Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697778813260.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 202 2 AN NUAL RE POR T Our Vision: Our Strategic Pillars: 1 Financial Intelligence 2 Preventive Measures 3 Technology Driven Processes 4 Partnerships 5 Our People Our Key Strategies: 1.

Develop and disseminate quality intelligence products for our stakeholders.

2.

Improve the quality and use of our intelligence products.

3.

Promote the understanding of money laundering risks and methods in Fiji.

4.
4.

Promote a risk based implementation of the preventive measures under the FTR Act.

5.

Enhance financial institutions and businesses understanding of their obligations under the FTR Act.

6.

Effectively supervise financial institutions and businesses for compliance with the FTR Act and take appropriate enforcement action in case of non-compliance.

7.

Effective data reporting.

8.

Develop innovative data management systems and analytic tools.

9.

Improve data quality and information security.

10.
10.

Enhance our network for information sharing.

11.

Strengthen relationships with domestic and international partners.

12.

Provide support to international partners on AML/CFT initiatives and engagements.

13.

Cultivate a skilled, motivated and high performing team.

14.

Ensure corporate governance through strong internal controls and performance reporting.
Annual Report Cover Theme The cover design represents the reliance on technology by the FIU in the deliverance of its functions and by financial institutions in their efforts to meet their obligations under Fiji’s anti-money laundering laws.

It also depicts FIU’s financial intelligence as a central information hub for law enforcement agencies in their successful investigation and prosecution of predicate crimes, money laundering offences, and restraining and forfeiture of assets and proceeds of crime.
TABLE OF CONTENTS 2022 ANNUAL REPORT FIJI FINANCIAL INTELLIGENCE UNIT 1 OUR VISION 2 DIRECTOR’S FOREWORD 3 GOVERNANCE STRUCTURE 4 OUR ACHIEVEMENTS Strategic Pillar 1: Financial Intelligence I.

Develop and Disseminate Quality Intelligence Products II.

Improve the Quality and Use of our Intelligence Products III.

Promoting the Understanding of Money Laundering Risks and Methods in Fiji Strategic Pillar 2: Preventive Measures I.

Promoting a Risk-Based Implementation of Preventive Measures II.
Enhancing Financial Institution’s Understanding of their Obligations 2 3 6 8 8 8 14 14 15 16 17 III.

Supervision of Financial Institutions for Compliance with the FTR Act and Appropriate 18 Enforcement Action Strategic Pillar 3: Technology Driven Processes I.

Effective Data Reporting II.

Develop Innovative Data Systems and Analytical Tools III.

Improve Data Quality and Information Security Strategic Pillar 4: Partnerships I.

Enhancing Network for Information Sharing II.


Strengthening Relationships with Domestic and International Partners III.

Provide Support to International Partners on AML/CFT Policy Initiatives and Engagements Strategic Pillar 5: Our People I. Cultivate a Skilled, Motivated and High Performing Team II.
Ensure Corporate Governance 5 EXPENDITURE STATEMENT & NOTES 6 NATIONAL AML COUNCIL 7 APPENDICES 8 SELECTED KEY STATISTICS 2018 - 2022 9 SELECTED KEY EVENTS 2022 STRATEGIC ANALYSIS REPORT 2022 FIJI FINANCIAL INTELLIGENCE UNIT 1 STRATEGIC ANALYSIS OVERVIEW 2 OUTCOMES – SUSPICIOUS TRANSACTIONS REPORTS 3 OUTCOMES – CASH TRANSACTION REPORTS 4 OUTCOMES – THRESHOLD TRANSACTION REPORTS 5 OUTCOMES – ELECTRONIC FUNDS TRANSFER REPORTS 6 OUTCOMES – BORDER CURRENCY REPORTS 7 EMERGING AND CONTINUING MONEY LAUNDERING TRENDS 8 CASE STUDIES 9 GLOSSARY 20 20 23 24 25 25 25 28 29 29 29 31 33 34 37 38 43 44 49 51 52 54 56 57 68 OUR VISION The Financial Intelligence Unit (FIU) is the leading agency in Fiji that is responsible for the prevention and detection of money laundering, terrorist financing and other serious criminal activities.
is established under the Financial The FIU Transactions Reporting (FTR) Act.

The role and functions of the FIU are provided under the FTR Act.

The vision of the FIU is to protect Fiji from money laundering.

The vision of the FIU rests on five strategic pillars representing the five core responsibilities the FIU undertakes to achieve its vision.
The five strategic pillars of the FIU are: • Pillar 1: Financial Intelligence • Pillar 2: Preventive Measures • Pillar 3: Technology Driven Processes • Pillar 4: Partnerships • Pillar 5: Our People The strategic pillars also supports and contributes to the statutory “functions, duties and powers” of the FIU as provided under the FTR Act.

The FIU is modelled as an “administrative FIU” that is currently administered by the Reserve Bank of Fiji (RBF).
The RBF provides funding and general administrative support for the FIU’s operations.

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

The Fiji Police Force (FPF) and the Fiji Revenue and Customs Service (FRCS) provide additional staffing support to the FIU.

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 in successfully investigating and prosecuting money laundering and other serious crimes as well as asset tracing and recovery.

This Annual Report provides information on the FIU’s achievements for 2022 under its five strategic pillars.
FIU Functions and Responsibilities Safety and integrity of Fiji’s financial system Detection, reporting and investigation of suspicious transactions and clients National and international networking and information exchange FINANCIAL INTELLIGENCE UNIT Foreign investors, local business people and ordinary Fijians are protected from illicit financial transactions Contribute to the investigation and prosecution of fraud, corruption, tax evasion and other complex financial crimes Conduct background and due diligence checks Fiji’s compliance with international AML/CFT requirements Implement preventive customer due diligence measures 2 3 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 DIRECTOR’S FOREWORD customers and clients for unusual, potential criminal activities.
The FTR Act and Regulations were amended in 2022 to revise the cash transaction reporting requirements and introduce a new $5,000 threshold transaction reporting the commercial banks.

These amendments further strengthens the mandatory data collected by the FIU.

for Information technology is a critical tool for the FIU and the FIU’s IT capability was further strengthened in 2022.

The “Taipan” project was also rolled out with the assistance of the Australian Government and AUSTRAC, the Australian FIU.
This project supports the FIU’s Strategic Pillar on technology driven processes.

The FIU is placed at the heart of the broader financial surveillance system in Fiji.

The FIU constantly receives and analyses large financial transaction data.
The FIU received over 4 million financial transaction data in 2022 and has in its central database over 25 million reports on CTRs, TTRs, EFTRs and STRs that is used daily by the FIU for financial analysis, investigation and profiling of individuals, entities and their assets.

The FIU participated in a number of key international and regional forums including the Pacific Financial Intelligence Community which is a forum of regional FIUs.
The FIU has witnessed significant changes in Fiji’s AML/CFT landscape under the FTR Act including: i.

Strengthening FIU IT capability; ii.

Data integration; iii.

Strengthen networking with domestic and international partner agencies; and iv.

Enforcement policies and guidelines.

I am pleased to present the 2022 Annual Report of the FIU.

The outcomes in the 2022 Annual Report reflects the important role the FIU plays in the fight against money laundering and terrorist financing in Fiji.
The FIU is the authority in Fiji that is tasked under the FTR Act to collect suspicious transactions and activities reports, analyse and further investigate and profile financial transaction, persons and assets and disseminate intelligence to relevant law enforcement authorities for investigation and prosecution of money laundering and other predicate crimes.
In 2022, the FIU continued to engage closely with financial institutions to ensure that they are implementing the AML/CFT preventive measures as required under the FTR Act.

Due to the FIU’s continued outreach and awareness, there was also an increase in the registration of AML Compliance Officers.
Financial institutions that are often referred as “gatekeepers” of the financial system, monitor their 2 3 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 The FIU will continue to contribute towards building a stronger legal, institutional, operational, networking, and regulatory environment on AML/CFT in Fiji that addresses domestic risk of money laundering and complies with the minimum international standards.
The FIU also exchanges intelligence and information at international level with foreign law enforcement agencies and 166 FIUs.

In relation to the core role of the FIU as the Fijian Government’s central financial intelligence agency, the FIU continued to provide the following to its law enforcement partners, both domestic and international: • Spontaneous Dissemination; • Investigative Support; • Strategic Analysis; and • Due Diligence and Background Checks.
In 2022, the key intelligence outcomes included 519 reports on 1,597 individuals and 276 entities as follows: • 219 intelligence reports on 359 individuals and 13 entities; • 87 investigative assistance and support in relation to 797 individuals and 30 entities; • 82 reports on background checks on 96 individuals and 82 entities; and • 131 DDA searches and assistance on 345 individuals and 151 entities.
The estimated value of transactions suspected to be tainted and linked to predicate criminal offences and tax evasion was $252 million in 2022.

I would like to thank the Governor and Board of the RBF for providing financial and administrative support to the FIU in 2022.

The FIU is also grateful to the Commissioner of FPF and the Chief Executive Officer of the FRCS for continuing to support the FIU with secondment of their officers.
I look forward to the ongoing and even stronger partnership with government agencies, private sector financial institutions, stakeholders, and the National AML Council in achieving our vision of “protecting Fiji from money laundering”.
Razim Buksh Director Financial Intelligence Unit 4 5 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 2022 AT A GLANCE Analysed 559 Suspicious Transaction Reports Engaged with 166 AML Compliance Officers of financial institutions Registered 33 new AML Compliance Officers Managed FIU’s database containing about 26 million financial transaction reports Received 572,269 CTRs in 2022 from 586,382 in 2021 Signed MOA with 2 foreign FIUs 32 MOAs for information exchange with foreign FIUs Disseminated 519 Intelligence Reports to partner agencies 46 Ad-hoc Policy Advisories issued Launched TAIPAN system for data analytics and mining Strengthened the cash transaction reporting framework Integration of bulk births and companies data on FIU’s CMS 573 Enquiries to financial institutions for more information Provided training and awareness to 109 employees of Financial Institutions Efficient operation of online reporting system which received 3,767,615 financial transaction reports Received 2,960,501 EFTRs in 2022 from 2,434,091(r) in 2021 Ongoing staff training and professional development 4 5 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 3 GOVERNANCE STRUCTURE Statutory Agency The FIU is a centralised, independent, administrative and statutory agency of the Fijian Government that was established in 2006 under the FTR Act.
The powers, duties and functions of the FIU are clearly defined in 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 Director FIU on the recommendation of the National AML Council.
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.

The Director is responsible for the preparation and implementation of FIU’s strategic plan, annual work plan and its annual budget.
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 the Director’s powers, duties and functions provided under the FTR Act.

Subsequent to this delegation and on the recommendation of the Governor, the Board of the RBF approved the organisation structure and annual funding of the FIU.
Director of the FIU The Director FIU acts as the Chief Executive Officer and exercises the powers, duties and functions of the FIU as specified in the FTR Act.

The Director Accountability to the Governor The Director FIU meets monthly with the Governor of the RBF and also provides monthly reports on the FIU’s performance and achievement of work plan targets.
The Director of the FIU provides regular progress updates to the National AML Council, Governor and Board of the RBF on key FIU outputs and outcomes against the FIU strategic plan and annual work plan.

The FIU complies with the administrative policies, processes and procedures of the RBF including human resources, IT resources and other policies and processes of the RBF.
FIU GOVERNANCE AND ACCOUNTABILITY FRAMEWORK Minister for Justice Governor and RBF Director FIU National AML Council • 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.
• 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.

• 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 7 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 The National AML Council The National AML 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.
The National AML Council is established under the FTR Act and its members, roles and functions are also provided under the FTR Act.1 Funding and Administration The FIU is fully funded by the RBF and exists independently and separately 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.
from The FIU has been administratively housed within the RBF since 2006.

The FIU is subject to all the administrative protocols, policies and procedures of include procurement, HR management, IT support, risk management, security, office space and financial accounts.

the RBF.

These 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.2 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.

The FIU does not currently receive any direct funding support from the Fijian Government.
Operational Governance The Fiji FIU implements the Egmont Group of International FIUs’ best practices on the following key areas: i. international exchange; cooperation and information ii.

receipt of confidential information; iii.

analysis and intelligence development; iv.

information security; v. compliance and enforcement; and vi.
operational independence and governance Independence and Functional Autonomy of the FIU While the FIU is administratively dependent on the RBF, the technical and core 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 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.

6 7 1 Refer to the section on National AML Council for more information.
2 Refer to the section on Expenditure Statement and Notes for more information.

FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 4 OUR ACHIEVEMENTS Strategic Pillar 1: Financial Intelligence A core pillar of the FIU is to produce high quality financial intelligence for its partners.

The FIU seeks to achieve this by: i. developing and disseminating quality intelligence products; ii.

improving the quality and use of its intelligence reports; and iii.
promoting the understanding of ML risks and methods in Fiji.

Financial intelligence enables law enforcement partners to investigate serious crimes, money laundering (ML) and terrorist financing (TF) activities.

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.

I.
I.

Develop and Disseminate Quality Intelligence Products Develop Intelligence Products In 2022, the FIU received a total of 3,767,615 financial transaction and other reports which are used to develop intelligence products.

These reports consisted of suspicious transaction reports (STR), cash transaction reports (CTR), threshold transaction reports (TTR), and electronic funds transfer report (EFTRs) which are submitted by financial institutions.
The TTR framework came into force in November 2022 and is a reporting obligation applicable only to commercial banks.

The FIU also received border currency declaration reports (BCR) from FRCS.

The FIU relies on technology for its intelligence development.

In 2022, the FIU continued to use the TRAQ system in its intelligence processes.

TRAQ is used by the FIU intelligence analysts to perform profiling of entities or persons of interest.
TRAQ utilises search tag features to identify information regarding specific names, bank accounts, transaction dates, transaction amounts and other relevant transaction details.

