470,153.56 total lost by 24 businesses and individuals Average of $144,589.73 lost by victims Victims: • 11% individuals • 89% businesses Top 3 countries funds were sent to: Hong Kong USA Australia (4 incidents totalling) $3,100,584.00 (5 incidents totalling) $1,475,988.69 (2 incidents totalling) $201,151.00 BEC Red Flags: • Unexpected urgent change to payment account details.
• Request comes from an almost identical email address that is difficult to differentiate.

• Emails sent outside normal business hours.

• Incorrect spelling and grammar usage.

• Invoice may look slightly different than usual invoices sent by the legitimate vendor/client/supplier.

What to do if you suspect BEC?

• Call the vendor/client/supplier on a known phone number to verify changes.

• Carefully check senders email addresses.

• Train staff on how to spot spoofed or spear-phishing emails.
• Immediately notify your bank if transfer has already occurred.

60 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 8 CASE STUDIES Money Laundering Cases: Success Stories in Fiji Double Dealings Mr Yong Chen, the complainant, was introduced to Mr Aidong Zhang by a close friend, Mr Shi Yuhu, who advised Mr Yong Chen that Mr Aidong Zhang was a “big businessman”, well known in Fiji and could generate $10 million profit per year.
The three met in China in 2014 together with family members of Mr Yong Chen and agreed to start a company called Bairain Group (Fiji) Ltd.

The company would have a share capital of $6 million, and Mr Yong Chen’s family would have 80% share of the company, while Mr Shi Yuhu and Mr Aidong Zhang would have 10% share each.

They agreed to form the company in Fiji and purchase a property.

Mr Shi Yuhu and Mr Aidong Zhang returned to Fiji and told Mr Yong Chen that 148 Waimanu Road was for sale for $5.5 million.
Mr Yong Chen agreed to purchase the property.

Mr Aidong Zhang sent an email with a draft copy of the Sales and Purchase Agreement confirming that $5.5 million was the purchase price.

Mr Yong Chen advised Mr Aidong Zhang to sign the Sales and Purchase Agreement on behalf of Bairain Group (Fiji) Ltd. After he signed the S&P Agreement, Mr Aidong Zhang asked Mr Yong Chen to send his share of the $1.5 million deposit, which was $1.2 million.
Since Bairain Group (Fiji) Ltd was not yet registered in Fiji, the $1.2 million was remitted to the bank account of Ostanding (Fiji) Limited, a company that was recently established.

Bairain Group (Fiji) Ltd was incorporated later in the year and Mr Yong Chen, believing that the purchase price was $5.5 million, remitted $4,037,620.65 to the bank account of Bairain Group (Fiji) Ltd.

Questions were raised amongst the shareholders in early 2015 regarding the purchase price of the property.
After consulting the vendor and his solicitor it was revealed that the actual purchase price for the property was $3.3 million and not $5.5 million.

In his defense, Mr Aidong Zhang stated that he and Mr Shi Yuhu decided that Ostanding (Fiji) Limited would purchase the property first for $3.3 million then sell it to Bairain Group (Fiji) Ltd.

Both men were directors of Ostanding (Fiji) Limited and would make a profit of $2.2 million.
In purchasing the property, Mr Aidong Zhang stated that he was acting as a middleman and the $1.2 million sent by Mr Chen Yong was the profit for Ostanding (Fiji) Limited.

On 16 August 2019 Mr Aidong Zhang was convicted of one count of obtaining property by deception and money laundering.

On 27 September 2019, he returned $1 million to Mr Yong Chen as ordered by the High Court.

On 31 October 2019, Mr Aidong Zhang was sentenced to 3 years imprisonment that was suspended for 18 months for both the charges.
He was also fined $100,000.00 and his shares in Barain Group (Fiji) Ltd terminated and given to the complainant.

The DPP has appealed the sentence.
61 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 PURCHASED RESTRAINED RESTRAINED Chang Hui Liu Married Aidong Zhang ACCOUNT SIGNATORIES SHAREHOLDERS FOREIGN JURISDICTION Shi Yuhu Liu Suhua Married New Trading Company STOLEN FUNDS Yong Chen FJ$1.2 million Bank Account #1 OWNS Bairain Group Limited DIRECTORS OWNS Bank Account #2 Ostanding Fiji Limited Court Outcome: Conviction Restitution Sentence* 1 Count Obtaining Property by Deception 1 Count Money Laundering Returned $1 million 3 years suspended sentence $100,000 fine Shares terminated * Appealed by ODPP 62 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Case Study 1: Cash and Drugs Person A was reported to the FIU in a STR for depositing $17,000.00 cash into his wife’s loan account.
Person A was asked about the source of the cash deposit and he advised that it was from the sale of a vehicle.

Person A stated that Person X purchased the vehicle with €14,500.00.

Analysis of Person X revealed that she was unemployed and had acquired 4 high value vehicles in a period of one year and received unusual cash deposits into her bank account.

She also received remittances totaling approximately $13,500.00 from individuals in Country Z.
It was later discovered that Person X was also associated with a Person Y, foreign national from Country Z.