The FIU uses its Case Management System (CMS) to centrally store all STR information, case analysis details and dissemination reports.

CMS is used by the FIU to raise queries directly through the system, conduct analysis and automatically generate case dissemination reports and link charts.
CMS also offers certain management functions, such as, the review and approval of STR closures, generation of management reports and system audits for each STR.

The FIU has access to a wide range of information on government databases which enables it to fulfil its analysis function.

As part of its analysis process, the FIU makes enquiries with financial institutions and government agencies.

The queries are aimed at developing further intelligence on information already provided in the STRs.
FIU queries may also be in relation to an ongoing investigation of money laundering and serious offences or proceeds of crime cases.

In 2022, the FIU made 1,639 queries to financial institutions and government agencies for further information to analyse STRs and develop other intelligence products.

Of these, 573 queries were made by the FIU to financial institutions while 1,066 queries were made to government agencies.
Enquiries to financial institutions were related to requests for information on customers such as identification details, transaction details or history, asset details or copies of relevant documents.
8 9 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 FIU Enquiries to Financial Institutions and Government Agencies 2022 573 Queries 1,066 Queries Financial Institutions Government Source: Fiji FIU The FIU is required under Section 25 (1) (e) of the FTR Act to analyse and assess all reports and information received.

In 2022, the FIU analysed 559 STRs.


As a result of this analysis, 322 STRs were filed away for future intelligence reference, 219 case dissemination reports were issued to law enforcement agencies and 18 cases were linked to other cases already disseminated.
STRs Analysed 2022 Analysed 559 Filed Away 322 Disseminated 219 Linked 18 Source: Fiji FIU At the end of the analysis process, the FIU assesses whether the STR and relevant analysis indicates that money laundering or a serious offence maybe taking place.

In some instances the reports or intelligence do not meet the threshold to be disseminated to law enforcement or other agencies and it is “filed away” for future reference.
STRs Filed Away for Future Reference 2018 2019 2020 2021 2022 Number of STRs Filed Away 248 132 372 551 322 Source: Fiji FIU Dissemination of Intelligence Products The FIU disseminates intelligence products spontaneously or upon request from our partner agencies.

Spontaneously disseminated intelligence products are referred to as case dissemination reports (CDR).
Intelligence products disseminated upon request can be used by law enforcement agencies in investigations or by government agencies when assessing the credibility of entities and individuals.

In 2022, the FIU disseminated a total of 519 intelligence products to law enforcement agencies, regulatory bodies, and government ministries.

This is an increase from 399 intelligence products disseminated in 2021.
Intelligence Reports Disseminated 2022 519 Intelligence Products 219 Case Dissemination Reports 300 Intelligence Products Disseminated Upon Request Source: Fiji FIU 8 9 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Case Dissemination Reports Out of the 519 intelligence products disseminated in 2022, 219 products were CDRs to law enforcement agencies.

This is an increase from 174 CDRs disseminated in 2021.
These CDRs were developed directly from STRs received in 2022 and prior to 2022, and contained information on 359 individuals and 13 entities.

Case Dissemination Reports 2022 219 Case Dissemination Reports 359 Individuals 13 Entities Source: Fiji FIU Case Dissemination Reports No.
of CDRs 350 300 250 200 150 100 50 0 321 270 84 219 174 2018 2019 2020 Years 2021 2022 Source: Fiji FIU Case Dissemination Reports to Law Enforcement Agencies Law Enforcement Agency and Reason for Dissemination FRCS-Taxation Division Possible violations under the Income Tax Act and VAT Act.

Fiji Police Force *including Transnational Crime Unit.

Possible violations under the Proceeds of Crime Act and serious offences under the Crimes Act and other relevant laws.
Immigration Department Possible violations under the Immigration Act and Passport Act.

FRCS-Customs Division Possible violations under the Customs Act.

FICAC Possible violations under the FICAC Act and Prevention of Bribery Act Others3 Total Source: Fiji FIU In 2022, 57% of CDRs were disseminated to FRCS while 19% 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.

Based on the CDR dissemination rates for 2022, the top two possible underlying criminal activities identified in the STRs were tax evasion and scams.

3 Other law enforcement agencies include Foreign FIUs and law enforcement agencies (22) and other regulatory bodies (19).
10 11 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Intelligence Products Disseminated Upon Request a) Law Enforcement Information Reports The FIU also provides financial intelligence to law enforcement agencies upon request.
The requests for assistance from the law enforcement agencies are related to investigations of suspected money laundering activities and other predicate offences such as forgery and fraud, drug trafficking, human trafficking, obtaining money by false pretences, cybercrime, larceny and corruption.

The requests may also be related to investigations initiated by a CDR that was disseminated to a law enforcement agency.
In 2022, the FIU disseminated 87 intelligence products that were directly requested by local law enforcement agencies such as the FPF, FICAC, Department of Immigration and FRCS, compared to 82 reports in 2021.

These reports contained information on 797 individuals and 30 entities.
Law Enforcement Information Reports 2022 797 Individuals 87 Law Enforcement Information reports Law Enforcement Agencies Requesting Intelligence 2018 2019 2020 2021 2022 Requesting Agency FICAC Fiji Police Force 28 84 FRCS 113 Immigration Department Others4 25 10 30 85 97 8 2 15 77 26 6 3 6 33 34 3 6 19 55 5 3 5 TOTAL 260 222 127 82 87 Source: Fiji FIU The FIU also assists law enforcement agencies in their own investigations by facilitating the tracing and “temporary suspension” of funds that are suspected to be proceeds of crime that are held within financial institutions.
This is to ensure that the funds are immediately secured while the formal investigations into the suspected criminal activity are underway.

Financial institutions are directed by the FIU to perform enhanced due diligence of the customer, monitor transactions and identify source of funds.

b) Financial Data Reports In 2022, the FIU provided 131 financial data reports on 345 individuals, 151 entities and 190 addresses and phone numbers to law enforcement agencies that requested for financial information.
30 Entities Source: Fiji FIU Prior to April 2021, these reports were accessed directly by approved officers from law enforcement agencies from the FIU database at the FIU office.

The FIU continued to facilitate these requests in 2022.

10 4 Other requesting agencies include the Ministry of Fisheries, Fijian Competition & Consumer Commission, Fiji Corrections Services and Legal Practitioners Unit.
11 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Financial Data Reports 2022 345 Individuals 131 Financial Data Reports Dissemination of Information to Foreign FIUs The FIU also receives information from foreign FIUs.

In 2022, the FIU received 19 foreign information reports from foreign FIUs through the Egmont Secure Web (ESW).

The FIU also sent three requests for information to foreign FIUs through ESW in 2022.
Information Exchanges with Other FIUs 151 Entities 2018 2019 2020 2021 2022 Source: Fiji FIU c) Credibility Check Reports The FIU conducts credibility checks on individuals and entities upon a request made in writing from a government department or authority as provided under section 25.1(m) of the FTR Act.

In 2022, the FIU disseminated 82 credibility check reports compared to 30 reports disseminated in 2021.

The credibility checks were conducted on 96 individuals and 82 entities.
Credibility Check Reports 2022 82 Credibility Check Reports 96 Individuals 82 Entities Source: Fiji FIU Number of requests sent to Fiji FIU Number of requests made by Fiji FIU 13 12 10 5 1 6 19 19 8 3 Source: Fiji FIU Alert & Instruction Notices to Financial Institutions The FIU may, under section 25(1)(h) of the FTR Act disseminate alerts 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.

There were five Alert & Instruction Notices issued by the FIU in 2022.
12 13 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Alert & Instruction Notices Issued 2022 Date Alert Notice Number Issued To Details The FIU issued six such directives in 2022 to financial institutions.
14 January 1/2022 All Commercial Banks Possible Fraud Date Alert Notice Number Issued To Details Directives Issued 2022 1 March 5/2022 All Commercial Banks and Money Remittance Service Providers Possible Advance Fee Fraud 14 April 6/2022 All Commercial Banks and Money Remittance Service Providers Stolen Currency Notice 1 September 10/2022 All Commercial Banks and Money Remittance Service Providers Stolen Currency Notice 9 December 11/2022 All Commercial Banks and Money Remittance Service Providers Stolen Currency Notice Source: Fiji FIU Directives to Financial Institutions The FIU has powers under section 25(1)(h) of the FTR Act to issue enforceable directives to financial institutions.
These directives require financial institutions to take appropriate steps in relation to any information or report received by the FIU and to enforce compliance with the FTR Act or facilitate any investigation anticipated by the FIU or a law enforcement agency.
28 January 2/2022 Mobile Phone Service Provider Enhanced Account Scrutiny 1 February 3/2022 Law Firm Enhanced Account Scrutiny 14 February 4/2022 Commercial Banks Enhanced Account Scrutiny 11 August 7/2022 Commercial Bank Enhanced Account Scrutiny 16 August 8/2022 Commercial Bank Enhanced Account Scrutiny 26 August 9/2022 Commercial Bank Enhanced Account Scrutiny Source: Fiji FIU The Alert & Instruction Notices and directives are enforceable instructions of the FIU and must be implemented by the financial institutions.
12 13 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 II.

Improve the Quality and Use of our Intelligence Products The FIU engaged closely with its law enforcement partners with the aim of improving the quality and use of its intelligence products.

system was launched in November 2022 and is currently undergoing parallel testing.

In 2022, the FIU held an annual meeting with the Chief Justice for the first time.
This meeting was held in addition to the regular annual meetings with the Commissioner of FPF, CEO FRCS, Director Immigration Department and Commissioner FICAC.

The meetings were aimed at improving our understanding of the intelligence needs of our law enforcement partners and explaining how the FIU’s intelligence products may meet their needs.

In 2022, the FIU installed the Taipan system.

The ingests structured FIU data, system securely analyses and sorts the data into simple search formats.
The data is also displayed on interactive dashboards for easy analysis and distribution.

The The FIU periodically provides feedback to financial institutions and other relevant agencies regarding outcomes to the reports or information given under the FTR Act.

In 2022, the FIU provided six feedback reports and held six meetings with the commercial banking sector.

The reports and meetings provided feedback on the outcomes of STRs and other reports submitted to the FIU.
The FIU also met with mobile phone service providers to strengthen engagement and provide feedback to the sector to enhance their compliance with the FTR Act.

The FIU also provided feedback to the money remittance service providers during their sector training in 2022.

III.
III.

Promote the Understanding of Money Laundering Risks and Methods in Fiji Review of Risks for the Banking and Remittance Sector Fiji is required under the international AML/CFT standards to identify, assess and understand the money laundering, terrorist financing and proliferation financing risks that it faces.

This means that Fiji must undertake a national assessment of these risks.

review of the ML/TF risks of the banking sector in Fiji.
Information on ML/TF risk was collected from banks and other sources and analysed during the year.

This project will continue in 2023.

The 2022 Strategic Analysis Report is included in the Strategic Analysis section of this Annual Report.

Fiji conducted its first ever national ML/TF risk assessment in 2015.
In 2022, the FIU continued its 14 15 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Strategic Pillar 2: Preventive Measures The FIU seeks to promote a safe and sound financial system to prevent or detect money laundering and terrorist financing activities.
The FIU does this through three broad strategies as follows: a) promoting risk-based implementation of preventive measures under the FTR Act; b) enhancing financial institution’s understanding of their obligations under the FTR Act; and c) effectively supervising financial institutions and taking appropriate enforcement action as needed.
Entities and businesses that are required to comply with the requirements of the FTR Act include: i. financial institutions such as, commercial banks, insurance companies and intermediaries, finance companies, money remitters, money changers, investment advisors, brokers and dealers, unit trust or managed funds, mobile phone money remitters; and ii.

other DNFBPs, such as, accounting firms, legal practitioners, 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.
Financial Institutions under the FTR Act Commercial Banks (6) Finance & Credit Companies (13) Real Estate Agents (89) Legal Practioners (173) Accountants (22) Financial Institutions under the FTR Act Insurers and Insurance Brokers (14) Superannuation Fund (1) Foreign Exchange Dealers and Money Remitters (10) Mobile Phone Money Remitters (2) Stock Exchange (1) Capital Market Intermediaries (13) 14 15 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 I.
Promote a Risk-Based Implementation of Preventive Measures The requirements in the FTR Act, commonly referred to as “preventive measures” are based on international AML/CFT standards, the FATF Recommendations.

Financial institutions can implement these preventive measures on a risk-based approach.
The FIU promotes a risk-based implementation of the FTR Act by: • providing clear guidance on the preventive measures and requirements of the FTR Act through the issue of Guidelines and policy advisories; • • training and ongoing awareness; industry/sector focussed AML/CFT forums and training webinars; and • ongoing engagement with financial institutions to assist them on how they can implement these preventive measures on a risk-based approach.
Enforceable Guidelines and Policy Advisories In 2022, the FIU continued to provide financial the institutions with advice and guidance on requirements under the FTR Act and Regulations.

The FIU has issued nine Enforceable Guidelines to date which provides detailed guidance on the key requirements under the FTR Act.

The FIU has issued 20 Policy Advisories to date which provides clarification on interpretation of certain requirements of the FTR Act.
The Guidelines and Policy Advisories are accessible on the FIU’s website.

The FIU also provides policy advice on an ad-hoc basis, as and when requested by financial institutions.

In 2022, the FIU issued 62 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.
Ad-hoc Policy Advisories Issued by FIU 2022 Nature of Advisory Customer Due Diligence Requirements The FIU provides advisories and guidelines aimed institutions gain a better at helping financial understanding of their obligations.

Transaction Reporting Requirements Other Issues (FIU Alert Notices, role of compliance officer, AML developments) During 2022, the FIU revised three Enforceable Guidelines to incorporate the revision to the cash transaction reporting requirements.
TOTAL Number of ad-hoc Policy Advisories Issued 13 35 14 62 Source: Fiji FIU FIU Enforceable Guidelines Revised 2022 Guideline Revised FIU Enforceable Guideline 3 on Reporting of Cash Transactions 5,000 and above 1 November 2022 FIU Enforceable Guideline 8 on AML Compliance Obligations of Real Estate Agents or Businesses.

FIU Enforceable Guideline 9 on Obligations of Legal Practitioners under the FTR Act & Regulations.
1 November 2022 1 November 2022 Source: Fiji FIU New Cash Transaction Reporting Requirements and Introduction of Threshold Transaction Reporting In 2021, the FIU conducted a review of the cash transaction reporting requirements as specified in the FTR Act.

The review included consultations with financial institutions.

The review was finalised in early 2022.


In late 2022, the FTR Act and Regulations were amended to revise this cash transaction reporting 16 17 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 requirements.
As a result of this amendment to the FTR Act and Regulations, from 1 November 2022 a revision to the cash transaction reporting framework was implemented as follows: a) commercial banks are required to report all transactions of $5,000 and above (referred to as a Threshold Transaction Report); b) all non-bank financial institutions are required to report cash transactions of $5,000 and above (referred to as a Cash Transaction Report).
The FTR (Amendment) Regulations 2022 also provides for a new Threshold Transaction Report form and a simplified CTR form that will be now used by the respective reporting entities.

these The FIU also revised three existing Guidelines to reflect these revisions in the cash transaction reporting requirements.

The Guidelines were aimed at providing detailed guidance to financial institutions on reporting transactions.
The FIU also provided awareness notices and briefings to financial institutions to raise awareness on these revised transaction reporting requirements and facilitate the implementation of these new requirements.

requirements revised for II.


Enhance Financial Institution’s Understanding of their Obligations The FIU promotes awareness and understanding of the FTR Act requirements through issuance of guidelines and advisories, targeted training and regular engagements with financial institutions through sector-based forums and meetings.

Engagement with Financial Institutions In 2022, the FIU held annual meetings with the heads of commercial banks and the two mobile phone money remitters in Fiji.
These annual meetings were aimed at engaging with senior management of these key financial institutions to discuss high level regulatory and compliance issues and to update them of upcoming FIU policy projects.

The FIU also had engagements and meetings with financial institutions one-on-one as needed during the year.
In 2022, the FIU held one virtual induction briefing for new AML Compliance Officers, a training webinar for the money remittance service providers sector and a face-to-face dialogue with the banking sector.

A total of 43 new AML Compliance Officers registered with the FIU in 2022.

The FIU engaged with the new AML Compliance Officers to educate them of their role and responsibilities.
Training and Awareness Programme In 2022, the FIU provided training and awareness programmes which were attended by a total of 109 employees.

The training covered the financial institutions’ obligations under the FTR Act and Regulations.

Engagement with AML Compliance Officers As at 2022, there were 166 AML Compliance Officers registered with the FIU.
Training and Awareness Programme 2022 Training and Awareness Number Attended The FIU continued to engage closely with the AML Compliance Officers of financial institutions during 2022 through sector trainings and one-on-one meetings and liaisons.

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.
Induction Briefing for new AML Compliance Officers (virtual) AML/CFT Training Webinar for the Money Remittance Service Providers including the Mobile Phone Money Remitters Dialogue with the Banking Sector (face-to- face) Total Employees Attended 60 38 11 109 Source: Fiji FIU 17 16 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 During 2022, the FIU continued its engagement with the real estate and legal sectors to enhance industry level awareness and compliance.
reporting requirements and the introduction of the threshold transaction reporting requirement.

The FIU also provided regular updates to all financial institutions on the revisions to the cash transaction The FIU also used its website to promote awareness of the requirements of the FTR Act including new initiatives, guidelines and policies issued by the FIU.

III.
III.

Supervise Financial Institutions for Compliance with the FTR Act and Take Appropriate Enforcement Action Supervision of Financial Institutions The FIU and RBF are required under the FTR Act to supervise financial institutions’ compliance with the FTR Act and Regulations.

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

Banking Act 2.

Exchange Control Act 3.


Companies Act 4.

Insurance Act 5.

National Payment Systems Act FIU Other Financial Institutions not under the supervision of the RBF 1.

Accountants 2.

Legal Practitioners 3.

Real Estate Agents or Businesses 4.


Other Financial Institutions Source: Fiji FIU Supervision of financial institutions for compliance with their obligations under the FTR Act and Regulations is undertaken by the FIU through a combination of onsite examination and offsite monitoring programmes.

The FIU’s Alert Monitoring System (AMS) was used to monitor financial institutions offsite on a weekly basis for their compliance with requirements to report CTRs and EFTRs to the FIU.
The weekly AMS reports were analysed by the FIU to identify breaches of the 5-day reporting obligation.

The FIU’s intelligence management team, during their analysis process also identified cases of possible non-compliance by financial institutions.

These included: i. data reporting quality issues; ii.

FIU alert & instruction notice breaches; and iii.

possible CTRs not reported to the FIU.

These cases were subject to internal enforcement processes by the FIU compliance team.
The FIU also relies on the onsite supervision programme of the RBF to assess the compliance of RBF licensed financial institutions with the FTR Act and Regulations.

These financial institutions include insurance companies and commercial banks, brokers, credit and finance companies, restricted foreign exchange dealers and money changers, mobile phone money remitters and capital markets.
During 2022, the FIU and RBF conducted joint on- site AML/CFT compliance examinations of two 18 19 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 restricted foreign exchange dealers at their relevant branches and offices in Sigatoka, Nadi, Lautoka, Ba, Tavua and Korovou.

non-compliance letter with regards to its EFTR reporting.

The financial institution worked with the FIU to rectify this non-compliance issue.
The FIU also provided policy advice to RBF supervisors as and when needed on AML/CFT compliance issues.

Appropriate Enforcement Action Enforcement tools are applied to ensure compliance by financial institutions with the FTR Act, FTR Regulations instructions, guidelines and directives issued by the FIU.
The FIU may undertake enforcement actions such as criminal/civil actions, administrative monetary penalties and other remedial measures to ensure that financial institutions comply with the law and other regulatory instruments.

The legal basis for applying enforcement action is provided under the FTR Act and FTR Regulations.

The following enforcement actions were undertaken by the FIU in 2022: 1.
In 2022, the FIU identified four money remittance service providers who breached the FIU Alert & Instruction Notices.

They were subjected to the enforcement process of the FIU and the matter was resolved by the reporting entities.

2.

Financial institutions are required to report their CTRs and EFTRs within 5 working days from the date of transaction.

During 2022, there were 16 breaches of the 5-day transaction reporting requirement.
The FIU addressed these breaches by immediately issuing notifications to the respective financial institutions to rectify the breaches.

In most of the cases, the financial institutions were able to rectify the breach within a reasonable time.

In 2022, there was an ongoing matter with one financial institution who was issued a formal Reporting Requirement Non-Compliance Reporting Requirement Non- Compliance No.

of breaches of the 5 days reporting requirement No.
of formal non- compliance letters/ correspondences issued 2018 2019 2020 2021 2022 28 23 30 21 16 8 2 2 2 1 Source: Fiji FIU 3.

As part of continuous data quality improvement, the FIU reviews the reports submitted by financial institutions to identify data quality issues and ensure that fields (especially mandatory fields) in the transaction reports are completed accurately.
Any data quality issues, once identified, is registered and communicated immediately by the FIU to the relevant financial institution for its necessary action.

In 2022, the FIU identified 19 data quality issues.

These related to CTRs or EFTRs submitted by financial institutions with incomplete or incorrect information.

The cases were subjected to the FIU’s enforcement processes and the issues were resolved by the relevant financial institutions within reasonable time.
18 19 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Strategic Pillar 3: Technology Driven Processes A core pillar of the FIU is to implement technology driven processes in the performance of its functions.

This is achieved by the following strategies: i. effective data reporting; ii.

developing innovative data management systems and analytic tools; and iii.

improving data quality and information security.

I.
I.

Effective Data Reporting The FIU’s Information Management System Online (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 in Fiji to securely and electronically submit financial transaction reports to the FIU.

In 2022, the FIU received a total of 3,767,615 financial transaction and other reports.

These reports consisted of STRs, CTRs, TTRs, EFTRs, and BCRs.
ODDS received an average of 313,968 financial transaction reports per month in 2022.

Financial Transaction Reports Received 2018 2019 2020 2021 2022 STR 632 622 736 261 435 Financial Transaction Reports Held on the FIU Database EFTR CTR TTR STR5 BCR Total 17,986,064 7,406,757 233,770 10,003 7,756 25,644,350 Source: Fiji FIU Suspicious Transaction Reports The FIU received 435 STRs6 in 2022 or an average of 36 STRs per month compared to 239 STRs received in 2021.
CTR 968,693 794,044 619,987 586,382 572,269 Suspicious Transaction Reported TTR 0 0 0 0 233,770 EFTR 1,357,246 1,515,681 1,866,197 2,434,091(r ) 2,960,501 BCR 969 1,102 266 99 640 TOTAL 2,327,540 2,311,449 2,487,186 3,020,833(r) 3,767,615 Monthly Total Average Source: Fiji FIU 193,962 192,621 207,266 251,736 (r) 313,968 As at 2022, the FIU had a total of 25,644,350 financial transaction reports and BCRs on its database which formed the basis of the FIU’s intelligence process.

No.
No.

of STRs 800 700 600 500 400 300 200 100 0 736 632 622 435 261 2018 2019 2020 2021 2022 Years Source: Fiji FIU 5 Includes 1,145 STRs that were reported between 2000 – 2005 under section 61 of the Proceeds of Crime Act.

6 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.

20 21 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 About 80% of STRs were received electronically via ODDS.
The remaining 20% of STRs were reported via email or hardcopy reports that were later converted into digital format on ODDS.

STRs are reported manually through an online form on ODDS.

The STRs from ODDS are then transferred to TRAQ which is an internal application used for analysis by the Intelligence Management team.

The STRs from TRAQ are automatically curated in a particular format and uploaded to CMS.
Cash Transaction Reports The FIU received 572,269 CTRs in 2022 or an average of around 47,689 CTRs per month.

This is a decrease of 2% compared to 586,382 CTRs received in 2021.

Cash Transactions Reported No.

of CTRs 1,200,000 1,000,000 968,693 794,044 619,987 586,382 572,269 800,000 600,000 400,000 200,000 0 reporting system.

The FIU also has a batch reporting specification document for EFTRs.

Threshold Transactions Reports In November 2022, commercial banks commenced reporting of TTRs to the FIU.
These are reports of all transactions of $5,000 and above conducted by bank customers.

The FIU received 233,770 TTRs between November and December 2022 or an average of around 116,885 TTRs per month.

Majority of the TTRs were batch reported on ODDS by commercial banks.

Electronic Funds Transfer Reports The FIU received 2,960,501 EFTRs in 2022 or an average of around 246,708 per month.

This is an increase of 22% compared to 2,434,091 EFTRs received in 2021.
Total EFTR for 2021 has been revised due to submission of back-dated EFTRs during 2022 as part of the FIU’s reporting compliance and data quality process.

Majority of the EFTRs were batch reported on ODDs and less than 1% of EFTRs were reported through the online data entry form.

Electronic Funds Transfer Reported 2018 2019 2020 2021 2022 Years Source: Fiji FIU About 99% of CTRs were batch reported on ODDS by financial institutions and 1% were reported manually via the online data entry form on ODDS.
The batch reporting of transactions is more efficient for large volumes of CTRs and it eliminates the risk of a human error during data entry.

No.
No.

of EFTRs 3,500,000 3,000,000 2,500,000 2,000,000 1,500,000 1,357,246 1,000,000 500,000 0 2,960,501 2,434,091 1,866,197 1,515,681 The FIU provides a CTR batch reporting specification document to the FIs which provides guidance to their IT team to develop an in-house batch 2018 2019 2020 2021 2022 Years Source: Fiji FIU 20 21 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Border Currency Reports In 2022, the FIU received 640 BCRs compared to 99 BCRs received in 2021.
The substantial increase in BCRs received is due to the significant increase in the number of travellers into and out of Fiji following the lifting of the COVID-19 travel restrictions in Fiji and globally.

ODDS Registration Sector Commercial Banks Foreign Exchange Dealers & Money Remitters Mobile Phone Money Remitters The BCRs are collected by FRCS at the border and sent to the FIU for inputting into ODDS.

Border Currency Declarations No.


of BCRs 1,200 1,000 969 1,102 800 600 400 200 0 2018 2019 640 266 2020 Years 99 2021 2022 Source: Fiji FIU ODDS Online Users At the end of 2022, 168 financial institutions were registered to use ODDS.

ODDS was accessed by 117 authorised individual users, 7,668 times during 2022.

The FIU continued to provide support and training to financial institutions on their use of ODDS to report transactions to the FIU.

No.
No.

of Reporting Entities Registered for Online Reporting to the FIU 6 11 2 12 72 14 11 3 26 1 10 168 Source: Fiji FIU Finance Companies Legal practitioners Insurance & Superannuation Accounting Firms Securities and Brokers Real Estate Agents Money Lenders Others TOTAL Financial Transaction Data At the end of 2022, ODDS had received about 26 million financial transaction reports in its database since on-line reporting commenced in 2008.
Total Number of Financial Transaction Reports Received 10,003 STRs received from all reporting financial institutions 7,406,757 CTRs received from all reporting financial institutions 233,770 TTRs received from the commercial banks 17,986, 064 ETRs received from the com- mercial banks, money remittance service providers and mobile phone money remitters 7,756 BCRs received from FRCS FIU ODDS Received about 26 million financial transaction reports since 2008 Source: Fiji FIU 22 23 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 II.
Develop Innovative Data Management Systems and Analytic Tools Transaction Query System The FIU continued to use TRAQ in its intelligence process to perform profiling of entities or persons of interest.