Person Y is suspected to be involved in the transshipment of illicit substances in and out of Fiji.

A case dissemination report was provided to Fiji Police Force for their profiling and investigation.
Indicators: • Frequent and unusual cash deposits • Acquisition of high value assets that do not match customer profile • Use of large amounts of foreign currency Possible offence: • Money laundering • Failure to declare currency • Drug trafficking Country Z Person M Person N Person O $4,601.00 $4,223.00 $4,626.00 $4,620.00 $6,913.00 Partner Person Y Person X 2019 13,500.00 OWNS OWNED Declared 11,000.00 AU$600.00 BCR Form Previous Owner OWNER OWNS Bank Account XYZ Company Person B SPOUSE Person A 63 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Case Study 2: Unexplained Wealth of a Businesswoman Person X, a businesswoman was reported in two STRs for conducting frequent large cash deposits into her personal account.
Profiling of Person X revealed that she was a young sole trader operating two businesses in an outer island in Fiji.

Person X acquired four vehicles under her name and her business trading names.

Analysis of her bank account revealed that more than $1,000,000.00 in cash was deposited into her bank account in 2018.

Her income declared in her 2018 income tax returns was less than half this amount.

In the first seven months of 2019 she received cash deposits amounting to more than $600,000.00.
A case dissemination was provided to the tax authority for possible under-declaration of income.

Further analysis also revealed that the business activities declared by Person X did not match the large volume of cash deposits received into her bank account.

A case dissemination report was also provided to Fiji Police Force for further profiling.
Indicators: • The significant cash transactions did not match her daily business operations and profile • Consecutive large cash deposits • Her earnings are more than what she has declared to out tax authority Offence: • Tax Evasion • Possible Drug related activities Case Study 3: Funds, Properties and Tax Evasion The Fiji FIU received a STR in October 2018 on the alleged sale of a Fijian business, Company D with a payment of reportedly $300,000.00 made overseas.
The directors were foreigners, Person X and his wife Person W, and Person Y.

The purchaser was a foreigner, Person A, reportedly a car dealer in Country Z.

It was also alleged that Person A was operating various businesses illegally in Fiji without proper business and ownership registration.

We also established that Person A made no tax declarations in Fiji.

In March 2019, Person A was brought to the attention of the Fiji FIU again in another STR.
He was reported for receiving a large inward telegraphic transfer of approximately $900,000.00 into his personal bank account in Fiji from one Person B in Country Y reportedly for the purchase of property in a prominent location in Fiji.

Upon bank account analysis, it was established that Person A was receiving large telegraphic transfers from various entities in Country Z.
Person A was found to be associated with many entities based in Country Z and received remittances totaling approximately FJ$3.1 million from Country Z into his Fijian bank accounts.
The majority of the funds were received from a Country Z based entity Company C. Further checks revealed that Person A was one of the directors of Company C. 64 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Person A transferred approximately $4.5 million domestically in 2014, 2015, and 2017 to 2019 to various local entities including Company D (approximately $62,500.00).
It appeared that Person A could have been evading tax in both Fiji and Country Z by co-mingling funds from his overseas and local businesses in Fiji.

A case dissemination report was provided to tax authorities in Fiji and Country Z.
Indicators: • Large telegraphic transfers from associated entities abroad • No tax lodgment made to local tax authority • Suspicious transfer of funds to local entities with no apparent relationship Possible Offence: • Tax evasion • Money laundering Former Directors Married Person Y Foreigner Person X Foreigner Person W Foreigner FJ$300,000.00 Majority of funds sent by Company C Country Z based entities FJ$62,500.00 Fiji based entities Director Company C Company D Fijian Business Person A Foreigner No Tax declarations Sold To Fiji Property Person B Foreigner FJ$4.5 million FJ$900,000.00 FJ$3.1 million from 2009 to 2019 65 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Case Study 4: Wire Transfers and Tax Evasion Person H, a dual citizen of Fiji and Country X, was brought to the attention of the Fiji FIU in two STRs for a possible case of tax evasion.
The matter was brought to the attention of the Fiji FIU by two commercial banks based on suspicion that Person H was conducting business like transactions from his personal bank accounts and receiving large telegraphic transfers from overseas.

that a revealed total of Fiji FIU analysis approximately $93,000.00 was remitted from Country X by his spouse, Person I into Person H’s local bank accounts in Fiji in 2013, 2016 to 2018.
The Fiji FIU also established that Person H remitted approximately $75,000.00 from his bank accounts in Country X to his Fijian bank accounts in 2012, 2013, 2015 and 2016.

Large remittances were received from the couples’ bank accounts in Country X.