It is the central repository for about 26 million financial transaction reports and BCRs received from financial institutions and FRCS respectively.
the ongoing maintenance and During 2022, support for TRAQ was crucial to ensure that the FIU intelligence team is able to effectively analyse the STRs received.

TRAQ was accessed by 13 FIU officers and 7 direct database access (DDA) officers in 2022.

DDA officers are officers from partner law enforcement agencies that are authorised to access TRAQ.

TRAQ was accessed 2,038 times by the FIU officers and 41 times by DDA officers during 2022.
FIU Alert and Monitoring System The FIU continued to use its AMS which monitors all financial transaction reports maintained on the FFIMSO database for identifying suspicious transactions.

Currently, AMS has 11 suspicious indicator rules which runs in the background.

Alerts are generated and emailed to the intelligence team for further analysis and profiling.

FIU Case Management System The FIU continued to use its CMS for managing STRs and CDRs.
CMS centrally stores all STR information, case analysis details and dissemination reports.

CMS also generates templates for case dissemination reports and link charts.

During 2022, there was ongoing support provided to ensure the effective operation of CMS.

Taipan Project In 2021, Australian Transaction Reports and Analysis Centre (AUSTRAC) formally engaged with Fiji FIU on a project to strengthen Fiji FIU’s information technology infrastructure.
The project aimed to develop a modern FIU platform called Taipan to enhance the collection, analysis and exchange of financial intelligence.

In 2022, Fiji FIU continued to work with AUSTRAC to identify the project scope, deployment process, security requirements, governance and testing of Taipan.

In April 2022, AUSTRAC visited the FIU to conduct a scoping visit and provide training and a demonstration of the Taipan system to the FIU and RBF project team.
Taipan IT Project Team from left to right: Mr Brian Giffney (AUSTRAC), Mr Kritesh Bali (FIU), Mr Lawrence Chandra (FIU) and Mr Ron Macpherson (AUSTRAC) In July 2022, AUSTRAC undertook a second visit to the FIU to deploy the Taipan software on the FIU IT environment.

The deployment process included installation and configuration of the Taipan software packages on the production environment, migration of FFIMSO data on to Taipan, and testing.
22 23 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 The FIU Intelligence team started parallel testing of Taipan after its deployment in July 2022 to ensure the system meets the FIU requirements and standards.

The Taipan system was formally handed over to the FIU in late 2022.

STR Process Automation In 2022, Fiji FIU continued to use rule based process automation on FFIMSO to provide preliminary summary analysis of STRs for users.
Information on the STR are run against FFIMSO data and matched against pre-defined rules and thresholds.

If the results did not meet these thresholds, they were filed away for future analysis.

If the results meet these thresholds, the STRs were assigned to an analyst for further analysis.

This process automation also contributes to the priority classification of all incoming STRs as it provides a quick preliminary summary analysis of FFIMSO data.
Remote Access to TRAQ for Partner Agencies and Direct Database Access In 2022, Fiji FIU continued work in exploring a secure remote access to TRAQ by FIU partner agencies.

Allowing remote access to TRAQ will enable FIU partner agencies to access FIU information in a secure, convenient and timely manner.

The FIU currently has 60 authorised DDA officers and they conduct large volumes of TRAQ searches for analysis and profiling purposes on FIU premises.

III.
III.

Improve Data Quality and Information Security Technology Solutions to Improve Data Quality The FIU employs controls which monitors the quality of data provided in financial transaction reports submitted by financial institutions on ODDs.

Data quality issues are quickly identified by FFIMSO and raised with financial institutions for correction to the reports.
Furthermore, the FIU continued to work with financial institutions to ensure that their CTR, EFTR and TTR reporting solutions adequately meet the minimum standards for reporting.

During 2022, the FIU worked closely with commercial banks to implement systems that would enable them to report the TTRs as required.

This will continue into 2023.

Access to Government Databases The FIU currently has direct online access to nine databases of partner government agencies.
These databases provide crucial information to the FIU intelligence development process.

In 2022, the FIU completed work on the acquisition of bulk Births and Registrar Of Companies (ROC) data from Digital Fiji.

The FIU developed an extraction process to download the bulk Births and ROC data from Digital Fiji’s secure Data Exchange Platform and upload this bulk data onto the FIU’s CMS.
The integration of the bulk Births and ROC data on CMS enabled the FIU Intelligence team to conduct efficient searches during its profiling, analysis and intelligence development process.

It also enabled the FIU to create links and relationships with existing data on CMS to profile entities.
Cyber Security and Cyber Risks In 2022, as part of ongoing cybersecurity measures the FIU conducted weekly cybersecurity scans on FFIMSO which flags any critical vulnerabilities and threats against potential cyber-attacks.

The FIU also benefitted from the cybersecurity protocols and measures employed by the RBF.

The FIU’s cybersecurity strategy is aimed to mitigate the risk of cyber-attacks and protect against unauthorised exploitation of FFIMSO.
24 25 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Strategic Pillar 4: Partnerships Collaboration with its partners is crucial for the FIU functions and it seeks to achieve this through three broad strategies as follows: i. enhancing its network for information sharing; ii.

strengthening relationships with domestic and international partners; and iii.

providing support to international partners on AML/CFT initiatives and engagement.

I.
I.

Enhance our Network for Information Sharing The FTR Act provides the FIU with the authority 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 14 local partner agencies to date.

As a result of these MOAs, the FIU is able to directly access nine databases of government partner agencies.

The FIU continued to engage with these partner agencies during 2022.
Refer to Appendix 1.

As part of these MOA arrangements, authorised officers from the FPF, FRCS, FICAC and RBF continued to have direct access to the FIU’s central database or TRAQ.

In 2022, there were 60 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 and profiling.
Two officers from FRCS and one officer from FPF continued to be seconded to the FIU in 2022 as provided under the MOA arrangement.

During 2022, the FRCS extended the secondment period for their two officers to three years.

Secondment Officers for 2022 from left: Shivnit Chand (FRCS - Tax), Alisi Faivakibau (FRCS - Customs) and CPL Lanieta Ranavono(FPF) II.
Strengthen Relationships with Domestic and International Partners Engagements with Domestic Partners During 2022, the Director FIU held annual meetings with the Heads of key partner agencies such as the FPF, FICAC, FRCS, Immigration Department and the Judiciary.

These meetings were aimed at discussing common issues and topics for collaboration and networking between agencies.
The FIU continued to contribute to national policy formulation, implementation and coordination through participation in various national committees such as Interagency National Trafficking Committee, Digital Financial Services Working Group and the Cyber Security Working Group.

the The FIU also made submissions to the Parliamentary Standing Committee on Foreign Affairs and Defence on the Convention on Cybercrime.
National AML Council In 2022, the FIU continued to support the work of the National AML Council as a member and secretariat.

There was one meeting of the National AML Council in 2022.

(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 2022.
24 25 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 The FIU provided high level updates to the Council on key issues, such as, the updates on Fiji’s compliance with the FATF Recommendations.
The FIU 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, financial sanctions relating to terrorist financing and proliferation financing and extradition.

The FIU also coordinated the compilation of Fiji’s sixth Follow-Up-Report to the APG.
through Engagements with International Partners The FIU engages closely with various international partners its membership of various international forums, working groups and taskforce.

Refer to Appendix 2.

Through its memberships of these international forums, working groups and taskforce, the FIU is able to exchange information and contribute to international AML/CFT policy formulation and projects.
Asia Pacific Group on Money Laundering Fiji is a member of the APG, an autonomous and collaborative international organisation currently comprising 41 member countries.

The FIU, as the designated lead agency for Fiji, liaised closely with the APG in 2022 on various national outputs, APG governance and other policy and mutual evaluation matters including the submission of Fiji’s sixth Follow-Up-Report.
During 2022, the FIU participated in the following key APG activities: i. participated in various APG surveys and contributed to discussion papers; ii.

Mutual Evaluation Committee meetings and discussions on mutual evaluation reports and FURs of APG members; and iii.

Project Team discussions on key issues affecting the APG membership.

The FIU continued to liaise with the APG on various AML/CFT issues relevant to Fiji during the year.
Pacific Financial Intelligence Community The FIU is a founding member of the Pacific Financial Intelligence Community (PFIC) which is a regional body consisting of FIUs from the South Pacific region including Australia and New Zealand.

The PFIC held its first meeting in 2021.

The PFIC provides a forum for Pacific FIUs focused on operational outcomes and other issues of specific interest to the Pacific region.
PFIC encourages multilateral and bilateral collaboration across the region on issues of mutual priority through the regular dialogue and engagement between members that it provides.

In 2022, PFIC held its inaugural face-to-face plenary in Port Moresby in Papua New Guinea.

The FIU continued to contribute to the discussions and decisions of PFIC and its Working Groups in 2022.

As a member of PFIC, the FIU chairs the PFIC’s Operational Working Group and is a member of the Research Working Group.
Pacific Financial Intelligence Community Plenary, Port Moresby, Papua New Guinea, November 2022 26 27 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Egmont Group is a The Fiji FIU member of the Egmont Group of FIUs.

The Fiji continued to participate in the activities of the Egmont Group during 2022.

This included contributing to Egmont surveys conducted during the year, reviewing and providing comments on Egmont governance papers, projects and questionnaires.
FIU As a member of the Egmont Group of FIUs, the Fiji FIU is committed to sharing information with 166 other Egmont Group members.

During 2022, the Fiji FIU continued to provide assistance and information to other Egmont Group members upon request via the ESW.

The FIU is also a member of the Egmont Group’s Membership Support and Compliance Working Group and Asia and Pacific Regional Group.
AUSTRAC In 2022, the FIU continued to benefit from its engagement with AUSTRAC through sharing of AML/CTF information and intelligence.

AUSTRAC successfully installed and launched the Taipan system for the FIU.

The system was formally handed over by AUSTRAC to FIU in late 2022.

AUSTRAC provided valuable intelligence based trainings for FIU staff in 2022.

These trainings consisted of virtual and face-to-face trainings.
This included the Pacific Financial Intelligence Analyst Course which was fully funded by AUSTRAC.

Memorandum of Agreements with Foreign FIUs The FIU is authorised under the FTR Act to 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.
These MOAs allow for a more formal engagement with international FIUs and partners on AML/CFT matters.

In 2022, the FIU signed two MOAs for the exchange of information with the FIUs of Timor Leste and Lao People’s Democratic Republic.

The FIU has signed MOAs with 32 foreign FIUs to date.

Refer to Appendix 3.
Signing of the MOA with The Unidade de Informação Financeira of Timor Leste, Kuala Lumpur, Malaysia, 25 July 2022 Taipan System Handover Ceremony, October 2022 Signing of the MOA with The Anti-Money Laundering Intelligence Office, National Coordination Committee For Anti-Money Laundering And Counter-Financing Of Terrorism Of The Lao People’s Democratic Republic, Kuala Lumpur, Malaysia, 26 July 2022 26 27 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Pacific AML/CFT Supervisors Forum The FIU is a member of the Pacific AML/CFT Supervisors Forum which consists of AML/ CFT supervisors from the Pacific including New Zealand and Australia.
The Forum provides a platform for supervisors to share their experiences and challenges on AML/CFT supervision in their respective jurisdictions.

The FIU participated in the meetings of the Forum in 2022.

III.

Provide Support to International Partners on AML/CFT Policy Initiatives and Engagements Fiji Mutual Evaluation - Progress Update Fiji’s 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.

Since 2016, and as a result of Fiji’s annual FUR from 2017 - 2021, the APG has upgraded Fiji’s compliance ratings for 17 FATF Recommendations to a “largely compliant” or “compliant” ratings (from the initial 2016 ratings as either a non-compliant or partially compliant rating).
Fiji submitted its sixth FUR in October 2022.

Fiji is in the process of addressing the remaining deficiencies in the FATF Recommendations.

The FIU as the secretariat to the National AML Council has been the key agency in coordinating the preparation of Fiji’s annual FURs since the 2016 MER was published.
28 29 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Strategic Pillar 5: Our People The FIU endeavours to enhance the potential of its people and governance processes by: i. cultivating a skilled, motivated and high performing team; and ii.

ensuring corporate governance through strong internal controls and performance reporting.
I. Cultivate a Skilled, Motivated and High Performing Team Professional Development of Staff During the year FIU staff attended various training workshops and technical forums as part of professional development of staff.

The trainings were provided virtually and face-to-face by various partners such as APG, AUSTRAC and UNODC.

Staffing As at the end of 2022, the FIU had nine permanent staff and three officers on secondment from partner agencies (one FPF officer and two FRCS officers).
FIU Organisation Structure 2022 Director FIU Manager Intelligence Management Manager Policy & Compliance Manager IT Management (vacant) Administration Intelligence Analyst (2) Policy & Compliance Analyst (1) Senior Systems Analyst (1) Senior Secretary Intelligence Anayst (Seconded from FPF) Intelligence Analyst (seconded from FRCS Customs) Intelligence Analyst (seconded from FRCS Tax) Systems Analyst (1) HR and other Support (provided by RBF) Source: Fiji FIU 28 29 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 II.
Ensure Corporate Governance Governance The FIU continued to provide monthly reports on its operations to the Governor of the RBF and the Chair of the National AML Council.

The FIU also provided regular updates to the Chair of the National AML Council on key AML/CFT national initiatives and projects.

The Fiji FIU fully implements the Egmont Group key governance instruments, namely the Egmont Charter, Operation Guidance, Principles of Information Exchange and Support and Compliance Process.
The FIU also implements the requirements of the international standards relating to financial intelligence units (Financial Action Taskforce Recommendation 29 and its Interpretive Note, Recommendation 40 and Immediate Outcomes 2, 3, 4 and 6).

These ensure that the FIU’s operations are in line with international best practice.

Communication and Media The FIU uses the media and its website to communicate key AML/CFT initiatives to the general public and its stakeholders.
The FIU revamped its website 2022 with the aim of making the website more user friendly and up-to-date.

In 2022, the FIU issued three media releases and held two interviews with the media on key AML/CFT issues.
Summary of Media Releases 2022 Date Issued Title 1 September 2022 Review of CTR Reporting Framework under the FTR Act 19 October 2022 Launch of TAIPAN 30 September 2022 Cryptocurrency Scam Alert Source: Fiji FIU 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 2022.

The salaries of the seconded officers were fully funded by their respective agencies.
30 30 31 31 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 5 EXPENDITURE STATEMENT & NOTES The RBF also provided other administrative support services to the FIU in 2022 in the areas of human resource management, accounting, information technology services, security services and other general administrative services.

The RBF continued to fund the operations of the FIU in 2022.

The FIU’s total expenditure for 2022 was $910,000 compared to $781,000 in 2021.
The expenditure of the FIU is incorporated into the financial statements of the RBF and is audited as part of its annual accounts.
Fiji Financial Intelligence Unit Statement of Expenditure For the year ended 31 December 2022 Expenses Salaries & wages Meetings IT expense Consultancy Insurance Printing, publications & stationery Other expenses Total expenses Note 31 December 2022 31 December 2021 $ $ 823,000 16,000 25,000 24,000 6,000 9,000 7,000 730,000 2,000 17,000 21,000 6,000 2,000 3,000 910,000 781,000 The statement of expenditure has been audited up to 31 July 2022.
The figures from 1 August 2022 to 31 December 2022 will be audited as part of the financial statement of the RBF in 2023.

30 30 31 31 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Fiji Financial Intelligence Unit Notes For the year ended 31 December 2022 1.

Salaries & Wages The total staff costs amount to $823,000 (2021: $730,000) for the year ended 31 December 2022.

The staff costs capture the total remuneration paid to the employees of the Financial Intelligence Unit.
The two – year salary freeze agreement with the union expired in 2022 resulting in resumption of rewards and recognition (R&R) program, reintroduction of merit bonuses and PWC market adjustment resulted in higher staff cost in the current financial year.

2.

Meetings Overseas Local 31 December 2022 $ 31 December 2021 $ 14,000 2,000 16,000 - 2,000 2,000 Courses, meetings and seminars cover the costs of attending local and overseas courses, conferences, meetings and trainings.
Re-opening of the country borders in 2022 resulted in the higher current year’s expenditure.

3.

IT Expense Licenses and maintenance Internet 31 December 2022 $ 31 December 2021 $ 24,000 1,000 25,000 16,000 1,000 17,000 The computer costs are for the annual maintenance and licensing costs for the Financial Intelligence Unit’s databases and the internet-related charges.

4.

Consultancy The consultancy cost amount to $24,000 (2021: $21,000) for the year ended 31 December 2022.
The cost includes the Financial Intelligence Unit’s databases subscription fees for intelligence gathering and membership to the Egmont Group.

5.

Insurance The insurance costs which amount to $6,000 (2021: $6,000) relate to the term life cover that is provided to the employees of the Financial Intelligence Unit.

6.
6.

Printing, Publications & Stationery Printing and Publication Public Relations 31 December 2022 $ 31 December 2021 $ 8,000 1,000 9,000 1,000 1,000 2,000 The printing, publications and stationery capture the cost of printing the Financial Intelligence Unit’s annual and border currency reports, publications and public relation materials.

7.
7.

Other Expenses Communication Advertising and General Expense 31 December 2022 $ 31 December 2021 $ 2,000 5,000 7,000 1,000 2,000 3,000 The other expenses amounted to $7,000 for the financial year ended 31 December 2022 (2021: $3,000).

32 32 33 33 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 6 NATIONAL AML COUNCIL The National AML Council is established under Section 35 of the FTR Act and is Fiji’s national AML/ CFT coordination committee.
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 prevention of money laundering or the financing of terrorism; 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.
The members of the National AML Council are: 1.

Permanent Secretary for the Ministry for Justice, as Chairperson; 2.

Director of the ODPP; 3.

Commissioner of Police; 4.

Governor of the RBF; 5.

Chief Executive Officer of the FRCS; and 6.

Director of the FIU.

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

In 2022, the invited members were the Commissioner FICAC and Acting Solicitor General.

The FIU also provides the secretariat to the Council.
Council’s Activities 2022 Key outputs driven by the National AML Council in 2022 were as follows: i. submission of Fiji’ 6th Follow-Up Report to the APG on 1 October 2022.

The report outlined measures Fiji had taken since 2016 to implement the recommendations of the mutual evaluation report; ii.

coordination of work currently being undertaken by the Office of the Solicitor General and Ministry of Justice to address the remaining gaps from Fiji’s 2016 MER; iii.
received and considered requests from agencies for funding assistance from the Forfeited Assets Fund; iv.

ongoing support and contribution to APG work, namely, Fiji’s contribution to the APG mutual evaluation programme, APG mandate paper and other governance issues; and v. ongoing review of Fiji’s national risk assessment including review of the vulnerabilities in the banking and remittance sector.

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 members of the Working Groups are representatives from 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.
The Working Groups provides updates at the National AML Council meetings on its activities.
32 32 33 33 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 7 APPENDICES APPENDIX 1: MOA SIGNED WITH DOMESTIC PARTNER AGENCIES Agency Date MOA Signed Type of MOA Immigration Department 12 July 2007 Information exchange FRCS Fiji Police Force Investment Fiji Ministry of Justice 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 13 June 2008 3 July 2008 Information exchange Information exchange Land Transport Authority 5 October 2009 Information exchange FICAC 3 November 2009 Information exchange Joint Taskforce RBF/FRCS/FIU 14 April 2010 Information exchange Maritime Safety Authority of Fiji 16 August 2012 Information exchange RBF 17 April 2014 Information exchange Fijian Elections Office 11 August 2016 Information exchange Real Estate Agents Licensing Board 24 April 2017 Information exchange Post Fiji Pte Limited 19 March 2020 Information exchange iTaukei Land Trust Board 4 August 2021 Information exchange Source: Fiji FIU APPENDIX 2: FIU REPRESENTATION IN REGIONAL/INTERNATIONAL COMMITTEES Name of Committee/Fora Host Agency/ Organisation Brief Description of Committee Role of Fiji FIU 1.
APG AFP 2.

APG Mutual Evaluation Committee APG An inter-governmental organisation, consisting of 41 member jurisdictions.

The objective of the APG is to ensure that individual members effectively implement the international standards against money laundering, terrorist financing and proliferation financing related to weapons of mass destruction.

• Support APG in implementing its ME and Follow Up Programme.
• Contribute to the development and implementation of procedures and mechanisms to help ensure uality and consistency in mutual evaluations, including follow-up.

Primary Contact Fiji Primary Contact Fiji 3.

Asia/Pacific ICRG Joint Group FATF Implement FATF ICRG process.

4.

Future of Global Network Project Egmont Group The HoFIUs comprise the Egmont Group’s governing body; making decisions on any matters that affect the Group’s membership, structure, budget and principles.
Member Member 34 35 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Name of Committee/Fora 5.

Egmont HoFIU Committee Host Agency/ Organisation Egmont Group 6.

Egmont Membership, Support and Compliance WG Egmont Group 7.

Egmont Information Exchange WG Egmont Group 8.


Pacific Financial Intelligence Community FIUs Brief Description of Committee Role of Fiji FIU The HoFIUs comprise the Egmont Group’s governing body; making decisions on any matters that affect the Group’s membership, structure, budget and principles.
Responsible for managing membership issues, working with the regions on outreach activities, processing membership applications from Candidate FIUs, and implementing the programme which the HoFIU have endorsed in the Egmont Group Support and Compliance Process.

The MSCWG will be responsible for addressing all membership, support, and compliance matters within the Egmont Group, including cooperation between FIUs.
Provide a forum for Egmont Group FIUs and Egmont Observers to leverage the synergies associated with their operational and strategic activities, to enhance cooperation and information exchange among them and to address challenges faced by FIUs in the fight against ML and TF.
• Regional forum of FIUs to foster enhanced multilateral and bilateral operational and strategic engagement ; Member Member Member • Share operational experiences to increase understanding of existing and emerging ML/TF risks and to share strategic priorities to seek mutual support on those priorities.

Member • Support, coordinate and facilitate the capacity-building needs of members.

9.

PFIC Operational Working Group FIUs 10.

PFIC Research Working Group FIUs 11.

12.


AFI Global Standards Proportionality Working Group AFI Pacific AML/CFT Supervisors Working Group Reserve Bank of NZ Working Group of PFIC focussed on regional operational outcomes for law enforcement.

Working Group of PFIC focussed on research on themes and issues of interest to the PFIC members.

Exchange information; develop and promote best practice on proportional global standards to facilitate financial inclusion.

Exchange information on AML/CFT supervision.


Networking between regional AML/CFT supervisors.
Member Member Primary Member Member Source: Fiji FIU APPENDIX 3: MOA SIGNED WITH FOREIGN FIUS Country Name of FIU Australia Australian Transactions Reports and Analysis Centre Bangladesh Financial Intelligence Unit Belgium Financial Intelligence Unit Brazil Council for Financial Activities Control Cambodia Cambodia FIU Canada Financial Transactions and Reports Analysis Centre of Canada China China Anti-Money Laundering Monitoring and Analysis Center Cook Islands Cook Islands FIU Date 19 May 2011 9 June 2015 3 September 2012 3 July 2013 5 December 2017 12 July 2011 6 October 2021 21 July 2011 France The Unit for Intelligence Processing and Action Against Illicit Financial Networks 12 July 2011 34 35 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Country Name of FIU India India FIU Indonesia Indonesian Financial Transaction Reports and Analysis Center Israel Japan Korea Israel Money Laundering Prohibition Authority Financial Intelligence Centre Korea FIU Lao People’s Democratic Republic The Anti-Money Laundering Intelligence Office, National Coordination Committee For Anti- Money Laundering And Counter-Financing Of Terrorism Of The Lao People’s Democratic Republic Lebanon Special Investigation Commission Macau SAR China Financial Intelligence Office Malaysia Unit Perisikan Kewangan, Bank Negara Malaysia Date 5 June 2014 10 July 2009 6 February 2013 9 June 2015 6 May 2011 26 July 2022 5 June 2014 6 and 13 March 2012 3 February 2010 29 January 2018 Papua New Guinea Philippines Papua New Guinea FIU The Anti-Money Laundering Council, The Financial Intelligence Unit of the Republic of the Philippines 13 July 2011 Samoa Samoa FIU Solomon Islands Solomon Islands FIU South Africa Financial Intelligence Centre Sri Lanka Financial Intelligence Unit of Central Bank of Sri Lanka 8 March 2013 12 July 2011 11 July 2012 21 July 2011 Anti-Money Laundering Division, Investigation Bureau, Ministry of Justice 10 July 2012 Republic of China (Taiwan) Republic of Marshall Islands Banking Commission-Financial Intelligence Unit
 Russia Federal Financial Monitoring Service (Russian Federation) Thailand The AML Office of the Kingdom of Thailand Timor-Leste The Unidade de Informação Financeira United Kingdom United States of America The Serious Organised Crime Agency United Kingdom FIU The Financial Crimes Enforcement Network Vanuatu Vanuatu FIU 24 July 2017 28 June 2013 25 October 2011 25 July 2022 12 July 2011 5 June 2014 (Amendment) 12 July 2011 8 March 2013 Source: Fiji FIU 36 37 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 8 SELECTED KEY STATISTICS 2018 - 2022 Year Suspicious Transaction Reports 2018 632 2019 622 2020 736 2021 261 2022 435 Cash Transaction Reports 968,693 794,044 619,987 586,382 572,269 0 0 0 0 233,770 1,357,246 1,515,681 1,866,197 2,434,091(r) 2,960,501 Transaction and Currency Reports Received by FIU Threshold Transaction Report7 Electronic Fund Transfer Transaction Reports Border Currency Reports Year Suspicious Transaction Reports Filed Away for future intelligence and analysis Case Dissemination Reports Intelligence and Information Reports to Stakeholders Information Dissemination Reports Due Diligence Reports Notices to Financial Institutions Alert Notices Directives Enquiries with Financial Institutions Request for further information to financial institutions Year Number of employees of Financial Institution Education and Awareness Number of Financial Institutions Employees of Law Enforcement Agencies 969 2018 248 321 260 118 15 2 446 2018 376 5 65 Year 2018 Breach of 5-day Reporting Requirement Number of breaches Number of Non-Compliance Letters/ Correspondences Issued 28 8 7 TTR reporting by banks commenced on 1 November 2022.
Source: Fiji FIU 36 37 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 9 SELECTED KEY EVENTS 2022 Month January Details 12 – 20 January APG Joint Group Meetings February 02 February Integration of bulk Ministry of Justice (Birth and ROC) data into FIU’s Case Management System 17 February PFIC Meeting March 21 March Annual Meeting with ANZ Country Head 22 March Annual Meeting with Bank of Baroda CEO Fiji Annual Meeting with Westpac CEO Fiji 23 March Annual Meeting with HFC Bank CEO 28 March 30 March April 4 April 4 April Annual Meeting with BSP Country Head Annual Meeting with Commissioner of Police Pacific AML/CFT Supervisors Forum Annual Meeting with FRCS CEO APG Ad Hoc Committee Meeting Annual Meeting with DC FICAC 12 - 14 April AUSTRAC Taipan Team Scoping Visit 26 April May 5 May 13 May 16 May 17 May 27 May June 1 June 2 June 7 June AML Compliance Officer's Induction Briefing Annual Meeting with Bred Bank CEO Meeting with Ministry of Defence - Consultation on National Border Security Upgrade Plan Annual Meeting with Digicel CEO Anti-Narcotics Strategy Consultation Workshop 4th REALB Conference National AML Council Meeting AML/CFT Dialogue with the Commercial Banks Annual Meeting with Chief Justice 29 June PFIC Meeting 38 39 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Month July Details 24 – 28 July APG Annual Plenary Meeting, Malaysia 25 July 26 July August Signing of the MOA with The Unidade de Informação Financeira of Timor Leste Signing of the MOA with The Anti-Money Laundering Intelligence Office, National Coordination Committee For Anti-Money Laundering And Counter-Financing Of Terrorism Of The Lao People’s Democratic Republic 17 August Digital Government Transformation-National Cyber Security Strategy Consultation 24 August Annual Meeting with Vodafone CEO September 5
 September Global Standards Proportionality Working Group 16th Meeting, Jordan 6 – 8 September AFI Global Policy Forum, Jordan 7 September PFIC Meeting 27 September October Pacific AML/CFT Supervisors Forum (virtual) Meeting with Solomon Islands FIU on Taipan (virtual) 3 October Parliament Standing Committee - FIU Submission on the Convention on Cybercrime 19 October Handover of Taipan system by AUSTRAC to Fiji FIU November 16-17 November PFIC Plenary, PNG December 6 December Pacific AML/CFT Supervisors Forum (virtual) 6 – 8 December UNODC Ransomware Experts Group Meeting Source: Fiji FIU 38 39 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 d n a l a n o i t a n g n o r t S & / , n o i t p u r r o c , d u a r f , g n i r e d n u a l y r e v o c e r t e s s a , s e m i r c l i a c n a n fi x e p m o c l r e h t o / .
d e t c e t o r p i s n a m e r ” m e t s y s l i a c n a n fi “ s ’ i j i F & y e m l i t ; , .
s n o i t c a s n a r t l i a c n a n fi d n a e d a r t r i e h t t c u d n o c o t 40 40 41 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 STRATEGIC ANALYSIS REPORT 2022 40 4141 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 2022 STRATEGIC ANALYSIS REPORT FIJI FINANCIAL INTELLIGENCE UNIT 1 STRATEGIC ANALYSIS OVERVIEW 2 OUTCOMES – SUSPICIOUS TRANSACTIONS REPORTS 3 OUTCOMES – CASH TRANSACTION REPORTS 4 OUTCOMES – THRESHOLD TRANSACTION REPORT 5 OUTCOMES – ELECTRONIC FUNDS TRANSFER REPORTS 6 OUTCOMES – BORDER CURRENCY REPORTS 7 EMERGING AND CONTINUING MONEY LAUNDERING TRENDS 8 CASE STUDIES 9 GLOSSARY 43 44 49 51 52 54 56 57 68 42 42 42 43 43 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 1 STRATEGIC ANALYSIS OVERVIEW 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 2022.