A case dissemination report was provided to the relevant taxation authority in Country X.
Indicators: • Large telegraphic transfers from related individuals and own accounts held abroad • Frequent transfer of funds from abroad to local bank accounts in Fiji over the years Offence: • Tax evasion in overseas country • Money laundering Approximately FJ$1.3 million from 2012 to 2019 Country X Fiji Owns Fijian bank account Married Various individuals’ bank account Person H Person I Dual citizen Fiji & country X Dual citizen Fiji & country X FJ$75,000.00 in 2012, 2013, 2015 & 2016 Person H and I’s bank accounts FJ$93,000.00 in 2013, 2016 to 2018 66 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Case Study 5: Business Email Compromise The Fiji FIU received a STR from a commercial bank that an overseas bank account had been used to fraudulently obtain funds from Company J, a local company based in Fiji.
The Fiji FIU established that criminals hacked email correspondences between Company J and their suppliers in Country A (business email compromise scam) and manipulated the payment instruction provided to Company J.

The hackers changed the beneficiary name and account number and advised Company J to send funds to an account based in Country B.

Funds totaling approximately $1.9 million was transferred to the bank account in Country B belonging to Company Z.
Company J realized that their accounts were hacked within 24 hours of sending the remittance and notified its bank and the Fiji FIU.

A case dissemination report was provided to the FIU in Country X and funds were successfully returned to the local bank in Fiji.
Indicators: • Sudden change in payment instructions for no apparent reason • Change in email address of suppliers • Change in tone of email and/or frequent request for updates on when transfer will be made Offence: • Cybercrime/cyber money laundering Company J Fiji-based entity Changes payment instruction to send funds to bank account in Country B FJ$1.9 million Business Email Compromise Owns Hacker(s)/ Cyber Criminal Bank account in Country B Country A Usual suppliers 67 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Case Study 6: Wire transfers and co-mingling of funds retired Person X, a foreign national was reported when there was a sudden change in account behaviour from dormant to frequent inward remittances ranging from $2,000.00 to $250,000.00.
Person X remittances totalling approximately $3.2 million from February 2018 to May 2019.

Analysis of Person X’s bank account also revealed that he had transferred approximately FJ$90,000.00 to Company XYZ.

Person X received approximately $1 miliion in remittances from Person Y. received Company XYZ, a local company, also received remittances from Person Y totalling $3.2 million from March 2018 to June 2019.

Person Y, a foreign investor is the sole shareholder/director of Company XYZ.
The relationship between Person X, Y and Company XYZ was unclear.

The Fiji FIU disseminated the case to the tax authority for further profiling.
Possible Offence: • Tax Evasion Indicators: • Significant bank account activity • Attempt to remit funds received from offshore into local account immediately after funds were received FJ$2.2 million $90,000.00 Person X Unkown relationship Unkown relationship Person Y FJ$1 million FJ$3.2 million Company XYZ 68 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 9 AFI AML GLOSSARY Alliance for Financial Inclusion FFIMSO Fiji FIU Information Management System Online Anti-Money Laundering FICAC Fiji Independent Commission Against Corruption AMS Alert and Monitoring System FIU Financial Intelligence Unit APG Asia Pacific Group on Money Laundering FNIC Fiji National Indentification Card APIFIU Association of Pacific Islands FIUs FRCS Fiji Revenue and Customs Services AUSTRAC Australian Transaction Reports and Analysis Centre Border Currency Report Case Dissemination Report BCR CDR CFT FUR FPF FTR Follow-Up Report Fiji Police Force Financial Transactions Reporting Combating the Financing of Terrorism GSPWG Global Standards Proportionality Working Group CTOG Counter Terrorism Officials Working Group CTR Cash Transaction Report DNFBP Designated Non-Financial Businesses and Professions DMS EFTR EMO ESW FATF Data Mining System Electronic Funds Transfer Report Electronic Money Order Egmont Secure Web Financial Action Task Force IMF MER International Monetary Fund Mutual Evaluation Report ML / TF Money Laundering and Terrorist Financing MOA Memorandum of Agreement MRSP Money Remittance Service Provider ODPP Office of the Director of Public Prosecutions RBF STR Reserve Bank of Fiji Suspicious Transaction Report 69 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 www.fijifiu.gov.fj FINANCIAL INTELLIGENCE UNIT STRATEGIC PLAN 2020-2024 Our Vision: Protecting Fiji from Money Laundering Our Strategic Pillars: Financial Intelligence Preventive Measures Technology Driven Processes Partnerships Our People 1.
Develop and disseminate intelligence Our Key Strategies: Maximise use of our intelligence Create more awareness on money laundering Implement risk based preventive measures Enhance financial institutions understanding of their obligations Effective supervision of financial institutions Effective data reporting Innovative data analytics Improve data quality and information security Enhance information sharing Strengthen partnerships Support international AML/CFT initiatives Cultivate a skilled, motivated and high performing team Corporate governance Level 5, Reserve Bank Building Reserve Bank of Fiji, Pratt Street, Suva, Fiji Phone: 322 3333 Fax: 331 6454 Email: info@fijifiu.gov.fj 2.
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70 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 Contact Information Financial Intelligence Unit Level 5, Reserve Bank Building Reserve Bank of Fiji Private Mail Bag Pratt Street, Suva, Fiji Telephone: (679) 322 3333 Facsimile: (679) 331 6454 Email: info@fijifiu.gov.fj Website: www.fijifiu.gov.fj 71 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019 www.fijifiu.gov.fj 72 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2019