Strategic analysis outcomes enable the FIU and its stakeholders to understand the patterns and trends on money laundering and related issues.
“Strategic analysis aims to interpret 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 implies developing knowledge (strategic intelligence) as it relates to money laundering, the financing of terrorism and other threats to the security of a country’s financial systems.” Strategic Analysis Products Typologies Trends Patterns Synthesis 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.
This is a recurring characteristic or trait that helps in the identification of a phenomenon/problem and that serves as an indicator or model for predicting future behaviour.

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

i s t c u d o r P s s y a n A c g e t a r t i l Activity analysis This focuses on identifying weaknesses of an economic sector or activity.

Advanced intelligence products These may include vulnerability assessments, risk assessments and significant event assessments.
Source: Fiji FIU Adapted from: Egmont Group of Financial Intelligence Units Operational Guidance for FIU Activities and the Exchange of Information.

42 42 43 43 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 2 OUTCOMES – SUSPICIOUS TRANSACTIONS REPORTS 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 (2022: 57%; 2021: 67%) followed by the money remittance service providers (2022: 35%; 2021: 14%).

Summary of Reporting Financial Institutions Financial Institutions and Persons Reporting Number of Financial Institutions Registered with FIU No.
of STRs Received 2018 2019 2020 2021 2022 Commercial Banks Money Remittance Service Providers Finance Companies Members of the Public Regulatory Authorities Law Firms Accounting Firms Insurance Companies and Superannuation Securities, Unit Trusts Real Estate Businesses Mobile Phone Operators Others8 6 391 459 636 177 246 11 183 136 68 36 154 11 - - TOTAL 139 632 622 736 261 435 Source: Fiji FIU Suspicious Transactions Reported No.
of STRs 736 632 622 435 261 800 700 600 500 400 300 200 100 0 2018 2019 2020 2021 2022 Years Source: Fiji FIU The increase in the total number of STRs reported in 2022 was due to the removal of COVID-19 restrictions that were in place for most of 2021.
STRs Reported 2022 Received 435 in 2022 from 261 in 2021 57% STRs reported by commercial banks 35% STRs reported by MRSPs Source: Fiji FIU Value of Transactions Reported as Suspicious The total value of suspicious transactions that were reported in 2022 slightly increased to about $25 million from about $22 million in 2021.

The average value of a transaction reported in 2022 as suspicious was $56,947 compared to $83,556 in 2021.
The decrease in the average value of suspicious transactions reported is because there were more low value STRs than high value STRs in 2022.

8 “Others” include STRs filed by foreign FIU’s.

44 45 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 “Grounds for Suspicion” in Suspicious Transaction Reports In 2022, majority of the STRs were reported on the grounds of suspected advance fee fraud and other scams followed by unusually large cash transactions.
It was also observed that a number of individuals were reported for unusual account activity and other serious offences.
Total Value of Transactions Reported as Suspicious Total Value ($ million) Number of STRs Average Value reported ($ per STR) 2018 2019 2020 2021 2022 78.8 57.4 56.2 21.8 24.7 632 622 736 261 435 124,684 92,283 76,359 83,556 56,947 Source: Fiji FIU Grounds for Suspicion on STRs Received 2022 Grounds for Suspicion Use Of Minors Account Unusually Large Foreign Exchange Possible Unexplained Wealth FIU/Other Watchlist Counterfeit Financial Instruments Third Party Transaction Avoiding Reporting Obligations Inconsistent with Customer Profile Unusually Large Foreign Transaction Violation of EC Requirements Unusual Use/Exchange Of Cash Other (One Off Large Transaction) Suspicious Behaviour Unusually Large Transfer Tax Evasion Fraud Or Other Serious Offence Unusual Account Activity Unusually Large Cash Transaction Advance Fee Fraud & Other Scams 0 20 40 60 80 100 120 140 160 Number of STRs Source: Fiji FIU 44 45 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 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.

87% of the STRs submitted by financial institutions in 2022 were reported on transactions valued below $25,000.
STRs involving large value transactions of more than $100,000 accounted for 6% of total STRs reported in 2022 compared to 8% in 2021.
Suspicious Transactions by Transaction Value 2022 Transaction Value $0 - $25,000.00 $25,000.01 - $50,000.00 $50,000.01 - $75,000.00 $75,000.01 - $100,000.00 $100,000.01 and above Total Number of STRs Percentage of STRs 376 23 5 4 27 435 87% 5% 1% 1% 6% 100% Source: Fiji FIU Suspicious Transactions by Instrument Type ‘Remittance’ the primary transactions was financial instrument type that was reflected in the STRs reported to the FIU in 2022.
Out of the 435 transactions reported as suspicious in 2022, 194 (45%) involved remittance 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 Instrument Type Year Cash Cheque Remittances Others Total Source: Fiji FIU Suspicious Transactions by Currency Type The majority (99%) of the STRs reported in 2022 involved Fijian currency.

The suspicious transactions that involved foreign currency decreased to 1% of total STRs in 2022 compared to 2% in 2021.
Suspicious Transactions by Geographical Location The FIU receives STRs from various commercial centres in Fiji.

Majority (280) 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.
Suspicious Transactions by Geographical Location 2018 2019 2020 2021 2022 Western 213 197 258 81 135 Central/ Eastern 349 353 429 168 280 Northern 68 72 48 12 20 Source: Fiji FIU 46 47 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Suspicious Transactions by Geographical Location 2022 Northern 20 435 STRs Western 135 Central 280 Source: Fiji FIU Suspicious Transactions by Customer Type There were 547 (99%) personal customers reported in STRs compared to 7 (1%) reports on corporate and business entities in 2022.
Suspicious Transactions by Customer Type 2022 923 841 529 547 376 2018 2019 2020 2021 103 40 2022 7 180 158 Individual Entity Source: Fiji FIU Suspicious Transaction Reports by Customer Age 91% of STRs on individuals were reported on customers over the age of 26 years.
Suspicious Transaction Reports by Customer Age 2022 0 - 18 Years 10 19 - 25 Years 18 47 - 54 Years 60 55 Years and Over 67 26 - 32 Years 58 40 - 46 Years 56 33 - 39 Years 60 Source: Fiji FIU Reasons for Suspicious Reporting A financial institution’s decision to report a transaction as suspicious is based on the evaluation of facts and context regarding a transaction(s) to determine if there is reasonable ground to suspect that the transaction(s) is related to the commission of a money laundering, terrorist financing or other serious offence.
There should be “sufficient facts” or credible and objective evidence to support a financial institution’s suspicion and its decision to report a transaction(s) to the FIU.

Financial institutions are required under the FTR Act to know their customers in order to identify transactions that may be unusual, suspicious or questionable for an individual customer or a type or category of customer.
46 47 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Examples of “Reasons” for Reporting Transactions as Suspicious Law Firm 11.

Client attempted to purchase a property with a large amount of cash.

Insurance Companies and Superannuation Fund 12.

Customer made 20 cash deposits in a span of two months.

Each deposit was below the reporting threshold.

13.

Large cash policy loan repayments.

Foreign Exchange Dealers 14.

15.

Customer wanted to send funds to a foreigner.


Sender and receiver had not met.

Sender claimed that the receiver was her Aunt’s husband.

Individuals living in a particular area receiving frequent remittances from individuals from Country X.

The above are extracts from actual STRs reported to the FIU in 2022.

Source: Fiji FIU Commercial Banks 1.

2.

3.

4.

5.

6.

7.

Multiple high value international money transfers from unknown third parties.
Customer has been receiving credits via cash deposits and IB transfers, customer is unemployed as per system records.

Multiple cash deposits and credits suspected to be business proceeds into a personal account.

Third party depositing business funds into the personal account of an individual residing abroad.

Attempted cheque fraud.

Rapid encashment of funds, immediately after funds were received from FRCS.
Cash deposits below the threshold found to be charged for various offences including unlawful possession of illicit drugs.

8.

Significantly large cash deposits in $100 bills.

Members of the Public 9.

Individual claiming that she can make people rich on social media.

She requested that people send her money and she will provide a Mastercard in return.

10.

Individual remitted funds to claim a “prize” that was a scam.
48 49 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 3 OUTCOMES – CASH TRANSACTION REPORTS Prior to November 2022, financial institutions were 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 Transactions Reported No.


of CTRs 1,200,000 1,000,000 968,693 In September 2022, amendments were made to the FTR Act and Regulations on the cash transaction reporting requirements.

From 1 November 2022, all non-bank financial institutions are required to report to the FIU cash transactions involving notes and coins only of $5,000 and above (or its equivalent in foreign currency).

Commercial banks were excluded from reporting CTRs and are required to report TTRs from 1 November 2022.
800,000 600,000 400,000 200,000 0 794,044 619,987 586,382 572,269 2018 2019 2020 2021 2022 Years Source: Fiji FIU The FIU received 572,269 CTRs in 2022 or an average of around 47,689 CTRs per month.

This is a decrease of 2% compared to 586,382 CTRs received in 2021.

CTRs Received by Sector The majority (99%) of the CTRs received during 2022 were reported by commercial banks.
Cash Transactions Reported Year 2018 2019 2020 2021 2022 Total CTRs Monthly Average CTRs 968,693 794,044 619,987 586,382 572,269 80,7249 66,170 51,666 48,865 47,689 Source: Fiji FIU 48 49 9 In 2018 one reporting institution reported backdated CTRs totalling 249,114 in October 2018.
FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Cash Transactions Reported by Sector Sector 2018 2019 2020 2021 2022 Commercial Banks Foreign Exchange Dealers and Money Remittance Service Providers Finance Companies Insurance and Superannuation Fund 963,313 788,467 616,660 583,175 565,312 3,163 3,381 1,414 1,448 4,960 1,251 1,186 1,000 841 1108 356 320 397 594 419 Law Firms 410 519 355 252 310 Securities/ Brokers/ Advisors Accountants Statutory Authority Real Estate Mobile Phone Money Remitters 183 161 153 72 151 2 0 15 0 0 4 6 0 0 0 8 0 0 0 0 0 0 0 6 3 CTRs Received by Direction of Cash Payment The CTRs received in 2022 consisted of 60% inward (IN)10 CTRs and 40% outward (OUT)11 CTRs.
Inward CTRs refer to cash transactions received by a financial institution.

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

The majority (41%) of CTRs received by the FIU in 2022 were for cash transactions between $10,001 and $20,000.

Approximately 71% of CTRs reported are for cash transactions between $10,001 and $50,000.
CTRs by Value of Transactions 2022 69,460 12% 3,017 1% 29,047 5% 62,041 11% 174,670 30% 234,034 41% Total 968,693 794,044 619,987 586,382 572,269 5,000 to 9,999 20,001 to 50,000 Source: Fiji FIU Exactly $10,000 50,001 to 100,000 10,001 to 20,000 More than 100,000 Source: Fiji FIU 10 IN also refers to cash deposits or credit transactions.

11 OUT also refers to cash withdrawal or debit transactions.
50 51 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 4 OUTCOMES – THRESHOLD TRANSACTION REPORTS Effective from 1 November 2022, the commercial reporting to the FIU all banks commenced transactions undertaken on behalf of its customers of $5,000 and above (or its equivalent in foreign currency).

This includes cash and non-cash transactions such as bank-to-bank transfers.

This transaction report from commercial banks are referred to as a Threshold Transaction Report (TTR).
The FIU received 233,770 TTRs in November and December 2022 or an average of around 116,885 TTRs per month.

TTRs by Value of Transactions 2022 The majority (42%) of TTRs received by the FIU in 2022 were for transactions between $5,000 and $9,999.
TTRs by Value of Transactions 2022 17,532 7% 15,216 6% Threshold Transactions Reported Year 2022 Total TTRs Monthly Average TTRs 233,770 116,885 41,404 18% Source: Fiji FIU 56,196 24% 97,244 42% 6,178 3% 5,000 to 9,999 $20,001 to $50,000 Exactly $10,000 $50,001 to $100,000 $10,001 to $20,000 More than $100,000 Source: Fiji FIU Revised FIU Policy on CTR Reporting From $10,000 to $5,000 $10,000 Cash Transaction Report (CTR) 2006 – Oct 2022 $5,000 Revised Cash Transaction Report (CTR) From Nov 2022 $5,000 New Threshold Transaction Report (TTR) From Nov 2022 Reported by all financial institutions and DNFBPs.
Report “cash” transaction of $10,000 and above.

“Cash” includes: notes & coins, bank draft, bank cheque, bearer bond, travelers’ cheque, postal note and money orders.

Reported by all non-bank financial institutions and DNFBPs.

Report cash transaction of $5,000 and above.

“Cash” now includes only currency notes & coins.

Reported only by commercial banks.

Report all debit and credit transactions of $5,000 and above.
Source: Fiji FIU 51 50 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 5 OUTCOMES – ELECTRONIC FUNDS TRANSFER REPORTS Commercial banks and money 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, 10 MRSPs, and 2 mobile phone operators are subject to EFTR reporting.
The FIU received 2,960,501 EFTRs in 2022 or an average of around 246,708 EFTRs per month.

This is an increase of 22% compared to 2,434,091 EFTRs received in 2021.

Total EFTRs for 2021 has been revised from 1,884,402 to 2,434,091 due to back dated reporting of EFTRs.

The total EFTRs received in 2022 included 177,484 EFTRs in domestic remittances.
Electronic Funds Transfer Transactions Reported Year 2018 2019 2020 2021 2022 Total EFTRs 1,357,246 1,515,681 1,866,197 Monthly Average EFTRs 113,104 126,307 155,516 2,434,09112 202,84113 2,960,501 246,708 Source: Fiji FIU Electronic Funds Transfer Transactions Reported EFTRs Received by Sector Majority (51%) of EFTRs were received from the MRSPs.

There was a notable increase of 35% in the number of EFTRs received from the mobile phone money remittance sector in 2022.
The increase in EFTRs from the mobile phone money remitters was due to the substantial demand by consumers for the use of the mobile money wallet for funds transfer.

This is considered as a convenient and cheaper alternative to remit funds to Fiji compared to traditional remittance channels.
EFTRs Received by Sector Sector 2018 2019 2020 2021 2022 Money Remittance Service Providers Commercial Banks Mobile Phone Money Remitters 968,016 1,088,292 1,376,295 1,319,304 980,133 346,282 360,595 329,965 348,597 479,275 42,948 66,794 159,937 766,19014 1,501,093 Total 1,357,246 1,515,681 1,866,197 2,434,091 2,960,501 Source: Fiji FIU EFTRs Received by Sector 2022 2,960,501 2,434,091 1,866,197 1,515,681 No.
of EFTRs 3,500,000 3,000,000 2,500,000 2,000,000 1,500,000 1,357,246 1,000,000 500,000 0 2018 2019 2020 2021 2022 Years Source: Fiji FIU 16% Commercial Banks 479,275 EFTRs by Sector 33% Money Remittance Service Providers 980,133 51% Mobile Phone Money Remitters 1,501,093 Source: Fiji FIU 12 Total EFTR for 2021 has been revised from 1,884,402 to 2,434,091 due to receipt of back-dated EFTRs during 2022 from a reporting entity.

13 Monthly average of EFTR for 2021 has been revised from 157,034 to 202,841.
14 EFTRs of Mobile Phone Money Remitters for 2021 has been revised from 216,501 to 766,190.

52 53 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 EFTRs by Direction of Remittances EFTRs may involve remittances into Fiji (inward) or remittances out of Fiji (outward).

Majority (91%) of EFTRs received during 2022 were for inward remittances compared to 87% of inward remittances in 2021.
EFTRs by Sending and Receiving Country Inward international remittance transactions reported to the FIU were conducted from the following ten major countries: Australia, United States of America, New Zealand, United Kingdom, Canada, Cook Islands, Vanuatu, France, Tuvalu and Ireland.
remittance international Outward transactions reported to the FIU were made to the following ten major countries: Australia, New Zealand, United States of America, India, China, Philippines, Hong Kong, Bangladesh, Singapore and Solomon Islands.
EFTRs: Top 5 Countries Conducting Inward/Outward Remittances to/from Fiji (Number of EFTRs) 2022 Outward Remittances 9% Inward Remittances 91% Outward 264,266 EFTRs Inward 2,696,235 EFTRs Top 5 Countries Inward Remittances Outward Remittances Australia USA 41% 1,100,190 Australia 16% 41,082 22% 602,621 New Zealand 12% 32,884 New Zealand 17% 446,434 USA 12% 8% 22,010 UK 9% 253,843 Canada 2% 64,276 India 5% 13,311 China 4% 9,250 Source: Fiji FIU 52 53 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 6 OUTCOMES – BORDER CURRENCY REPORTS 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 FRCS Customs officials at the ports and submitted to the FIU for central recording, analysis and for its intelligence purpose.

In 2022, 640 BCRs were received by the FIU compared to 99 BCRs received in 2021.
The increase in BCRs is due to the rise in the number of travellers into and out of Fiji after the removal of travel restrictions related to the pandemic.

BCR Declarations Persons Declaring Declarations made by inbound travellers Declarations made by outbound travellers 2018 2019 2020 2021 2022 434 436 81 29 201 535 666 185 70 439 Border Currency Declarations No.
of BCRs 1,200 1,000 969 1,102 800 600 400 200 0 2018 2019 640 266 2020 Years 99 2021 2022 Source: Fiji FIU BCRs by Transaction Value The total value of currency declared by travellers in the BCRs in 2022 was about $38 million compared to $2 million in 2021.
Value of Border Currency Reports Received Persons Declaring Travellers Arriving in Fiji Travellers Departing Fiji Value of Currency Declared ($million) 2018 2019 2020 2021 2022 22.6 19.3 5.4 0.5 4.9 40.1 44.3 10.5 1.5 32.8 TOTAL 969 1,102 266 99 640 Total 62.7 63.6 15.9 2.0 37.7 Source: Fiji FIU Source: Fiji FIU 54 55 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 BCRs by Transaction Value (Inbound/ Outbound) Majority of BCRs declared by inbound and outbound travellers ranged in the value of $10,000 - $100,000.
Inbound/ Outbound BCRs by Value 2022 195 $10,000 - $100,000 97% 3 > $100,000 3% INBOUND OUTBOUND 397 $10,000 - $100,000 90% 13 $100,001 - $500,000 3% 29 > $500,001 7% Source: Fiji FIU BCRs by Direction of Travel There were more declarations made by outbound travellers compared to inbound travellers in 2022.

In 2022, 69 % of declarations were made by outbound travellers while 31 % of declarations were made by inbound travellers.
Direction of Travel in BCRs Reported 2022 Total number of BCRs: 640 69% Outbound Travellers, $33m 31% Inbound Travellers, $5m Source: Fiji FIU BCRs by Reason for Travel Majority (25%) of travellers stated their reason for travel both in and out of Fiji as “Holiday”.

21% of travellers stated their reason for travel both in and out of Fiji as “Other” which includes traveling for education, conference, funeral, returning home, transit, employment, residence and no reason provided.
BCRs by Reason for Travel 2022 Holiday 160 BCRs, 25% Migration 53 BCRs, 8% Medical 45 BCRs, 7% Visitng Friends / Relatives 153 BCRs, 24% Business 95 BCRs, 15% Other15 134 BCRs, 21% Source: 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 2022, there was one reported case of BCR non- declaration, compared to nil cases in 2021.
This case involved a passenger who was departing from Fiji for Vanuatu on 13 July and failed to declare excess foreign currency equivalent to more than FJD$86,000.

The passenger was subsequently fined $3,750 for the breach of border currency declaration under the FTR Act.
54 15 Other includes education (39), conference (10), funeral (7), returning home (11), transit (22), employment (33), residence (8) and no reason provided (44) 55 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 7 EMERGING AND CONTINUING MONEY LAUNDERING TRENDS Declining Trend Pyramid Scams Pyramid scams were reported as an increasing trend in 2021, however, the FIU noted that there was a decline in the number of reports on individuals engaging in pyramid scams in 2022.
Continuing Trend Use of Mobile Money Wallets and Visa Debit Cards There was a continuing trend of individuals using mobile money wallets and VISA debit cards in various reports regarding scams.

There was also an increase in the usage of personal mobile money wallets to receive business deposits.

Scams Other types of scams, including romance, investment, loan and lottery scams continued to be observed in 2022.
While most of the perpetrators of these scams were based abroad, the FIU noted a few cases where the perpetrators were local.

56 57 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 8 CASE STUDIES Case Study 1: Internal Theft Mr. A, Mr. B and Company C were brought to the attention of the Fiji FIU in 2022 for possible theft involving approximately $1.3 million from Company D from 2016 to March 2022.

Mr. A and Mr. B were employees of Company D during the time of theft.
Mr. A was also the trustee of Company D and he maintains a bank account with Bank F. Mr. A’s financial activity revealed that he received suspicious cash deposits of $58,000.00 in 2016 and frequent internet banking transfers of $280,000.00 from Company C. Fiji FIU analysis revealed that Mr. A and his son also received remittances totalling $36,000.00 from Mr. B. Mr. A also acquired one vehicle in 2017 valued at $27,500.00.
Mr. B was the account clerk for Company D and maintains a bank account with Bank F. Mr. B’s financial activity showed that he received frequent internet banking transfers totalling $63,000.00 from Company D. It is also established that Mr. B acquired three vehicles in 2022 valued from $15,500.00 to $19,000.00.

Case Study 1: Internal Theft Fiji FIU further established that Company C ceased operating in 2015 but continued to maintain a bank account with Bank F and the account was solely operated by Mrs. A.
Company C’s financial activity shows totalling that suspicious cash deposits $400,000.00 were conducted into the account whereby the funds were immediately transferred to Mr. A’s bank account.

A case dissemination report was provided to the Fiji Police Force.

Indicators: • Regular receipt of unusual deposits that are inconsistent with the bank account holder’s financial background.

• Using a business bank account of an inactive business.
Possible Offence: • Theft Company D spouse remittance $26,000.00 Mrs. A Mr. A Trustee of Company D remittance $10,000.00 Mr. B Accounts Clerk of Company D Mr. A’s son Company D bank account (Bank F) transfer $63,000.00 Company C owned by Mrs. A • ceased in 2015 2 vehicles • 1 acquired in 2017 valued at $27,500.00 • 1 acquired in 2002 cash deposit $400,000.00 C Enterprise bank account Bank F Mr. A bank account Mr. B bank account 3 vehicles • all acquired in 2022 • valued from $15,500.00 to $19,000.00 IB transfer $280,000.00 Received sus- picious deposit totaling approximately $58,000.00 56 57 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Case Study 2: Fake Documents Mrs. X, Mr. X and Mr. Z were brought to the attention of the Fiji FIU in 2022 for submitting falsified documents to Finance Company D for loan applications totalling approximately $27,800.00.
The three individuals stated that they were employed with Company C and provided payslips when they applied for their loans.

Finance Company D contacted the Company C, to confirm whether they had employed Mrs. X, Mr. X and Mr. Z.

Company C confirmed that the individuals were not their employees.

Mr. Z revealed that the individuals opened their bank account with Finance Company D on the same date they were applying for personal loans.

A case dissemination report was provided to the Fiji Police Force.
Indicators: • Fake supporting documents.
Possible Offence: Fiji FIU established that Mrs. X was previously brought to the attention of FIU in 2009 and 2014 for possible money laundering and other criminal offences, and is married to Mr. X. Fiji FIU analysis of Mrs. X, Mr. X and • Forgery • Fraud Case Study 2: Fake Documents Company C spouse Mr. X Claimed to be employed for Company C Mrs. X Claimed to be employed for Company C Mr. Z Claimed to be employed for Company C Loan Application with fake documents Company D bank account 58 59 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Case Study 3: Tax Evasion Mr. K and Company XYZ were brought to the attention of the Fiji FIU for frequent deposits made to Mr. K’s bank account by his employer, Company XYZ.
Fiji FIU established that while Mr. K had not declared any taxable income in 2020, he received a total of $173,355.00 in cash deposits from Company XYZ during the same period.

It was also established that Company XYZ received deposits totalling $2.5 million in 2020 into their bank account despite declaring only $1.3 million in sales to the Fiji Revenue & Customs Service.

Case Study 3: Tax Evasion A case dissemination report was provided to the Fiji Revenue & Customs Service.
Indicators: • Unusual account activity.

• Large cash deposits.

Possible Offence: • Using personal bank accounts to conduct business financial activity.
Tax Declaration: $1.3 million in sales No Tax Declarations Fiji Tax Authority Employer $173,355 Mr. K Owns Company XYZ $2.5 million Bank Account Bank Account 58 59 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Case Study 4: Corruption and Unexplained Wealth Mr. R, a politically exposed person (PEP), was brought to the attention of the Fiji FIU for receiving large cash deposits from various individuals and entities in Fiji.
Fiji FIU analysis revealed that from 2017 to 2022, Mr. R received close to $1 million in large cash deposits from various entities and foreigners in Fiji.

Further analysis showed that Mr. R received remittances totalling $0.5 million from 2019 to 2022.

These from remittances were various individuals and entities in Countries A, B, C and D. Most of the remittances (approximately $370,000.00), were received from Country A.
Open source searches showed that Mr. R had travelled to Country A in his capacity as a PEP and met with numerous government officials in Country A. received Case Study 4: Corruption and Unexplained Wealth Fiji Mr. R PEP Owns A case dissemination report was provided to FICAC to examine the case for possible unexplained wealth as result of corruption and bribery.

Indicators: • Cash Deposits apart from salary.

• Large cheque withdrawals.

• Large remittance from offshore.


Possible Offence: • Unexplained wealth • Corruption • Bribery • Possible tax related offence/tax evasion Countries Travelled to Country A as a PEP and met with government officials $1 million $0.5 million Company C Bank Account A B C D 60 61 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 facto partner’s bank account to deposit cash and allegedly withdrew cash on the same day.

A case dissemination report was provided to the Fiji Police Force.
Indicators: • Frequent cash deposits into Mr. X’s de-facto partner’s bank account and cash withdrawals on the same day.

• Customers’ term deposits and/or bank accounts not being credited upon inquiry.

Possible Offence: • Obtaining financial advantage by deception • Forgery • Theft Case Study 5: Internal Theft Mr. X was brought to the attention of the Fiji FIU by a member of public and a financial institution for fraudulently obtaining funds by deception.
Mr. X obtained cash of over $235,000.00 from sixteen customers through fifty separate transactions while being employed at a financial institution.

Mr. X, in his capacity as a Head Teller of a financial institution, received cash from customers on behalf of his employer and did not deposit the cash into the respective bank accounts of the customers.

Instead, the cash was taken by himself.


Mr. X issued fake term deposit acknowledgement receipts and forged the signatures of his supervisors to conceal the fraudulent act.

Furthermore, his de-facto partner, of Ms. X, was also brought to the attention of the Fiji FIU for frequent cash deposits that did not fit her bank account profile.
It was established that Mr. X used his de- Case Study 5: Internal Theft Customers Customers Bank A Employed by $235,000.00 Head Teller De-facto Partner Fake and forged documents Mr. X Owns Ms. X Cash Deposits Same day cash withdrawal Bank Account Bank Account 61 60 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Case Study 6: Bribery The Fiji FIU received a suspicious transaction report from a member of the public, alleging that Mr. Y, in his capacity as an Executive member of a financial institution, was receiving commissions in exchange for loan approvals.
Initial analysis showed that Mr. Y had acquired two properties, two vehicles and had large bank account balances.

The accumulated wealth and assets of Mr. Y did not commensurate with his declared salary and business income.

Mr. Y also owns a sugarcane farm, and is the Director and Shareholder of a real estate company.

Case Study 6: Bribery A case dissemination report was provided to FICAC.

Indicators: • Accumulated unexplained wealth.
Possible Offence: • Corruption • Fraud Financial Institution Executive Member Real Estate Business Property Motor Vehicle Mr. Y Property Motor Vehicle Sugarcane Farm Bank account balance Bank account balance 62 63 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Case Study 7: Large Foreign Remittances, Share Purchase and Real Estate Mrs. Y was brought to the attention of the Fiji FIU for possible money laundering involving large foreign remittances and real estate transactions totalling $352,000.00.
In October 2017, Mrs. Y opened a personal bank account and stated her occupation as Director of Company B (an entity in Fiji).

In February 2018, Mrs. Y received two remittances from Country 1 totalling approximately $199,000.00 and paid $178,000.00 to Company B for her shares.

From February 2018 to January 2020, Mrs. Y received three additional remittances from Country 1 totalling approximately $256,000.00.
In November 2019 and January 2020, Mrs. Y paid a total of $352,000.00 to two law firms for property settlement.

Fiji FIU analysis established that Mrs. Y was a national of Country 1 who was residing in Fiji under a residence permit.

In September 2017, Mrs. Y was issued a Fiji investor permit for one year, however, her investor permit was not renewed as a result of not meeting reporting requirements.
Fiji FIU analysis also established no properties owned by Mrs. Y despite the reported property settlement transactions.

Queries with financial institutions established that Mrs. Y conducted the property settlement transactions on behalf of one Mr. G. Analysis of immigration information revealed that Mr. G is Mrs. Y’s husband.

Mr. G was also a national of Country 1 who was currently residing in Fiji under a residence permit.
Fiji FIU analysis established one property owned by Mr. G. The date the property was purchased matches the time period that Mrs. Y conducted the property settlement transactions.

It is suspicious that Mr. G did not conduct the property settlement transactions himself.

It is also suspicious that Mrs. Y is not a co-owner of the property despite her relationship to Mr. G, and despite her conducting the settlement transactions.
Analysis of company ownership information revealed no records of Mrs. Y being a current and/or previous Director of Company B.

Furthermore, analysis of Mrs. Y’s bank account information revealed no payment from Company B to confirm the sale of her company shares.

Mrs. Y may still be a shareholder of Company B despite her investor permit status.

A case dissemination report was provided to the Fiji Immigration Department.
Indicators: • Regular receipt of large, foreign remittances from risk jurisdictions in relation to financial crime.

• Large, foreign remittances invested into local entities shortly after receipt.

• Large, foreign remittances invested into real estate shortly after receipt.

• Conducting property settlement transactions on behalf of another party.
Possible Offence: • Violation of Fiji immigration laws • Provision of false or misleading information 62 63 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Case Study 7: Large Foreign Remittances, Share Purchase and Real Estate Country 1 5 remittances totalling approximately $455,000 Property owns Mr. G Husband Bank Account owns Mrs. Y Director Solicitors for $352,000 payment for property Law firms $178,000 payment for shares Fiji owns Company B Bank Account 64 65 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Case Study 8: Personal Mobile Phone Money Remitter Accounts and Business Transactions Ms. C was reported to the Fiji FIU for unusual financial activity involving the receipt and withdrawal of large funds from her three mobile money accounts.
The funds were allegedly sourced from her business activity.

It was further reported that Ms. C also accompanies her father, Mr. C, to conduct withdrawal transactions from his mobile money accounts.

From January to September 2022, Ms. C reportedly made withdrawal totalling approximately $75,000.00 from her mobile money accounts.
transactions Fiji FIU analysis established that from January 2019 to April 2022, Ms. C conducted deposit and withdrawal transactions in her mobile money accounts totalling $66,218.00 and $65,842.00 respectively.

Fiji FIU analysis also established that from 2018 to 2021, Mr. C, father of Ms. C, conducted large cash deposit and withdrawal transactions ($10,000.00 and above) totalling $755,450.00 and $589,483.00 respectively from his two bank accounts.
Analysis of Ms. C’s taxpayer information revealed that she is a Director of Company P, and that she has never lodged any income tax returns.

Analysis of Mr. C’s taxpayer information revealed that his income tax returns from 2017 to 2019 showed “Not Filed” as the status because his income was below the threshold.

Ms. C’s and Mr. C’s financial activities seemed inconsistent with their taxpayer information.

A case dissemination report was provided to the Fiji Revenue and Customs Service.
Indicators: • A single individual owns more than one mobile money account.

• Large deposits and withdrawals conducted frequently in mobile money accounts within a short time period.
Possible Offence: • Tax evasion • Money laundering Case Study 8: Personal Mobile Phone Money Remitter Accounts and Business Transactions $65,842.00 Total withdrawals from January 2019 to April 2022 $66,218.00 Total deposits from January 2019 to April 2022 r e t t i m e R y e n o M e n o h P e l i b o M owns daughter owns Ms. C Mr. C $589,483.00 Total large cash withdrawals conducted from 2018 to 2021 Bank Accounts $755,450.00 Total large cash deposits conducted from 2018 to 2021 65 64 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Case Study 9: Corrupt Practice of an Executive Mr. M, an executive at a local statutory body, was brought to the attention of the Fiji FIU for a possible case of unexplained wealth and corruption as a result of obtaining bribes.
Fiji FIU analysis established that Mr. M and his brother, Mr. J who is employed in Country A received $45,870.00 in cash deposits from September 2016 to January 2020 into their joint bank account.

The sources of funds of these deposits could not be established.

In July 2014, Mr. M and Mr. J collectively acquired two properties in the central division.

They obtained further loans totalling more than $1,000,000.00 to expand the properties.
The properties have eight rental flats in total and received rental income of $271,000.00 from September 2016 to January 2022.

Mr. M and Mr. J were declaring a loss on their rental income from 2018 to 2020.

In November 2019, Mr. M acquired a vehicle valued at $96,500.00 whereby he made payments of $29,000.00 from his bank account.

However, financing of the remaining balance of $67,500.00 could not be traced to his bank account transactions.
Similarly, Mr. M’s spouse, Mrs. M, acquired a vehicle valued at $64,500.00 whereby she made payments of $46,090.00 from her bank account.

However, Case Study 9: Corrupt Practice of an Executive financing of the remaining balance of $18,410.00 could not be traced to her bank account transactions.

Mr. and Mrs. M, and their child frequently travelled to Country A and Country W from 2013 to 2018.
Further analysis established that Mr. M’s transactions and accumulation of wealth were inconsistent with the annual income declared.

A case dissemination report was provided to FICAC to examine the case for possible unexplained wealth as a result of bribery in Mr. M’s capacity as an executive at a local statutory body.

Indicators: • Consecutive cash deposits into a joint account apart from rental income.

• Rental income received is more than what is declared to the tax authority.

• Luxurious lifestyle.


• High value of properties and vehicles.
Possible Offence: • Bribery • Tax Evasion • Unexplained Wealth • Corruption jointly owned properties values at $1,022,269.93 child rental income Mr. J owns employed and resides brothers Mr. M spouse Mrs. M owns owns paid $46,090.00 bank account multiple joint bank accounts multiple bank accounts car valued at $96,500 bank account car valued at $64,500 66 Country A family travelled from 2013 to 2018 Country W paid $29,000.00 67 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Case Study 10: Unusual Accumulation of Superannuation Contributions Mr. R was brought to the attention of the Fiji FIU for possible unexplained wealth and tax evasion by conducting high value deposits totalling $2,000,000.00 over the course of four years.
Initial analysis revealed that Mr. R was previously brought to the attention of the Fiji FIU for diverting business funds into his personal account.

Mr. R used his personal account to conduct business transactions, and received large cheque and cash deposits of more than $500,000.00 in a 10 month period.

A case dissemination report was provided to the Fiji Revenue and Customs Service in 2010.

Fiji FIU analysis also established that Mr. R was a civil contractor and director of two entities.
He received salary deposits totalling $737,440.00 from November 2019 to November 2021 into his personal bank account.

It was also noted that Mr. R conducted voluntary contributions to his superannuation fund totalling $2,419,995.15 from October 2016 to February 2022.

These deposits from were conducted through bank cheques business accounts.
Further analysis established a discrepancy of $8,340,000.00 between the taxable income declared by Mr. R and the deposits received into his bank and superannuation accounts.

A case dissemination report was provided to the Fiji Revenue and Customs Service for further profiling and investigation on Mr. R for possible tax evasion and unexplained wealth.

Indicators: • Unusual deposits from business bank account into personal superannuation fund account.
• Income declared did not match the large volume and value of deposits received into the bank accounts.

• Individual accumulated unexplained wealth.
Possible Offence: • Tax related offence/tax evasion • Unexplained Wealth 66 67 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 9 AFI AML AMS APG GLOSSARY Alliance for Financial Inclusion Anti-Money Laundering Alert and Monitoring System Asia Pacific Group on Money Laundering AUSTRAC Australian Transaction Reports and Analysis Centre FIU FRCS FUR FPF FTR Border Currency Report GSPWG BCR BDM Financial Intelligence Unit Fiji Revenue and Customs Service Follow-Up Report Fiji Police Force Financial Transactions Reporting Global Standards Proportionality Working Group Births, Deaths and Marriages MER Mutual Evaluation Report CAMLMAC China Anti Money Laundering Monitoring and Analysis Center ML / TF Money Laundering and Terrorist Financing CDR CFT CMS CTR DDA DNFBP EFTR ESW FATF FFIMSO FICAC Case Dissemination Report MOA Memorandum of Agreement Combating the Financing of Terrorism MRSP Money Remittance Service Provider Case Management System Cash Transaction Report Direct Database Access Designated Non-Financial Businesses and Professions Electronic Funds Transfer Report Egmont Secure Web Financial Action Task Force Fiji FIU Information Management System Online Fiji Independent Commission Against Corruption NRA ODDS ODPP PFIC RBF ROC STR TF National Risk Assessment Online Data Delivery System Office of the Director of Public Prosecutions Pacific Financial Intelligence Community Reserve Bank of Fiji Registrar of Companies Suspicious Transaction Report Terrorist Financing TRAQ Transaction Query System 68 68 69 69 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 Contact Information Fiji Financial Intelligence Unit Tower Level 5, RBF Building 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 68 68 69 69 FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022 www.fijifiu.gov.fj 70 PB FIJI FINANCIAL INTELLIGENCE UNIT ANNUAL REPORT 2022